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Filing # 190946912 E-Filed 01/31/2024 02:03:58 PM
IN THE COUNTY COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH COUNTY, STATE OF FLORIDA
CIVIL DIVISION
UNIVERSAL PAIN SPECIALISTS, INC.,
D/B/A UNIVERSAL SPINE & JOINT
SPECIALISTS, AS ASSIGNEE OF
LOURDES CORTES-MEIJAS,
Plaintiff, CASE NO.:
vs.
GEICO CASUALTY COMPANY,
Defendant.
___________________________________/
PLAINTIFF’S FIRST REQUEST TO PRODUCE TO DEFENDANT
Plaintiff, UNIVERSAL PAIN SPECIALISTS, INC., D/B/A UNIVERSAL SPINE &
JOINT SPECIALISTS, AS ASSIGNEE OF LOURDES CORTES-MEIJAS, by and through his
undersigned attorney, pursuant to Rule 1.350 Florida Rules of Civil Procedure, hereby requests
that the Defendant, GEICO CASUALTY 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:
A. All notations regarding notice of the accident;
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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 March 9, 2023 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 March 9, 2023 accident.
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.
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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/ Ben Kincer .
BEN KINCER, ESQUIRE
Florida Bar No.: 108895
ANTHONY T. PRIETO, ESQUIRE
Florida Bar No.: 195529
MORGAN AND MORGAN
3705 N. Himes Avenue
Tampa, Florida 33607
(Tel) 813/877-8600 / (Fax) 813/876-1884
Attorneys for Plaintiff
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