Preview
Filing # 106351109 E-Filed 04/16/2020 04:10:02 PM
IN THE CIRCUIT COURT IN AND FOR BAY COUNTY, FLORIDA
NATALIE SORRENTO,
Plaintiff,
v. Case No.: 20000243CA
ALLSTATE INSURANCE COMPANY,
Defendant.
/
DEFENDANT’S FIRST REQUEST FOR PRODUCTION
OF DOCUMENTS TO PLAINTIFF
Defendant, ALLSTATE INSURANCE COMPANY, pursuant to Fla. R. Civ. P. 1.350,
requests the above-named Plaintiff, NATALIE A. SORRENTO, to produce for inspection,
copying and all other purposes within the time period permitted by said rule, which are not work
product, at the Law Office of Vernis & Bowling of Northwest Florida, P.A., 315 South Palafox
Street, Pensacola, FL 32502, the following:
REQUEST FOR PRODUCTION
REQ TNO.1: All medical, surgical, x-ray, dental, rehabilitative, ambulance,
hospital, or nursing reports, records, and statements for services concerning treatment,
examination and/or evaluation of Plaintiff, NATALIE A. SORRENTO, at any time, both before
and after the incident set forth in the complaint, for any conditions which Plaintiff claim was
caused and/or aggravated by the incident set for in the complaint, or if no records are in the
possession of Plaintiff, an authorization to obtain same. This request does not include those
records made at the specific request of the counsel for Plaintiff or in the preparation of Plaintiffs
case for trial.
RESPONSE:REQUEST NO. 2: Copies of all spinal x-rays, CT scans, MRI scans and myelograms
done of Plaintiff, NATALIE A. SORRENTO, alleged to have been injured at any time, both
before and after the incident set forth in the complaint.
RESPONSE:
REQUEST NO. 3: Any statements made by Plaintiff, NATALIE A. SORRENTO,
whether written and/or recorded, related to this accident. This request includes audio and video
tapes of Plaintiff.
RESPONSE:
REQUEST NO. 4: All statements, including, but not limited to, recorded telephone
interviews, tapes, written statements, signed or unsigned, of initial and/or present Defendant to
this matter, or any of its agents, servants or employees relative to the within incident and any
other issue which involves the instant litigation.
RESPONSE:
REQUEST NO.5: Any and all statements, including, but not limited to, recorded
telephone interviews, tapes, written statements, whether signed or unsigned, of all witnesses to
the incident relative to the subject matter of this action and/or any witnesses having knowledge
regarding any and all facts and issues in the instant litigation.
RESPONSE:
REQUEST NO. 6: All incident reports filed by Plaintiff, NATALIE A. SORRENTO,
for any purpose, including but not limited to, reports to employers and/or insurance companies
regarding the incident, if applicable, and/or any other reports filled out by Plaintiff.RESPONSE:
REQUEST NO. 7: All correspondence the Plaintiff or her attorney received from any
agent, servant and/or employee of initial and/or present Defendant to this matter, or her insurance
carrier.
RESPONSE:
REQUEST NO. 8: All notes concerning any oral conversations Plaintiff or any agent,
servant and/or employee of her attorney’s office had with any agent, servant and/or employee of
initial and/or present Defendant to this matter, or her insurance carrier.
RESPONSE:
REQUEST NO. 9: All photographs, or digital color copies, slides, movie films, and
video of the Plaintiff, NATALIE A. SORRENTO, to be used to depict the quality of life of the
Plaintiff prior to the incident and those depicting injuries to Plaintiff sustained as a result of the
within incident.
RESPONSE:
REQUEST NO. 10: All photographs, or digital color copies, slides, movie films, and
video taken of the scene of the incident.
RESPONSE:REQUEST NO. 11: All photographs taken by Plaintiff or anyone on behalf of Plaintiff
reflecting any and all damages to Plaintiff’s vehicle.
RESPONSE:
REQUEST NO. 12: All property damage estimates and completed repair statements for
the vehicle belonging to Plaintiff or operated by Plaintiff which was involved in the incident.
