On December 13, 2016 a
Request,Application
was filed
involving a dispute between
Summers, Jeanette,
and
Seaside Beach Club Condominium Assn Inc,
for Neg - Premises Liability Commercial
in the District Court of Broward County.
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Filing # 58898856 E-Filed 07/12/2017 11:36:26 AM
IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: 16-022598(09)
JEANETTE SUMMERS,
Plaintiff,
vs.
SEASIDE BEACH CLUB CONDOMINIUM
ASSOCIATION, INC.,
Defendant.
/
REQUEST FOR ATTENDANCE AT MEDICAL EXAMINATION
Defendant, SEASIDE BEACH CLUB CONDOMINIUM ASSOCIATION, INC., by and through
its undersigned counsel and pursuant to Rule 1.360 of the Florida Rules of Civil Procedure, hereby
requests Plaintiff, JEANETTE SUMMERS, attend and submit herself to an examination by Dr. Stephen
Jacobs of Orthopaedic Center of South Florida on Wednesday, August 23, 2017 at 9:15 a.m. The
examination will take place at Orthopaedic Center of South Florida, 600 South Pine Island Road,
Suite 300, Plantation, FL 33324.
lL. Said examination shall include the taking of such x-rays and other laboratory procedures
as may be indicated by said doctor as incident and necessary to complete said examination.
2. Plaintiff is requested to bring with her at the time of the examination any and all x-rays,
MRI's or other diagnostic films taken as a result of the alleged injuries from the incident which is the
subject of this lawsuit.
3. That the results of the examination shall be reported by the appointed doctor to the
Defendant in writing in a detailed report setting out the doctor's findings and conclusions and upon
request of Plaintiff, the defendant shall deliver a copy thereto to Plaintiff.
*4* FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 7/12/2017 11:36:25 AM.****4. That the initial expense of the examination shall be borne by Defendant and shall be paid
prior to the date of the examination to be later taxed as costs in this cause. Should the Plaintiff fail to
appear or cancel the appointment (either by someone from Plaintiff's counsel’s calling Dr. Jacobs’ office
to cancel or the Plaintiff herself, the Defendant shall seek reimbursement of the expense of the
examination.
5. Dr. Jacobs’ Cancellation/No Show Policy: 48 hours to time of appointment No show or
Cancellations-Full Fee- $975.00.
6. Plaintiff's counsel has agreed to the date and time of said examination via email.
CERTIFICATE OF SERVICE
1 HEREBY CERTIFY a copy of the foregoing has been furnished by E-Service to all
counsel listed below this 12th day of July, 2017.
WILLIAM W. PRICE, P.A.
Counsel for Defendant, Seaside Beach Club
Condominium Association, Inc.
521 South Olive Avenue
West Palm Beach, FL 33401
(561) 659-3212
(561) 659-0323 (fax)
Primary: George. hebert@wpricepa.com
Secondary: kari.stratton@wpriccpa.com
i /s/ Gorge E. Hebat, Jr.
George E. Hebert, Jr.
Fla. Bar No: 0031835
Counsel List
William C. Ruggiero
LAW OFFICES OF WILLIAM C. RUGGIERO
200 South Andrews Avenue, Suite 703
Ft. Lauderdale, FL 33301
954-462-2300
Primary: Ruggicro@ WCRlaw.com
Secondary: mnelson@WCRlaw.com
Document Filed Date
July 12, 2017
Case Filing Date
December 13, 2016
Category
Neg - Premises Liability Commercial
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Filing # 58898856 E-Filed 07/12/2017 11:36:26 AM IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: 16-022598(09) JEANETTE SUMMERS, Plaintiff, vs. SEASIDE BEACH CLUB CONDOMINIUM ASSOCIATION, INC., Defendant. / REQUEST FOR ATTENDANCE AT MEDICAL EXAMINATION Defendant, SEASIDE BEACH CLUB CONDOMINIUM ASSOCIATION, INC., by and through its undersigned counsel and pursuant to Rule 1.360 of the Florida Rules of Civil Procedure, hereby requests Plaintiff, JEANETTE SUMMERS, attend and submit herself to an examination by Dr. Stephen Jacobs of Orthopaedic Center of South Florida on Wednesday, August 23, 2017 at 9:15 a.m. The examination will take place at Orthopaedic Center of South Florida, 600 South Pine Island Road, Suite 300, Plantation, FL 33324. lL. Said examination shall include the taking of such x-rays and other laboratory procedures as may be indicated by said doctor as incident and necessary to complete said examination. 2. Plaintiff is requested to bring with her at the time of the examination any and all x-rays, MRI's or other diagnostic films taken as a result of the alleged injuries from the incident which is the subject of this lawsuit. 3. That the results of the examination shall be reported by the appointed doctor to the Defendant in writing in a detailed report setting out the doctor's findings and conclusions and upon request of Plaintiff, the defendant shall deliver a copy thereto to Plaintiff. *4* FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 7/12/2017 11:36:25 AM.****4. That the initial expense of the examination shall be borne by Defendant and shall be paid prior to the date of the examination to be later taxed as costs in this cause. Should the Plaintiff fail to appear or cancel the appointment (either by someone from Plaintiff's counsel’s calling Dr. Jacobs’ office to cancel or the Plaintiff herself, the Defendant shall seek reimbursement of the expense of the examination. 5. Dr. Jacobs’ Cancellation/No Show Policy: 48 hours to time of appointment No show or Cancellations-Full Fee- $975.00. 6. Plaintiff's counsel has agreed to the date and time of said examination via email. CERTIFICATE OF SERVICE 1 HEREBY CERTIFY a copy of the foregoing has been furnished by E-Service to all counsel listed below this 12th day of July, 2017. WILLIAM W. PRICE, P.A. Counsel for Defendant, Seaside Beach Club Condominium Association, Inc. 521 South Olive Avenue West Palm Beach, FL 33401 (561) 659-3212 (561) 659-0323 (fax) Primary: George. hebert@wpricepa.com Secondary: kari.stratton@wpriccpa.com i /s/ Gorge E. Hebat, Jr. George E. Hebert, Jr. Fla. Bar No: 0031835 Counsel List William C. Ruggiero LAW OFFICES OF WILLIAM C. RUGGIERO 200 South Andrews Avenue, Suite 703 Ft. Lauderdale, FL 33301 954-462-2300 Primary: Ruggicro@ WCRlaw.com Secondary: mnelson@WCRlaw.com