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Filing# 136526926 E-Filed 10/14/2021 09:14:03 AM
INTHE CIRCUIT COURT OF THE
PABLO GORORDO and GLENDA LUCIA JUDICIAL CIRCUIT IN AND FOR
17th
SANTIAGO DE AGUILAR as arent and natural BROWARD COUNTY, FLORIDA
guardian of D.A.S. and J.A.S.,minors ,
CASE NO.: CACE-21-010675 (12)
Plaintiffs,
VS.
H& INTERNATIONAL TRADING LL and
CLARA ROBINSON, P.A.,
Defendants.
i
PLAINTIFF. GLENDA LUCIA SANTIAGO DE AGUILAR'S. as parent and
natural guardian to D.A.S. & J.A.S.. minors. RESPONSE TO
DEFENDANT'S REOUEST FOR PRODUCTION
COME NOW the Plaintiff,GLENDA LUCIA SANTIAGO DE AGUILAR as parent and natural
guardianofD.A.S. and J.A.S.,minors, byand throughundersigned counsel, and responds totheDefendant's,
H& INTERNATIONAL TRADINGLLandCLARA ROBINSON, P.A., Request for Productionpropounded
to Plaintiff on July 6, 2021 ,
as follows:
1 Copies of Plaintiffs all pages of unexpired and expired: Passport from all other countries, U.S.
Passport or Passport Card, U. S. Citizen ID card, Certificate ofU. S. Citizenship,Pennanent Resident
Card, Certificate of Naturalization, foreign passport, Alien Registration Card, Employment
Authorization Card, Driver's license or ID card issued by any federal, state or local government
entity,school ID card,Military Dependent'sID card, Voter's registrationcard, U.S. Military card or
draft rec ord, Native American tribal document, U.S. social security card issued by the Social
Security Administration, and any documents issued by the Department of Homeland Security
verifyingyour and minors D.A.S and J.A.S.'s identityand eligibility
for employment in the United
States.
Response: (Noted born in Dominican Republic, we do not have mom ID on file)
2. Any and all hospital,medical or other bills,paid or owing, and resultingfrom the subjectincident.
Response: See all available, on both minors, attached.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/14/2021 09:14:03 AM.****
3. Any and all hospital,clinic,emergency room records,x- rays, MRIs, CT studies,medical reports,
doctors' reports, office notes or other medical records related to or connected with the medical care
and treatment rendered to the Plaintiff and minors D.A.S. and J.A.S.
Response: See all available,on both minors, attached.
4. Any and all written or recorded statements taken from any person who has any knowledge
concerning the subjectincident.
Response:
5. Any and all written or recorded statements taken of this Defendant or this Defendant's agents,
servants and employees, related to or connected with the subjectincident.
Response: Objection;equal access
6. Any and all digitalimages or reprints from photographs(film or digital),films, slides, graphs,
videotapes,charts,and other documentary evidence ofthe incident scene, the partiesand any product
or other property involved in or pertaining to the subject incident.
Response: See all attached
7. Marriage Certificate for the present marriage o f the Plaintiff.
Response: (GS is Married) Objection,irrelevant as Plaintiff is not pursuing a Consortium Claim
8 Birth certificates of the Plaintiff and minors D.A. S. and J.A. S.
Response: (Need these sent thru)
9. Any and all documentation demonstrating legalcustody of minors D.A.S. and J.A.S. by Plaintiff.
Response: See attached birth certificates.
10. Any and all police accident/incident reports and police investigationreports related to or connected
with the subjectincident.
Response: None
11. Any and all investigationreports or analyses made by any governmental agency or department
concerning the subjectincident.
Response: None
12. Any and all fire/rescue reports, ambulance or other emergency medical services reports or other
similar reports or records.
Response: See attached to Number 3
13. Any and all digitalimages or reprintsfrom photographs (film or digital),
slides or videotapes (film
or digital)taken of Plaintiffs and minors D.A.S. and J.A.S.'s injuries
at any point in time since the
date of the accident to the present time.
Response: See any injuryphotos available for either minor, attached
14. Any and all documents pertaining to any claims by Plaintiff against any other person, entity,or
insurer as a result of the allegedincident.
Response: None
15. Any and all documents pertaining to any settlement of any claim by the Plaintiff with any other
person, entity or insurer in connection with the subjectincident.
Response: None
16. Any and all medical records for medical treatment or examinations received by the Plaintiff,and
minors D.A.S. and J.A.S. in the last ten (10) years.
