On August 22, 2018 a
Answer
was filed
involving a dispute between
Ms Medical Rehab,
and
Infinity Auto Insurance Company,
for Personal Injury Protection ($8,001 - $15,000)
in the District Court of Miami-Dade County.
Preview
Filing #115705219 E-Filed 10/27/2020 04:36:35 PM
IN THE COUNTY COURT IN AND FOR
DADE COUNTY, FLORIDA
Ms Medical Rehab CIVIL DIVISION
a/a/o Reinier Toledo,
CASE NO. 18-17295 CC 25 02
Plaintiff,
vs,
Infinity Auto Insurance Company,
Defendant.
/
PLAINTIFF’S MOTION TO COMPEL BETTER ANSWERS TO
EXAMINATION UNDER OATH REQUEST TO PRODUCE
COMES NOW the Plaintiff, Ms Medical Rehab a/a/o Reinier Toledo, by and
through its undersigned counsel, hereby files this Motion to Compel Better Answers to
Examination under Oath Request to Produce and as grounds therefore states the following:
1) Plaintiff propounded Examination under Oath Request to Produce upon
Defendant, on May 1, 2020.
2) Defendant has improperly Objected and or Insufficiently answered to
Plaintiff's Examination under Oath Request to Produce #’s 1, 2, 3, 4, 5, 6, 7, and 8.
3) Defendant’s failure to sufficiently answer said Discovery has hindered the
Plaintiff's ability to prepare for trial. Plaintiff respectfully moves this Honorable Court
overrule Defendant’s Objections to Plaintiff's Discovery Requests.
WHEREFORE, the Plaintiff, Ms Medical Rehab alalo Reinier Toledo,
respectfully requests this Honorable Court enter an Order granting the Plaintiff's Motion
to Compel Better Answers to Examination under Oath Request to Produce based on the
foregoing, and any other relief this Honorable Court deems just and proper.
a a a
CERTIFICATE OF SERVICE
1 HEREBY CERTIFY that a true and correct copy of the foregoing was sent via e-
mail to Michelle Paredes, Esq., Miamilegal@ipacc.com; michelle.paredes@kemper.com,
Law Office of Deborah N, Perez & Asst., 8400 NW 36th Street, Suite 250, Miami, FL
33166 on October 27, 2020.
MERTZ LAW GROUP
4970 SW 728? AVE
SUITE 109
MIAMI, FL 33155
305-821-4581 ‘TELEPHONE
305-821-3738 FACSIMILE
ervice@mertzlawgroup.com
/s/ Lewis J. Mertz, Jr. Esq.
LEWIS J. MERTZ, JR., ESQ.
FBN: 513598
a
Document Filed Date
October 27, 2020
Case Filing Date
August 22, 2018
Category
Personal Injury Protection ($8,001 - $15,000)
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Filing #115705219 E-Filed 10/27/2020 04:36:35 PM IN THE COUNTY COURT IN AND FOR DADE COUNTY, FLORIDA Ms Medical Rehab CIVIL DIVISION a/a/o Reinier Toledo, CASE NO. 18-17295 CC 25 02 Plaintiff, vs, Infinity Auto Insurance Company, Defendant. / PLAINTIFF’S MOTION TO COMPEL BETTER ANSWERS TO EXAMINATION UNDER OATH REQUEST TO PRODUCE COMES NOW the Plaintiff, Ms Medical Rehab a/a/o Reinier Toledo, by and through its undersigned counsel, hereby files this Motion to Compel Better Answers to Examination under Oath Request to Produce and as grounds therefore states the following: 1) Plaintiff propounded Examination under Oath Request to Produce upon Defendant, on May 1, 2020. 2) Defendant has improperly Objected and or Insufficiently answered to Plaintiff's Examination under Oath Request to Produce #’s 1, 2, 3, 4, 5, 6, 7, and 8. 3) Defendant’s failure to sufficiently answer said Discovery has hindered the Plaintiff's ability to prepare for trial. Plaintiff respectfully moves this Honorable Court overrule Defendant’s Objections to Plaintiff's Discovery Requests. WHEREFORE, the Plaintiff, Ms Medical Rehab alalo Reinier Toledo, respectfully requests this Honorable Court enter an Order granting the Plaintiff's Motion to Compel Better Answers to Examination under Oath Request to Produce based on the foregoing, and any other relief this Honorable Court deems just and proper. a a a CERTIFICATE OF SERVICE 1 HEREBY CERTIFY that a true and correct copy of the foregoing was sent via e- mail to Michelle Paredes, Esq., Miamilegal@ipacc.com; michelle.paredes@kemper.com, Law Office of Deborah N, Perez & Asst., 8400 NW 36th Street, Suite 250, Miami, FL 33166 on October 27, 2020. MERTZ LAW GROUP 4970 SW 728? AVE SUITE 109 MIAMI, FL 33155 305-821-4581 ‘TELEPHONE 305-821-3738 FACSIMILE ervice@mertzlawgroup.com /s/ Lewis J. Mertz, Jr. Esq. LEWIS J. MERTZ, JR., ESQ. FBN: 513598 a