On June 16, 2017 a
Party Discovery
was filed
involving a dispute between
Clemente,
Levine,
and
Senior Health-Treasure Isles Llc,
Treasure Isle Care Center,,
for Nursing Home Negligence
in the District Court of Miami-Dade County.
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Filing # 59543886 E-Filed 07/26/2017 02:20:27 PM
IN THE CIRCUIT COURT OF THE
11™ JUDICIAL CIRCUIT, IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CIVIL DIVISION
CASENO.: 17-CA-014511-01
ISABEL LEVINE, as Personal
Representative of the Estate of
JOSE L. CLEMENTE, Deceased,
VS.
Plaintiff,
SENIOR HEALTH - TREASURE
ISLES, LLC. d/b/a TREASURE
ISLE CARE CENTER,
Defendant.
/
PLAINTIFF’S RESPONSES TO DEFENDANT’S FIRST REQUEST FOR PRODUCTION
COMES NOW the Plaintiff, ISABEL LEVINE, as Personal Representative of the Estate of
JOSE L. CLEMENTE, Deceased, by and through her undersigned counsel, and pursuant to Rule
1.340, Fla.R.Civ.P., hereby files this, her Responses to Defendant, SENIOR HEALTH -
TREASURE ISLES, LLC. d/b/a TREASURE ISLE CARE CENTER, First Request for Production
served on July 12, 2017.
1,
2.
A lost wage claim is not anticipated at this time.
A copy of the medical bills are enclosed in the CD being forwarded to Defense counsel
contemporaneously with this responses.
To the best of Claimant’s knowledge, Jose Clemente is insured by Medicare #: 109-44-
8826-A. All subrogation liens will be provided to Defense counsel immediately upon receipt.
To date, none.
A copy of the medical records are enclosed in the CD being forwarded to Defense counsel
contemporaneously with this responses.
The Plaintiff is not in possession of any photographs responsive to that request.
See response to Number 3.10.
11.
12.
13.
14,
15.
16.
17.
18.
19.
20.
21.
22.
23.
24,
25.
26.
Experts to be used at the time of trial have yet to be finalized.
See response to Number 8.
This information is enclosed in the CD being forwarded to Defense counsel
contemporaneously with this responses.
The Plaintiff is not in possession of any photographs responsive to that request.
This information is enclosed in the CD being forwarded to Defense counsel
contemporaneously with this responses.
The Plaintiff is not in possession of any documents responsive to that request.
The Plaintiff is not in possession of any documents responsive to that request.
The Plaintiff is not in possession of any documents responsive to that request.
None.
A copy of the medical bills are enclosed in the CD being forwarded to Defense counsel
contemporaneously with this responses.
A copy of the medical records are enclosed in the CD being forwarded to Defense counsel
contemporaneously with this responses.
None.
The Plaintiff is not in possession of any documents responsive to that request.
See response to Number 3.
This information is enclosed in the CD being forwarded to Defense counsel
contemporaneously with this responses.
See response to Number 22.
The Plaintiff is not in possession of any documents responsive to that request.
This information is enclosed in the CD being forwarded to Defense counsel
contemporaneously with this responses.
See response to Number 25.CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via the
Florida Courts E-filing Portal: Amy L. Christiansen, Esq.; achri sgr.com; this 26" day
of July, 2017.
FORD, DEAN & ROTUNDO, P.A.
Attorneys for Plaintiff
Turnberry Plaza, Suite 600
2875 N.E. 191 Street
Aventura, FL 33180
Tel: (305) 670-2000
Fax: (305) 670-1353
By:
WI A. DEAN, B.C.S.
Florida Bar No.: 118354
Document Filed Date
July 26, 2017
Case Filing Date
June 16, 2017
Category
Nursing Home Negligence
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Filing # 59543886 E-Filed 07/26/2017 02:20:27 PM IN THE CIRCUIT COURT OF THE 11™ JUDICIAL CIRCUIT, IN AND FOR MIAMI-DADE COUNTY, FLORIDA CIVIL DIVISION CASENO.: 17-CA-014511-01 ISABEL LEVINE, as Personal Representative of the Estate of JOSE L. CLEMENTE, Deceased, VS. Plaintiff, SENIOR HEALTH - TREASURE ISLES, LLC. d/b/a TREASURE ISLE CARE CENTER, Defendant. / PLAINTIFF’S RESPONSES TO DEFENDANT’S FIRST REQUEST FOR PRODUCTION COMES NOW the Plaintiff, ISABEL LEVINE, as Personal Representative of the Estate of JOSE L. CLEMENTE, Deceased, by and through her undersigned counsel, and pursuant to Rule 1.340, Fla.R.Civ.P., hereby files this, her Responses to Defendant, SENIOR HEALTH - TREASURE ISLES, LLC. d/b/a TREASURE ISLE CARE CENTER, First Request for Production served on July 12, 2017. 1, 2. A lost wage claim is not anticipated at this time. A copy of the medical bills are enclosed in the CD being forwarded to Defense counsel contemporaneously with this responses. To the best of Claimant’s knowledge, Jose Clemente is insured by Medicare #: 109-44- 8826-A. All subrogation liens will be provided to Defense counsel immediately upon receipt. To date, none. A copy of the medical records are enclosed in the CD being forwarded to Defense counsel contemporaneously with this responses. The Plaintiff is not in possession of any photographs responsive to that request. See response to Number 3.10. 11. 12. 13. 14, 15. 16. 17. 18. 19. 20. 21. 22. 23. 24, 25. 26. Experts to be used at the time of trial have yet to be finalized. See response to Number 8. This information is enclosed in the CD being forwarded to Defense counsel contemporaneously with this responses. The Plaintiff is not in possession of any photographs responsive to that request. This information is enclosed in the CD being forwarded to Defense counsel contemporaneously with this responses. The Plaintiff is not in possession of any documents responsive to that request. The Plaintiff is not in possession of any documents responsive to that request. The Plaintiff is not in possession of any documents responsive to that request. None. A copy of the medical bills are enclosed in the CD being forwarded to Defense counsel contemporaneously with this responses. A copy of the medical records are enclosed in the CD being forwarded to Defense counsel contemporaneously with this responses. None. The Plaintiff is not in possession of any documents responsive to that request. See response to Number 3. This information is enclosed in the CD being forwarded to Defense counsel contemporaneously with this responses. See response to Number 22. The Plaintiff is not in possession of any documents responsive to that request. This information is enclosed in the CD being forwarded to Defense counsel contemporaneously with this responses. See response to Number 25.CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via the Florida Courts E-filing Portal: Amy L. Christiansen, Esq.; achri sgr.com; this 26" day of July, 2017. FORD, DEAN & ROTUNDO, P.A. Attorneys for Plaintiff Turnberry Plaza, Suite 600 2875 N.E. 191 Street Aventura, FL 33180 Tel: (305) 670-2000 Fax: (305) 670-1353 By: WI A. DEAN, B.C.S. Florida Bar No.: 118354