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Filing # 173434472 E-Filed 05/18/2023 10:22:04 AM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL COURT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL DIVISION
Case No.: 2023-000559-CA
Division: Civil
GREGORY TEAGUE,
Plaintiff,
Vv.
CINDY HORNBUCKLE and
THE STANDARD FIRE INSURANCE COMPANY,
Defendants.
/
RE UEST TO PRODUCE
PURSUANT to Rule 1.350 of the Florida Rules of Civil Procedure, the Plaintiff,
GREGORY TEAGUE, is hereby requested to produce to the Defendant, THE STANDARD
FIRE INSURANCE COMPANY, within thirty (30) days from the receipt hereof, the following
items:
Defendant asserts there is a need of the requested materials in the preparation of
Defendant’s case and is unable without undue hardship to obtain the substantial equivalent of the
materials by other means.
If the party or parties to whom this request is directed claims that any of the information
requested is privileged or subject to protection as trial preparation material, the party shall make
the claim expressly and shall describe the nature of the documents not produced pursuant to
Florida Rule of Civil Procedure 1.280(b)(5).
1 All documents evidencing or supporting the claim for personal injuries, including
emotional distress, allegedly suffered by the plaintiff in the accident giving rise to this lawsuit,
including but not limited to the following:
A All bills, receipts, and cancelled checks relating to medical expenses;
B All written reports, office notes, hospital records, correspondence, X-ray
readings and other documentation prepared by any physician or medical expert.
Cc All photographs, notes, diaries, physical evidence or other documents and
objects which relate to the plaintiff's claim for personal injuries or emotional distress.
D. All films and diagnostic studies, reports and documents, including but not
limited to x-rays, MRIs, CT scans, and the like.
2. Copies of all medical reports received by the Plaintiff, Plaintiff's attorney,
investigators, agents, servants, or employees, from doctors, physicians, or anyone else who has
rendered treatment to the Plaintiff PRIOR to the accident which is the subject matter of this lawsuit.
3 Copies of all hospital records from any hospital where the Plaintiff was a patient
PRIOR to the accident which is the subject matter of this lawsuit, which are in the possession of the
Plaintiff, Plaintiff's attorney, investigators, agents, servants or employees.
4 Any and all documents, writings and/or other tangible objects which would identify
each and every collateral source (as defined by the applicable Florida Statutes), which has already
paid any benefits or from which benefits are otherwise payable or available for any of the damages,
losses or injuries that Plaintiffis claiming in this lawsuit.
5 All written and/or recorded statements taken from the Defendants in this action,
concerning this action or its subject matter or a stenographic, mechanical, electrical or other
recording or transcription of a statement that is a substantial verbatim recital or oral statement.
6. Any and all photographs, graphs, charts, and other documentary evidence of the
scene, parties, or vehicles, if applicable, involved in or pertaining to the subject accident or
occurrence or issues in this cause which the Plaintiff will use at trial, or which has been furnished to
any expert who will be listed as an expert witness for trial.
7 Please provide legible copies of the following all brochures, applications,
contracts, agreements, liens, correspondence or other similar documents received by you,
completed by you, anyone on your behalf and your attorney(s) as part of the process of entering
into all agreements, negotiations and contracts with a lender, litigation funding company,
litigation lending company, medical funding company, or similar entity.
8 Copies of all written materials concerning any settlement by Plaintiff with any other
person or entity which may have been liable for the damages claimed by the Plaintiff, together with
all Releases, Litigation Loan Agreements, “Mary Carter” or other similar Agreements.
9 Copies of all automobile insurance policies which provide or may provide PIP
benefits, medical payments or disability payments to Plaintiff with regards to the damages alleged to
have been incurred as a result of the subject accident, together with the relevant declarations or face
sheet, reflecting available coverages and deductibles.
10. Copies of any and all PIP documents submitted by Plaintiff to any PIP carrier,
including any Notice of Loss forms, PIP payout logs, Reimbursement Forms, Wage Loss forms, or
other documentation of loss.
