On December 31, 2018 a
DEFENDANT HARBOR FREIGHT TOOLS USA INC SECOND REQUEST FOR PRODUCTION TO PLAINTIFF
was filed
involving a dispute between
Robinson Gloria J,
and
Harbor Freight Tools Usa Inc,
Rathbun, Thomas,
for NEGPL - NEGLIGENCE PREMISES LIABILITY COMM
in the District Court of Polk County.
Preview
Filing # 98496176 E-Filed 11/06/2019 04:32:53 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
SECOND REQUESTS FOR PRODUCTION TO PLAINTIFF GLORIA J. ROBINSON
Defendant HARBOR FREIGHT TOOLS USA, INC., 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:
REQU
1. Please produce the police report referenced during your deposition testimony
taken under oath on July 12, 2019, with regard to a prior hit-and-run accident that you were
involved in.
2. Please produce any documents received from any source, or sent by you or on
your behalf, evidencing application for benefits, payments or benefits received, proof of injury,
severity of injury, time frame of injury, as a result of the hit-and-run accident referenced during
your deposition testimony taken under oath on July 12, 2019.
3. Please produce a copy of the Social Security Administration Application(s) for
Social Security Disability Insurance Benefits completed by you or on your behalf, as well as any
-1-
24540871.v1
2018CA-005166-0000-00 Received in Polk 11/06/2019 05:27 PMand all response(s) thereto.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that on the 6th day of November, 2019, a true and correct copy
of the foregoing document was filed with the Clerk of Court using the Florida Courts e-Filing
Portal which will send an automatic e-mail message to all parties who have registered with the e-
Filing Portal.
Secondary Email Addresses:
pseuza @ goldbergsegalla.com
kcharlton @ goldbergsepalla.com
sherndon @ goldbergsegalla.com
24540871.v1
2018CA-005166-0000-00
| Bran D. Zgut
BRIAN D. EQUI, ESQ.
Florida Bar No. 143936
bequi@ goldbergseealia.com
FRANCIS E. PIERCE, IV, ESQ.
Florida Bar No. 085271
fpierce@ goldbergsegalla.com
GOLDBERG SEGALLA, LLP
800 N. Magnolia Avenue, Suite 1201
Orlando, FL 32803
(407) 458-5600
Attorneys for Defendants
Received in Polk 11/06/2019 05:27 PM
Preview
Filing # 98496176 E-Filed 11/06/2019 04:32:53 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 SECOND REQUESTS FOR PRODUCTION TO PLAINTIFF GLORIA J. ROBINSON Defendant HARBOR FREIGHT TOOLS USA, INC., 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: REQU 1. Please produce the police report referenced during your deposition testimony taken under oath on July 12, 2019, with regard to a prior hit-and-run accident that you were involved in. 2. Please produce any documents received from any source, or sent by you or on your behalf, evidencing application for benefits, payments or benefits received, proof of injury, severity of injury, time frame of injury, as a result of the hit-and-run accident referenced during your deposition testimony taken under oath on July 12, 2019. 3. Please produce a copy of the Social Security Administration Application(s) for Social Security Disability Insurance Benefits completed by you or on your behalf, as well as any -1- 24540871.v1 2018CA-005166-0000-00 Received in Polk 11/06/2019 05:27 PMand all response(s) thereto. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that on the 6th day of November, 2019, a true and correct copy of the foregoing document was filed with the Clerk of Court using the Florida Courts e-Filing Portal which will send an automatic e-mail message to all parties who have registered with the e- Filing Portal. Secondary Email Addresses: pseuza @ goldbergsegalla.com kcharlton @ goldbergsepalla.com sherndon @ goldbergsegalla.com 24540871.v1 2018CA-005166-0000-00 | Bran D. Zgut BRIAN D. EQUI, ESQ. Florida Bar No. 143936 bequi@ goldbergseealia.com FRANCIS E. PIERCE, IV, ESQ. Florida Bar No. 085271 fpierce@ goldbergsegalla.com GOLDBERG SEGALLA, LLP 800 N. Magnolia Avenue, Suite 1201 Orlando, FL 32803 (407) 458-5600 Attorneys for Defendants Received in Polk 11/06/2019 05:27 PM