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Filing # 38034770 E-Filed 02/19/2016 01:41:47 PM
IN THE CIRCUIT COURT OF THE FIFTEENTH
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
SYLVIENNE SOUFFRANT, CASE NO.: 502015CA013650XXXXMB (AA)
Plaintiff,
vs.
MARIE JOSEPH AND GEICO
GENERAL INSURANCE COMPANY,
Defendants.
ATEMAmM AAC NATION HAN Con pron amen Ww AAT ey
DEFENDANT'S REQUEST FOR COMPREHENSIVE MEDICAL PAAMINA TION
If the CME is not cancelled more than 48 hours in advance, a $1950.00 cancellation fee will apply
(Creole interpreter has been requested)
Pursuant to Fla.R.Civ.P. 1.360, the Defendant, MARIE JOSEPH (hereinafter
“Defendant”), hereby requests the Plaintiff, SYLVIENNE SOUFFRANT (hereinafter
“Plaintiff’), to have Plaintiffs physical condition examined as indicated below, and further
requests the Plaintiff to serve a response within thirty (30) days after service of this Request as
provided in the above Rule:
1. That the Defendant would request the Plaintiff to appear to have Plaintiffs
physical condition examined by a neurosurgeon, JORDAN C. GRABEL, M.D., whose address
is 1411 N. Flagler Drive, Suite 5900, West Palm Beach, FL 33401 on Wednesday,
June 8, 2016 at 3:00 p.m.
2. That the above physician will obtain a history of the accident, injuries and
complaints of the Plaintiff; will conduct a physical examination, including any testing which may
be necessary; will request any X-rays, if necessary, will make a diagnosis of the physical or
mental condition of the Plaintiff and will render opinions concerning the Plaintiff's condition.
FILED: PALM BEACH COUNTY, SHARON R. BOCK, CLERK, 02/19/2016 01:41:47 PM3. In the event that the Plaintiff objects to this examination and fails to respond to
this Request, or fails to permit the examination, the undersigned will move the Court for an
Order under Fla.R.Civ.P. 1.380 to allow said discovery examination.
4, Unless a timely and valid objection to this Notice is filed within the time set forth
by Rule 1.360, the Plaintiff is required by this Rule to be in attendance at the above-scheduled
examination.
5. Pursuant to Rule 1.360, if the physician performing the examination is called as a
witness, the physician shall not be identified as one appointed by the Court.
6. The cost of the examination will be originally borne by the Defendant, but is
subject to taxation by the Court upon proper motion.
7. The Plaintiff is requested to bring to said examination any X-rays, CT Scan films,
MRI films or other diagnostic test results relating to the alleged injuries.
8. That there is good cause for this Request for the examination in that the Plaintiff
has placed Plaintiff's physical condition in issue and the Defendant has not had the benefit of
such an examination of the physical/mental condition of the Plaintiff.
5. if requested by the party to whom a request for examination is made, the party
requesting the examination shall deliver to the other party, in accordance with Rule 1.360(b)(1),
a copy of a detailed written report setting out the examiner’s findings. After delivery of the
detailed written report, the party requesting the examination to be made shall be entitled upon
request to receive from the party to whom the request for examination is made a similar report of
the same condition previously or thereafter made.
10. Please advise the undersigned if an interpreter is needed.11. ‘It is necessary that Plaintiff present valid photo identification upon arrival to
the medical examination.
I HEREBY CERTIFY that on February 19, 2016, the foregoing was electronically filed
with the Florida Courts E-Filing Portal and that as a registered participant of the Portal I have
effectuated service through the Portal in compliance with Rule 2.516, Fla. R. Jud. Admin., on
Courtney S. Hickey, Esq., The Stafford Firm, P.A. and Adam Baer, Esq. Law Offices of
Jeffrey R. Hickman.
cc:
Jordan C. Grabel, M.D.
NICHOLAS J. RYAN & ASSOCIATES
110S. E. 6th Street, Suite 2100
Fort Lauderdale, FL 33301
Telephone: (954) 627-9401
E-mail for service (FL R. Jud. Admin. 2.516):
flor.law-rickpenalta.299019@statefarm.com
otha.