11. Copies of any and all applications for social security disability, together with all
records, correspondence and evaluations being utilized by the Social Security Administration for
review of your disability.
12. Any and all documents reflecting any amounts of any collateral sources paid to the
Plaintiff on account of expenses incurred as a result of the incident complained of. This is to
include but not be limited to Social Security, Income Disability, Auto Insurance, Group Employee
Insurance, Wage Continuation Plans, etc.
13. Copies of all “Letters of Protection” provided to your medical providers where
you agree that the medical provider’s bills your treatment will be paid of any monies that you
recover in this litigation.
14. Please provide a copy of any and all current and prior insurance cards providing
coverage to you for automobile, homeowners, and/or medical coverage.
15. All documents evidencing or supporting the claim for lost earnings or earning
capacity, including but not limited to the following:
A Federal and State tax returns filed for the past ten (10) years;
B Records of profit and loss, and all other documentation concerning any
businesses in which the plaintiff
has had an ownership interest for the past ten (10) years;
Cc Any other documents or summaries which relate to the plaintiff's income
for the past ten (10) years;
D. Payroll records, time sheets, or other documentation to reflect the total
amount of time which the plaintiff has missed from employment as a result of the injuries
received in the accident giving rise to this lawsuit.
E. All documents, certificates and diplomas relating to the plaintiff's
educational pursuits since attendance at or graduation from high school.
F All documents relating to the plaintiffs military service, including
induction and discharge documents.
16. All documents evidencing or supporting the claim for property damages,
including, but not limited to the following:
A All bills, estimates, invoices or cancelled checks relating to estimates or
repair of this property;
B All photographs, diagrams, summaries or other documentation concerning
the property allegedly damaged in the accident giving rise to this lawsuit;
Cc All receipts, estimates, purchase orders or other documentation reflecting
the fair market value of the property before and after the accident giving rise to this lawsuit.
17. All documents evidencing the payment by any persons or organizations, of any of
the damage allegedly sustained by the plaintiff, in the accident giving rise to this lawsuit,
including but not limited to the following:
A Any and all releases, assignments, agreements, settlement pleadings, or
receipts for expense advance of any of the damage claims alleged to have resulted from the
accident in question, or in settlement of any claims arising directly or indirectly out of this
accident, or from the medical care and treatment received following this accident.
B Any evidence of payment of medical expenses, property damage or any
other damage alleged to have resulted from the accident in question.
18. All documents, photographs, diagrams or reports prepared by the plaintiff or by
anyone, including potential expert witnesses, acting on behalf of the plaintiff, which relate to the
accident giving rise to this lawsuit or the damages claimed to have resulted from that accident.
19. All statements, prior testimony, or other rendering of facts and opinions, whether
written, tape-recorded or summarized, in the possession of or available to the plaintiff or the
plaintiff's attorney, which relate to the accident giving rise to this lawsuit or the damages alleged
to have resulted from that accident.
20. All exhibits which may be introduced into evidence on behalf of the plaintiff at
the trial of this lawsuit, or used by the plaintiff and any witnesses in preparation for giving
testimony in this case, at the discovery or trial stages of this lawsuit.
This Request for Production is designed to be continuing in nature, and the plaintiff is
therefore requested to supplement the response as soon as any additional information and
documentation is received by or available to the plaintiff or the plaintiff's attorney.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
email to Angela Cc Agostino, Esquire at agostino@forthepeople.com,
jsantiago@forthepeople.com and sorzech@forthepeople.com; and Daniel Lemongello, Esquire at
marial@hill-lem-law.com, joant@hill-lem-law.com and danI@hill-lem-law.com, on this 18 day
of May, 2023.