RESPONSE:
REQUEST NO. 13: With regard to insurance available to Plaintiff, all contracts of
insurance along with the declaration sheets of all insurance in effect on the date of the accident
which is the subject of this cause. “Insurance” is defined as medical, automobile, PIP, medical
payment, hospitalization, Medicaid, Medicare, disability, workers’ compensation, health and
accident and/or employment related insurance.
RESPONSE:
REQUEST NO. 14: Any and all applications and/or claims submitted by Plaintiff,
NATALIE A. SORRENTO, for insurance benefits made by Plaintiff to pay the damages
described in the complaint, including, but not limited to, payments for medical expenses, funeral
expenses, lost wages, lost earning capacity, and any period of disability following said incident.
RESPONSE:
REQUEST NO. 15: All bills and statements for medical treatment, devices and
medicines, the cost of which is claimed to have been incurred as a result of the injuries sustained
in this cause by Plaintiff, NATALIE A. SORRENTO.
RESPONSE:REQUEST NO. 16: Any and all bills and records of hospitals in which Plaintiff,
NATALIE A. SORRENTO, has been a patient or received treatment allegedly as a result of the
injuries sustained in this cause by said Plaintiff, or for any other pre-existing medical condition
or prior injury, or if no records are in the possession of Plaintiff, an authorization to obtain same.
RESPONSE:
REQUEST NO. 17: Any and all writings and documents of any sort showing payments
by any source of any of the damages claimed by Plaintiff, NATALIE A. SORRENTO, in the
Complaint including, but not limited to, payments for medical expenses, funeral expenses, lost
wages, loss of earning capacity, and any period of disability following the incident, including,
but not limited to, all claims for personal injury protection benefits, medical payments benefits,
liability insurance benefits, uninsured motorist benefits, and all other claims to some person,
business organization, insurance carrier or governmental entity to pay the same items of expense
claimed by Plaintiff in this lawsuit. This request includes, but is not limited to: records of
payments, checks and duplicate checks, check stubs, and all writings relating to any payments
made under the insurance policies covered by Request No. 13 above, as a result of the accident
which is the subject of this cause.
RESPONSE:
REQUEST NO. 18: The contract, insurance policy, release or other writing of
whatsoever kind and nature which is the basis for payment of the benefits described in Request
Nos. 13 and 14 above.
RESPONSE:
REQUEST NO. 19: Any indemnity agreement entered into by Plaintiff, NATALIE A.
SORRENTO, which falls under the provisions of Fla. R. Civ. P. 1.280(b) (2).RESPONSE:
REQUEST NO. 20: Copies of income tax returns and W-2 forms in connection with
Federal Income Tax Returns filed by Plaintiff, NATALIE A. SORRENTO, with any other
person for the three (3) calendar years prior to the year which the incident described in the
complaint took place; the year which the incident took place; and each year after the incident to
the current time.
RESPONSE:
REQUEST NO. 21: Copies of all withholding statements, pay envelopes, deposit slips,
or any other evidence of income earned by Plaintiff NATALIE A. SORRENTO for the current
calendar year.
RESPONSE:
REQUEST NO. 22: Copies of any applications for employment made by Plaintiff,
NATALIE A. SORRENTO, during the three (3) years prior to the incident or after the incident.
RESPONSE:
REQUEST NO. 23: Calendars, daily diaries and/or appointment books kept by, or for
Plaintiff, NATALIE A. SORRENTO, which reflect notations as to lost wages, alleged injuries or
limitations for a period of five (5) years prior to this Request for Production.
RESPONSE:REQUEST NO. 24: Any documents which constitute, evidence, or reflect any special
damages Plaintiff, NATALIE A. SORRENTO, has suffered as a result of the accident at issue for
which she is seeking compensation, other than medical bills and lost wages.
RESPONSE:
REQUEST NO. 25: Any and all reports prepared by experts expected to testify at trial.
(“Experts” are not limited to medical doctors.) Mims v. Casademont, 464 So.2d 643 (Fla.3d
DCA 1985).
RESPONSE:
REQUEST NO. 26: Copies of any releases and any other type of settlement agreements
between Plaintiff and any other party which may have been responsible for the damages claimed
by Plaintiff for this incident or for any prior or subsequent injury or accident.
RESPONSE:
REQ NO. 27: A legible copy of the back and front of Plaintiff's health insurance
card(s).
