On May 01, 2014 a
Party Discovery
was filed
involving a dispute between
Central Therapy Center, Inc.,
Garcia, Eriche,
and
Progressive Select Insurance Company,
for Personal Injury Protection ($8,001 - $15,000)
in the District Court of Miami-Dade County.
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Filing # 34397854 E-Filed 11/12/2015 05:09:27 PM
14-4824 IN THE COUNTY COURT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CIVIL DIVISION
CASE NUMBER: 14-02253 CC 26 (04)
CENTRAL THERAPY CENTER, INC.,
a/afo ERICHE GARCIA,
Plaintiff,
vs.
PROGRESSIVE SELECT INSURANCE
COMPANY.
Defendant.
PLAINTIFI’S RESPONSE TO REQUEST FOR PRODUCTION
COMES NOW, the Plaintiff, CENTRAL THERAPY CENTER, INC., a/a/o ERICHE
GARCIA, by and through the undersigned attorney, and files its response to Defendant’s
Request for Production, propounded upon Plaintiff November 5, 2014, and states as follows:
1, See attached.
2. See attached relevant medical license,
3. Objection, irrelevant and immaterial as not reasonably caiculated to lead to the discovery
of admissible evidence. Without waiving said objection, none in Plaintiff's possession.
4. See attached.
5. See attached.
6. None.
7. None.
Page f of 2CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was e-mailed this
{ 4 “day of November, 2015, to: Paul Kluck, Esq., Beighley, Myrick & Udell, P.A., at:
noticeé6@bmulaw.com.
CORREDOR, HUSSEINI & SNEDAKER, P.A.
Attorneys for Plaintiff
9130 S, Dadeland Bivd.
Two Datran Center, Suite 1902
Miami, Florida 33156
(305)670-1880 Phone
(305) 670-1985 Facsimile
service@corredorhusseinilaw.com.
Page 2 of 2
Document Filed Date
November 12, 2015
Case Filing Date
May 01, 2014
Category
Personal Injury Protection ($8,001 - $15,000)
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Filing # 34397854 E-Filed 11/12/2015 05:09:27 PM 14-4824 IN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CIVIL DIVISION CASE NUMBER: 14-02253 CC 26 (04) CENTRAL THERAPY CENTER, INC., a/afo ERICHE GARCIA, Plaintiff, vs. PROGRESSIVE SELECT INSURANCE COMPANY. Defendant. PLAINTIFI’S RESPONSE TO REQUEST FOR PRODUCTION COMES NOW, the Plaintiff, CENTRAL THERAPY CENTER, INC., a/a/o ERICHE GARCIA, by and through the undersigned attorney, and files its response to Defendant’s Request for Production, propounded upon Plaintiff November 5, 2014, and states as follows: 1, See attached. 2. See attached relevant medical license, 3. Objection, irrelevant and immaterial as not reasonably caiculated to lead to the discovery of admissible evidence. Without waiving said objection, none in Plaintiff's possession. 4. See attached. 5. See attached. 6. None. 7. None. Page f of 2CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was e-mailed this { 4 “day of November, 2015, to: Paul Kluck, Esq., Beighley, Myrick & Udell, P.A., at: noticeé6@bmulaw.com. CORREDOR, HUSSEINI & SNEDAKER, P.A. Attorneys for Plaintiff 9130 S, Dadeland Bivd. Two Datran Center, Suite 1902 Miami, Florida 33156 (305)670-1880 Phone (305) 670-1985 Facsimile service@corredorhusseinilaw.com. Page 2 of 2