Preview
Filing # 84305266 E-Filed 02/01/2019 03:33:35 PM
IN THE CIRCUIT COURT OF THE TENTH JUDICIAL CIRCUIT
IN AND FOR POLK COUNTY, FLORIDA
GLORIA J. ROBINSON,
Plaintiff,
vs. CASE NO.: 2018-CA-005166
SECTION: 08
HARBOR FREIGHT TOOLS USA, INC.
AND TOM RATHBUN,
Defendants.
DEFENDANT, HARBOR FREIGHT TOOLS USA, INC.’S FIRST REQUESTS FOR
PRODUCTION TO PLAINTIFF GLORIA J. ROBINSON
Defendant HARBOR FREIGHT TOOLS USA, INC. (hereinafter “HFT”), by and
through the undersigned counsel and pursuant to Fla. R. Civ. P. 1.350, requests Plaintiff
GLORIA J. ROBINSON to produce for inspection and/or copying within thirty (30) days of the
date hereof, the following:
REQUESTS
1. Copies of Plaintiff GLORIA J. ROBINSON’S Federal Income Tax Returns,
LR.S. 1040 Forms and W-2 Withholding Tax Statements, financial statements for the tax years
2011 through 2018, and evidence of 2019 income through to the date of production. If Plaintiff
has not yet filed her 2018 tax return, please provide evidence of income for 2018.
2. If Plaintiff GLORIA J. ROBINSON is not a U. S. citizen, please produce copies
of any and all documents establishing or verifying her identity and employment eligibility,
including but not limited to U. S. Passport (unexpired or expired), Certificate of U.S. Citizenship
(INS Form N-560 or N-561), Certificate of Naturalization, unexpired foreign Passport, with I-
-1-
22083483.v1.
2018CA-005166-0000-00 Received in Polk 02/01/2019 05:03 PM551 stamp or attached INS Form I-94 indicating unexpired employment authorization, Alien
Registration Receipt Card with photograph (INS Form I-151 or I-551), unexpired Employment
Authorization Card (INS Form I-668A), Driver License or ID Card issued by a state, Voter’s
Registration Card, U.S. Military Card or draft records, Native American tribal documents, U. S.
Social Security Card issued by the Social Security Administration (other than a card stating it not
valid for employment), ID Card for use of Resident Citizens in the United States (INS Form I-
179), or any other similar document verifying her identity and eligibility for employment in the
United States.
3. Any and all hospital, physician, clinic, prescription, therapy, or other medical
related bills, as well as explanation of benefits statements, paid or owing, resulting from the
subject incident, relative to Plaintiff GLORIA J. ROBINSON.
4. Any and all hospital, physician, chiropractic, clinic, emergency room or other
health care provider records, x-rays, tomography studies, medical reports, and doctors' reports,
related to or connected with any medical care or treatment rendered to Plaintiff GLORIA J.
ROBINSON related to the subject incident.
5. Any and all of Plaintiff GLORIA J. ROBINSON’S hospital, physician, clinic,
prescription, therapy, or other medical related bills, paid or owing, for the past ten (10) years.
6. Any and all of Plaintiff GLORIA J. ROBINSON’S hospital, outpatient,
prescription, or other medical bills, paid or owing, for the past ten (10) years resulting
specifically from any surgeries.
7. Any and all hospital, physician, chiropractic, clinic, emergency room records, x-
rays, tomography studies, medical reports, and doctors' reports, related to or connected with the
22083483.v1.
2018CA-005166-0000-00 Received in Polk 02/01/2019 05:03 PMmedical care and treatment rendered to Plaintiff GLORIA J. ROBINSON during the past ten (10)
years.
8. Any and all hospital, clinic, emergency room records, x-rays, tomography studies,
medical reports, and doctors' reports, related to or connected with the medical care and treatment
rendered to Plaintiff GLORIA J. ROBINSON from any surgeries in her lifetime.
9. Any and all hospital, physician, chiropractic, clinic, emergency room or other
health care provider records, x-rays, tomography studies, operative reports, medical reports, and
doctors’ reports, specifically related to any pre-existing condition that Plaintiff GLORIA J.
ROBINSON suffered prior to the subject incident that are alleged in the Complaint to have been
aggravated as a result of the subject incident.
10. Any and all hospital, physician, chiropractic, clinic, emergency room or other
health care provider records, x-rays, tomography studies, operative reports, medical reports, and
doctors' reports, specifically related to the significant and permanent loss of an important bodily
function that Plaintiff GLORIA J. ROBINSON alleges in the Complaint to have suffered as a
result of the subject incident.