C. Richard Penalta, Esq.
Florida Bar No.: 0947474
Attorney for Defendant, Marie Joseph
Attomeys and Staff of Nicholas J. Ryan & Associates are Employees
of the Corporate Law Department of State Farm Mutual Automobile
Insurance Comnany
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Filing # 38034770 E-Filed 02/19/2016 01:41:47 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA SYLVIENNE SOUFFRANT, CASE NO.: 502015CA013650XXXXMB (AA) Plaintiff, vs. MARIE JOSEPH AND GEICO GENERAL INSURANCE COMPANY, Defendants. ATEMAmM AAC NATION HAN Con pron amen Ww AAT ey DEFENDANT'S REQUEST FOR COMPREHENSIVE MEDICAL PAAMINA TION If the CME is not cancelled more than 48 hours in advance, a $1950.00 cancellation fee will apply (Creole interpreter has been requested) Pursuant to Fla.R.Civ.P. 1.360, the Defendant, MARIE JOSEPH (hereinafter “Defendant”), hereby requests the Plaintiff, SYLVIENNE SOUFFRANT (hereinafter “Plaintiff’), to have Plaintiffs physical condition examined as indicated below, and further requests the Plaintiff to serve a response within thirty (30) days after service of this Request as provided in the above Rule: 1. That the Defendant would request the Plaintiff to appear to have Plaintiffs physical condition examined by a neurosurgeon, JORDAN C. GRABEL, M.D., whose address is 1411 N. Flagler Drive, Suite 5900, West Palm Beach, FL 33401 on Wednesday, June 8, 2016 at 3:00 p.m. 2. That the above physician will obtain a history of the accident, injuries and complaints of the Plaintiff; will conduct a physical examination, including any testing which may be necessary; will request any X-rays, if necessary, will make a diagnosis of the physical or mental condition of the Plaintiff and will render opinions concerning the Plaintiff's condition. FILED: PALM BEACH COUNTY, SHARON R. BOCK, CLERK, 02/19/2016 01:41:47 PM3. In the event that the Plaintiff objects to this examination and fails to respond to this Request, or fails to permit the examination, the undersigned will move the Court for an Order under Fla.R.Civ.P. 1.380 to allow said discovery examination. 4, Unless a timely and valid objection to this Notice is filed within the time set forth by Rule 1.360, the Plaintiff is required by this Rule to be in attendance at the above-scheduled examination. 5. Pursuant to Rule 1.360, if the physician performing the examination is called as a witness, the physician shall not be identified as one appointed by the Court. 6. The cost of the examination will be originally borne by the Defendant, but is subject to taxation by the Court upon proper motion. 7. The Plaintiff is requested to bring to said examination any X-rays, CT Scan films, MRI films or other diagnostic test results relating to the alleged injuries. 8. That there is good cause for this Request for the examination in that the Plaintiff has placed Plaintiff's physical condition in issue and the Defendant has not had the benefit of such an examination of the physical/mental condition of the Plaintiff. 5. if requested by the party to whom a request for examination is made, the party requesting the examination shall deliver to the other party, in accordance with Rule 1.360(b)(1), a copy of a detailed written report setting out the examiner’s findings. After delivery of the detailed written report, the party requesting the examination to be made shall be entitled upon request to receive from the party to whom the request for examination is made a similar report of the same condition previously or thereafter made. 10. Please advise the undersigned if an interpreter is needed.11. ‘It is necessary that Plaintiff present valid photo identification upon arrival to the medical examination. I HEREBY CERTIFY that on February 19, 2016, the foregoing was electronically filed with the Florida Courts E-Filing Portal and that as a registered participant of the Portal I have effectuated service through the Portal in compliance with Rule 2.516, Fla. R. Jud. Admin., on Courtney S. Hickey, Esq., The Stafford Firm, P.A. and Adam Baer, Esq. Law Offices of Jeffrey R. Hickman. cc: Jordan C. Grabel, M.D. NICHOLAS J. RYAN & ASSOCIATES 110S. E. 6th Street, Suite 2100 Fort Lauderdale, FL 33301 Telephone: (954) 627-9401 E-mail for service (FL R. Jud. Admin. 2.516): flor.law-rickpenalta.299019@statefarm.com otha. C. Richard Penalta, Esq. Florida Bar No.: 0947474 Attorney for Defendant, Marie Joseph Attomeys and Staff of Nicholas J. Ryan & Associates are Employees of the Corporate Law Department of State Farm Mutual Automobile Insurance Comnany