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Filing# 164843547 E-Filed 01/17/2023 11:50:45 AM
INTHE CIRCUIT COURT OF THE 17
,TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE-21-016578
JOY FURER,
Plaintiff,
V
GG RE HOLLYWOOD BEACH 613 LLC,
and RELAXPRO, LLC,
Defendants.
i
DEFENDANT GG RE HOLLYWOOD BEACH 613 LLC, FOURTH REQUEST FOR
PRODUCTION TO PLAINTIFF
The Defendant, GG RE HOLLYWOOD BEACH 613 LLC, (hereinafter
"Hollywood Beach"),
by and through the undersigned counsel, and in accordance with Rule 1.350 of the Florida Rules of
Civil Procedure, requests that Plaintiff, JOY FURER, produce the followingwithin thirty(30)days
after the service of this Request:
1. Executed NYS HIPPA form for provider Natures First LTC. (Form followed to plaintiff
counsel email).
2. Executed NYS HIPPA form for provider Dominque Cozien, MD. (Form followed to plaintiff
counsel email).
3. Executed NYS HIPPA form for provider Raz Winiarsky, MD. (Form followed to plaintiff
counsel email).
4. Executed NYS HIPPA form for provider Donald E Heitma, MD. (Form followed to plaintiff
counsel email).
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/17/2023 11:50:45 AM.****
CASE NO.: CACE-21-016578
5. Executed NYS HIPPA form for provider Malgorzata Land, M.D. (Form followed to plaintiff
counsel email).
6. Executed NYS HIPPA form for company Heartshare First Step Early Childhood Center.
(Form followed to plaintiff
counsel email).
7. Executed NYS HIPPA form for company Department of Education Office of General
Counsel. (Form followed to plaintiff
counsel email).
8. Executed NYS HIPPA form for company Adaptive Community Network. (Form followed to
counsel email).
plaintiff
9. Executed NYS HIPPA form for company Small Wonder Preschool QIueens. (Form followed
to counsel email).
plaintiff
10. Executed NYS HIPPA form for company Yai/Nyl, Greenpoint School. (Form followed to
counsel email).
plaintiff
11. Executed NYS HIPPA form for company Besen and Associates. (Form followed to plaintiff
counsel email).
12. Executed NYS HIPPA form for company Therapeutic Resources. (Form followed to plaintiff
counsel email).
13. Executed NYS HIPPA form for company Lori & Associates. (Form followed to plaintiff
counsel email).
14. Executed NYS HIPPA form for company B.O.L.D. Preschool. (Form followed to plaintiff
counsel email).
15. Executed NYS HIPPA form for company Lavelle School for the Blind. (Form followed to
counsel email).
plaintiff
21Page
CASE NO.: CACE-21-016578
16. Executed NYS HIPPA form for company Episcopal Social Services. (Form followed to
counsel email).
plaintiff
17. Executed NEW YORK STATE DEPARTMENT OF HEALTH Office of Health Insurance
Programs Authorization to Release Protected Medicaid Member Information to a Third
Party. (Form followed to plaintiff
counsel email).
18. Any and all copiesof State Income Tax Returns and applicable
attachments for the years of2018,
2020 and 2021.
19. Any and all copies of Federal Income Tax Returns and applicableattachments for the years of
2018, 2020 and 2021.
20. Any and all documents pertainingto the Motor Vehicle Accident that occurred on or about 2015,
includingbut not limited to policereports, tickets occurring from accident,medical records,
names of medical providersseen as a result of the accident, any lawsuit documents filed as a
result of accident.
21. Any and all documents pertainingto the Motor Vehicle Accident that occurred on or about 2020,
includingbut not limited to policereports, tickets occurring from accident, medical records,
names of medical providersseen as a result of the accident,any lawsuit documents filed as a
result of accident.
22. Any and all copies of medical records including but not limited to doctors' reports, physical
therapyrecords,hospitalrecords,patientquestionnaires, reports, consultation reports,
disability
records,includingnames of medications and/or equipment,names of prescribing
prescription
doctors, patient history,notes regarding consultations for medications and/or equipment,
payments made for and/or equipment doctors notes, chart notes, admission
prescriptions to
hospitalnotes, dischargenotes, nurses' notes, operativereports, diagnosis,prognosis,workers
31Page
CASE NO.: CACE-21-016578
reports or records, X-ray Reports, Disc
compensation reports or records, disability for films,
CT: Reports, Disc for films, M.Rl Reports, Disc for films for from all providersseen after the
date of June 1, 2022.