/s/Amy L. Glasser
Amy L. Glasser, Esquire
Law Offices of Jack D. Evans
1 North Dale Mabry Highway, Suite 805
Tampa, Florida 33609
Telephone: (813) 357-6211
Attorney for Defendant, Standard Fire
Florida Bar No.: 1025000
Email: aglasser@travelers.com
JDETampa@Travelers.com
Preview
Filing # 173434472 E-Filed 05/18/2023 10:22:04 AM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL COURT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL DIVISION Case No.: 2023-000559-CA Division: Civil GREGORY TEAGUE, Plaintiff, Vv. CINDY HORNBUCKLE and THE STANDARD FIRE INSURANCE COMPANY, Defendants. / RE UEST TO PRODUCE PURSUANT to Rule 1.350 of the Florida Rules of Civil Procedure, the Plaintiff, GREGORY TEAGUE, is hereby requested to produce to the Defendant, THE STANDARD FIRE INSURANCE COMPANY, within thirty (30) days from the receipt hereof, the following items: Defendant asserts there is a need of the requested materials in the preparation of Defendant’s case and is unable without undue hardship to obtain the substantial equivalent of the materials by other means. If the party or parties to whom this request is directed claims that any of the information requested is privileged or subject to protection as trial preparation material, the party shall make the claim expressly and shall describe the nature of the documents not produced pursuant to Florida Rule of Civil Procedure 1.280(b)(5). 1 All documents evidencing or supporting the claim for personal injuries, including emotional distress, allegedly suffered by the plaintiff in the accident giving rise to this lawsuit, including but not limited to the following: A All bills, receipts, and cancelled checks relating to medical expenses; B All written reports, office notes, hospital records, correspondence, X-ray readings and other documentation prepared by any physician or medical expert. Cc All photographs, notes, diaries, physical evidence or other documents and objects which relate to the plaintiff's claim for personal injuries or emotional distress. D. All films and diagnostic studies, reports and documents, including but not limited to x-rays, MRIs, CT scans, and the like. 2. Copies of all medical reports received by the Plaintiff, Plaintiff's attorney, investigators, agents, servants, or employees, from doctors, physicians, or anyone else who has rendered treatment to the Plaintiff PRIOR to the accident which is the subject matter of this lawsuit. 3 Copies of all hospital records from any hospital where the Plaintiff was a patient PRIOR to the accident which is the subject matter of this lawsuit, which are in the possession of the Plaintiff, Plaintiff's attorney, investigators, agents, servants or employees. 4 Any and all documents, writings and/or other tangible objects which would identify each and every collateral source (as defined by the applicable Florida Statutes), which has already paid any benefits or from which benefits are otherwise payable or available for any of the damages, losses or injuries that Plaintiffis claiming in this lawsuit. 5 All written and/or recorded statements taken from the Defendants in this action, concerning this action or its subject matter or a stenographic, mechanical, electrical or other recording or transcription of a statement that is a substantial verbatim recital or oral statement. 6. Any and all photographs, graphs, charts, and other documentary evidence of the scene, parties, or vehicles, if applicable, involved in or pertaining to the subject accident or occurrence or issues in this cause which the Plaintiff will use at trial, or which has been furnished to any expert who will be listed as an expert witness for trial. 7 Please provide legible copies of the following all brochures, applications, contracts, agreements, liens, correspondence or other similar documents received by you, completed by you, anyone on your behalf and your attorney(s) as part of the process of entering into all agreements, negotiations and contracts with a lender, litigation funding company, litigation lending company, medical funding company, or similar entity. 8 Copies of all written materials concerning any settlement by Plaintiff with any other person or entity which may have been liable for the damages claimed by the Plaintiff, together with all Releases, Litigation Loan Agreements, “Mary Carter” or other similar Agreements. 9 Copies of all automobile insurance policies which provide or may provide PIP benefits, medical payments or disability payments to Plaintiff with regards to the damages alleged to have been incurred as a result of the subject accident, together with the relevant declarations or face sheet, reflecting available coverages and deductibles. 