On January 16, 100 a
Party Discovery
was filed
involving a dispute between
Justino Vega Pena,
Justin Willie Vega,
and
Hl Universal Inc,
Sony Joseph,
for AUTO NEGLIGENCE
in the District Court of Palm Beach County.
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Filing # 116555786 E-Filed 11/12/2020 12:53:09 PM
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY, FLORIDA
CIRCUIT CIVIL DIVISION
CASE NO.: 50-2020-CA-007743 (AN)
JUSTINO VEGA PENA and JUSTIN
WILLIE VEGA,
Plaintiff,
v.
SONY JOSEPH and HL UNIVERSAL, INC.,
a Florida Profit Corporation,
Defendants.
/
DEFENDANTS’ THIRD REQUEST FOR PRODUCTION TO
PLAINTIFF, JUSTINO VEGA PENA
COMES NOW Defendants, by and through their undersigned counsel, and requests that
Plaintiff, JUSTINO VEGA PENA produce the following for inspection and/or copying at the offices
of Lewis Brisbois Bisgaard & Smith LLP, Attorneys for Defendants, 110 SE 6" Street, Suite 2600,
Fort Lauderdale, Florida 33301 within thirty (30) days from the date hereof pursuant to Rule 1.350,
Fla.R.Civ.P.
1. All correspondence, records, emails, and documents between Plaintiff and Standard
Fire Insurance Company related to the UM claim stemming from the motor vehicle accident on
February 7, 2018.
2. All medical records submitted by Plaintiff to Standard Fire Insurance Company
related to the UM claim stemming from the motor vehicle accident on February 7, 2018.
3. All billing records submitted by Plaintiff to Standard Fire Insurance Company related
to the UM claim stemming from the motor vehicle accident on February 7, 2018.
4832-0329-2370.1
*** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 11/12/2020 12:53:09 PM ***CASE NO.: 50-2020-CA-007743 (AN)
4. All photographs submitted by Plaintiff to Standard Fire Insurance Company related to
the UM claim stemming from the motor vehicle accident on February 7, 2018.
5. All demands made by Plaintiff to Standard Fire Insurance Company related to the
UM claim stemming from the motor vehicle accident on February 7, 2018.
6. All offers made by Standard Fire Insurance Company related to the UM claim
stemming from the motor vehicle accident on February 7, 2018.
7. All documents reflecting any settlement with Standard Fire Insurance Company
related to the UM claim stemming from the motor vehicle accident on February 7, 2018
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that we electronically filed the foregoing with the Clerk of the
Court by using the Florida Courts E-Filing Portal which will send a Notice of Electronic Filing to:
Carlos Jimenez, Esq., and Scott Goldstein, Esq., CARLOS J. JIMENEZ, P.L., 1880 North Congress
Avenue, Suite 315, Boynton Beach, FL 33426, Counsel for Plaintiff, eService@247Injurylaw.com;
by e-mail on November 12, 2020.
LEWIS BRISBOIS BISGAARD & SMITH, LLP
Attorneys for Defendants
110 SE 6" Street, Suite 2600
Fort Lauderdale, FL 33301
(954)728-1280
(954)728-1282 fax
Jeffrey. Mowers@LewisBrisbois.com
Ellise.Silverberg@LewisBrisbois.com
Ftlemaildesig@LewisBrisbois.com
BY: _/A/Jeffrey A. Mowers
JEFFREY A. MOWERS
FBN 508240
4832-0329-2370.1 2
Document Filed Date
December 13, 2059
Case Filing Date
January 16, 100
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Filing # 116555786 E-Filed 11/12/2020 12:53:09 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIRCUIT CIVIL DIVISION CASE NO.: 50-2020-CA-007743 (AN) JUSTINO VEGA PENA and JUSTIN WILLIE VEGA, Plaintiff, v. SONY JOSEPH and HL UNIVERSAL, INC., a Florida Profit Corporation, Defendants. / DEFENDANTS’ THIRD REQUEST FOR PRODUCTION TO PLAINTIFF, JUSTINO VEGA PENA COMES NOW Defendants, by and through their undersigned counsel, and requests that Plaintiff, JUSTINO VEGA PENA produce the following for inspection and/or copying at the offices of Lewis Brisbois Bisgaard & Smith LLP, Attorneys for Defendants, 110 SE 6" Street, Suite 2600, Fort Lauderdale, Florida 33301 within thirty (30) days from the date hereof pursuant to Rule 1.350, Fla.R.Civ.P. 1. All correspondence, records, emails, and documents between Plaintiff and Standard Fire Insurance Company related to the UM claim stemming from the motor vehicle accident on February 7, 2018. 2. All medical records submitted by Plaintiff to Standard Fire Insurance Company related to the UM claim stemming from the motor vehicle accident on February 7, 2018. 3. All billing records submitted by Plaintiff to Standard Fire Insurance Company related to the UM claim stemming from the motor vehicle accident on February 7, 2018. 4832-0329-2370.1 *** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 11/12/2020 12:53:09 PM ***CASE NO.: 50-2020-CA-007743 (AN) 4. All photographs submitted by Plaintiff to Standard Fire Insurance Company related to the UM claim stemming from the motor vehicle accident on February 7, 2018. 5. All demands made by Plaintiff to Standard Fire Insurance Company related to the UM claim stemming from the motor vehicle accident on February 7, 2018. 6. All offers made by Standard Fire Insurance Company related to the UM claim stemming from the motor vehicle accident on February 7, 2018. 7. All documents reflecting any settlement with Standard Fire Insurance Company related to the UM claim stemming from the motor vehicle accident on February 7, 2018 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that we electronically filed the foregoing with the Clerk of the Court by using the Florida Courts E-Filing Portal which will send a Notice of Electronic Filing to: Carlos Jimenez, Esq., and Scott Goldstein, Esq., CARLOS J. JIMENEZ, P.L., 1880 North Congress Avenue, Suite 315, Boynton Beach, FL 33426, Counsel for Plaintiff, eService@247Injurylaw.com; by e-mail on November 12, 2020. LEWIS BRISBOIS BISGAARD & SMITH, LLP Attorneys for Defendants 110 SE 6" Street, Suite 2600 Fort Lauderdale, FL 33301 (954)728-1280 (954)728-1282 fax Jeffrey. Mowers@LewisBrisbois.com Ellise.Silverberg@LewisBrisbois.com Ftlemaildesig@LewisBrisbois.com BY: _/A/Jeffrey A. Mowers JEFFREY A. MOWERS FBN 508240 4832-0329-2370.1 2