On January 12, 2018 a
Party Discovery
was filed
involving a dispute between
Christner, Robert,
and
Security National Insurance Company,
for Auto Negligence
in the District Court of Broward County.
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Filing # 107106630 E-Filed 05/06/2020 08:48:21 AM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR,
BROWARD COUNTY, FLORIDA
ROBERT CHRISTNER CASE NO.: CACE-18-00873 (02)
Plaintiff,
vs.
SECURITY NATIONAL INSURANCE
COMPANY
Defendants.
/
DEFENDAN UPDATE REQUEST TO PRODUCE TO PL. TIFF
Defendants, SECURITY NATIONAL INSURANCE COMPANY, by and
through their undersigned attorney, and pursuant to and in compliance with Florida Rule
of Civil Procedure 1.350, files this Update Request to Produce to Plaintiff, and requests
that Plaintiff produce and permit Defendants to inspect and copy each of the following
documents within thirty (30) days:
1. Federal Income Tax Returns of the Plaintiff for the years 2013 through 2020
inclusive, together with all schedules, attachments, addendums, W-2 forms, and 1099 forms,
or provide a signed authorization that is attached.
2. Any and all documents reflecting weekly, monthly, or annual income which
the Plaintiffreceived from any self-employment from January 1, 2013, to the present.
3. Any and all medical records from any health care provider containing
information regarding the injuries and damages allegedly sustained by the Plaintiff as a
result of the incident which is the subject matter of this litigation.
4. Any and all statements, invoices or bills for services rendered by any health
care provider for care, treatment or evaluation of the injuries and damages allegedly
sustained by the Plaintiff as a result of the incident which is the subject matter of this
litigation.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/06/2020 08:48:21 AM.****5. Any and all medical records in Plaintiff's possession reflecting any and all
medical treatment which is NOT RELATED to the subject matter of this litigation.
6. A copy of any motor vehicle accident/homicide report regarding any
incidents after this subject incident.
7. Any and all photographs depicting any damage vehicles to any incidents that
occurred after this subject incident.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished via E-Mail on May 6, 2020 to:
Richard B. Doyle, Jr.
506 SE 8th Street
Fort Lauderdale, FL 33316
Email: pleadings@loughren-doyle.com
Attomey for Plaintiff ROBERT CHRISTNER
/s/_ Anthony D. Cutrona
CARLOS M. LLORENTE, ESQUIRE
FL. Bar No.: 507997
ANTHONY D. CUTRONA, ESQUIRE
FL. Bar No.: 124074
Law Offices of Christina M. Sanabria
1200 South Pine Island Road Suite 725
Plantation FL 33324
Phone: (954) 585-5581
Fax: (954) 316-5291
Primary Email:
Anthony.Cutrona@farmersinsurance.com
Noemi.hernandez@farmersinsurance.com
Attomey for Defendant
Document Filed Date
May 06, 2020
Case Filing Date
January 12, 2018
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Filing # 107106630 E-Filed 05/06/2020 08:48:21 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR, BROWARD COUNTY, FLORIDA ROBERT CHRISTNER CASE NO.: CACE-18-00873 (02) Plaintiff, vs. SECURITY NATIONAL INSURANCE COMPANY Defendants. / DEFENDAN UPDATE REQUEST TO PRODUCE TO PL. TIFF Defendants, SECURITY NATIONAL INSURANCE COMPANY, by and through their undersigned attorney, and pursuant to and in compliance with Florida Rule of Civil Procedure 1.350, files this Update Request to Produce to Plaintiff, and requests that Plaintiff produce and permit Defendants to inspect and copy each of the following documents within thirty (30) days: 1. Federal Income Tax Returns of the Plaintiff for the years 2013 through 2020 inclusive, together with all schedules, attachments, addendums, W-2 forms, and 1099 forms, or provide a signed authorization that is attached. 2. Any and all documents reflecting weekly, monthly, or annual income which the Plaintiffreceived from any self-employment from January 1, 2013, to the present. 3. Any and all medical records from any health care provider containing information regarding the injuries and damages allegedly sustained by the Plaintiff as a result of the incident which is the subject matter of this litigation. 4. Any and all statements, invoices or bills for services rendered by any health care provider for care, treatment or evaluation of the injuries and damages allegedly sustained by the Plaintiff as a result of the incident which is the subject matter of this litigation. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/06/2020 08:48:21 AM.****5. Any and all medical records in Plaintiff's possession reflecting any and all medical treatment which is NOT RELATED to the subject matter of this litigation. 6. A copy of any motor vehicle accident/homicide report regarding any incidents after this subject incident. 7. Any and all photographs depicting any damage vehicles to any incidents that occurred after this subject incident. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via E-Mail on May 6, 2020 to: Richard B. Doyle, Jr. 506 SE 8th Street Fort Lauderdale, FL 33316 Email: pleadings@loughren-doyle.com Attomey for Plaintiff ROBERT CHRISTNER /s/_ Anthony D. Cutrona CARLOS M. LLORENTE, ESQUIRE FL. Bar No.: 507997 ANTHONY D. CUTRONA, ESQUIRE FL. Bar No.: 124074 Law Offices of Christina M. Sanabria 1200 South Pine Island Road Suite 725 Plantation FL 33324 Phone: (954) 585-5581 Fax: (954) 316-5291 Primary Email: Anthony.Cutrona@farmersinsurance.com Noemi.hernandez@farmersinsurance.com Attomey for Defendant