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Filing # 134001977 E-Filed 09/03/2021 10:39:00 AM
USA MEDICARE ADVISORS INSURANCE IN THE CIRCUIT COURT OF THE 17TH
AGENCY LLC, a Florida Limited Liability JUDICIAL CIRCUIT IN AND FOR
Company, BROWARD COUNTY, FLORIDA
Plaintiffs, CASE NO: CACE-21-010364
VS.
ELITE HEALTH INVESTMENTS, INC., a
Florida Profit Corporation,
Defendant.
FIRST REQUEST FOR PRODUCTION
The ELITE HEALTH INVESTMENTS, INC., a
Florida Profit Corporation (Hereinafter "ELITE"), by and through undersigned counsel,
pursuant to Florida Rule of Civil Procedure 1.350, requests the Plaintiff/Counter-
Defendant, ,
USA MEDICARE ADVISORS INSURANCE AGENCY LLC, a Florida
Limited Liability Company (Hereinafter "UMA"), to produce and permit the inspection
and copying of the following documents and papers within thirty (30) days, at the
office of the attorneys for the
1. Copies of any and all contracts, agreements, and memoranda in your
possession between the parties.
2. Copies of any and all
correspondences sent between you and the
including but not limited to emails, text
messages, handwritten letters, or voice memos pertaining to the claims in
the Complaint.
3. Copies of any and all correspondence received from Defendant/Counter-
Plaintiff, including but not limited to emails, text messages, handwritten
letters, or voice memos pertaining to the claims in the Complaint.
4. Copies of any and all correspondences sent between Plaintiff/Counter-
Defendant and any third party concerning this matter.
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/03/2021 10:38:59 AM.****
5. Copies of any and all documents for any and all damages claimed by the
pertaining to this matter.
6. Copies of any and all documents and/or invoices sent by you to the
pertaining to this matter.
7- Copies of any and all statements previously made by the Plaintiff/Counter-
Defendant or concerning the subject matter of
this action, including any written statements, signed or otherwise adopted
or approved by the and any stenographic,
mechanical, electrical or other type of recording or any transcription thereof
made by the hereto and contemporaneously
recorded.
8. Copies of any and all files and documents kept by Plaintiff/Counter-
Defendant pertaining to the Downline Agent
Agreement.
9. Copies of any and all checks, statements, and/or other documents showing
any and all payments made by you to
10. Copies of any and all checks, statements, and/or other documents showing
any and all payments received by you from
11. Copies of any and all video and/photographic evidence, whether in digital,
film, computer or any other format of any kind that depicts any part of the
incident described in the complaint.
12. Copies of any and all reports prepared by
regarding
13. Copies of any and all documents intends to
introduce into evidence at trial.
14. Copies of any and all documentation relied upon in support of
affirmative defenses.
15. Copies of any and all written or otherwise recorded rules, policies, and
procedures provided to any employee or agent of Plaintiff/Counter-
Defendant within the past 5 years.
16. Copies of any and all written or otherwise recorded information provided to
any employee or agent of within the past 5
years
17. Copies of any and all licenses held by any
18. Copies of any and all documents relied upon to respond to
Defendant/Counter-P aintiff's First Set of Interrogatories and
Defendant/Counter-P aintiff's First Request for Admissions.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished
via the e-portal to: Veronika Balbuzanova, Esq., Johnson I Dalal, 111 N. Pine Island Road,
Suite 103, Plantation, FL 33324; on :
September 3, 2021
BECK LAW, P.A.
901 Clint Moore Road, Suite C
Boca Raton, FL 33487
Tel: (561) 990-1647
Fax: (561) 717-9673
By: /s/ JOSHUA S. BECK, ESQ.
Florida Bar No.- 040659
Primary E-Mail:
Secondary E-Mail: beck@becklawpa.corn
Attorney for
Preview
Filing # 134001977 E-Filed 09/03/2021 10:39:00 AM USA MEDICARE ADVISORS INSURANCE IN THE CIRCUIT COURT OF THE 17TH AGENCY LLC, a Florida Limited Liability JUDICIAL CIRCUIT IN AND FOR Company, BROWARD COUNTY, FLORIDA Plaintiffs, CASE NO: CACE-21-010364 VS. ELITE HEALTH INVESTMENTS, INC., a Florida Profit Corporation, Defendant. FIRST REQUEST FOR PRODUCTION The ELITE HEALTH INVESTMENTS, INC., a Florida Profit Corporation (Hereinafter "ELITE"), by and through undersigned counsel, pursuant to Florida Rule of Civil Procedure 1.350, requests the Plaintiff/Counter- Defendant, , USA MEDICARE ADVISORS INSURANCE AGENCY LLC, a Florida Limited Liability Company (Hereinafter "UMA"), to produce and permit the inspection and copying of the following documents and papers within thirty (30) days, at the office of the attorneys for the 1. Copies of any and all contracts, agreements, and memoranda in your possession between the parties. 2. Copies of any and all correspondences sent between you and the including but not limited to emails, text messages, handwritten letters, or voice memos pertaining to the claims in the Complaint. 3. Copies of any and all correspondence received from Defendant/Counter- Plaintiff, including but not limited to emails, text messages, handwritten letters, or voice memos pertaining to the claims in the Complaint. 4. Copies of any and all correspondences sent between Plaintiff/Counter- Defendant and any third party concerning this matter. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/03/2021 10:38:59 AM.**** 5. Copies of any and all documents for any and all damages claimed by the pertaining to this matter. 6. Copies of any and all documents and/or invoices sent by you to the pertaining to this matter. 7- Copies of any and all statements previously made by the Plaintiff/Counter- Defendant or concerning the subject matter of this action, including any written statements, signed or otherwise adopted or approved by the and any stenographic, mechanical, electrical or other type of recording or any transcription thereof made by the hereto and contemporaneously recorded. 8. Copies of any and all files and documents kept by Plaintiff/Counter- Defendant pertaining to the Downline Agent Agreement. 9. Copies of any and all checks, statements, and/or other documents showing any and all payments made by you to 10. Copies of any and all checks, statements, and/or other documents showing any and all payments received by you from 11. Copies of any and all video and/photographic evidence, whether in digital, film, computer or any other format of any kind that depicts any part of the incident described in the complaint. 12. Copies of any and all reports prepared by regarding 13. Copies of any and all documents intends to introduce into evidence at trial. 14. Copies of any and all documentation relied upon in support of affirmative defenses. 15. Copies of any and all written or otherwise recorded rules, policies, and procedures provided to any employee or agent of Plaintiff/Counter- Defendant within the past 5 years. 16. Copies of any and all written or otherwise recorded information provided to any employee or agent of within the past 5 years 17. Copies of any and all licenses held by any 18. Copies of any and all documents relied upon to respond to Defendant/Counter-P aintiff's First Set of Interrogatories and Defendant/Counter-P aintiff's First Request for Admissions. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via the e-portal to: Veronika Balbuzanova, Esq., Johnson I Dalal, 111 N. Pine Island Road, Suite 103, Plantation, FL 33324; on : September 3, 2021 BECK LAW, P.A. 901 Clint Moore Road, Suite C Boca Raton, FL 33487 Tel: (561) 990-1647 Fax: (561) 717-9673 By: /s/ JOSHUA S. BECK, ESQ. Florida Bar No.- 040659 Primary E-Mail: Secondary E-Mail: beck@becklawpa.corn Attorney for