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Filing # 78513216 E-Filed 09/27/2018 11:14:55 AM
IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE-18-001790 (12)
DOUGLAS BRANCH,
Plaintiff,
vs.
SOUTH FLORIDA LIGHTING TEAM LLC
and the CITY OF FORT LAUDERDALE,
Defendants.
/
SOUTH FLORIDA LIGHTING TEAM, LLC’S
FIRST REQUEST FOR PRODUCTION TO PLAINTIFF
COMES NOW, the Defendant, SOUTH FLORIDA LIGHTING TEAM, LLC (“SFLT”),
by and through the undersigned counsel, and pursuant to the Florida Rules of Civil Procedure,
and requests Plaintiff, DOUGLAS BRANCH (“Plaintiff”), to produce the following, for
inspection and/or photocopying, at the offices of Kubicki Draper, Penthouse, City National Bank
Building, 25 West Flagler Street, Miami, FL 33130:
Any and all medical reports, medical records, forms, memorandum, and other
writings of all medical doctors, chiropractors or other health care providers as a
result of the incident alleged herein.
Any and all medical reports, medical records, forms, memorandum, and other
writings of all medical doctors, chiropractors or other health care providers who
have rendered any care or treatment to the Plaintiff during the last ten years.
Any and all hospital records, including, but not limited to admissions records,
admission summary, discharge summary and nurses’ notes as a result of the
incident alleged herein.
Any and all hospital records, including, but not limited to admissions records,
admissions summary, discharge summary and nurses’ notes pertaining to the
Plaintiff during the last ten years.
*4* FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 9/27/2018 11:14:54 AM.****12.
13.
15.
16.
Branch v. South Florida Lighting Team
Case No.: CACE-18-001790 (12)
Page 2
True copies of any and all medical bills and /or statements for services rendered,
paid or unpaid and any and all evidence of payment by the Plaintiff or on behalf
of the Plaintiff of any of the medical bills or statements as a result of the incident
alleged herein.
All documentary evidence of benefits or payments to the Plaintiff or on his/her
behalf as defined by Florida Statute Section 627.7373 (2), and all other
documentary evidence of benefits paid under any collateral sources.
Copies of all declaration sheets, explanation pamphlets and insurance policies
providing group and/or private health insurance benefits and automobile
insurance benefits to the Plaintiff.
Copies of all declarations sheets, explanation pamphlets and insurance policies
providing disability benefits/income to Plaintiff herein.
All receipts, invoices, bills, checks, statements, ledgers, and copies reflecting all
food and beverages you consumed the day of the subject incident.
Copies of the W-2 Withholding Tax Statements and any and all other business
records or income records and other evidence of 2007, 2008, 2009, 2010, 2011,
2012, 2013, 2014, 2015, 2016 and 2017 income.
Copies of 2007, 2008, 2009, 2010, 2011, 2012, 2013, 2014, 2015, 2016, and 2017
Federal Income Tax Returns.
Evidence of 2018 income to date.
Any and all photographs and video recordings in the possession, custody or
control of the Plaintiff, Plaintiff's agents, servants, or attorneys, showing the area
of the subject incident, of the Plaintiff showing the alleged injuries following the
subject incident, and any other photographs pertaining to the claims alleged
herein.
All ordinances, regulations, rules, statutes, customs and practices, and
publications upon which the claims herein are made.
Any and all statements, obtained by you, your agents or your attorneys, of the
defendant, its agents, servants and employees either recorded or written prior to
all the time of, or subsequent to the subject incident.
Any and all depositions given by Plaintiff in the last ten years.Branch v. South Florida Lighting Team
Case No.: CACE-18-001790 (12)
CERTIFICATE OF SERVICE
Page 3
WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via
the Florida Courts Efiling Portal this 27th day of September, 2018 to all counsel on the attached
service list.
Fernando Ramirez, Esq.
Leifer Law Firm
1200 North Federal Highway, Suite 320
Boca Raton, Florida 33432
Counsel to Plaintiff
framirez@ ei w.com
samantha@leiferlaw.com
Michael T. Burke, Esq.
Johnson, Anselmo, Murdoch,
Burke, Piper & Hochman, P.A.
