On June 21, 2017 a
Request,Application
was filed
involving a dispute between
Llerena, Roberto,
Llerena, Xiomara,
and
Andres Quintana Inc,
Learning And Growing Family Child Care,
Quintana Family Day Care Home,
for Comm Premises Liability
in the District Court of Miami-Dade County.
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Filing # 58070546 E-Filed 06/21/2017 02:49:06 PM
IN THE CIRCUIT COURT OF THE 11TH
JUDICIAL CIRCUIT IN AND FOR MIAMI-
DADE COUNTY, FLORIDA
XIOMARA LLERENA and ROBERTO
LLERENA, GENERAL JURISDICTION DIVISION
Plaintiffs, Case No:
vs. Florida Bar No: 0008486
ANDRES QUINTANA INC. d/b/a
QUINTANA FAMILY DAY CARE
HOME a/k/a LEARNING AND
GROWING FAMILY CHILD CARE,
Defendant.
REQUEST FOR PRODUCTION
COMES NOW the Plaintiffs, XIOMARA LLERENA and ROBERTO LLERENA, by
and through their undersigned counsel and pursuant to the applicable Florida Rules of Civil
Procedure and requests the Defendant, ANDRES QUINTANA INC. d/b/a QUINTANA
FAMILY DAY CARE HOME a/k/a LEARNING AND GROWING FAMILY CHILD CARE, to
produce the following for inspection and/or copying within the time prescribed by said Rule at
the below-named offices:
1. Incident reports and/or accident reports which were prepared by the Defendant
and/or any other person, firm, or entity in the regular course of business,
2. Any and all statements of the Plaintiff revealing knowledge of facts relevant and
material to the claims and defenses in the instant litigation.
3, Any and all photographs, movies, charts and other documentary evidence of the
scene and/or parties involved in or pertaining to the subject accident, occurrences or issues
involved in this cauise.4, Any and all insurance policies providing benefits or coverage to the Defendant for
any claimed injury or damage from the subject accident or occurrence.
5. Any and all photographs and/or movies of the Plaintiff resulting from surveillance
and/or investigation of the Plaintiff.
6. Any and all maintenance and/or management agreements for the subject premises
in existence on the date of the subject incident that relate to maintaining, inspecting and repairing
the walkway where the accident occurred.
7. Any and all documents which reflect written or oral complaints received by you
for the subject premises within the five (5) year period prior to the date of accident regarding slip
and/or trip and fall on the subject property.
8. Policy and procedural manuals for the subject premises regarding:
a Inspection, cleaning and maintenance of the premises.
b. What to do when a guest is injured on the premises.
c. Keeping the premises safe and well maintained.
d. Accident and injury prevention on the premises.
9. Any and all videotapes of the subject accident.
10. Any and all contracts for management or maintenance of the subject property
between any of the persons, firm and corporations that relate in any way to the cleaning,
inspection or maintenance of the walkway area where the Plaintiff fell.
As grounds for the foregoing Request, the Plaintiffs are unable without undue hardship,
to obtain the substantial equivalent of same by other means.WE HEREBY CERTIFY that a true and correct copy of the foregoing was served along
with the Summons and Complaint in the above captioned cause,
FRIEDLAND LAW GROUP
Attorneys for Plaintiff
1430 South Dixie Highway, Suite 305
Coral Gables, Florida 33146
Tel: (305) 661-2008
Fax: (305) 661-2001
é 3
riedland, Esq.
Document Filed Date
June 21, 2017
Case Filing Date
June 21, 2017
Category
Comm Premises Liability
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Filing # 58070546 E-Filed 06/21/2017 02:49:06 PM IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI- DADE COUNTY, FLORIDA XIOMARA LLERENA and ROBERTO LLERENA, GENERAL JURISDICTION DIVISION Plaintiffs, Case No: vs. Florida Bar No: 0008486 ANDRES QUINTANA INC. d/b/a QUINTANA FAMILY DAY CARE HOME a/k/a LEARNING AND GROWING FAMILY CHILD CARE, Defendant. REQUEST FOR PRODUCTION COMES NOW the Plaintiffs, XIOMARA LLERENA and ROBERTO LLERENA, by and through their undersigned counsel and pursuant to the applicable Florida Rules of Civil Procedure and requests the Defendant, ANDRES QUINTANA INC. d/b/a QUINTANA FAMILY DAY CARE HOME a/k/a LEARNING AND GROWING FAMILY CHILD CARE, to produce the following for inspection and/or copying within the time prescribed by said Rule at the below-named offices: 1. Incident reports and/or accident reports which were prepared by the Defendant and/or any other person, firm, or entity in the regular course of business, 2. Any and all statements of the Plaintiff revealing knowledge of facts relevant and material to the claims and defenses in the instant litigation. 3, Any and all photographs, movies, charts and other documentary evidence of the scene and/or parties involved in or pertaining to the subject accident, occurrences or issues involved in this cauise.4, Any and all insurance policies providing benefits or coverage to the Defendant for any claimed injury or damage from the subject accident or occurrence. 5. Any and all photographs and/or movies of the Plaintiff resulting from surveillance and/or investigation of the Plaintiff. 6. Any and all maintenance and/or management agreements for the subject premises in existence on the date of the subject incident that relate to maintaining, inspecting and repairing the walkway where the accident occurred. 7. Any and all documents which reflect written or oral complaints received by you for the subject premises within the five (5) year period prior to the date of accident regarding slip and/or trip and fall on the subject property. 8. Policy and procedural manuals for the subject premises regarding: a Inspection, cleaning and maintenance of the premises. b. What to do when a guest is injured on the premises. c. Keeping the premises safe and well maintained. d. Accident and injury prevention on the premises. 9. Any and all videotapes of the subject accident. 10. Any and all contracts for management or maintenance of the subject property between any of the persons, firm and corporations that relate in any way to the cleaning, inspection or maintenance of the walkway area where the Plaintiff fell. As grounds for the foregoing Request, the Plaintiffs are unable without undue hardship, to obtain the substantial equivalent of same by other means.WE HEREBY CERTIFY that a true and correct copy of the foregoing was served along with the Summons and Complaint in the above captioned cause, FRIEDLAND LAW GROUP Attorneys for Plaintiff 1430 South Dixie Highway, Suite 305 Coral Gables, Florida 33146 Tel: (305) 661-2008 Fax: (305) 661-2001 é 3 riedland, Esq.