On January 16, 100 a
Motion-Secondary
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 # 116989753 E-Filed 11/19/2020 04:17:54 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 JUSTIN WILLIE VEGA’S RESPONSE TO DEFENDANT’S
MEDICARE/MEDICAID REQUEST FOR PRODUCTION
COME NOW the Plaintiff, JUSTIN WILLIE VEGA by and through his undersigned
counsel, and hereby files this Notice of Filing Responses to Defendant’s Medicaid/Medicare
Request for Production and states as follows:
1. A copy of your Medicare card.
RESPONSE: None.
2. A copy of your Medicaid card.
RESPONSE: See attached Medicaid information currently in Plaintiff's possession.
3. A copy of your Social Security Disability card.
RESPONSE: None.
4. A copy of your Supplemental Security Income card.
RESPONSE: None.
5. Copies of any and all of your applications for Medicare or Medicaid benefits
during the past 10 years
RESPONSE: None in Plaintiff's possession.
*** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 11/19/2020 04:17:54 PM ***6. Copies of any and all your applications for Social Security benefits including but
not limited to Social Security Disability and/or Supplemental Security income benefits during
the past 10 years.
RESPONSE: None
7. Copies of any and all Social Security award letters you received during the past 10
years.
RESPONSE: None
8. Copies of any and all documents and communications regarding any and all
Medicare benefits identified in your Answer to Medicare Interrogatory No. 4.
RESPONSE: None
9. Copies of any and all documents and communications regarding any and all
Medicaid benefits identified in your Answer to Medicare Interrogatory No. 4.
RESPONSE: None in Plaintiff's possession.
10. Copies of any and all documents and communications regarding any and all
Social Security Disability benefits identified in your Answer to Medicare Interrogatory No. 4.
RESPONSE: None
11. Copies of any and all documents and communications regarding any and all
Supplemental Security Income benefits identified in your Answer to Medicare Interrogatory No.
4,
RESPONSE: None
12. Copies of any and all documents and communications regarding your current
Medicare, Medicaid, Social Security Disability and/or Supplemental Security Income recipient
status as identified in your Answer to Medicare Interrogatory No. 5.
RESPONSE: See attached Medicaid information currently in Plaintiff's possession.
13. Copies of any and all documents and communications regarding any and all
requests for hearing for Social Security Disability and/or Supplemental Security Income benefits
identified in your Answer to Medicare Interrogatory No. 6.
RESPONSE: None
CERTIFICATE OF SERVICE ON THE NEXT PAGECERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 19" 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
Attorneys 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
Document Filed Date
December 13, 2064
Case Filing Date
January 16, 100
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Filing # 116989753 E-Filed 11/19/2020 04:17:54 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 JUSTIN WILLIE VEGA’S RESPONSE TO DEFENDANT’S MEDICARE/MEDICAID REQUEST FOR PRODUCTION COME NOW the Plaintiff, JUSTIN WILLIE VEGA by and through his undersigned counsel, and hereby files this Notice of Filing Responses to Defendant’s Medicaid/Medicare Request for Production and states as follows: 1. A copy of your Medicare card. RESPONSE: None. 2. A copy of your Medicaid card. RESPONSE: See attached Medicaid information currently in Plaintiff's possession. 3. A copy of your Social Security Disability card. RESPONSE: None. 4. A copy of your Supplemental Security Income card. RESPONSE: None. 5. Copies of any and all of your applications for Medicare or Medicaid benefits during the past 10 years RESPONSE: None in Plaintiff's possession. *** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 11/19/2020 04:17:54 PM ***6. Copies of any and all your applications for Social Security benefits including but not limited to Social Security Disability and/or Supplemental Security income benefits during the past 10 years. RESPONSE: None 7. Copies of any and all Social Security award letters you received during the past 10 years. RESPONSE: None 8. Copies of any and all documents and communications regarding any and all Medicare benefits identified in your Answer to Medicare Interrogatory No. 4. RESPONSE: None 9. Copies of any and all documents and communications regarding any and all Medicaid benefits identified in your Answer to Medicare Interrogatory No. 4. RESPONSE: None in Plaintiff's possession. 10. Copies of any and all documents and communications regarding any and all Social Security Disability benefits identified in your Answer to Medicare Interrogatory No. 4. RESPONSE: None 11. Copies of any and all documents and communications regarding any and all Supplemental Security Income benefits identified in your Answer to Medicare Interrogatory No. 4, RESPONSE: None 12. Copies of any and all documents and communications regarding your current Medicare, Medicaid, Social Security Disability and/or Supplemental Security Income recipient status as identified in your Answer to Medicare Interrogatory No. 5. RESPONSE: See attached Medicaid information currently in Plaintiff's possession. 13. Copies of any and all documents and communications regarding any and all requests for hearing for Social Security Disability and/or Supplemental Security Income benefits identified in your Answer to Medicare Interrogatory No. 6. RESPONSE: None CERTIFICATE OF SERVICE ON THE NEXT PAGECERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 19" 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 Attorneys 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