11. Any and all hospital, physician, chiropractic, clinic, emergency room or other
health care provider records, x-rays, tomography studies, operative reports, medical reports, and
doctors' reports, specifically related to the significant and permanent scarring or disfigurement
that Plaintiff GLORIA J. ROBINSON alleges in the Complaint to have suffered as a result of the
subject incident.
12. Any and all pharmacy records directly resulting from the subject incident for
Plaintiff GLORIA J. ROBINSON.
22083483.v1.
2018CA-005166-0000-00 Received in Polk 02/01/2019 05:03 PM13. Any and all pharmacy records in your possession for prescriptions filled over the
past ten (10) years for Plaintiff GLORIA J. ROBINSON.
14. Reprint (not a copy) of all x-rays, MRIs, CT Scan, or any other diagnostic
procedures or tests depicting Plaintiff GLORIA J. ROBINSON’S alleged injuries relating to the
subject incident.
15. Medical reports, opinions, or other written memoranda from doctors, nurses, other
medical practitioners, or expert witnesses containing information concerning the injuries and/or
damages allegedly sustained by Plaintiff GLORIA J. ROBINSON as a result of the subject
incident.
16. Any and all medical records, reports, and medical bills generated as a result of
any EMS, ambulance service, fire/rescue, or hospital transportation service, with regard to
transportation of Plaintiff GLORIA J. ROBINSON to a hospital on the date of the subject
incident, as a direct result of the subject incident.
17. Any and all medical records, reports, and medical bills generated as a result of
any EMS, ambulance service, fire/rescue, or hospital transportation service, with regard to
transportation of Plaintiff GLORIA J. ROBINSON to a hospital on any date after the date of the
subject incident, for which transportation was a direct result of the subject incident.
18. Any and all police reports, and police investigation records and files of any type
regarding the subject incident from any police agency.
19. Any and all written or recorded statements taken from any person who has any
knowledge concerning the subject incident, or notes taken from interviews of any witnesses to
the claims regarding the subject incident.
22083483.v1.
2018CA-005166-0000-00 Received in Polk 02/01/2019 05:03 PM20. Any and all written or recorded statements taken of Defendant HFT’s agents,
servants and employees, related to or connected with the subject incident.
21. Any and all uncropped photographs, full-frame photographs, video, graphs,
charts, drawings, and other documentary evidence of the alleged incident and/or scene of the
incident described in Plaintiff’ s Complaint.
22. Any and all uncropped, full-frame photographs, films, slides, videotapes and or
other documentary evidence of Plaintiff GLORIA J. ROBINSON’S alleged injuries as described
in Plaintiff's Amended Complaint.
23. Any and all photographs and/or unedited videos of Plaintiff GLORIA J.
ROBINSON in her injured condition.
24. Any and all photographs and/or unedited videos of Plaintiff GLORIA J.
ROBINSON taken at any time within one year prior to the subject accident, depicting Plaintiff
GLORIA J. ROBINSON in an uninjured condition.
25. Any and all uncropped, full-frame photographs, slides, recorded video, DVDs,
negatives and motion pictures of any type which Plaintiff intends to introduce at trial, if such
determination has been made.
26. Any and all releases, settlement agreements, Mary Carter Agreements,
correspondence and memos pertaining to same (whether pending or completed) between the
Plaintiff and any other parties or their insurers.
27. A written summary of any and all oral Mary Carter Agreements between the
Plaintiff and any other parties or their insurers, as well as any and all oral covenants or
agreements of any sort whatsoever related to or connected with the subject incident.
28. Copy of Plaintiff GLORIA J. ROBINSON’S Social Security card.
5.
22083483.v1.
2018CA-005166-0000-00 Received in Polk 02/01/2019 05:03 PM29. Copy of Plaintiff GLORIA J. ROBINSON’S most recent Social Security
Statement.
30. Copy of Plaintiff GLORIA J. ROBINSON’S Application(s) for Social Security
Disability, if applicable, and response(s) thereto.
31. Copy of any and all documents evidencing payments to Plaintiff GLORIA J.
ROBINSON from the Social Security Administration as a result of any application(s) for Social
Security Disability.
32. | Copy of any and all documents evidencing payments to Plaintiff GLORIA J.
ROBINSON from the Social Security Administration reflecting payments of Social Security
benefits.