23. Any and all copies of document evidencing employment since January 1, 2010, includingbut
not limited to employment applicationsand/or letters from employers statingjob duties and/or
and/or restrictions,
responsibilities, pay rate, hours per week work on average, job role and start
date.
24. Any and all insurance records since January 1, 2021, to present, includingbut not limited to list
of codes with correspondingexplanation
in denying any medical payments for medical treatment
and services,copies of Medical Payment Log Sheet, any and all similar log sheets that lists and
reflects any and all requests for payment/ reimbursement for bills / and the payment of medical
bills from medical treatment that any medical providerprovided.
25. Any and all copies of subrogation files and lien pertainingto the allegedincident dated January
5,2021.
26. Any and all copies of any records associated with Plaintiff's disability
benefits includingbut not
approvals,denials,records applicableto disability,
limited to applications, physicianstatements,
and monetary compensation received.
physicianassessment, physicalattestation,
27. Any and all copies of any records associated with Plaintiff's rental assistance through the ERAP
or any other entityincluding but not limited to applications,
approvals,denials,physician
and monetary compensation received.
statements, physicianassessment, physicalattestation,
DATED January 17, 2023
41Page
CASE NO.: CACE-21-016578
ANDERSONGLENN LLP
s/.John .J. Glenn
John J. Glenn, Esquire
Florida Bar No.. 957860
jglenn@asglaw.com
Amanda N. Rumker, Esquire
Florida Bar No.: 122580
arumker@asglaw.com
2650 North MilitaryTrail,Suite 430
Boca Raton, Florida 33341
Tel.: (561) 893-9192
Fax: (561) 893-9194
Attorneys for GG RE
Hollywood Beach 613 LLC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on January 17, 2023, I filed the foregoingdocument
electronically
with the Clerk of the Court using Florida Court's E-FilingPortal and certify
that all counsel of record
have been served via transmission of Notice of Electronic Filinggenerated by Florida Court E-Filing
Portal or in some other authorized manner for those counsel or partieswho are not authorized to receive
Notices of Electronic Filing.
electronically
s/.John .J. Glenn
John J. Glenn, Esquire
51Page
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Filing# 164843547 E-Filed 01/17/2023 11:50:45 AM INTHE CIRCUIT COURT OF THE 17 ,TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-21-016578 JOY FURER, Plaintiff, V GG RE HOLLYWOOD BEACH 613 LLC, and RELAXPRO, LLC, Defendants. i DEFENDANT GG RE HOLLYWOOD BEACH 613 LLC, FOURTH REQUEST FOR PRODUCTION TO PLAINTIFF The Defendant, GG RE HOLLYWOOD BEACH 613 LLC, (hereinafter "Hollywood Beach"), by and through the undersigned counsel, and in accordance with Rule 1.350 of the Florida Rules of Civil Procedure, requests that Plaintiff, JOY FURER, produce the followingwithin thirty(30)days after the service of this Request: 1. Executed NYS HIPPA form for provider Natures First LTC. (Form followed to plaintiff counsel email). 2. Executed NYS HIPPA form for provider Dominque Cozien, MD. (Form followed to plaintiff counsel email). 3. Executed NYS HIPPA form for provider Raz Winiarsky, MD. (Form followed to plaintiff counsel email). 4. Executed NYS HIPPA form for provider Donald E Heitma, MD. (Form followed to plaintiff counsel email). *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/17/2023 11:50:45 AM.**** CASE NO.: CACE-21-016578 5. Executed NYS HIPPA form for provider Malgorzata Land, M.D. (Form followed to plaintiff counsel email). 6. Executed NYS HIPPA form for company Heartshare First Step Early Childhood Center. (Form followed to plaintiff counsel email). 7. Executed NYS HIPPA form for company Department of Education Office of General Counsel. (Form followed to plaintiff counsel email). 8. Executed NYS HIPPA form for company Adaptive Community Network. (Form followed to counsel email). plaintiff 9. Executed NYS HIPPA form for company Small Wonder Preschool QIueens. (Form followed to counsel email). plaintiff 10. Executed NYS HIPPA form for company Yai/Nyl, Greenpoint School. (Form followed to counsel email). plaintiff 11. Executed NYS HIPPA form for company Besen and Associates. (Form followed to plaintiff counsel email). 12. Executed NYS HIPPA form for company Therapeutic Resources. (Form followed to plaintiff counsel email). 13. Executed NYS HIPPA form for company Lori & Associates. (Form followed to plaintiff counsel email). 