RESPONSE:
REQUEST NO. 28: A legible copy of the back and front of Plaintiffs driver’s license.
RESPONSE:REQUEST NO. 29: Copy of any and all photographs, blow-ups, recordings, charts,
graphs, sketches and any other tangible items or documentary evidence which Plaintiff intends to
use during the trial of this cause and which have not been produced in response to any of the
preceding paragraphs.
RESPONSE:
REQUEST NO. 30: Copies of any and all records/documents _ reflecting
monies/payments (of any kind) received from the Social Security Administration and/or
Medicare/Medicaid.
RESPONSE:
REQUEST NO. 31: Copies of any and all records from the Social Security
Administration reflecting any determination of the award for any type of benefit, including
copies of any and all medical records, correspondence, etc.
RESPONSE:
REQUEST NO. 32: Copies of any and all cellular telephone records for the cellular
telephone Plaintiff, NATALIE A. SORRENTO, had at the time of the incident including
telephone number, account number, statements, and an itemization of calls/texts made and/or
received.
RESPONSE:
REQUEST NO. 33: Copies of all report cards and additional school records including,
but not limited to, curriculum selections or changes, school records regarding attendance and
grade, and correspondence from schools and to school administrators, teachers and other
employees including, but not limited to, grade reporting, courses not completed/dropped,
disciplinary issues, grade issues and/or attendance issues, for Plaintiff, NATALIE A.SORRENTO, for the period three years before the subject incident to present. If all these records
are not in the possession of Plaintiff, an authorization to obtain same.
RESPONSE:
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
electronic service to Joseph A. Zarzaur, Jr., Esq., with Zarzaur Law, P.A., P. O. Box 12350,
Pensacola, FL 32591; joc@zarzarulaw.com; service@zarzaurlaw.com, this 16™ day of April,
2020.
/s/ Jerry D. Sanders
Jerry D. Sanders, Esq.
Fla. Bar No. 112798
Vernis & Bowling of Northwest Florida, P.A.
315 South Palafox Street
Pensacola, Florida 32502
Telephone: (850) 433-5461
Facsimile: (850) 432-0166
JSanders@Florida-Law.com
ikerns@Florida-Law.com
vtaylor@Florida-Law.com
Attorney for Defendant,
ALLSTATE INSURANCE COMPANY
Preview
Filing # 106351109 E-Filed 04/16/2020 04:10:02 PM IN THE CIRCUIT COURT IN AND FOR BAY COUNTY, FLORIDA NATALIE SORRENTO, Plaintiff, v. Case No.: 20000243CA ALLSTATE INSURANCE COMPANY, Defendant. / DEFENDANT’S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO PLAINTIFF Defendant, ALLSTATE INSURANCE COMPANY, pursuant to Fla. R. Civ. P. 1.350, requests the above-named Plaintiff, NATALIE A. SORRENTO, to produce for inspection, copying and all other purposes within the time period permitted by said rule, which are not work product, at the Law Office of Vernis & Bowling of Northwest Florida, P.A., 315 South Palafox Street, Pensacola, FL 32502, the following: REQUEST FOR PRODUCTION REQ TNO.1: All medical, surgical, x-ray, dental, rehabilitative, ambulance, hospital, or nursing reports, records, and statements for services concerning treatment, examination and/or evaluation of Plaintiff, NATALIE A. SORRENTO, at any time, both before and after the incident set forth in the complaint, for any conditions which Plaintiff claim was caused and/or aggravated by the incident set for in the complaint, or if no records are in the possession of Plaintiff, an authorization to obtain same. This request does not include those records made at the specific request of the counsel for Plaintiff or in the preparation of Plaintiffs case for trial. RESPONSE:REQUEST NO. 2: Copies of all spinal x-rays, CT scans, MRI scans and myelograms done of Plaintiff, NATALIE A. SORRENTO, alleged to have been injured at any time, both before and after the incident set forth in the complaint. RESPONSE: REQUEST NO. 3: Any statements made by Plaintiff, NATALIE A. SORRENTO, whether written and/or recorded, related to this accident. This request includes audio and video tapes of Plaintiff. RESPONSE: REQUEST NO. 4: All statements, including, but not limited to, recorded telephone interviews, tapes, written statements, signed or unsigned, of initial and/or present Defendant to this matter, or any of its agents, servants or employees relative to the within incident and any other issue which involves