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Filing # 176568380 E-Filed 06/30/2023 03:52:55 PM
IN THE CIRCUIT COURT, FOURTH
JUDICIAL CIRCUIT, IN AND FOR
DUVAL COUNTY, FLORIDA
CASE NO.: 2023-CA-6709
DIVISION: CV-A
TERRY BROCK,
Plaintiff(s),
vs.
MISS BECKY SEAFOOD INC.,
Defendants.
______________________________________
DEFENDANT MISS BECKY SEAFOOD INC.’S REQUEST FOR PRODUCTION OF
DOCUMENTS TO PLAINTIFF
TO: TERRY BROCK
c/o Joshua Frisbie
20 North Orange Avenue, Suite 1600
Orlando, FL 32801
Attorney for Plaintiff
Defendant MISS BECKY SEAFOOD INC. requests that Plaintiff TERRY BROCK
produce for inspection, copying or photographing at the offices of Boyd & Jenerette, P.A., 201
North Hogan Street, Suite 400, Jacksonville, Florida 32202, on or before thirty (30) days from the
date of these requests, the following documents:
1. All medical and hospital bills including prescription bills incurred to date.
2. All claim forms or medical reports submitted on your behalf under medical
payments or personal injury protection of any insurance policy.
3. Receipt for all food and beverage consumed on the date of loss as alleged in the
complaint.
4. All other bills, statements and/or estimates which plaintiff claim to be related or
and caused by the incident described in the complaint.
05443923
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 07/01/2023 11:26:14 PM
5. Income tax returns for the five years before the accident to the present, including
all attachments (W-2s, W-4s, 1099s, etc.)
6. Complete the highlighted areas and execute the attached Request for Social
Security Earnings Information (SSA-7050).
7. All medical reports, opinions or other written documents from doctors, nurses, and
other medical practitioners, or other expert witnesses containing information concerning the
injuries sustained by plaintiff in the incident referred to in the complaint.
8. All hospital records for hospitalization which resulted from the incident referred to
in the complaint.
9. Copy of all written or transcribed statements made or given by plaintiff or
defendants and/or any witnesses relating or pertaining to the incident referred to in the complaint.
10. Copy of the insurance policy which affords coverage for the incident referred to in
the complaint.
11. All records (including, but not limited to, insurance policies, applications, claim
forms, correspondence and notices of benefits paid or denied) of collateral source benefits,
personal injury protection benefits, workers compensation benefits, and unemployment
compensation benefits applied for or received by you after the accident alleged in the complaint.
12. Photographs taken of the plaintiff following the incident referred to in the complaint
purporting to show injuries sustained by the plaintiff and photographs taken of the accident scene
or, if applicable, the equipment involved in the incident.
13. Copy of any and all records which you maintain support any claim for any lost
wages.
14. Regarding any lost wages or lost earning capacity, all notes, memos, ledger sheets,
time records, wage records or writings of any kind showing any jobs since this incident that you
have not been able to obtain or fulfill because of this incident, and any other writings of any kind
whatsoever which in anyway pertain to any lost wages or lost earning capacity.
15. Any items of physical evidence, including any objects, substances, diagrams,
measurements, plans, blueprints, documents, letters, or any other tangible items obtained which
relate to the incident described in the complaint.
16. If you have ever served in the military or are a military dependent, please complete
all highlighted sections and execute the attached Request for Military Records (SF180), the
05443923
attached Dept of VA - Request for and Authorization to Release Health Information (VA Form
10-5345) and Authorization for Disclosure of Medical or Dental Information directed to
TRICARE Health Plan (DD 2870).
17. If you have applied for social security disability, please identify at which office
your applied and execute If you have applied for social security disability, please identify at which
office your applied and complete the highlighted areas and execute the attached social security
release (SSA-3288).
18. Attach a copy of your cellular telephone bill for the date of loss as alleged in the
complaint.
19. Please provide the shoes you were wearing at the time of the alleged slip and fall.
20. Copies of all notices pursuant to Florida Statutes §768.76(6), i.e. all notices that you
are legally required to send to the provider of any collateral sources of claimant’s intent to claim
damages from the tortfeasor.
21. Copies of any correspondence received from the provider of any collateral sources,
including, but not limited to any correspondence which indicates that the collateral source provider
intends to maintain their right of subrogation or reimbursement or waive their right of subrogation
or reimbursement.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing has been furnished by eService on June
30, 2023 to Joshua Frisbie, Esq., Morgan & Morgan P.A., (jfrisbie@forthepeople.com) 20 N.
Orange Ave., Ste. 1600, Orlando, FL 32801.
BOYD & JENERETTE, P.A.
