Request,Application: CORZO MEDICAL CENTER, INC. VS UNITED AUTOMOBILE INSURANCE COMPANY

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                                Filing # 86960468 E-Filed 03/26/2019 11:31:54 AM

CORZO MEDICAL CENTER, INC., IN THE COUNTY COURT IN AND FOR

a/alo DANILO MEJIA, MIAMI-DADE COUNTY, FLORIDA
Plaintiff, CIVIL DIVISION

vs. CASE NO: 14-000803 CC 25 (03)

UNITED AUTOMOBILE INSURANCE
COMPANY, a Florida Corporation FL BAR NO. 145556

Defendant

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DEFENDANT’S ATTORNEY FEE RE

 

ST TO PRODUCE

COMES NOW Defendant, UNITED AUTOMOBILE INSURANCE COMPANY, by

and through the undersigned counsel and hereby files this Request to Produce to Plaintiff's

counsel, and requests that the Plaintiff's counsel produce copies of the following items, at the

offices of the undersigned within THIRTY (30) days from the date of service herein

1

we

A complete copy of your file in this matter (excluding attorney-client communications)
which documents time expended on this file by Plaintiffs counsel or others.

A copy of all billing or other time records, including original time records and all
handwritten notes prepared by secretaries, lawyers, or assistants, including phone
messages, internal memos to the file, and other papers indicating work to be done or
which was done on this file, and/or any assignments given to or delegated to or by
anyone in connection with this matter.

Copies of your Westlaw/Lexis/Nexis or other computer research billing documentation
from the beginning of this suit to the present that are related to this case.

A resume, curriculum vitae and/or list outlining the work related experience, educational
experience and years admitted to the Florida Bar for each lawyer who worked on this file.

A list of all the PIP cases for the last three years that shows how many times Plaintiff’s
Counsel has represented Plaintiff,

A copy of any all orders and or judgments as to fees from the past 3 years awarding fees
to Plaintiff's counsel in any matter (not just PIP cases).

Invoices, drafts, or other documents which reflects your claims for costs.8. Copies of any and all bills and statement of accounts submitted by your expert witness
for this case.

9. Any information in your possession or control that supports your contention regarding
your hourly rate.

10. Any information in your possession or control that supports your contention that you are
entitled to a multiplier for your work in this case.

11. The resume or curriculum vitae of your expert witness detailing his/her experience as an
attorney and as an expert witness on attorney’s fees

12. Any and all expert reports or correspondence exchanged between you and your expert

13. Any and all documents or materials whatsoever provided to your expert in connection
with this case, whether such documents or materials were provided by the, the Plaintiff or
the Plaintiffs counsel or any witness or any other person.

14. Any and all records pertaining to the fees and expenses charged by your expert in
connection with this case.

15. Any and all invoices, letters and/or other documentation evidencing the hourly rate
charged to actual “paying” clients during the time the instant action was pending.

16. If seeking a multiplier: any and all evidence that you and / or your expert will be relying
on if any to support testimony.

CERTIFICATE OF SERVICE

WE HEREBY CERTIFY that the foregoing document has been furnished by e-mail on
March 26, 2019 to: Kevin Whitehead, Esq, at KEVIN W. WHITEHEAD, P.A.;
kw@kwwpa.com, 2100 Coral Way, Suite 603, Miami, FL 33145

House Counsel of

United Automobile Insurance Company
Attorneys for the Defendant

P.O. BOX 694260

Miami, FL 33269-9854

Phone (305) 774-6160

Email: HC_Service@uaig.net

/s/ Camille A White
By Camille A White, Esq