On December 10, 2015 a
Request,Application
was filed
involving a dispute between
Hanchak, Carol J.,
and
Fonseca, Mario Enrique,
Garrison Prop & Casualty Ins Co,
for Auto Negligence
in the District Court of Broward County.
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Filing # 47524675 E-Filed 10/12/2016 02:22:30 PM
IN THE CIRCUIT COURT
OF THE 17™ JUDICIAL
CIRCUIT IN AND FOR BROWARD
COUNTY, FLORIDA
CASE NO.: CACE 15-15021721 (18)
DIVISION: GENERAL JURISDICTION
CAROL HANCHAK,
Plaintiff,
vs.
MARIO ENRIQUE FONSECA and
GARRISON PROPERTY AND
CASUALTY INSURANCE COMPANY,
Defendant.
/
AMENDED REQUEST FOR PHYSICAL EXAMINATION OF P TIFF
Please advise if an interpreter is needed.
Defendant, GARRISON PROPERTY AND CASUALTY INSURANCE COMPANY, by
and through its undersigned counsel, pursuant to Florida Rules of Civil Procedure 1.360, requests
that the Plaintiff, CAROL HANCHAK, submit to a physical examination and state:
1. The Plaintiffs condition is in controversy in that the Plaintiff is claiming money
damages for injuries allegedly sustained in the incident upon which this lawsuit is based.
Therefore, the Defendant has good cause and is entitled under Rule 1.360 to request an
examination of the Plaintiff.
2. An appointment for examination of the Plaintiff has been made with Dr. Manish
Gupta at his offices located at Sports & Orthopedic Center, 9325 Glades Road, Suite 205,
Boca Raton, FL 33434 (561) 314-7200. Said examination is set for October 28, 2016, at 3:30
PM.
** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 10/12/2016 2:22:29 PM.****CASE NO. CACE 15-15021721 (18)
3. Said examination shall be non-invasive and will include medical history, physical
examination, and other appropriate non-invasive diagnostic testing.
4, Unless a timely and valid objection to this Request is filed within the time set
forth by Rule 1.360, the Plaintiff is required by this Rule to be in attendance at the above-
scheduled examination.
5. Pursuant to Rule 1.360, if the physician performing the examination is called as a
witness, the physician shall not be identified as one appointed by the Court.
6. The cost of the examination will be originally borne by the Defendant but is
subject to taxation by the Court upon proper motion.
7. Failure of the Plaintiff to appear at the scheduled examination will result in a
disruption fee for which the Defendant will look to the Plaintiff for reimbursement.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served via e-mail
to: David Hammer, Esq., GLANTZ & GLANTZ, P.A., 7951 Southwest 6th Street, Suite 200,
Plantation, FL 33324, dhammer@glantzlaw.com, jmecrary@glantzlaw.com,
personalinjury@glantzlaw.com this 12" day of October, 2016.
LAW OFFICES OF ROBERT D. TETREAULT
Attorneys for Defendant GARRISON
1000 South Pine Island Road, Suite 420
Plantation, Florida 33324
Primary e-mail: cik.pld.sfl@usaa.com
Phone (954) 370-3129 Fax (954) 474-0689
By: Craig I. Kartiganer /s/
CRAIG I. KARTIGANER
Florida Bar No.: 709468
Document Filed Date
October 12, 2016
Case Filing Date
December 10, 2015
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Filing # 47524675 E-Filed 10/12/2016 02:22:30 PM IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 15-15021721 (18) DIVISION: GENERAL JURISDICTION CAROL HANCHAK, Plaintiff, vs. MARIO ENRIQUE FONSECA and GARRISON PROPERTY AND CASUALTY INSURANCE COMPANY, Defendant. / AMENDED REQUEST FOR PHYSICAL EXAMINATION OF P TIFF Please advise if an interpreter is needed. Defendant, GARRISON PROPERTY AND CASUALTY INSURANCE COMPANY, by and through its undersigned counsel, pursuant to Florida Rules of Civil Procedure 1.360, requests that the Plaintiff, CAROL HANCHAK, submit to a physical examination and state: 1. The Plaintiffs condition is in controversy in that the Plaintiff is claiming money damages for injuries allegedly sustained in the incident upon which this lawsuit is based. Therefore, the Defendant has good cause and is entitled under Rule 1.360 to request an examination of the Plaintiff. 2. An appointment for examination of the Plaintiff has been made with Dr. Manish Gupta at his offices located at Sports & Orthopedic Center, 9325 Glades Road, Suite 205, Boca Raton, FL 33434 (561) 314-7200. Said examination is set for October 28, 2016, at 3:30 PM. ** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 10/12/2016 2:22:29 PM.****CASE NO. CACE 15-15021721 (18) 3. Said examination shall be non-invasive and will include medical history, physical examination, and other appropriate non-invasive diagnostic testing. 4, Unless a timely and valid objection to this Request is filed within the time set forth by Rule 1.360, the Plaintiff is required by this Rule to be in attendance at the above- scheduled examination. 5. Pursuant to Rule 1.360, if the physician performing the examination is called as a witness, the physician shall not be identified as one appointed by the Court. 6. The cost of the examination will be originally borne by the Defendant but is subject to taxation by the Court upon proper motion. 7. Failure of the Plaintiff to appear at the scheduled examination will result in a disruption fee for which the Defendant will look to the Plaintiff for reimbursement. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served via e-mail to: David Hammer, Esq., GLANTZ & GLANTZ, P.A., 7951 Southwest 6th Street, Suite 200, Plantation, FL 33324, dhammer@glantzlaw.com, jmecrary@glantzlaw.com, personalinjury@glantzlaw.com this 12" day of October, 2016. LAW OFFICES OF ROBERT D. TETREAULT Attorneys for Defendant GARRISON 1000 South Pine Island Road, Suite 420 Plantation, Florida 33324 Primary e-mail: cik.pld.sfl@usaa.com Phone (954) 370-3129 Fax (954) 474-0689 By: Craig I. Kartiganer /s/ CRAIG I. KARTIGANER Florida Bar No.: 709468