Preview
Filing # 132498723 E-Filed 08/11/2021 04:43:44 PM
IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT
IN AND FOR CITRUS COUNTY, FLORIDA
NORMAN L. CARTWRIGHT, III
And COLLEEN CARTWRIGHT,
Husband and Wife,
Plaintiffs,
vs. Case No.: 2021 CA 000537 A
R.T. BROWN, INC., a Florida Profit
Corporation, d/b/a BROWN FUNERAL
HOME AND CREMATORY
and
CITRUS MEMORIAL HOSPITAL, INC.,
a Florida Profit Corporation,
Defendants.
/
DEFENDANT, CITRUS MEMORIAL HOSPITAL, INC.’s INITIAL REQUEST TO PRODUCE
TO PLAIN
CITRUS MEMORIAL HOSPITAL, INC., by and through the undersigned counsel and pursuant
to Florida Rules of Civil Procedure 1.350, propounds upon Plaintiff, NORMAN L. CARTWRIGHT, III,
this Initial Request to Produce and requests that she produce within thirty (30) days of service at a
reasonable time as might be mutually agreed upon by the attorneys for the parties, for the purpose of
inspection and copying the matters described in the following list.
Defendant states the need to examine, copy and inspect the attached and described items and is
unable to obtain these items by other means, or alternatively, the Defendant is otherwise entitled to these
items under the applicable Rules of Civil Procedure and case law interpreting such Rules.
ITEMS REQUESTED
1. All documents shown to or generated by, any person whom you intend to call to testify as
an expert witness at trial of this matter.
2. A copy of a curriculum vitae for each expert witness Plaintiff expects to testify at trial.
3. All documents supporting Plaintiff's alleged economic damages.Copies of all medical bills resulting from the incident which is the subject of this lawsuit,
including, but not limited to, doctors, hospitals, clinics, therapists, ambulance, and prescriptions.
Copies of income tax returns for the past six (6) years, beginning with the most current tax
return filed.
Copies of all medical records, reports, opinions, and other materials from doctors, nurses,
therapists, hospitals, clinics, radiologists, other health care providers, and any other individuals
concerning the injuries or damages allegedly sustained by Plaintiff as a result of the subject
incident.
Copies of all photographs, maps, drawings and videotapes depicting Plaintiff's alleged injuries
and/or the scene of the alleged incident.
All statements made by any witnesses to the subject incident.
Any and all other documentary evidence which Plaintiff intends to introduce at the trial of
this cause of action,
A copy of your marriage certificate or license.
Copies of any and all documents reflecting:
a. All payments made to you, or on your behalf, by or pursuant to the United States
Social Security Act, as a result of the incident alleged in your Complaint.
b. All payments made to you, or on your behalf, by or pursuant to, any federal, state,
or local Income Disability Act, as a result of the incident described in your
Complaint.
c. All payments made to you, or on your behalf, by or pursuant to, any other public
programs providing medical expenses, disability payments, or other similar
benefits, as a result of the incident described in your Complaint.
d. All payments made to you, or on your behalf, by or pursuant to, any health,
sickness, or income disability insurance, as a result of the incident described in
your Complaint.
e, All payments made to you, or on your behalf, by or pursuant to, any insurance that
provides health benefits or income disability coverage as a result of the incident
described in your Complaint.
f. All payments made to you, or on your behalf, as a result of this incident, by or
pursuant to, any similar insurance benefits, except life insurance benefits, available
to you, whether purchased by you, or provided by others.
g. All payments made to you, or on your behalf as a result of the incident described
in your Complaint, by or pursuant to, any contract or agreement of any group,
organization, partnership or corporation to provide, pay for, or reimburse the cost
of hospital, medical, dental or other health care services incurred by you or on your
behalf as a result of the subject incident.h. All payments made to you, or on your behalf, as a result of the subject incident, by
or pursuant to any contractual or voluntary wage continuation plan provided by
employers or other system intended to provide wages during a period of disability.
i, All payments made by you, or on your behalf, as a result of the incident described
in your Complaint, by or pursuant to, Worker's Compensation Insurance.
j. Any and all payments made to you or on your behalf as a result of the incident
described in your Complaint, by or pursuant to, medical expense coverage.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the af day of August 2021 I electronically filed the
foregoing with the Clerk of the Court by using the Florida Court E-Filing Portal, which will send a Notice
of Electronic Filing to the following:
Thomas D. Hippelheuser, Esquire
LAW OFFICES OF BRENT C. MILLER, P.A.
