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Filing# 169625634 E-Filed 03/24/2023 07:19:16 PM
IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
PRESGAR IMAGING OF CMI NORTH,
LC and BEACHES OPEN MRI OF
TAMARAC, LLC, as assignees,individually, CONSOLIDATED
And on behalf of all similarlysituated persons,
Case Nos.: CACE 20-010138 (02)
Plaintiffs, CACE-20-013306 (18)
CACE-20-014646 (14)
V CACE-20-014759 (21)
LM GENERAL INSURANCE COMPANY,
Defendant.
i
DEFENDANTS' REQUEST FOR PRODUCTION TO PLAINTIFFS
REGARDING ATTORNEY'S FEES AND COSTS
Defendants, LM General Insurance Company, LM Insurance Corporation, The First
Liberty Insurance Corporation,and Liberty Mutual Insurance Company, by and through their
undersigned counsel, hereby file their Request for Production to Plaintiffs Regarding Attorney's
Fees and Costs as follows:
DOCUMENTS TO BE PRODUCED
1 All billingrecords that show the amount of time spent by any and all of Plaintiffs'
attorneys in this case.
2. All other types of records,checks, notes or other types of documents that show the
amount of time spent by Plaintiffs' attorneys in this case.
3. All other types of records, checks, notes or other types of documents that show the
time that was spent by any legalassistant,
paralegalor other professionalor para-professional
in
this case for which recovery is being sought.
69450541;1
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/24/2023 07:19:16 PM.****
4. All documents of any description
whatsoever that evidence the costs or expenses
of any kind that were incurred by the Plaintiffs and/or their attorneys or representatives,
in the
handling of this case, for which recovery is being sought.
5. Rdsumd of your his/her experienceas an attorney
expert witness (ifany) detailing
and as a fee witness.
6. Any and all expert reports.
7. Copies of any and all bills and statement of accounts submitted by your expert
witness for this case.
8. Any and all contracts or agreements, including but not limited to retainer
agreements and fee agreements between Plaintiffs and any of their attorneys which relate to the
instant litigation.
9. Any and all contemporaneous time records, including, but not limited to
handwritten records or computerized records,evidencing the amount oftime expended by any and
all of Plaintiff's attorneys in this litigation.
10. Any and all contemporaneous time records, including, but not limited to
handwritten records or computerized records, evidencingthe amount of time expended by legal
paralegalor other professionalor para-professional
assistant, in this litigation.
11. All court orders within the past five years awarding any of Plaintiffs' counsel a fee
in an insurance lawsuit.
12. All court orders within the past five years awarding any of Plaintiffs' counsel a fee
in connection with a non-insurance lawsuit.
13. All depositionsor other sworn testimony or affidavits given by any of Plaintiffs'
counsel within the past five years in connection with a fee disputefor an insurance lawsuit.
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69450541;1
14. All depositionsor other sworn testimony or affidavits given by any o f Plaintiffs'
counsel within the past five years in connection with a fee disputefor an non-insurance lawsuit.
Respectfullysubmitted,
AKERMAN LLP
Attorneys for Defendants
98 Southeast 7?? Street,Suite 1100
Miami, FL 33131
Phone: (305) 374-5600
Fax: (305) 374-5095
By- s/ Gary J. Guzzi
GARY J. GUZZI
Florida Bar No.: 159440
e-mail: gary. guzzi@akerman.com
Secondary e-mail: maria.revoredo@akerman.com
ANTONIO MORIN
Florida Bar No. 187860
e-mail: antonio.morin@akerman.com
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 24?? day of March, 2023, I served the foregoingvia e-
mail upon the following *leadings@injurylawyers.com) Thomas J. Wenzel, Esq., Steinger,
Greene & Feiner, 2727 NW 62nd Street,Ft. Lauderdale, FL 33309; (dclark@clarkmartino.com;
J. Daniel Clark, Esq.,Clark
jliza@clarkmartino.com) & Martino, 3407 W. Kennedy Blvd., Tampa,
FL 33609; (dcaldevilla@dgfirm.com; David M.
serviceclerk@dgfirm.com) Caldevilla,Esq., de la
Parte & Gilbert, P.A., P.O. Box 2350, Tampa, FL 33601-2350; (service@chadbarrlaw.com;
chad@chadbarrlaw.com) Chad A. Barr, Esq.,Chad Barr Law, 238 N. Westmonte Drive, Suite 200,
Altamonte Springs,FL 32714; *imberly@simoeslaw.com; service@simoeslaw.corn)Kimberly
Simoes, Esq.,The Simoes Law Group, P.A., 351 E. New York Avenue, Deland, FL 32724.
