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Filing # 115983658 E-Filed 11/02/2020 01:19:52 PM
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
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.
/
PLAINTIFF JUSTINO VEGA RESPONSE TO DEFENDANT’S
REQUEST FOR PRODUCTION
COME NOW the Plaintiff, JUSTINO VEGA, by and through his undersigned counsel,
and hereby files this Notice of Filing Responses to Defendant’s Request for Production and
states as follows:
1 Copies of Income Tax Returns, including all schedules, attachments and W2 forms, or
a properly executed authorization for obtaining a true copy of Federal Income Tax Returns for the
three year period prior to the date of accident to date.
RESPONSE: Objection, not reasonably calculated to lead to the discovery of admissible
evidence. Plaintiff is not making a claim for lost wages.
2. A record of earnings for the current year to date.
RESPONSE: Objection, not reasonably calculated to lead to the discovery of admissible
evidence. Plaintiff is not making a claim for lost wages.
3. Any and all medical records for treatment resulting from the lawsuit incident
including, but not limited to, hospital, doctor, nurse, therapy, psychiatric and/or psychological
records.
RESPONSE: See attached.
4. Any and all medical bills (paid or owing) incurred as a result of the lawsuit incident.
RESPONSE: See attached.
*** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 11/02/2020 01:19:52 PM ***5. Any and all medical records for treatment received by the plaintiff in the five year
period prior to the lawsuit incident, including, but not limited to, hospital, doctor, nurse, therapy,
psychiatric and/or psychological records.
RESPONSE: None in Plaintiff's possession.
6. Any and all documents or records pertaining to collateral source benefits of any
nature obtained by Plaintiff or to which Plaintiff may have a claim.
RESPONSE: See the attached PIP log and medical bills.
7. Any and all statements of any employee, agent or representative of defendant, its
employees or agents.
RESPONSE: None in Plaintiff’s possession.
8 Any and all statements of any independent witnesses who observed the incident
complained of or who were on the scene immediately before or after the incident.
RESPONSE: None in Plaintiff's possession.
9. Any and all photographs taken at the scene of the incident on the date of incident or at
any other time.
RESPONSE: See attached.
10. Any photographs of Plaintiff showing his or her injury or condition after reaching
maximum medical improvement and his or her condition prior to the injuries complained of.
RESPONSE: None.
lL. Any other photographs pertaining to the claims alleged in this action.
RESPONSE: See attached.
12. Complete cell phone billing records for the one hour period before the accident and
one hour after the subject accident.
RESPONSE: None in Plaintiff's possession.
13. Pharmacy records for a two-year period prior to the date of the accident.
RESPONSE: None in Plaintiff's possession.
14. Any notes, diaries, logs, journals, letters, electronic mail, text messages, calendars,
Facebook postings, tweets, or other social media messages that relate or refer to your accident, yourinjuries, or travel or vacation activities since the date of accident.
RESPONSE: None
15. Copies of all documents reflecting any claim Plaintiff has made in the past for
personal injury, wages or other compensation.
RESPONSE: None in Plaintiff's possession.
16. A photocopy of any health insurance policies or records in the plaintiff's possession
for the last seven (7) years, or if unavailable, the name and address of any company who has custody
of such documents.
RESPONSE: See attached health insurance card. No policies currently in Plaintiff's
possession.
17. Copies of any disability insurance applications or other paperwork regarding
applications or policies in the last seven (7) years, or if unavailable, the name and address of any
company who has custody of such documents.
RESPONSE: None in Plaintiff's possession.
18. Please produce properly executed and completed authorizations for obtaining
information from the Social Security Administration relating to Plaintiff's earnings. (A copy of the
appropriate release form is attached hereto.)
RESPONSE: Objection, not reasonably calculated to lead to the discovery of admissible
evidence. Plaintiff is not making a claim for lost wages.
19. Please produce properly executed and completed authorizations for obtaining true and
correct copies of Plaintiff's Federal Income Tax Returns for the three years prior to the year of
accident to date (Authorizations are attached hereto.)
RESPONSE: Objection, not reasonably calculated to lead to the discovery of admissible
evidence. Plaintiff is not making a claim for lost wages.
20. Please produce properly executed HIPAA Authorization Form (attached hereto.)
RESPONSE: Objection, all medical records shall be subpoenaed pursuant to the Florida
Rules of Civil Procedure.
