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Filing # 156048816 E-Filed 08/24/2022 04:24:13 PM
IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIRCUIT CIVIL DIVISION
BARBARA GONZALEZ,
CASE NO.: 082021CA000968XXXXXX
Plaintiff,
v.
MICHAEL G. EDWARDS and HHS
ENVIRONMENTAL SERVICES, LLC.
Defendants.
___________________________________/
DEFENDANTS, MICHAEL G. EDWARDS and HHS
ENVIRONMENTAL SERVICES, LLC.’S, UPDATED REQUESTS FOR PRODUCTION
TO PLAINTIFF, BARBARA GONZALEZ
Defendants, MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES,
LLC., by and through undersigned counsel, and pursuant to Rule 1.350 of the Florida Rules of
Civil Procedure, hereby request that Plaintiff, BARBARA GONZALEZ, produce the following
at the offices of the undersigned.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was e-mailed to all
counsel of the attached Service List this 24th day of August, 2022.
KUBICKI DRAPER
9100 South Dadeland Blvd.
Suite 1800
Miami, FL 33156
Telephone: (305) 982-6604
Facsimile: (305) 374-7846
Pleadings: FIC-KD@kubickidraper.com
By: /s/ Francesca Ippolito-Craven
FRANCESCA IPPOLITO-CRAVEN
fic@kubickidraper.com
Florida Bar Number: 0145361
LISANDRA GUERRERO
lg@kubickidraper.com
Florida Bar Number: 0098521
SERVICE LIST
Co-counsel for Plaintiff:
Michael J. Rossi, Esq.
MICHAEL J. ROSSI, P.A.
115 South Albany Avenue
Tampa, FL 33606
michael@michaelrossilaw.com
Helen Stratigakos, Esq.
STRATIGAKOS LAW, P.A.
412 East Madison Street, Suite 814
Tampa, FL 33602
helen@stratigakoslaw.com
marty@stratigakoslaw.com
UPDATED REQUESTS FOR PRODUCTION
1. Any and all medical reports, medical records, forms, memorandum and other writings of
all medical doctors, chiropractors or other health care providers as a result of the incident
alleged herein for treatment rendered subsequent to October 25, 2021.
RESPONSE:
2. Any and all hospital records, including, but not limited to admissions records, admissions
summary, discharge summary and nurses' notes as a result of the incident alleged herein
for treatment rendered subsequent to October 25, 2021.
RESPONSE:
3. Any and all radiology images, including, but not limited to MRI films, MRI images, CT
Scan Films, CT Scan Images, X-Ray Films and/or X-Ray images, as a result of the
incident alleged herein for treatment rendered subsequent to October 25, 2021.
RESPONSE:
4. True copies of any and all medical bills and/or statements for services rendered, paid or
unpaid and any and all evidence of payment by Plaintiff or on behalf of the Plaintiff of
any of the medical bills and/or statements as a result of the incident alleged herein for
treatment rendered subsequent to October 25, 2021.
RESPONSE:
5. All documentary evidence of benefits or payments to Plaintiff or on his behalf as defined
by Florida Statute Section 627.7372(2), and all other documentary evidence of benefits
paid under workman's compensation law and/or any other collateral sources since
October 25, 2021.
RESPONSE:
6. Bills, receipts, or other evidence of expenses and out-of-pocket expenses incurred as a
result of the incident which is the subject of this litigation.
RESPONSE:
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Filing # 156048816 E-Filed 08/24/2022 04:24:13 PM IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIRCUIT CIVIL DIVISION BARBARA GONZALEZ, CASE NO.: 082021CA000968XXXXXX Plaintiff, v. MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES, LLC. Defendants. ___________________________________/ DEFENDANTS, MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES, LLC.’S, UPDATED REQUESTS FOR PRODUCTION TO PLAINTIFF, BARBARA GONZALEZ Defendants, MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES, LLC., by and through undersigned counsel, and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, hereby request that Plaintiff, BARBARA GONZALEZ, produce the following at the offices of the undersigned. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was e-mailed to all counsel of the attached Service List this 24th day of August, 2022. KUBICKI DRAPER 9100 South Dadeland Blvd. Suite 1800 Miami, FL 33156 Telephone: (305) 982-6604 Facsimile: (305) 374-7846 Pleadings: FIC-KD@kubickidraper.com By: /s/ Francesca Ippolito-Craven FRANCESCA IPPOLITO-CRAVEN fic@kubickidraper.com Florida Bar Number: 0145361 LISANDRA GUERRERO lg@kubickidraper.com Florida Bar Number: 0098521 SERVICE LIST Co-counsel for Plaintiff: Michael J. Rossi, Esq. MICHAEL J. ROSSI, P.A. 115 South Albany Avenue Tampa, FL 33606 michael@michaelrossilaw.com Helen Stratigakos, Esq. STRATIGAKOS LAW, P.A. 412 East Madison Street, Suite 814 Tampa, FL 33602 helen@stratigakoslaw.com marty@stratigakoslaw.com UPDATED REQUESTS FOR PRODUCTION 1. Any and all medical reports, medical records, forms, memorandum and other writings of all medical doctors, chiropractors or other health care providers as a result of the incident alleged herein for treatment rendered subsequent to October 25, 2021. RESPONSE: 2. Any and all hospital records, including, but not limited to admissions records, admissions summary, discharge summary and nurses' notes as a result of the incident alleged herein for treatment rendered subsequent to October 25, 2021. RESPONSE: 3. Any and all radiology images, including, but not limited to MRI films, MRI images, CT Scan Films, CT Scan Images, X-Ray Films and/or X-Ray images, as a result of the incident alleged herein for treatment rendered subsequent to October 25, 2021. RESPONSE: 4. True copies of any and all medical bills and/or statements for services rendered, paid or unpaid and any and all evidence of payment by Plaintiff or on behalf of the Plaintiff of any of the medical bills and/or statements as a result of the incident alleged herein for treatment rendered subsequent to October 25, 2021. RESPONSE: 5. All documentary evidence of benefits or payments to Plaintiff or on his behalf as defined by Florida Statute Section 627.7372(2), and all other documentary evidence of benefits paid under workman's compensation law and/or any other collateral sources since October 25, 2021. RESPONSE: 6. Bills, receipts, or other evidence of expenses and out-of-pocket expenses incurred as a result of the incident which is the subject of this litigation. RESPONSE: