Party Discovery: SOS MEDICAL CENTER -VS- GEICO GENERAL INSURANCE COMPANY

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                                IN THE COUNTY COURT OF THE 18TH
JUDICIAL CIRCUIT, IN AND FOR
SEMINOLECOUNTY, FLORIDA

CASE NO.: 2024SC003594

SOS MEDICAL CENTER DBA CIMA
MEDICAL CENTER

        (a/a/o Stanley Auguste)

                        Plaintiff,




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GEICO GENERAL INSURANCE




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COMPANY

                  Defendant.




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           F I      PLAINTIFF’S FIRST REQUEST TO PRODUCE




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        The Plaintiff, SOS MEDICAL CENTER DBA CIMA MEDICAL CENTER by

and through undersigned counsel, hereby requests the Defendant produce the items and




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matters hereinafter set forth.

        YOUR ATTENTION IS INVITED TO THE REQUIREMENTS OF FLA.




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        R. CIV. P. 1.350(B) WHEREIN THE PARTY TO WHOM THIS
        REQUEST IS DIRECTED IS REQUIRED TO SERVE A WRITTEN
        RESPONSE HERETO WITHIN 45 DAYS AFTER THE SERVICE
        HEREOF WITH THE COMPLAINT OR PETITION AND SUBJECT TO
        THE ALLOWANCE OF A SHORTER OR LONGER TIME BY THE
        COURT.

        PLAINTIFF REQUESTS THAT ALL COPIES OR ITEMS PRODUCED
        BE AT LEAST FULL SIZE (8 ½” X 11” OR 8 ½” X 14”). IF YOUR
        DOCUMENTS ARE KEPT IN ELECTRONIC FORMAT, YOU MAY
        SERVE THE RESPONSIVE DOCUMENTS IN ELECTRONIC PDF
        FORMAT. PLEASE DO NOT EMAIL THE UNDERSIGNED OR THE
        UNDERSIGNED’S SERVICE EMAIL ADDRESS WITH ANY
        COMPRESSED FILES (I.E. “.ZIP”). PLEASE FEEL FREE TO
        CONTACT THE UNDERSIGNED TO COORDINATE TRANSMISSION
        OF FILES LARGER THAN THE SIZE LIMITATIONS OF FLA. R. JUD.
        ADMIN. 2.516(B)(1)(E)(IV) OR REGARDING SUBMISSIONS WHERE
        IT WOULD BE MORE CONVENIENT FOR YOU TO SUBMIT VIA
        COMPRESSED FILE FORMAT.

        CONSTRUE ALL REQUESTS FOR PRODUCTION BELOW
        REQUESTING “DOCUMENTS”, “FILES”, OR THE LIKE AS ALSO
        BEING INCLUSIVE OF A REQUEST FOR ANY SUCH MATERIALS
        THAT YOU HAPPEN TO STORE IN ELECTRONIC OR OTHER
        FORMAT.

             The items and matters to be produced are as follows:

1.      The entire PIP file maintained by you or anyone on your behalf regarding Stanley




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Auguste, cover to cover, including original jackets and everything contained within the file.




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2.         All insurance policies that would cover Stanley Auguste, together with any

declaration of coverage page and sworn statement of a corporate officer of Defendant




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attesting to the coverage and authentic of the policy as required by Florida Statutes.




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3.      All documents upon which you may rely to support your Affirmative Defenses.




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4.      All documents that tend to show your Affirmative Defenses lack legal or factual




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support.




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5.      Any and all indicators or evidence of fraud in Defendant’s possession (o the




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possession of its vendors/contractors) regarding the motor vehicle accident of 03/07/2022 or

regarding the bills at issue in this case.

6.      All sworn statements, recorded statements, or written statements taken of any

interested party to this action including, but not limited to, SOS MEDICAL CENTER DBA

CIMA MEDICAL CENTER or Stanley Auguste.

7.      Any and all sworn statements, recorded statements, written statements, or reports

from any potential witness relevant to the instant action.

8.      Any and all surveillance films or photographs taken by you or anyone on your

behalf of SOS MEDICAL CENTER DBA CIMA MEDICAL CENTER or Stanley
Auguste.

9.      An un redacted log of personal injury protection benefits paid by the insurer on

behalf of the insured (“PIP Log”).

10.     All explanations of review in Stanley Auguste’s claim at issue in the instant lawsuit



        As good cause for same, the Plaintiff would show unto the Court that said

documents requested above are in the exclusive care, custody, and control of the




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Defendants, agents, servants, employees, insurance companies, or attorneys; that thy are




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relevant and material to the issues of the lawsuit, and the Plaintiff cannot secure same or the




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equivalent thereof but for leave of this Court.




            F I               CERTIFICATE OF SERVICE




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        I HEREBY CERTIFY that a true and correct copy of the foregoing was attached

to the copy of the Summons and Complaint to be served by process on the Defendant.




        NO                                        STEINGER, GREENE & FEINER




      U                                           /s/ Thomas J. Wenzel
                                                  THOMAS J. WENZEL, ESQUIRE
                                                  Fla. Bar No.: 104117
                                                  133 NW 100th Avenue
                                                  Plantation, FL 33324
                                                  Telephone:     954 491 7701
                                                  Fax Number: 954 634 8312
                                                     Service:    pleadings@injurylawyers.com

                                                  Attorney for Plaintiff