21. Please produce properly executed and completed authorizations for obtaining
Plaintiff's Medicare and Florida Medicaid information (a copy of the appropriate authorizations are
attached hereto.)RESPONSE: Objection, not reasonably calculated to lead to the discovery of admissible
evidence, Plaintiff is not a Medicare or Medicaid beneficiary.
22. Please produce properly executed and completed authorization for obtaining
Plaintiff's Social Security Administration records relating to any claims made by the Plaintiff
(a copy of the appropriate authorization is attached hereto.)
RESPONSE: Objection, not reasonably calculated to lead to the discovery of admissible
evidence. Plaintiff has not made any such claims.
23. Proof that you area U.S. citizen or lawful permanent resident, including execution of
the attached Form G-639.
RESPONSE: Objection, not reasonably calculated to lead to the discovery of admissible
evidence.
24. If you are not a U.S. citizen or lawful permanent resident, proof of your immigration
status.
RESPONSE: Objection, not reasonably calculated to lead to the discovery of admissible
evidence.
25. A copy of Plaintiff’s Florida Driver’s License.
RESPONSE: See attached
26. A copy of Plaintiff's PIP Insurance card or policy.
RESPONSE: See attached
27. A copy of the registration for the vehicle driven by Plaintiff at the time of the
accident.
RESPONSE: See attached
28. A copy of the ticket/citation, if any, issued to Plaintiff at the time of the accident by
police.
RESPONSE: None.
29. To the extent not requested above, any and all documents that support any of the
claims in this action.
RESPONSE: See all documents previously referenced in response to this Request for
Production.CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 2™ Day of November, 2020 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 Jeffrey A. Mowers
Esq., at Jeffrey. Mowers@lewisBrisbois.com; Ellise.Silverberg@LewisBrisbois.com:
Ftlemaildesig@LewisBrisbois.com
LAW OFFICES OF CARLOS J. JIMENEZ, PL
Attomeys for Plaintiff
1880 North Congress Avenue, Suite 315
Boynton Beach, FL 33426
(561-253-0434; Fax: 561-253-0435)
eService@247InjuryLaw.com
Electronically Signed
By:
CARLOS J. JIMENEZ
Florida Bar No.: 0636746
SCOTT GOLDSTEIN, ESQUIRE
Florida Bar No.: 0540951
Preview
Filing # 115983658 E-Filed 11/02/2020 01:19:52 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA 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. / PLAINTIFF JUSTINO VEGA RESPONSE TO DEFENDANT’S REQUEST FOR PRODUCTION COME NOW the Plaintiff, JUSTINO VEGA, by and through his undersigned counsel, and hereby files this Notice of Filing Responses to Defendant’s Request for Production and states as follows: 1 Copies of Income Tax Returns, including all schedules, attachments and W2 forms, or a properly executed authorization for obtaining a true copy of Federal Income Tax Returns for the three year period prior to the date of accident to date. RESPONSE: Objection, not reasonably calculated to lead to the discovery of admissible evidence. Plaintiff is not making a claim for lost wages. 2. A record of earnings for the current year to date. RESPONSE: Objection, not reasonably calculated to lead to the discovery of admissible evidence. Plaintiff is not making a claim for lost wages. 3. Any and all medical records for treatment resulting from the lawsuit incident including, but not limited to, hospital, doctor, nurse, therapy, psychiatric and/or psychological records. RESPONSE: See attached. 4. Any and all medical bills (paid or owing) incurred as a result of the lawsuit incident. RESPONSE: See attached. *** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 11/02/2020 01:19:52 PM ***5. Any and all medical records for treatment received by the plaintiff in the five year period prior to the lawsuit incident, including, but not limited to, hospital, doctor, nurse, therapy, psychiatric and/or psychological records. RESPONSE: None in Plaintiff's possession. 6. Any and all documents or records pertaining to collateral source benefits of any nature obtained by Plaintiff or to which Plaintiff may have a claim. RESPONSE: See the attached PIP log and medical bills. 7. Any and all statements of any employee, agent or representative of defendant, its employees or agents. RESPONSE: None in Plaintiff’s possession. 8 Any and all statements of any independent witnesses who observed the incident complained of or who were on the scene immediately before or after the incident. RESPONSE: None in Plaintiff's possession. 9. Any and all photographs taken at the scene of the incident on the date of incident or at any other time. RESPONSE: See attached. 