33. Copy of Plaintiff GLORIA J. ROBINSON’S Birth Certificate.
34. Copy of Plaintiff GLORIA J. ROBINSON’S Driver's License.
35. Any and all degrees, diplomas or certificates of Plaintiff GLORIA J.
ROBINSON’S educational achievement or competency.
36. Any and all educational records of Plaintiff GLORIA J. ROBINSON with regard
to current or former educational pursuits.
37. Any and all investigation reports or analyses made by any governmental or police
agency or department concerning the subject incident.
38. Any report or analysis prepared by any expert witness or treating physician
expected to testify at trial. See Mims v. Casademont, 464 So. 2d 643 (Fla. 3d DCA 1985).
39. The Plaintiff's notification to collateral source providers, as required by Florida
Statute §768.76(7).
22083483.v1.
2018CA-005166-0000-00 Received in Polk 02/01/2019 05:03 PM40. All contracts, identification cards, applications and statements for each and every
insurance company, HMO, PPO, or private or governmental entity, including Medicaid and
Medicare, which has provided services, payment or reimbursement for any medical or health
related services Plaintiff GLORIA J. ROBINSON has received for the past ten (10) years.
41. Any and all statements, explanation of benefits, notices, letters, notes, memoranda
or other documents, however titled and in whatever form, detailing, listing, explaining or
itemizing all payments made by any third party for the damages and medical, hospital or other
health care services provided to Plaintiff GLORIA J. ROBINSON as a result of the alleged
incident. (For purposes of this request for production, "any third party" includes but is not
limited to any federal, state, local or other public program providing medical expenses payments;
any health, accident or sickness insurance providing insurance benefits or medical expenses
payments; any contract or agreement of any group, organization, partnership or corporation to
provide, pay for or reimburse the costs of your hospital, medical or other health care services;
Medicare; Medicaid, and Workers' Compensation Law).
42. Any and all statements, explanation, notices, letter, notes, memoranda or other
documents, however titled and in whatever form, detailing, listing, explaining and itemizing any
third party's claims of right of subrogation or reimbursement for any amounts paid or payable
and the amount of each third party's claim.
43. Any and all documents evidencing prior or current lawsuits of any kind, wherein
Plaintiff GLORIA J. ROBINSON is/was a Plaintiff or Defendant, Claimant or Respondent,
including small claims matters, and excluding the current matter. This request is for any lawsuit
during Plaintiff GLORIA J. ROBINSON’S lifetime, and requests any and all documents from
any court. If you are not in possession of the documents, please identify state and court filed,
-7-
22083483.v1.
2018CA-005166-0000-00 Received in Polk 02/01/2019 05:03 PMopposing party, and any other identifiable information so as to allow this Defendant to obtain
records.
44. Any and all records evidencing Plaintiff GLORIA J. ROBINSON’S employment
for the ten (10) years prior to the subject accident, and the year and months since the subject
accident, including evidence of prior and current income.
45. Any and all records evidencing Plaintiff GLORIA J. ROBINSON’S additional
income from any source received on a regular basis for the ten (10) years prior to the subject
accident, and the year and months since the subject accident, including evidence of prior and
current income.
46. Please produce any and all cellular telephone records for any cellular telephone in
Plaintiff's possession on the date and time of the subject incident evidencing voice calls, text
messaging, data usage and transfer of any type.
47. Please produce the shoes and clothing that Plaintiff GLORIA J. ROBINSON was
wearing at the time of the alleged fall.
48. Please produce any items that Plaintiff GLORIA J. ROBINSON was carrying or
had on her person at the time of the alleged fall.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that on the 1“ day of February, 2019, a true and correct copy of
the foregoing document was filed with the Clerk of Court using the Florida Courts e-Filing
22083483.v1.
2018CA-005166-0000-00 Received in Polk 02/01/2019 05:03 PMPortal which will send an automatic e-mail message to all parties who have registered with the e-
Filing Portal.
of BranD. Zgue
BRIAN D. EQUI, ESQ.
Florida Bar No. 143936
bequi@ goldbergsegalla.com
FRANCIS E. PIERCE, IV, ESQ.
Florida Bar No. 085271
{pierce @ goldbergsegalia. com
Secondary Email Addresses: GOLDBERG SEGALLA, LLP
pscuza @ goldbergsegaila.com 800 N. Magnolia Avenue, Suite 1201
8 Orlando, FL 32803
(407) 458-5600
Attorneys for Defendants
22083483.v1.