________________________________
ROBERT E. SCHRADER, III
Florida Bar Number: 15180
JENNIFER L. MEIER
Florida Bar No. 1018374
201 North Hogan Street, Suite 400
Jacksonville, Florida 32202
904-353-6241 – Telephone
05443923
904-353-2863 – Facsimile
Attorneys for Defendant
Primary Address for E-service:
efiling@boydjen.com
05443923
Preview
Filing # 176568380 E-Filed 06/30/2023 03:52:55 PM IN THE CIRCUIT COURT, FOURTH JUDICIAL CIRCUIT, IN AND FOR DUVAL COUNTY, FLORIDA CASE NO.: 2023-CA-6709 DIVISION: CV-A TERRY BROCK, Plaintiff(s), vs. MISS BECKY SEAFOOD INC., Defendants. ______________________________________ DEFENDANT MISS BECKY SEAFOOD INC.’S REQUEST FOR PRODUCTION OF DOCUMENTS TO PLAINTIFF TO: TERRY BROCK c/o Joshua Frisbie 20 North Orange Avenue, Suite 1600 Orlando, FL 32801 Attorney for Plaintiff Defendant MISS BECKY SEAFOOD INC. requests that Plaintiff TERRY BROCK produce for inspection, copying or photographing at the offices of Boyd & Jenerette, P.A., 201 North Hogan Street, Suite 400, Jacksonville, Florida 32202, on or before thirty (30) days from the date of these requests, the following documents: 1. All medical and hospital bills including prescription bills incurred to date. 2. All claim forms or medical reports submitted on your behalf under medical payments or personal injury protection of any insurance policy. 3. Receipt for all food and beverage consumed on the date of loss as alleged in the complaint. 4. All other bills, statements and/or estimates which plaintiff claim to be related or and caused by the incident described in the complaint. 05443923 ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 07/01/2023 11:26:14 PM 5. Income tax returns for the five years before the accident to the present, including all attachments (W-2s, W-4s, 1099s, etc.) 6. Complete the highlighted areas and execute the attached Request for Social Security Earnings Information (SSA-7050). 7. All medical reports, opinions or other written documents from doctors, nurses, and other medical practitioners, or other expert witnesses containing information concerning the injuries sustained by plaintiff in the incident referred to in the complaint. 8. All hospital records for hospitalization which resulted from the incident referred to in the complaint. 9. Copy of all written or transcribed statements made or given by plaintiff or defendants and/or any witnesses relating or pertaining to the incident referred to in the complaint. 10. Copy of the insurance policy which affords coverage for the incident referred to in the complaint. 11. All records (including, but not limited to, insurance policies, applications, claim forms, correspondence and notices of benefits paid or denied) of collateral source benefits, personal injury protection benefits, workers compensation benefits, and unemployment compensation benefits applied for or received by you after the accident alleged in the complaint. 12. Photographs taken of the plaintiff following the incident referred to in the complaint purporting to show injuries sustained by the plaintiff and photographs taken of the accident scene or, if applicable, the equipment involved in the incident. 13. Copy of any and all records which you maintain support any claim for any lost wages. 14. Regarding any lost wages or lost earning capacity, all notes, memos, ledger sheets, time records, wage records or writings of any kind showing any jobs since this incident that you have not been able to obtain or fulfill because of this incident, and any other writings of any kind whatsoever which in anyway pertain to any lost wages or lost earning capacity. 15. Any items of physical evidence, including any objects, substances, diagrams, measurements, plans, blueprints, documents, letters, or any other tangible items obtained which relate to the incident described in the complaint. 16. If you have ever served in the military or are a military dependent, please complete all highlighted sections and execute the attached Request for Military Records (SF180), the 05443923 attached Dept of VA - Request for and Authorization to Release Health Information (VA Form 10-5345) and Authorization for Disclosure of Medical or Dental Information directed to TRICARE Health Plan (DD 2870). 17. If you have applied for social security disability, please identify at which office your applied and execute If you have applied for social security disability, please identify at which office your applied and complete the highlighted areas and execute the attached social security release (SSA-3288). 18. Attach a copy of your cellular telephone bill for the date of loss as alleged in the complaint. 19. Please provide the shoes you were wearing at the time of the alleged slip and fall. 20. Copies of all notices pursuant to Florida Statutes §768.76(6), i.e. all notices that you are legally required to send to the provider of any collateral sources of claimant’s intent to claim damages from the tortfeasor. 21. Copies of any correspondence received from the provider of any collateral sources, including, but not limited to any correspondence which indicates that the collateral source provider intends to maintain their right of subrogation or reimbursement or waive their right of subrogation or reimbursement. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been furnished by eService on June 30, 2023 to Joshua Frisbie, Esq., Morgan & Morgan P.A., (jfrisbie@forthepeople.com) 20 N. Orange Ave., Ste. 1600, Orlando, FL 32801. BOYD & JENERETTE, P.A. ________________________________ ROBERT E. SCHRADER, III Florida Bar Number: 15180 JENNIFER L. MEIER Florida Bar No. 1018374 201 North Hogan Street, Suite 400 Jacksonville, Florida 32202 904-353-6241 – Telephone 05443923 904-353-2863 – Facsimile Attorneys for Defendant Primary Address for E-service: efiling@boydjen.com 05443923