10. Any photographs of Plaintiff showing his or her injury or condition after reaching maximum medical improvement and his or her condition prior to the injuries complained of. RESPONSE: None. lL. Any other photographs pertaining to the claims alleged in this action. RESPONSE: See attached. 12. Complete cell phone billing records for the one hour period before the accident and one hour after the subject accident. RESPONSE: None in Plaintiff's possession. 13. Pharmacy records for a two-year period prior to the date of the accident. RESPONSE: None in Plaintiff's possession. 14. Any notes, diaries, logs, journals, letters, electronic mail, text messages, calendars, Facebook postings, tweets, or other social media messages that relate or refer to your accident, yourinjuries, or travel or vacation activities since the date of accident. RESPONSE: None 15. Copies of all documents reflecting any claim Plaintiff has made in the past for personal injury, wages or other compensation. RESPONSE: None in Plaintiff's possession. 16. A photocopy of any health insurance policies or records in the plaintiff's possession for the last seven (7) years, or if unavailable, the name and address of any company who has custody of such documents. RESPONSE: See attached health insurance card. No policies currently in Plaintiff's possession. 17. Copies of any disability insurance applications or other paperwork regarding applications or policies in the last seven (7) years, or if unavailable, the name and address of any company who has custody of such documents. RESPONSE: None in Plaintiff's possession. 18. Please produce properly executed and completed authorizations for obtaining information from the Social Security Administration relating to Plaintiff's earnings. (A copy of the appropriate release form is attached hereto.) RESPONSE: Objection, not reasonably calculated to lead to the discovery of admissible evidence. Plaintiff is not making a claim for lost wages. 19. Please produce properly executed and completed authorizations for obtaining true and correct copies of Plaintiff's Federal Income Tax Returns for the three years prior to the year of accident to date (Authorizations are attached hereto.) RESPONSE: Objection, not reasonably calculated to lead to the discovery of admissible evidence. Plaintiff is not making a claim for lost wages. 20. Please produce properly executed HIPAA Authorization Form (attached hereto.) RESPONSE: Objection, all medical records shall be subpoenaed pursuant to the Florida Rules of Civil Procedure. 21. Please produce properly executed and completed authorizations for obtaining Plaintiff's Medicare and Florida Medicaid information (a copy of the appropriate authorizations are attached hereto.)RESPONSE: Objection, not reasonably calculated to lead to the discovery of admissible evidence, Plaintiff is not a Medicare or Medicaid beneficiary. 22. Please produce properly executed and completed authorization for obtaining Plaintiff's Social Security Administration records relating to any claims made by the Plaintiff (a copy of the appropriate authorization is attached hereto.) RESPONSE: Objection, not reasonably calculated to lead to the discovery of admissible evidence. Plaintiff has not made any such claims. 23. Proof that you area U.S. citizen or lawful permanent resident, including execution of the attached Form G-639. RESPONSE: Objection, not reasonably calculated to lead to the discovery of admissible evidence. 24. If you are not a U.S. citizen or lawful permanent resident, proof of your immigration status. RESPONSE: Objection, not reasonably calculated to lead to the discovery of admissible evidence. 25. A copy of Plaintiff’s Florida Driver’s License. RESPONSE: See attached 26. A copy of Plaintiff's PIP Insurance card or policy. RESPONSE: See attached 27. A copy of the registration for the vehicle driven by Plaintiff at the time of the accident. RESPONSE: See attached 28. A copy of the ticket/citation, if any, issued to Plaintiff at the time of the accident by police. RESPONSE: None. 29. To the extent not requested above, any and all documents that support any of the claims in this action. RESPONSE: See all documents previously referenced in response to this Request for Production.CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 2™ Day of November, 2020 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 Jeffrey A. Mowers Esq., at Jeffrey. Mowers@lewisBrisbois.com; Ellise.Silverberg@LewisBrisbois.com: Ftlemaildesig@LewisBrisbois.com LAW OFFICES OF CARLOS J. JIMENEZ, PL Attomeys for Plaintiff 1880 North Congress Avenue, Suite 315 Boynton Beach, FL 33426 (561-253-0434; Fax: 561-253-0435) eService@247InjuryLaw.com Electronically Signed By: CARLOS J. JIMENEZ Florida Bar No.: 0636746 SCOTT GOLDSTEIN, ESQUIRE Florida Bar No.: 0540951