2018CA-005166-0000-00 Received in Polk 02/01/2019 05:03 PM
Preview
Filing # 84305266 E-Filed 02/01/2019 03:33:35 PM IN THE CIRCUIT COURT OF THE TENTH JUDICIAL CIRCUIT IN AND FOR POLK COUNTY, FLORIDA GLORIA J. ROBINSON, Plaintiff, vs. CASE NO.: 2018-CA-005166 SECTION: 08 HARBOR FREIGHT TOOLS USA, INC. AND TOM RATHBUN, Defendants. DEFENDANT, HARBOR FREIGHT TOOLS USA, INC.’S FIRST REQUESTS FOR PRODUCTION TO PLAINTIFF GLORIA J. ROBINSON Defendant HARBOR FREIGHT TOOLS USA, INC. (hereinafter “HFT”), by and through the undersigned counsel and pursuant to Fla. R. Civ. P. 1.350, requests Plaintiff GLORIA J. ROBINSON to produce for inspection and/or copying within thirty (30) days of the date hereof, the following: REQUESTS 1. Copies of Plaintiff GLORIA J. ROBINSON’S Federal Income Tax Returns, LR.S. 1040 Forms and W-2 Withholding Tax Statements, financial statements for the tax years 2011 through 2018, and evidence of 2019 income through to the date of production. If Plaintiff has not yet filed her 2018 tax return, please provide evidence of income for 2018. 2. If Plaintiff GLORIA J. ROBINSON is not a U. S. citizen, please produce copies of any and all documents establishing or verifying her identity and employment eligibility, including but not limited to U. S. Passport (unexpired or expired), Certificate of U.S. Citizenship (INS Form N-560 or N-561), Certificate of Naturalization, unexpired foreign Passport, with I- -1- 22083483.v1. 2018CA-005166-0000-00 Received in Polk 02/01/2019 05:03 PM551 stamp or attached INS Form I-94 indicating unexpired employment authorization, Alien Registration Receipt Card with photograph (INS Form I-151 or I-551), unexpired Employment Authorization Card (INS Form I-668A), Driver License or ID Card issued by a state, Voter’s Registration Card, U.S. Military Card or draft records, Native American tribal documents, U. S. Social Security Card issued by the Social Security Administration (other than a card stating it not valid for employment), ID Card for use of Resident Citizens in the United States (INS Form I- 179), or any other similar document verifying her identity and eligibility for employment in the United States. 3. Any and all hospital, physician, clinic, prescription, therapy, or other medical related bills, as well as explanation of benefits statements, paid or owing, resulting from the subject incident, relative to Plaintiff GLORIA J. ROBINSON. 4. Any and all hospital, physician, chiropractic, clinic, emergency room or other health care provider records, x-rays, tomography studies, medical reports, and doctors' reports, related to or connected with any medical care or treatment rendered to Plaintiff GLORIA J. ROBINSON related to the subject incident. 5. Any and all of Plaintiff GLORIA J. ROBINSON’S hospital, physician, clinic, prescription, therapy, or other medical related bills, paid or owing, for the past ten (10) years. 6. Any and all of Plaintiff GLORIA J. ROBINSON’S hospital, outpatient, prescription, or other medical bills, paid or owing, for the past ten (10) years resulting specifically from any surgeries. 7. Any and all hospital, physician, chiropractic, clinic, emergency room records, x- rays, tomography studies, medical reports, and doctors' reports, related to or connected with the 22083483.v1. 2018CA-005166-0000-00 Received in Polk 02/01/2019 05:03 PMmedical care and treatment rendered to Plaintiff GLORIA J. ROBINSON during the past ten (10) years. 8. Any and all hospital, clinic, emergency room records, x-rays, tomography studies, medical reports, and doctors' reports, related to or connected with the medical care and treatment rendered to Plaintiff GLORIA J. ROBINSON from any surgeries in her lifetime. 9. Any and all hospital, physician, chiropractic, clinic, emergency room or other health care provider records, x-rays, tomography studies, operative reports, medical reports, and doctors’ reports, specifically related to any pre-existing condition that Plaintiff GLORIA J. ROBINSON suffered prior to the subject incident that are alleged in the Complaint to have been aggravated as a result of the subject incident. 10. Any and all hospital, physician, chiropractic, clinic, emergency room or other health care provider records, x-rays, tomography studies, operative reports, medical reports, and doctors' reports, specifically related to the significant and permanent loss of an important bodily function that Plaintiff GLORIA J. ROBINSON alleges in the Complaint to have suffered as a result of the subject incident. 