205 E. Burleigh Boulevard
«
fo aut Le Kesveman, 6
JOSEPH F. KINMAN, JR., ESQUIRE
Florida Bar No.: 33090
Primary: jfk@ ci
Secondary: jlb@law-fla.com
BEYTIN, McLAUGHLIN, McLAUGHLIN,
O’HARA, KINMAN & BOCCHINO
1706 East Eleventh Ave.
Tampa, FL 33605
Phone: (813) 226-3000
Facsimile: (813) 226-3001
Attorney for Defendant Citrus Memorial Hospital
Preview
Filing # 132498723 E-Filed 08/11/2021 04:43:44 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR CITRUS COUNTY, FLORIDA NORMAN L. CARTWRIGHT, III And COLLEEN CARTWRIGHT, Husband and Wife, Plaintiffs, vs. Case No.: 2021 CA 000537 A R.T. BROWN, INC., a Florida Profit Corporation, d/b/a BROWN FUNERAL HOME AND CREMATORY and CITRUS MEMORIAL HOSPITAL, INC., a Florida Profit Corporation, Defendants. / DEFENDANT, CITRUS MEMORIAL HOSPITAL, INC.’s INITIAL REQUEST TO PRODUCE TO PLAIN CITRUS MEMORIAL HOSPITAL, INC., by and through the undersigned counsel and pursuant to Florida Rules of Civil Procedure 1.350, propounds upon Plaintiff, NORMAN L. CARTWRIGHT, III, this Initial Request to Produce and requests that she produce within thirty (30) days of service at a reasonable time as might be mutually agreed upon by the attorneys for the parties, for the purpose of inspection and copying the matters described in the following list. Defendant states the need to examine, copy and inspect the attached and described items and is unable to obtain these items by other means, or alternatively, the Defendant is otherwise entitled to these items under the applicable Rules of Civil Procedure and case law interpreting such Rules. ITEMS REQUESTED 1. All documents shown to or generated by, any person whom you intend to call to testify as an expert witness at trial of this matter. 2. A copy of a curriculum vitae for each expert witness Plaintiff expects to testify at trial. 3. All documents supporting Plaintiff's alleged economic damages.Copies of all medical bills resulting from the incident which is the subject of this lawsuit, including, but not limited to, doctors, hospitals, clinics, therapists, ambulance, and prescriptions. Copies of income tax returns for the past six (6) years, beginning with the most current tax return filed. Copies of all medical records, reports, opinions, and other materials from doctors, nurses, therapists, hospitals, clinics, radiologists, other health care providers, and any other individuals concerning the injuries or damages allegedly sustained by Plaintiff as a result of the subject incident. Copies of all photographs, maps, drawings and videotapes depicting Plaintiff's alleged injuries and/or the scene of the alleged incident. All statements made by any witnesses to the subject incident. Any and all other documentary evidence which Plaintiff intends to introduce at the trial of this cause of action, A copy of your marriage certificate or license. Copies of any and all documents reflecting: a. All payments made to you, or on your behalf, by or pursuant to the United States Social Security Act, as a result of the incident alleged in your Complaint. b. All payments made to you, or on your behalf, by or pursuant to, any federal, state, or local Income Disability Act, as a result of the incident described in your Complaint. c. All payments made to you, or on your behalf, by or pursuant to, any other public programs providing medical expenses, disability payments, or other similar benefits, as a result of the incident described in your Complaint. d. All payments made to you, or on your behalf, by or pursuant to, any health, sickness, or income disability insurance, as a result of the incident described in your Complaint. e, All payments made to you, or on your behalf, by or pursuant to, any insurance that provides health benefits or income disability coverage as a result of the incident described in your Complaint. f. All payments made to you, or on your behalf, as a result of this incident, by or pursuant to, any similar insurance benefits, except life insurance benefits, available to you, whether purchased by you, or provided by others. g. All payments made to you, or on your behalf as a result of the incident described in your Complaint, by or pursuant to, any contract or agreement of any group, organization, partnership or corporation to provide, pay for, or reimburse the cost of hospital, medical, dental or other health care services incurred by you or on your behalf as a result of the subject incident.h. All payments made to you, or on your behalf, as a result of the subject incident, by or pursuant to any contractual or voluntary wage continuation plan provided by employers or other system intended to provide wages during a period of disability. i, All payments made by you, or on your behalf, as a result of the incident described in your Complaint, by or pursuant to, Worker's Compensation Insurance. j. Any and all payments made to you or on your behalf as a result of the incident described in your Complaint, by or pursuant to, medical expense coverage. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the af day of August 2021 I electronically filed the foregoing with the Clerk of the Court by using the Florida Court E-Filing Portal, which will send a Notice of Electronic Filing to the following: Thomas D. Hippelheuser, Esquire LAW OFFICES OF BRENT C. MILLER, P.A. 205 E. Burleigh Boulevard « fo aut Le Kesveman, 6 JOSEPH F. KINMAN, JR., ESQUIRE Florida Bar No.: 33090 Primary: jfk@ ci Secondary: jlb@law-fla.com BEYTIN, McLAUGHLIN, McLAUGHLIN, O’HARA, KINMAN & BOCCHINO 1706 East Eleventh Ave. Tampa, FL 33605 Phone: (813) 226-3000 Facsimile: (813) 226-3001 Attorney for Defendant Citrus Memorial Hospital