10. Copies of any and all PIP documents submitted by Plaintiff to any PIP carrier, including any Notice of Loss forms, PIP payout logs, Reimbursement Forms, Wage Loss forms, or other documentation of loss. 11. Copies of any and all applications for social security disability, together with all records, correspondence and evaluations being utilized by the Social Security Administration for review of your disability. 12. Any and all documents reflecting any amounts of any collateral sources paid to the Plaintiff on account of expenses incurred as a result of the incident complained of. This is to include but not be limited to Social Security, Income Disability, Auto Insurance, Group Employee Insurance, Wage Continuation Plans, etc. 13. Copies of all “Letters of Protection” provided to your medical providers where you agree that the medical provider’s bills your treatment will be paid of any monies that you recover in this litigation. 14. Please provide a copy of any and all current and prior insurance cards providing coverage to you for automobile, homeowners, and/or medical coverage. 15. All documents evidencing or supporting the claim for lost earnings or earning capacity, including but not limited to the following: A Federal and State tax returns filed for the past ten (10) years; B Records of profit and loss, and all other documentation concerning any businesses in which the plaintiff has had an ownership interest for the past ten (10) years; Cc Any other documents or summaries which relate to the plaintiff's income for the past ten (10) years; D. Payroll records, time sheets, or other documentation to reflect the total amount of time which the plaintiff has missed from employment as a result of the injuries received in the accident giving rise to this lawsuit. E. All documents, certificates and diplomas relating to the plaintiff's educational pursuits since attendance at or graduation from high school. F All documents relating to the plaintiffs military service, including induction and discharge documents. 16. All documents evidencing or supporting the claim for property damages, including, but not limited to the following: A All bills, estimates, invoices or cancelled checks relating to estimates or repair of this property; B All photographs, diagrams, summaries or other documentation concerning the property allegedly damaged in the accident giving rise to this lawsuit; Cc All receipts, estimates, purchase orders or other documentation reflecting the fair market value of the property before and after the accident giving rise to this lawsuit. 17. All documents evidencing the payment by any persons or organizations, of any of the damage allegedly sustained by the plaintiff, in the accident giving rise to this lawsuit, including but not limited to the following: A Any and all releases, assignments, agreements, settlement pleadings, or receipts for expense advance of any of the damage claims alleged to have resulted from the accident in question, or in settlement of any claims arising directly or indirectly out of this accident, or from the medical care and treatment received following this accident. B Any evidence of payment of medical expenses, property damage or any other damage alleged to have resulted from the accident in question. 18. All documents, photographs, diagrams or reports prepared by the plaintiff or by anyone, including potential expert witnesses, acting on behalf of the plaintiff, which relate to the accident giving rise to this lawsuit or the damages claimed to have resulted from that accident. 19. All statements, prior testimony, or other rendering of facts and opinions, whether written, tape-recorded or summarized, in the possession of or available to the plaintiff or the plaintiff's attorney, which relate to the accident giving rise to this lawsuit or the damages alleged to have resulted from that accident. 20. All exhibits which may be introduced into evidence on behalf of the plaintiff at the trial of this lawsuit, or used by the plaintiff and any witnesses in preparation for giving testimony in this case, at the discovery or trial stages of this lawsuit. This Request for Production is designed to be continuing in nature, and the plaintiff is therefore requested to supplement the response as soon as any additional information and documentation is received by or available to the plaintiff or the plaintiff's attorney. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by email to Angela Cc Agostino, Esquire at agostino@forthepeople.com, jsantiago@forthepeople.com and sorzech@forthepeople.com; and Daniel Lemongello, Esquire at marial@hill-lem-law.com, joant@hill-lem-law.com and danI@hill-lem-law.com, on this 18 day of May, 2023. /s/Amy L. Glasser Amy L. Glasser, Esquire Law Offices of Jack D. Evans 1 North Dale Mabry Highway, Suite 805 Tampa, Florida 33609 Telephone: (813) 357-6211 Attorney for Defendant, Standard Fire Florida Bar No.: 1025000 Email: aglasser@travelers.com JDETampa@Travelers.com