the instant litigation. RESPONSE: REQUEST NO.5: Any and all statements, including, but not limited to, recorded telephone interviews, tapes, written statements, whether signed or unsigned, of all witnesses to the incident relative to the subject matter of this action and/or any witnesses having knowledge regarding any and all facts and issues in the instant litigation. RESPONSE: REQUEST NO. 6: All incident reports filed by Plaintiff, NATALIE A. SORRENTO, for any purpose, including but not limited to, reports to employers and/or insurance companies regarding the incident, if applicable, and/or any other reports filled out by Plaintiff.RESPONSE: REQUEST NO. 7: All correspondence the Plaintiff or her attorney received from any agent, servant and/or employee of initial and/or present Defendant to this matter, or her insurance carrier. RESPONSE: REQUEST NO. 8: All notes concerning any oral conversations Plaintiff or any agent, servant and/or employee of her attorney’s office had with any agent, servant and/or employee of initial and/or present Defendant to this matter, or her insurance carrier. RESPONSE: REQUEST NO. 9: All photographs, or digital color copies, slides, movie films, and video of the Plaintiff, NATALIE A. SORRENTO, to be used to depict the quality of life of the Plaintiff prior to the incident and those depicting injuries to Plaintiff sustained as a result of the within incident. RESPONSE: REQUEST NO. 10: All photographs, or digital color copies, slides, movie films, and video taken of the scene of the incident. RESPONSE:REQUEST NO. 11: All photographs taken by Plaintiff or anyone on behalf of Plaintiff reflecting any and all damages to Plaintiff’s vehicle. RESPONSE: REQUEST NO. 12: All property damage estimates and completed repair statements for the vehicle belonging to Plaintiff or operated by Plaintiff which was involved in the incident. RESPONSE: REQUEST NO. 13: With regard to insurance available to Plaintiff, all contracts of insurance along with the declaration sheets of all insurance in effect on the date of the accident which is the subject of this cause. “Insurance” is defined as medical, automobile, PIP, medical payment, hospitalization, Medicaid, Medicare, disability, workers’ compensation, health and accident and/or employment related insurance. RESPONSE: REQUEST NO. 14: Any and all applications and/or claims submitted by Plaintiff, NATALIE A. SORRENTO, for insurance benefits made by Plaintiff to pay the damages described in the complaint, including, but not limited to, payments for medical expenses, funeral expenses, lost wages, lost earning capacity, and any period of disability following said incident. RESPONSE: REQUEST NO. 15: All bills and statements for medical treatment, devices and medicines, the cost of which is claimed to have been incurred as a result of the injuries sustained in this cause by Plaintiff, NATALIE A. SORRENTO. RESPONSE:REQUEST NO. 16: Any and all bills and records of hospitals in which Plaintiff, NATALIE A. SORRENTO, has been a patient or received treatment allegedly as a result of the injuries sustained in this cause by said Plaintiff, or for any other pre-existing medical condition or prior injury, or if no records are in the possession of Plaintiff, an authorization to obtain same. RESPONSE: REQUEST NO. 17: Any and all writings and documents of any sort showing payments by any source of any of the damages claimed by Plaintiff, NATALIE A. SORRENTO, in the Complaint including, but not limited to, payments for medical expenses, funeral expenses, lost wages, loss of earning capacity, and any period of disability following the incident, including, but not limited to, all claims for personal injury protection benefits, medical payments benefits, liability insurance benefits, uninsured motorist benefits, and all other claims to some person, business organization, insurance carrier or governmental entity to pay the same items of expense claimed by Plaintiff in this lawsuit. This request includes, but is not limited to: records of payments, checks and duplicate checks, check stubs, and all writings relating to any payments made under the insurance policies covered by Request No. 13 above, as a result of the accident which is the subject of this cause. RESPONSE: REQUEST NO. 18: The contract, insurance policy, release or other writing of whatsoever kind and nature which is