On October 19, 2020 a
Request for Copies (Pursuant to Rule 1.351)
was filed
involving a dispute between
Emergui , Esther,
Zafranu , Evelyn,
and
Progressive Select Insurance Company,
for Auto Negligence
in the District Court of Broward County.
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Filing # 119546588 E-Filed 01/13/2021 11:53:32 AM
IN THE CIRCUIT COURT OF THE 17"
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE 20017273
EVELYN ZAFRANI and
ESTHER EMERGUI,
Plaintiff,
Vv.
PROGRESSIVE SELECT INSURANCE
COMPANY, a foreign corporation,
Defendants.
/
REQUEST FOR COPIES PURSUANT TO RULE 1.351
Plaintiff, in the above-styled case, by and through the undersigned counsel, and Rule 1.351,
Fla. R. Civ. P., hereby waives her objection to the Notices of Production from Non-Party served
by counsel for Defendant under certificates of service dated 1/08/2021, and requests that said
Defendant’s counsel provide legible copies of each and every item furnished in responses to the
subpoenas referred to in the Notices of Production from Non-Party within ten (10) days after said
documents and items have been furnished, and failing in’ that, would hereby object to the use
thereof at trial, and would further reserve the right to move or compel, for sanctions, or for an
Order in Limine restricting the use thereof, as to the records produced by the following:
As to Ester Emergui:
1. Enrique Hanabergh, Jr.
. LifeShield National Insurance Company
2.
3. Mount Sinai Medical Center - Billing Dept.
4. Mount Sinai Medical Center - Medical Records
5
. Mount Sinai Medical Center - Radiology Dept.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/13/2021 11:53:31 AM.****As to Evelyn Zafrani:
1. Renee Alexis
2, Ambetter c/o Sunshine Health Community Solutions, Inc.
3. Plantation, FL 33324
4. Clinton Burkett, MD.
CERTIFICATE OF SERVICE
1 HEREBY CERTIFY that a copy of the foregoing document has been furnished via the
E-Filing Portal/e-mail to Yasser Kader, Esq. at FtLauderdaleHHC-@Progressive.com on this
| 3 tay of January, 2021.
LAW OFFICES OF ANIDJAR & LEVINE, P.A.
Attorney for Plaintiff
300 SE 17" Street
Fort Lauderdale, FL 33316
Tel: (954) 525-0050 / Fax: (954) 525-0020
E-service at: pleadings@anl-law.com
Say eee ee eee eee eee reer ee
DEVON WORKMAN, FSQ.
FBN 1004245
Document Filed Date
January 13, 2021
Case Filing Date
October 19, 2020
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Filing # 119546588 E-Filed 01/13/2021 11:53:32 AM IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 20017273 EVELYN ZAFRANI and ESTHER EMERGUI, Plaintiff, Vv. PROGRESSIVE SELECT INSURANCE COMPANY, a foreign corporation, Defendants. / REQUEST FOR COPIES PURSUANT TO RULE 1.351 Plaintiff, in the above-styled case, by and through the undersigned counsel, and Rule 1.351, Fla. R. Civ. P., hereby waives her objection to the Notices of Production from Non-Party served by counsel for Defendant under certificates of service dated 1/08/2021, and requests that said Defendant’s counsel provide legible copies of each and every item furnished in responses to the subpoenas referred to in the Notices of Production from Non-Party within ten (10) days after said documents and items have been furnished, and failing in’ that, would hereby object to the use thereof at trial, and would further reserve the right to move or compel, for sanctions, or for an Order in Limine restricting the use thereof, as to the records produced by the following: As to Ester Emergui: 1. Enrique Hanabergh, Jr. . LifeShield National Insurance Company 2. 3. Mount Sinai Medical Center - Billing Dept. 4. Mount Sinai Medical Center - Medical Records 5 . Mount Sinai Medical Center - Radiology Dept. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/13/2021 11:53:31 AM.****As to Evelyn Zafrani: 1. Renee Alexis 2, Ambetter c/o Sunshine Health Community Solutions, Inc. 3. Plantation, FL 33324 4. Clinton Burkett, MD. CERTIFICATE OF SERVICE 1 HEREBY CERTIFY that a copy of the foregoing document has been furnished via the E-Filing Portal/e-mail to Yasser Kader, Esq. at FtLauderdaleHHC-@Progressive.com on this | 3 tay of January, 2021. LAW OFFICES OF ANIDJAR & LEVINE, P.A. Attorney for Plaintiff 300 SE 17" Street Fort Lauderdale, FL 33316 Tel: (954) 525-0050 / Fax: (954) 525-0020 E-service at: pleadings@anl-law.com Say eee ee eee eee eee reer ee DEVON WORKMAN, FSQ. FBN 1004245