s/ Gary J. Guzzi
Attorney
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69450541;1
Preview
Filing# 169625634 E-Filed 03/24/2023 07:19:16 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA PRESGAR IMAGING OF CMI NORTH, LC and BEACHES OPEN MRI OF TAMARAC, LLC, as assignees,individually, CONSOLIDATED And on behalf of all similarlysituated persons, Case Nos.: CACE 20-010138 (02) Plaintiffs, CACE-20-013306 (18) CACE-20-014646 (14) V CACE-20-014759 (21) LM GENERAL INSURANCE COMPANY, Defendant. i DEFENDANTS' REQUEST FOR PRODUCTION TO PLAINTIFFS REGARDING ATTORNEY'S FEES AND COSTS Defendants, LM General Insurance Company, LM Insurance Corporation, The First Liberty Insurance Corporation,and Liberty Mutual Insurance Company, by and through their undersigned counsel, hereby file their Request for Production to Plaintiffs Regarding Attorney's Fees and Costs as follows: DOCUMENTS TO BE PRODUCED 1 All billingrecords that show the amount of time spent by any and all of Plaintiffs' attorneys in this case. 2. All other types of records,checks, notes or other types of documents that show the amount of time spent by Plaintiffs' attorneys in this case. 3. All other types of records, checks, notes or other types of documents that show the time that was spent by any legalassistant, paralegalor other professionalor para-professional in this case for which recovery is being sought. 69450541;1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/24/2023 07:19:16 PM.**** 4. All documents of any description whatsoever that evidence the costs or expenses of any kind that were incurred by the Plaintiffs and/or their attorneys or representatives, in the handling of this case, for which recovery is being sought. 5. Rdsumd of your his/her experienceas an attorney expert witness (ifany) detailing and as a fee witness. 6. Any and all expert reports. 7. Copies of any and all bills and statement of accounts submitted by your expert witness for this case. 8. Any and all contracts or agreements, including but not limited to retainer agreements and fee agreements between Plaintiffs and any of their attorneys which relate to the instant litigation. 9. Any and all contemporaneous time records, including, but not limited to handwritten records or computerized records,evidencing the amount oftime expended by any and all of Plaintiff's attorneys in this litigation. 10. Any and all contemporaneous time records, including, but not limited to handwritten records or computerized records, evidencingthe amount of time expended by legal paralegalor other professionalor para-professional assistant, in this litigation. 11. All court orders within the past five years awarding any of Plaintiffs' counsel a fee in an insurance lawsuit. 12. All court orders within the past five years awarding any of Plaintiffs' counsel a fee in connection with a non-insurance lawsuit. 13. All depositionsor other sworn testimony or affidavits given by any of Plaintiffs' counsel within the past five years in connection with a fee disputefor an insurance lawsuit. 2 69450541;1 14. All depositionsor other sworn testimony or affidavits given by any o f Plaintiffs' counsel within the past five years in connection with a fee disputefor an non-insurance lawsuit. Respectfullysubmitted, AKERMAN LLP Attorneys for Defendants 98 Southeast 7?? Street,Suite 1100 Miami, FL 33131 Phone: (305) 374-5600 Fax: (305) 374-5095 By- s/ Gary J. Guzzi GARY J. GUZZI Florida Bar No.: 159440 e-mail: gary. guzzi@akerman.com Secondary e-mail: maria.revoredo@akerman.com ANTONIO MORIN Florida Bar No. 187860 e-mail: antonio.morin@akerman.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 24?? day of March, 2023, I served the foregoingvia e- mail upon the following *leadings@injurylawyers.com) Thomas J. Wenzel, Esq., Steinger, Greene & Feiner, 2727 NW 62nd Street,Ft. Lauderdale, FL 33309; (dclark@clarkmartino.com; J. Daniel Clark, Esq.,Clark jliza@clarkmartino.com) & Martino, 3407 W. Kennedy Blvd., Tampa, FL 33609; (dcaldevilla@dgfirm.com; David M. serviceclerk@dgfirm.com) Caldevilla,Esq., de la Parte & Gilbert, P.A., P.O. Box 2350, Tampa, FL 33601-2350; (service@chadbarrlaw.com; chad@chadbarrlaw.com) Chad A. Barr, Esq.,Chad Barr Law, 238 N. Westmonte Drive, Suite 200, Altamonte Springs,FL 32714; *imberly@simoeslaw.com; service@simoeslaw.corn)Kimberly Simoes, Esq.,The Simoes Law Group, P.A., 351 E. New York Avenue, Deland, FL 32724. s/ Gary J. Guzzi Attorney 3 69450541;1