Party Discovery: LCM Imaging, Inc. A/A/O Kelly Byron vs Garrison Property & Casualty Insurance Company

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                                Filing # 125916459 E-Filed 04/30/2021 10:12:00 AM


                            IN THE COUNTY COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
                                 IN AND FOR HILLSBOROUGH COUNTY, STATE OF FLORIDA
                                                                 CIVIL DIVISION

                  LCM IMAGING INC., a/a/o KELLY
                  BYRON,

                                    Plaintiff,

                  vs.                                                                  CASE NO.:

                  GARRISON PROPERTY & CASUALTY
                  INSURANCE COMPANY,

                                    Defendant.
                  ___________________________________/



                                PLAINTIFF’S FIRST REQUEST TO PRODUCE TO DEFENDANT

                           Plaintiff, LCM IMAGING INC., a/a/o KELLY BYRON, by and through his undersigned
                  attorney,   pursuant    to Rule    1.350   Florida   Rules   of  Civil  Procedure,     hereby   requests   that  the
                  Defendant,    GARRISON         PROPERTY        &   CASUALTY         INSURANCE         COMPANY,          to produce
                  the items and matters hereinafter set forth.
                           The items and matters to be produced are as follows:

                           1.   A copy of all insurance policies that would be of benefit to the Plaintiff here, a

                                declaration of coverage in regard to the policy that the insured is covered under, a

                                sworn statement of a corporate officer or Defendant attesting to the coverage and

                                authenticity of the policy as required by Florida Statutes.



                           2.   The entire PIP file maintained by you or anyone on your behalf with regard to the

                                Plaintiff, cover to cover, including original jackets and everything contained within

                                the file, included but not limited to:




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                                A.   All notations regarding notice of the accident;

                                B.   All notifications of telephone conversations, including messages;
                                C.   All accident reports prepared by you, any law enforcement agencies, or your
                                     insured;

                                D.   All interoffice memoranda;

                                E.   All correspondence to or from anyone, including but not limited to any insurance
                                     agencies and doctor’s offices, any employers; and agencies hired to select doctors
                                     for Independent Medical Examinations; and any law enforcement agencies.

                                F.   Any and all PIP forms, including but not limited to PIP applications; medical
                                     report forms; employer verification forms, authorization forms and any other
                                     forms contained in said file; and,

                                G.   All records of the time expended on file or costs expended on file in the handling
                                     of any aspect of the Plaintiff’s claim.

                                    For any and all documents for which Defendant claims a privilege, please include

                                    a brief description of the document, to include the number of pages, to assist the

                                    court should an in camera inspection be necessary.



                           3.   Copies of all records transmitted by you in any form whatsoever to any physician’s

                                office or health care provider’s office concerning the insured’s physical and/or mental

                                condition.

                           4.   Any and all surveillance reports, claims history reports or other investigative reports

                                prepared by you or on your behalf with regard to the insured, or the Plaintiff.

                           5.   A current PIP payout sheet on the insured, regarding the 4/13/17 accident.

                           6.   Any and all estimates of repair or statements concerning the nature and extent of

                                damage to any of the vehicles involved in the 4/13/17 accident.




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                           7.   IME reports or records on the insured, and all documentation (of any kind, whether

                                sent by fax or mail) to and from any company for the purpose of obtaining an IME

                                report or records.

                           8.   EMC reports or records on the insured, and all documentation (of any kind, whether

                                sent by fax or mail) to and from any company for the purpose of obtaining an EMC

                                report or records, and/or any reports submitted to Defendant.

                           9.   Any and all documentation regarding any Peer Review done regarding the insured’s

                                treatment, including but not limited to:



                                a)   All Peer Review Reports.

                                b)   All records sent and/or used by the Peer Review Provider.


                                                         CERTIFICATE OF SERVICE

                                    I hereby certify that a true and correct copy of the foregoing has been furnished to

                  the Defendant along with service of the Complaint.


                                                                                 ____/s/ Amy T. Sullivan________
                                                                                 AMY T. SULLIVAN, ESQUIRE
                                                                                 Florida Bar No.: 108387
                                                                                 ANTHONY T. PRIETO, ESQUIRE
                                                                                 Florida Bar No.: 195529
                                                                                 MORGAN AND MORGAN
                                                                                 3705 N. Himes Ave.
                                                                                 Tampa, Florida      33607
                                                                                 Tel:  813/877-8600 / Fax:       813/202-7192
                                                                                 Attorneys For Plaintiff




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