On July 17, 2015 a
Party Discovery
was filed
involving a dispute between
Collura, Brandon,
and
State Farm Mutual Automobile Insurance Company,
for Auto Negligence
in the District Court of Broward County.
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Filing # 37408197 E-Filed 02/04/2016 11:43:26 AM
IN. THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
BRANDON COLLURA, CASE NO.: CACE15012665 (08)
Plaintiff,
VS.
STATE FARM MUTUAL
AUTOMOBILE INSURANCE
COMPANY, A FOREIGN PROFIT
CORPORATION,
Defendant.
/
DEFENDANT’S SUPPLEMENTAL REQUEST FOR PRODUCTION TO P. TIFF
PURSUANT TO RULE 1.350, the Defendant, STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY (hereinafter “Defendant”), by and through their undersigned attorneys,
requests the Plaintiff, BRANDON COLLURA (hereinafter “Plaintiff’), to translate or prepare in
reasonably useable form and produce those documents and items enumerated below at the office
of the undersigned counsel and that the same be done within thirty (30) days in accordance with
said Rule.
1. Have the Plaintiff sign and date the attached Authorization from Northwestern
Memorial Hospital — Medical Records Dept. before a notary public since said facility refuses to
honor a properly served Subpoena. Return the original signed and dated Authorization to the
undersigned’s office. See Rojas v. Ryder, 641 So.2d 855 (Fla. 1994).
2. Have the Plaintiff sign and date the attached Authorization from Northwestern
Memorial Hospital — Radiology Dept. before a notary public since said facility refuses to honor a
properly served Subpoena. Return_the_original_signed_and_ dated Authorization to_the
undersigned’s office. See Rojas vy. Ryder, 641 So.2d 855 (Fla. 1994).
3. Have the Plaintiff sign and date the attached Authorization from Northwestern
Memorial Hospital — Accounting Dept. before a notary public since said facility refuses to honor
a properly served Subpoena. Return _the original signed and dated Authorization _to_the
undersigned’s office. See Rojas v. Ryder, 641 So.2d 855 (Fla. 1994).
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 2/4/2016 11:43:26 AM.****CASE NO.: CACE15012665 (08)
I HEREBY CERTIFY that on February 4, 2016, the foregoing was electronically filed with
the Florida Courts E-Filing Portal and that as a registered participant of the Portal I have
effectuated service through the Portal in compliance with Rule 2.516, Fla. R. Jud. Admin., on
Elizabeth S. Mitchell, Esq., Carner, Newmark & Cohen, LLP and 600 S. Andrews Avenue, Suite
301 Fort Lauderdale, FL 33301.
NICHOLAS J. RYAN & ASSOCIATES
110S. E. 6th Street, Suite 2100
Fort Lauderdale, FL 33301
Telephone: (954) 627-9401
E-mail for service (FL R. Jud. Admin. 2.516):
flor.law-lisabaligian.294019@statefarm.com
SR
By:
Lisa J. Baligian, Esq.
Florida Bar No.: 956181
Attorney for Defendant, State Farm Mutual
Automobile Insurance Company
Attomeys and Staff of Nicholas J. Ryan & Associates are Employees of
the Corporate Law Department of State Farm Mutual Automobile
Insurance Company
Document Filed Date
February 04, 2016
Case Filing Date
July 17, 2015
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Filing # 37408197 E-Filed 02/04/2016 11:43:26 AM IN. THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA BRANDON COLLURA, CASE NO.: CACE15012665 (08) Plaintiff, VS. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, A FOREIGN PROFIT CORPORATION, Defendant. / DEFENDANT’S SUPPLEMENTAL REQUEST FOR PRODUCTION TO P. TIFF PURSUANT TO RULE 1.350, the Defendant, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY (hereinafter “Defendant”), by and through their undersigned attorneys, requests the Plaintiff, BRANDON COLLURA (hereinafter “Plaintiff’), to translate or prepare in reasonably useable form and produce those documents and items enumerated below at the office of the undersigned counsel and that the same be done within thirty (30) days in accordance with said Rule. 1. Have the Plaintiff sign and date the attached Authorization from Northwestern Memorial Hospital — Medical Records Dept. before a notary public since said facility refuses to honor a properly served Subpoena. Return the original signed and dated Authorization to the undersigned’s office. See Rojas v. Ryder, 641 So.2d 855 (Fla. 1994). 2. Have the Plaintiff sign and date the attached Authorization from Northwestern Memorial Hospital — Radiology Dept. before a notary public since said facility refuses to honor a properly served Subpoena. Return_the_original_signed_and_ dated Authorization to_the undersigned’s office. See Rojas vy. Ryder, 641 So.2d 855 (Fla. 1994). 3. Have the Plaintiff sign and date the attached Authorization from Northwestern Memorial Hospital — Accounting Dept. before a notary public since said facility refuses to honor a properly served Subpoena. Return _the original signed and dated Authorization _to_the undersigned’s office. See Rojas v. Ryder, 641 So.2d 855 (Fla. 1994). *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 2/4/2016 11:43:26 AM.****CASE NO.: CACE15012665 (08) I HEREBY CERTIFY that on February 4, 2016, the foregoing was electronically filed with the Florida Courts E-Filing Portal and that as a registered participant of the Portal I have effectuated service through the Portal in compliance with Rule 2.516, Fla. R. Jud. Admin., on Elizabeth S. Mitchell, Esq., Carner, Newmark & Cohen, LLP and 600 S. Andrews Avenue, Suite 301 Fort Lauderdale, FL 33301. NICHOLAS J. RYAN & ASSOCIATES 110S. E. 6th Street, Suite 2100 Fort Lauderdale, FL 33301 Telephone: (954) 627-9401 E-mail for service (FL R. Jud. Admin. 2.516): flor.law-lisabaligian.294019@statefarm.com SR By: Lisa J. Baligian, Esq. Florida Bar No.: 956181 Attorney for Defendant, State Farm Mutual Automobile Insurance Company Attomeys and Staff of Nicholas J. Ryan & Associates are Employees of the Corporate Law Department of State Farm Mutual Automobile Insurance Company