14. Executed NYS HIPPA form for company B.O.L.D. Preschool. (Form followed to plaintiff counsel email). 15. Executed NYS HIPPA form for company Lavelle School for the Blind. (Form followed to counsel email). plaintiff 21Page CASE NO.: CACE-21-016578 16. Executed NYS HIPPA form for company Episcopal Social Services. (Form followed to counsel email). plaintiff 17. Executed NEW YORK STATE DEPARTMENT OF HEALTH Office of Health Insurance Programs Authorization to Release Protected Medicaid Member Information to a Third Party. (Form followed to plaintiff counsel email). 18. Any and all copiesof State Income Tax Returns and applicable attachments for the years of2018, 2020 and 2021. 19. Any and all copies of Federal Income Tax Returns and applicableattachments for the years of 2018, 2020 and 2021. 20. Any and all documents pertainingto the Motor Vehicle Accident that occurred on or about 2015, includingbut not limited to policereports, tickets occurring from accident,medical records, names of medical providersseen as a result of the accident, any lawsuit documents filed as a result of accident. 21. Any and all documents pertainingto the Motor Vehicle Accident that occurred on or about 2020, includingbut not limited to policereports, tickets occurring from accident, medical records, names of medical providersseen as a result of the accident,any lawsuit documents filed as a result of accident. 22. Any and all copies of medical records including but not limited to doctors' reports, physical therapyrecords,hospitalrecords,patientquestionnaires, reports, consultation reports, disability records,includingnames of medications and/or equipment,names of prescribing prescription doctors, patient history,notes regarding consultations for medications and/or equipment, payments made for and/or equipment doctors notes, chart notes, admission prescriptions to hospitalnotes, dischargenotes, nurses' notes, operativereports, diagnosis,prognosis,workers 31Page CASE NO.: CACE-21-016578 reports or records, X-ray Reports, Disc compensation reports or records, disability for films, CT: Reports, Disc for films, M.Rl Reports, Disc for films for from all providersseen after the date of June 1, 2022. 23. Any and all copies of document evidencing employment since January 1, 2010, includingbut not limited to employment applicationsand/or letters from employers statingjob duties and/or and/or restrictions, responsibilities, pay rate, hours per week work on average, job role and start date. 24. Any and all insurance records since January 1, 2021, to present, includingbut not limited to list of codes with correspondingexplanation in denying any medical payments for medical treatment and services,copies of Medical Payment Log Sheet, any and all similar log sheets that lists and reflects any and all requests for payment/ reimbursement for bills / and the payment of medical bills from medical treatment that any medical providerprovided. 25. Any and all copies of subrogation files and lien pertainingto the allegedincident dated January 5,2021. 26. Any and all copies of any records associated with Plaintiff's disability benefits includingbut not approvals,denials,records applicableto disability, limited to applications, physicianstatements, and monetary compensation received. physicianassessment, physicalattestation, 27. Any and all copies of any records associated with Plaintiff's rental assistance through the ERAP or any other entityincluding but not limited to applications, approvals,denials,physician and monetary compensation received. statements, physicianassessment, physicalattestation, DATED January 17, 2023 41Page CASE NO.: CACE-21-016578 ANDERSONGLENN LLP s/.John .J. Glenn John J. Glenn, Esquire Florida Bar No.. 957860 jglenn@asglaw.com Amanda N. Rumker, Esquire Florida Bar No.: 122580 arumker@asglaw.com 2650 North MilitaryTrail,Suite 430 Boca Raton, Florida 33341 Tel.: (561) 893-9192 Fax: (561) 893-9194 Attorneys for GG RE Hollywood Beach 613 LLC CERTIFICATE OF SERVICE I HEREBY CERTIFY that on January 17, 2023, I filed the foregoingdocument electronically with the Clerk of the Court using Florida Court's E-FilingPortal and certify that all counsel of record have been served via transmission of Notice of Electronic Filinggenerated by Florida Court E-Filing Portal or in some other authorized manner for those counsel or partieswho are not authorized to receive Notices of Electronic Filing. electronically s/.John .J. Glenn John J. Glenn, Esquire 51Page