11. Any and all hospital, physician, chiropractic, clinic, emergency room or other health care provider records, x-rays, tomography studies, operative reports, medical reports, and doctors' reports, specifically related to the significant and permanent scarring or disfigurement that Plaintiff GLORIA J. ROBINSON alleges in the Complaint to have suffered as a result of the subject incident. 12. Any and all pharmacy records directly resulting from the subject incident for Plaintiff GLORIA J. ROBINSON. 22083483.v1. 2018CA-005166-0000-00 Received in Polk 02/01/2019 05:03 PM13. Any and all pharmacy records in your possession for prescriptions filled over the past ten (10) years for Plaintiff GLORIA J. ROBINSON. 14. Reprint (not a copy) of all x-rays, MRIs, CT Scan, or any other diagnostic procedures or tests depicting Plaintiff GLORIA J. ROBINSON’S alleged injuries relating to the subject incident. 15. Medical reports, opinions, or other written memoranda from doctors, nurses, other medical practitioners, or expert witnesses containing information concerning the injuries and/or damages allegedly sustained by Plaintiff GLORIA J. ROBINSON as a result of the subject incident. 16. Any and all medical records, reports, and medical bills generated as a result of any EMS, ambulance service, fire/rescue, or hospital transportation service, with regard to transportation of Plaintiff GLORIA J. ROBINSON to a hospital on the date of the subject incident, as a direct result of the subject incident. 17. Any and all medical records, reports, and medical bills generated as a result of any EMS, ambulance service, fire/rescue, or hospital transportation service, with regard to transportation of Plaintiff GLORIA J. ROBINSON to a hospital on any date after the date of the subject incident, for which transportation was a direct result of the subject incident. 18. Any and all police reports, and police investigation records and files of any type regarding the subject incident from any police agency. 19. Any and all written or recorded statements taken from any person who has any knowledge concerning the subject incident, or notes taken from interviews of any witnesses to the claims regarding the subject incident. 22083483.v1. 2018CA-005166-0000-00 Received in Polk 02/01/2019 05:03 PM20. Any and all written or recorded statements taken of Defendant HFT’s agents, servants and employees, related to or connected with the subject incident. 21. Any and all uncropped photographs, full-frame photographs, video, graphs, charts, drawings, and other documentary evidence of the alleged incident and/or scene of the incident described in Plaintiff’ s Complaint. 22. Any and all uncropped, full-frame photographs, films, slides, videotapes and or other documentary evidence of Plaintiff GLORIA J. ROBINSON’S alleged injuries as described in Plaintiff's Amended Complaint. 23. Any and all photographs and/or unedited videos of Plaintiff GLORIA J. ROBINSON in her injured condition. 24. Any and all photographs and/or unedited videos of Plaintiff GLORIA J. ROBINSON taken at any time within one year prior to the subject accident, depicting Plaintiff GLORIA J. ROBINSON in an uninjured condition. 25. Any and all uncropped, full-frame photographs, slides, recorded video, DVDs, negatives and motion pictures of any type which Plaintiff intends to introduce at trial, if such determination has been made. 26. Any and all releases, settlement agreements, Mary Carter Agreements, correspondence and memos pertaining to same (whether pending or completed) between the Plaintiff and any other parties or their insurers. 27. A written summary of any and all oral Mary Carter Agreements between the Plaintiff and any other parties or their insurers, as well as any and all oral covenants or agreements of any sort whatsoever related to or connected with the subject incident. 28. Copy of Plaintiff GLORIA J. ROBINSON’S Social Security card. 5. 22083483.v1. 2018CA-005166-0000-00 Received in Polk 02/01/2019 05:03 PM29. Copy of Plaintiff GLORIA J. ROBINSON’S most recent Social Security Statement. 30. Copy of Plaintiff GLORIA J. ROBINSON’S Application(s) for Social Security Disability, if applicable, and response(s) thereto. 31. Copy of any and all documents evidencing payments to Plaintiff GLORIA J. ROBINSON from the Social Security Administration as a result of any application(s) for Social Security Disability. 32. | Copy of any and all documents evidencing payments to Plaintiff GLORIA J. ROBINSON from the Social Security Administration reflecting payments of Social Security benefits. 33. Copy of Plaintiff GLORIA J. ROBINSON’S Birth Certificate. 34. Copy of Plaintiff GLORIA J. ROBINSON’S Driver's License. 35. Any and all degrees, diplomas or certificates of Plaintiff GLORIA J. ROBINSON’S educational achievement or competency. 