2455 E. Sunrise Blvd., Ste. 1000
Fort Lauderdale, Florida 33304
Counsel to City of Fort Lauderdale
Burke@jambg.com
Cardona@jambg.com
BY:
KUBICKI DRAPER
Counsel to
South Florida Lighting Team, LLC
25 West Flagler Street, Penthouse
Miami, Florida 33130
Direct Line: (305) 982-6715
ist Michael Suareg
PETER S. BAUMBERGER
Florida Bar No.: 117803
MICHAEL F, SUAREZ
Florida Bar No.: 88845
SERVICE LIST
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Filing # 78513216 E-Filed 09/27/2018 11:14:55 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-18-001790 (12) DOUGLAS BRANCH, Plaintiff, vs. SOUTH FLORIDA LIGHTING TEAM LLC and the CITY OF FORT LAUDERDALE, Defendants. / SOUTH FLORIDA LIGHTING TEAM, LLC’S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF COMES NOW, the Defendant, SOUTH FLORIDA LIGHTING TEAM, LLC (“SFLT”), by and through the undersigned counsel, and pursuant to the Florida Rules of Civil Procedure, and requests Plaintiff, DOUGLAS BRANCH (“Plaintiff”), to produce the following, for inspection and/or photocopying, at the offices of Kubicki Draper, Penthouse, City National Bank Building, 25 West Flagler Street, Miami, FL 33130: Any and all medical reports, medical records, forms, memorandum, and other writings of all medical doctors, chiropractors or other health care providers as a result of the incident alleged herein. Any and all medical reports, medical records, forms, memorandum, and other writings of all medical doctors, chiropractors or other health care providers who have rendered any care or treatment to the Plaintiff during the last ten years. Any and all hospital records, including, but not limited to admissions records, admission summary, discharge summary and nurses’ notes as a result of the incident alleged herein. Any and all hospital records, including, but not limited to admissions records, admissions summary, discharge summary and nurses’ notes pertaining to the Plaintiff during the last ten years. *4* FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 9/27/2018 11:14:54 AM.****12. 13. 15. 16. Branch v. South Florida Lighting Team Case No.: CACE-18-001790 (12) Page 2 True copies of any and all medical bills and /or statements for services rendered, paid or unpaid and any and all evidence of payment by the Plaintiff or on behalf of the Plaintiff of any of the medical bills or statements as a result of the incident alleged herein. All documentary evidence of benefits or payments to the Plaintiff or on his/her behalf as defined by Florida Statute Section 627.7373 (2), and all other documentary evidence of benefits paid under any collateral sources. Copies of all declaration sheets, explanation pamphlets and insurance policies providing group and/or private health insurance benefits and automobile insurance benefits to the Plaintiff. Copies of all declarations sheets, explanation pamphlets and insurance policies providing disability benefits/income to Plaintiff herein. All receipts, invoices, bills, checks, statements, ledgers, and copies reflecting all food and beverages you consumed the day of the subject incident. Copies of the W-2 Withholding Tax Statements and any and all other business records or income records and other evidence of 2007, 2008, 2009, 2010, 2011, 2012, 2013, 2014, 2015, 2016 and 2017 income. Copies of 2007, 2008, 2009, 2010, 2011, 2012, 2013, 2014, 2015, 2016, and 2017 Federal Income Tax Returns. Evidence of 2018 income to date. Any and all photographs and video recordings in the possession, custody or control of the Plaintiff, Plaintiff's agents, servants, or attorneys, showing the area of the subject incident, of the Plaintiff showing the alleged injuries following the subject incident, and any other photographs pertaining to the claims alleged herein. All ordinances, regulations, rules, statutes, customs and practices, and publications upon which the claims herein are made. Any and all statements, obtained by you, your agents or your attorneys, of the defendant, its agents, servants and employees either recorded or written prior to all the time of, or subsequent to the subject incident. Any and all depositions given by Plaintiff in the last ten years.Branch v. South Florida Lighting Team Case No.: CACE-18-001790 (12) CERTIFICATE OF SERVICE Page 3 WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via the Florida Courts Efiling Portal this 27th day of September, 2018 to all counsel on the attached service list. Fernando Ramirez, Esq. Leifer Law Firm 1200 North Federal Highway, Suite 320 Boca Raton, Florida 33432 Counsel to Plaintiff framirez@ ei w.com samantha@leiferlaw.com Michael T. Burke, Esq. Johnson, Anselmo, Murdoch, Burke, Piper & Hochman, P.A. 2455 E. Sunrise Blvd., Ste. 1000 Fort Lauderdale, Florida 33304 Counsel to City of Fort Lauderdale Burke@jambg.com Cardona@jambg.com BY: KUBICKI DRAPER Counsel to South Florida Lighting Team, LLC 25 West Flagler Street, Penthouse Miami, Florida 33130 Direct Line: (305) 982-6715 ist Michael Suareg PETER S. BAUMBERGER Florida Bar No.: 117803 MICHAEL F, SUAREZ Florida Bar No.: 88845 SERVICE LIST