Response: No unrelated medical reports in Plaintiff' s possession.
17. Anyand all medical records for anymental health treatment orexamination received bythe Plaintiff
and minors D.A.S. and J.A.S. in the last ten (10) years.
Response: Objection,irrelevant to the subjectinjuriesand harassing
18. Anyand all reports prepared byany experts who have been retained bythe Plaintiffto testifyat trial,
including a copy of each experts C.V.
Response: Objection,this Matter is pending a Trial Period assignment and Discovery is on-going. It
is unknown what evidence/ experts would be used at this time.
19. Certified copies of any and all insurance policiesthat provide or may provide benefits or coverage
to the Plaintiff and minors D.A.S. and J.A.S. for any damage claimed as a result of the subject
incident.
Response: All available,attached
20. Each andevery document, model, plat,map, drawing,motionpicture,videotape,photograph orother
tangible evidence identified or referred to in your answers to Initial Interrogatoriesserved by this
Defendant to Plaintiff.
Response: Anything not previously presented is attached
21. The Plaintiffs notification to collateral source providers,as required by Florida Statute §768.76(6)
and any response thereto as required by Florida Statute §768.76(7).
Response: Subrogation Responses from Oscar Health is pending. Plaintiff will provide under
Supplemental Responses, should anything be presented.
22. All correspondence, forms or other documents provided by Defendant to the Plaintiffat the time of
the subjectincident.
Response:
23. All contracts, identification cards, applications,statements, explanation o f benefits or similar
document for each insurance company, HMO, PPO, or private or governmental entityidentified in
your answer Initial Interrogatories
served by this Defendant to Plaintiff
Response: See attached.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via U.S.
Mail to: JACK R. SIMMONS, ESQ. and PETER S. BAUMBERGER, ESQ., KUBICKI DRAPER Counsel
for Defendants 9100 S. Dadeland Blvd., Suite 1800 Miami, FL 33156
rs@kubickidraper.com; kenia.fernandez@kubickidraper.com;psb@kubickidraper.com, on this 14t day of
ith
October 2021
BERMAN LAW GROUP
Attorneys for Plaintiffs
Post Office Box 272789
Boca Raton, Florida 33427
Telephone: (561) 826-5200
Facsimile: (561) 826-5201
-By./s/ Craig A. Collin
Craig A. Collin,Esq.
Florida Bar No.: 0065281
service@thebermanlawgroup.com
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Filing# 136526926 E-Filed 10/14/2021 09:14:03 AM INTHE CIRCUIT COURT OF THE PABLO GORORDO and GLENDA LUCIA JUDICIAL CIRCUIT IN AND FOR 17th SANTIAGO DE AGUILAR as arent and natural BROWARD COUNTY, FLORIDA guardian of D.A.S. and J.A.S.,minors , CASE NO.: CACE-21-010675 (12) Plaintiffs, VS. H& INTERNATIONAL TRADING LL and CLARA ROBINSON, P.A., Defendants. i PLAINTIFF. GLENDA LUCIA SANTIAGO DE AGUILAR'S. as parent and natural guardian to D.A.S. & J.A.S.. minors. RESPONSE TO DEFENDANT'S REOUEST FOR PRODUCTION COME NOW the Plaintiff,GLENDA LUCIA SANTIAGO DE AGUILAR as parent and natural guardianofD.A.S. and J.A.S.,minors, byand throughundersigned counsel, and responds totheDefendant's, H& INTERNATIONAL TRADINGLLandCLARA ROBINSON, P.A., Request for Productionpropounded to Plaintiff on July 6, 2021 , as follows: 1 Copies of Plaintiffs all pages of unexpired and expired: Passport from all other countries, U.S. Passport or Passport Card, U. S. Citizen ID card, Certificate ofU. S. Citizenship,Pennanent Resident Card, Certificate of Naturalization, foreign passport, Alien Registration Card, Employment Authorization Card, Driver's license or ID card issued by any federal, state or local government entity,school ID card,Military Dependent'sID card, Voter's registrationcard, U.S. Military card or draft rec ord, Native American tribal document, U.S. social security card issued by the Social Security Administration, and any documents issued by the Department of Homeland Security verifyingyour and minors D.A.S and J.A.S.'s identityand eligibility for employment in the United States. Response: (Noted born in Dominican Republic, we do not have mom ID on file) 2. Any and all hospital,medical or other bills,paid or owing, and resultingfrom the subjectincident. Response: See all available, on both minors, attached. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/14/2021 09:14:03 AM.**** 3. Any and all hospital,clinic,emergency room records,x- rays, MRIs, CT studies,medical reports, doctors' reports, office notes or other medical records related to or connected with the medical care and treatment rendered to the Plaintiff and minors D.A.S. and J.A.S. Response: See all available,on both minors, attached. 