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Filing # 126076800 E-Filed 05/03/2021 06:00:15 PM
IN THE CIRCUIT COURT OF THE ISTH
JUDICIAL CIRCUIT, IN AND FOR
PALM BEACH COUNTY, FLORIDA
CASE NO.: 502020CA014445XXXXMB
JANE DOE, Division: AF
Plaintiff,
v.
BOCA RATON REGIONAL HOSPITAL, INC.,
d/b/a BOCA RATON REGIONAL HOSPITAL,
and DEVON BRIGANTI,
Defendant.
DEFENDANT, DEVON BRIGANTI, RESPONSE TO REQUEST FOR,
PRODUCTION PROPOUNDED BY DEFENDANT.
BOCA RATON HOSPITAL
Defendant, DEVON BRIGANTI, by and through undersigned counsel, pursuant to
Rule 1.350, Florida Rules of Civil Procedure, files his Responses to Request for Production
propounded by Defendant, BOCA RATONREGIONAL HOSPITAL, and further provides
the following:
*Defendant’s responses are based off of what he has in possession and does not
include or account for anything that may have been previously produced by another
party in response to discovery during this case, as Defendant will not be duplicating
previous discovery.
1. Copies of any and all correspondence between DEVON BRIGANTI and the
Plaintiff, together with complete copies of any text messages, E-mail(s), direct message(s),
social media message(s), instant message(s), and/or any other materials obtained by
the Defendant from the Plaintiff at any time prior to the date this suit was filed up to the
date of this request.
1
*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 05/03/2021 06:00:15 PM ***RESPONSE: No actual messages of any kind in possession or stored electronically
by Defendant. Discovery is ongoing.
2. Any and all physical and/or documentary evidence that refutesPlaintiff’s claim
against the Defendant.
RESPONSE: Objection to the extent the request calls for work product, otherwise
none in possession at this time. Discovery is ongoing.
3. Any and all insurance policies which may provide coverage for theactions
alleged in the complaint.
RESPONSE: None known to exist.
Counsel, please see note above on pg 1 marked with *.
CERTIFICATE OF SERVICE
I certify that a copy hereof has been furnished to the attorneys listed on theattached
service list, via E-Portal, on May 3, 2021.
s/Julie N. Pagni
Julie N. Pagni, Esq, FBN 111459
Pagni Law, PLLC
Phone: (954) 817-3441
Email: pagnilaw@gmail.com
Secondary Email: eservicepagnilaw@gmail.com
Attorney for Defendant, Devon BrigantiSERVICE LIST
Senior Justice Law Firm David J. Brevda, Esq.
7700 Congress Avenue
Suite 3216
Boca Raton, FL 33487
Telephone: (561) 717-0817
Email: Eservice@SeniorJustice.com
Email: lori@seniorjustice.com
Attorneys for Plaintiff, Jane Doe
FALK, WAAS, HERNANDEZ, SOLOMON,
MENDLESTEIN & DAVIS, P.A.
RoseMarie Antonacci-Pollock, Esq.
1900 NW Corporate Blvd., Suite 210-E
Boca Raton, FL 33431
Telephone: (561) 367-2510
Facsimile: (305) 447-1777
Attorneys for Defendant, Boca Raton Regional Hospital,
Inc. d/b/a Boca RatonRegional Hospital
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Filing # 126076800 E-Filed 05/03/2021 06:00:15 PM IN THE CIRCUIT COURT OF THE ISTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502020CA014445XXXXMB JANE DOE, Division: AF Plaintiff, v. BOCA RATON REGIONAL HOSPITAL, INC., d/b/a BOCA RATON REGIONAL HOSPITAL, and DEVON BRIGANTI, Defendant. DEFENDANT, DEVON BRIGANTI, RESPONSE TO REQUEST FOR, PRODUCTION PROPOUNDED BY DEFENDANT. BOCA RATON HOSPITAL Defendant, DEVON BRIGANTI, by and through undersigned counsel, pursuant to Rule 1.350, Florida Rules of Civil Procedure, files his Responses to Request for Production propounded by Defendant, BOCA RATONREGIONAL HOSPITAL, and further provides the following: *Defendant’s responses are based off of what he has in possession and does not include or account for anything that may have been previously produced by another party in response to discovery during this case, as Defendant will not be duplicating previous discovery. 1. Copies of any and all correspondence between DEVON BRIGANTI and the Plaintiff, together with complete copies of any text messages, E-mail(s), direct message(s), social media message(s), instant message(s), and/or any other materials obtained by the Defendant from the Plaintiff at any time prior to the date this suit was filed up to the date of this request. 1 *** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 05/03/2021 06:00:15 PM ***RESPONSE: No actual messages of any kind in possession or stored electronically by Defendant. Discovery is ongoing. 2. Any and all physical and/or documentary evidence that refutesPlaintiff’s claim against the Defendant. RESPONSE: Objection to the extent the request calls for work product, otherwise none in possession at this time. Discovery is ongoing. 3. Any and all insurance policies which may provide coverage for theactions alleged in the complaint. RESPONSE: None known to exist. Counsel, please see note above on pg 1 marked with *. CERTIFICATE OF SERVICE I certify that a copy hereof has been furnished to the attorneys listed on theattached service list, via E-Portal, on May 3, 2021. s/Julie N. Pagni Julie N. Pagni, Esq, FBN 111459 Pagni Law, PLLC Phone: (954) 817-3441 Email: pagnilaw@gmail.com Secondary Email: eservicepagnilaw@gmail.com Attorney for Defendant, Devon BrigantiSERVICE LIST Senior Justice Law Firm David J. Brevda, Esq. 7700 Congress Avenue Suite 3216 Boca Raton, FL 33487 Telephone: (561) 717-0817 Email: Eservice@SeniorJustice.com Email: lori@seniorjustice.com Attorneys for Plaintiff, Jane Doe FALK, WAAS, HERNANDEZ, SOLOMON, MENDLESTEIN & DAVIS, P.A. RoseMarie Antonacci-Pollock, Esq. 1900 NW Corporate Blvd., Suite 210-E Boca Raton, FL 33431 Telephone: (561) 367-2510 Facsimile: (305) 447-1777 Attorneys for Defendant, Boca Raton Regional Hospital, Inc. d/b/a Boca RatonRegional Hospital