Party Discovery: AMERICAN REHABILITATION MEDICAL CENTER, INC. VS STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY

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                                Filing # 58970416 E-Filed 07/13/2017 01:19:41 PM

IN THE COUNTY COURT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA

AMERICAN REHABILITATION
MEDICAL CENTER, INC. CASE NO.: 17-4882 CC 26 (03)
(Consuelo Hector, Patient)

vs.

Plaintiff,

STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY,

Defendant.
/

PLAINTIFF’S REQUEST TO PRODUCE RE: ADJUSTER QUALIFICATIONS

COMES NOW, Plaintiff, by and through the undersigned counsel, and

pursuant to Florida Rule of Civil Procedure 1.350, requests the Defendant produce

for inspection and copying at the offices of the undersigned attorney within thirty

(30) days after service of this request:

1. Any documents from this defendant insurance company that indicate the
knowledge, training, and experience of every person, on behalf of the defendant,
who was involved in the claim handling process, i.e., made any decision to pay, in
whole or part, or not to pay the claim, set forth in the plaintiffs pending cause of
action. These documents include but are not limited to:

A.

B.

The Florida license of that person in that claim handling process.

Formal classroom training by this or any other PIP insurance company of
the person in that claim handling process.

Mail-in correspondence course from this or any other PIP insurance
company of the person in that claim handling process.

. Employment application of classroom training by this or any other PIP

insurance company of the person in that claim handling process.

The definition or job description from this defendant of the job duties of the
person in that claim handling process.F. Trial testumony where that person in that claim handling process was
declared an expert by any court of competent jurisdiction.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a copy of the foregoing was filed with the Clerk of
Miami-Dade County through the Florida Courts e-Filing Portal, which will serve
electronically: Susette Gruebele, Esq., Cole, Scott & Kissane, P.A.,
suzette.gruebele@csklegal.com, lina.gil-mccool@csklegal.com, on July 13, 2017.

LEONARD J. VALDES, P.A.
8660 West Flagler Street, Suite 124
Miami, FL 33144

Telephone: 305-567-0910
Facsimile: 786-454-8905

Service: pleadings@valdeslaw.com

By: __/s/ Leonard J. Valdes
Leonard J. Valdes, D.C., Esq.
Florida Bar No. 84762