the basis for payment of the benefits described in Request Nos. 13 and 14 above. RESPONSE: REQUEST NO. 19: Any indemnity agreement entered into by Plaintiff, NATALIE A. SORRENTO, which falls under the provisions of Fla. R. Civ. P. 1.280(b) (2).RESPONSE: REQUEST NO. 20: Copies of income tax returns and W-2 forms in connection with Federal Income Tax Returns filed by Plaintiff, NATALIE A. SORRENTO, with any other person for the three (3) calendar years prior to the year which the incident described in the complaint took place; the year which the incident took place; and each year after the incident to the current time. RESPONSE: REQUEST NO. 21: Copies of all withholding statements, pay envelopes, deposit slips, or any other evidence of income earned by Plaintiff NATALIE A. SORRENTO for the current calendar year. RESPONSE: REQUEST NO. 22: Copies of any applications for employment made by Plaintiff, NATALIE A. SORRENTO, during the three (3) years prior to the incident or after the incident. RESPONSE: REQUEST NO. 23: Calendars, daily diaries and/or appointment books kept by, or for Plaintiff, NATALIE A. SORRENTO, which reflect notations as to lost wages, alleged injuries or limitations for a period of five (5) years prior to this Request for Production. RESPONSE:REQUEST NO. 24: Any documents which constitute, evidence, or reflect any special damages Plaintiff, NATALIE A. SORRENTO, has suffered as a result of the accident at issue for which she is seeking compensation, other than medical bills and lost wages. RESPONSE: REQUEST NO. 25: Any and all reports prepared by experts expected to testify at trial. (“Experts” are not limited to medical doctors.) Mims v. Casademont, 464 So.2d 643 (Fla.3d DCA 1985). RESPONSE: REQUEST NO. 26: Copies of any releases and any other type of settlement agreements between Plaintiff and any other party which may have been responsible for the damages claimed by Plaintiff for this incident or for any prior or subsequent injury or accident. RESPONSE: REQ NO. 27: A legible copy of the back and front of Plaintiff's health insurance card(s). RESPONSE: REQUEST NO. 28: A legible copy of the back and front of Plaintiffs driver’s license. RESPONSE:REQUEST NO. 29: Copy of any and all photographs, blow-ups, recordings, charts, graphs, sketches and any other tangible items or documentary evidence which Plaintiff intends to use during the trial of this cause and which have not been produced in response to any of the preceding paragraphs. RESPONSE: REQUEST NO. 30: Copies of any and all records/documents _ reflecting monies/payments (of any kind) received from the Social Security Administration and/or Medicare/Medicaid. RESPONSE: REQUEST NO. 31: Copies of any and all records from the Social Security Administration reflecting any determination of the award for any type of benefit, including copies of any and all medical records, correspondence, etc. RESPONSE: REQUEST NO. 32: Copies of any and all cellular telephone records for the cellular telephone Plaintiff, NATALIE A. SORRENTO, had at the time of the incident including telephone number, account number, statements, and an itemization of calls/texts made and/or received. RESPONSE: REQUEST NO. 33: Copies of all report cards and additional school records including, but not limited to, curriculum selections or changes, school records regarding attendance and grade, and correspondence from schools and to school administrators, teachers and other employees including, but not limited to, grade reporting, courses not completed/dropped, disciplinary issues, grade issues and/or attendance issues, for Plaintiff, NATALIE A.SORRENTO, for the period three years before the subject incident to present. If all these records are not in the possession of Plaintiff, an authorization to obtain same. RESPONSE: CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by electronic service to Joseph A. Zarzaur, Jr., Esq., with Zarzaur Law, P.A., P. O. Box 12350, Pensacola, FL 32591; joc@zarzarulaw.com; service@zarzaurlaw.com, this 16™ day of April, 2020. /s/ Jerry D. Sanders Jerry D. Sanders, Esq. Fla. Bar No. 112798 Vernis & Bowling of Northwest Florida, P.A. 315 South Palafox Street Pensacola, Florida 32502 Telephone: (850) 433-5461 Facsimile: (850) 432-0166 JSanders@Florida-Law.com ikerns@Florida-Law.com vtaylor@Florida-Law.com Attorney for Defendant, ALLSTATE INSURANCE COMPANY