4. Any and all written or recorded statements taken from any person who has any knowledge concerning the subjectincident. Response: 5. Any and all written or recorded statements taken of this Defendant or this Defendant's agents, servants and employees, related to or connected with the subjectincident. Response: Objection;equal access 6. Any and all digitalimages or reprints from photographs(film or digital),films, slides, graphs, videotapes,charts,and other documentary evidence ofthe incident scene, the partiesand any product or other property involved in or pertaining to the subject incident. Response: See all attached 7. Marriage Certificate for the present marriage o f the Plaintiff. Response: (GS is Married) Objection,irrelevant as Plaintiff is not pursuing a Consortium Claim 8 Birth certificates of the Plaintiff and minors D.A. S. and J.A. S. Response: (Need these sent thru) 9. Any and all documentation demonstrating legalcustody of minors D.A.S. and J.A.S. by Plaintiff. Response: See attached birth certificates. 10. Any and all police accident/incident reports and police investigationreports related to or connected with the subjectincident. Response: None 11. Any and all investigationreports or analyses made by any governmental agency or department concerning the subjectincident. Response: None 12. Any and all fire/rescue reports, ambulance or other emergency medical services reports or other similar reports or records. Response: See attached to Number 3 13. Any and all digitalimages or reprintsfrom photographs (film or digital), slides or videotapes (film or digital)taken of Plaintiffs and minors D.A.S. and J.A.S.'s injuries at any point in time since the date of the accident to the present time. Response: See any injuryphotos available for either minor, attached 14. Any and all documents pertaining to any claims by Plaintiff against any other person, entity,or insurer as a result of the allegedincident. Response: None 15. Any and all documents pertaining to any settlement of any claim by the Plaintiff with any other person, entity or insurer in connection with the subjectincident. Response: None 16. Any and all medical records for medical treatment or examinations received by the Plaintiff,and minors D.A.S. and J.A.S. in the last ten (10) years. Response: No unrelated medical reports in Plaintiff' s possession. 17. Anyand all medical records for anymental health treatment orexamination received bythe Plaintiff and minors D.A.S. and J.A.S. in the last ten (10) years. Response: Objection,irrelevant to the subjectinjuriesand harassing 18. Anyand all reports prepared byany experts who have been retained bythe Plaintiffto testifyat trial, including a copy of each experts C.V. Response: Objection,this Matter is pending a Trial Period assignment and Discovery is on-going. It is unknown what evidence/ experts would be used at this time. 19. Certified copies of any and all insurance policiesthat provide or may provide benefits or coverage to the Plaintiff and minors D.A.S. and J.A.S. for any damage claimed as a result of the subject incident. Response: All available,attached 20. Each andevery document, model, plat,map, drawing,motionpicture,videotape,photograph orother tangible evidence identified or referred to in your answers to Initial Interrogatoriesserved by this Defendant to Plaintiff. Response: Anything not previously presented is attached 21. The Plaintiffs notification to collateral source providers,as required by Florida Statute §768.76(6) and any response thereto as required by Florida Statute §768.76(7). Response: Subrogation Responses from Oscar Health is pending. Plaintiff will provide under Supplemental Responses, should anything be presented. 22. All correspondence, forms or other documents provided by Defendant to the Plaintiffat the time of the subjectincident. Response: 23. All contracts, identification cards, applications,statements, explanation o f benefits or similar document for each insurance company, HMO, PPO, or private or governmental entityidentified in your answer Initial Interrogatories served by this Defendant to Plaintiff Response: See attached. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via U.S. Mail to: JACK R. SIMMONS, ESQ. and PETER S. BAUMBERGER, ESQ., KUBICKI DRAPER Counsel for Defendants 9100 S. Dadeland Blvd., Suite 1800 Miami, FL 33156 rs@kubickidraper.com; kenia.fernandez@kubickidraper.com;psb@kubickidraper.com, on this 14t day of ith October 2021 BERMAN LAW GROUP Attorneys for Plaintiffs Post Office Box 272789 Boca Raton, Florida 33427 Telephone: (561) 826-5200 Facsimile: (561) 826-5201 -By./s/ Craig A. Collin Craig A. Collin,Esq. Florida Bar No.: 0065281 service@thebermanlawgroup.com