36. Any and all educational records of Plaintiff GLORIA J. ROBINSON with regard to current or former educational pursuits. 37. Any and all investigation reports or analyses made by any governmental or police agency or department concerning the subject incident. 38. Any report or analysis prepared by any expert witness or treating physician expected to testify at trial. See Mims v. Casademont, 464 So. 2d 643 (Fla. 3d DCA 1985). 39. The Plaintiff's notification to collateral source providers, as required by Florida Statute §768.76(7). 22083483.v1. 2018CA-005166-0000-00 Received in Polk 02/01/2019 05:03 PM40. All contracts, identification cards, applications and statements for each and every insurance company, HMO, PPO, or private or governmental entity, including Medicaid and Medicare, which has provided services, payment or reimbursement for any medical or health related services Plaintiff GLORIA J. ROBINSON has received for the past ten (10) years. 41. Any and all statements, explanation of benefits, notices, letters, notes, memoranda or other documents, however titled and in whatever form, detailing, listing, explaining or itemizing all payments made by any third party for the damages and medical, hospital or other health care services provided to Plaintiff GLORIA J. ROBINSON as a result of the alleged incident. (For purposes of this request for production, "any third party" includes but is not limited to any federal, state, local or other public program providing medical expenses payments; any health, accident or sickness insurance providing insurance benefits or medical expenses payments; any contract or agreement of any group, organization, partnership or corporation to provide, pay for or reimburse the costs of your hospital, medical or other health care services; Medicare; Medicaid, and Workers' Compensation Law). 42. Any and all statements, explanation, notices, letter, notes, memoranda or other documents, however titled and in whatever form, detailing, listing, explaining and itemizing any third party's claims of right of subrogation or reimbursement for any amounts paid or payable and the amount of each third party's claim. 43. Any and all documents evidencing prior or current lawsuits of any kind, wherein Plaintiff GLORIA J. ROBINSON is/was a Plaintiff or Defendant, Claimant or Respondent, including small claims matters, and excluding the current matter. This request is for any lawsuit during Plaintiff GLORIA J. ROBINSON’S lifetime, and requests any and all documents from any court. If you are not in possession of the documents, please identify state and court filed, -7- 22083483.v1. 2018CA-005166-0000-00 Received in Polk 02/01/2019 05:03 PMopposing party, and any other identifiable information so as to allow this Defendant to obtain records. 44. Any and all records evidencing Plaintiff GLORIA J. ROBINSON’S employment for the ten (10) years prior to the subject accident, and the year and months since the subject accident, including evidence of prior and current income. 45. Any and all records evidencing Plaintiff GLORIA J. ROBINSON’S additional income from any source received on a regular basis for the ten (10) years prior to the subject accident, and the year and months since the subject accident, including evidence of prior and current income. 46. Please produce any and all cellular telephone records for any cellular telephone in Plaintiff's possession on the date and time of the subject incident evidencing voice calls, text messaging, data usage and transfer of any type. 47. Please produce the shoes and clothing that Plaintiff GLORIA J. ROBINSON was wearing at the time of the alleged fall. 48. Please produce any items that Plaintiff GLORIA J. ROBINSON was carrying or had on her person at the time of the alleged fall. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that on the 1“ day of February, 2019, a true and correct copy of the foregoing document was filed with the Clerk of Court using the Florida Courts e-Filing 22083483.v1. 2018CA-005166-0000-00 Received in Polk 02/01/2019 05:03 PMPortal which will send an automatic e-mail message to all parties who have registered with the e- Filing Portal. of BranD. Zgue BRIAN D. EQUI, ESQ. Florida Bar No. 143936 bequi@ goldbergsegalla.com FRANCIS E. PIERCE, IV, ESQ. Florida Bar No. 085271 {pierce @ goldbergsegalia. com Secondary Email Addresses: GOLDBERG SEGALLA, LLP pscuza @ goldbergsegaila.com 800 N. Magnolia Avenue, Suite 1201 8 Orlando, FL 32803 (407) 458-5600 Attorneys for Defendants 22083483.v1. 2018CA-005166-0000-00 Received in Polk 02/01/2019 05:03 PM