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Filing # 134021747 E-Filed 09/03/2021 01:10:23 PM
IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT
IN AND FOR CITRUS COUNTY, FLORIDA
CIVIL DIVISION
NORMAN L., CARTWRIGHT, III,
Plaintiff,
v. CASENO.: 2021 CA 000537 A
R. T. BROWN, INC., d/b/a BROWN
FUNERAL HOME AND CREMATORY,
and CITRUS MEMORIAL HOSPITAL,
INC.,
Defendants.
/
DEFENDANT’S REQUEST TO PRODUCE TO PLAINTIFF
Defendant, R. T. BROWN, INC., d/b/a BROWN FUNERAL HOME AND
CREMATORY, by and through the undersigned attorneys, pursuant to Florida Rule of Civil
Procedure 1.350 respectfully requests Plaintiff, NORMAN L. CARTWRIGHT, IIL, to produce for
inspection and/or copying at the offices of the undersigned within thirty (30) days, the following:
1. A true copy of Plaintiff, NORMAN L. CARTWRIGHT, III’s, birth certificate.
2. A copy of Plaintiff, NORMAN L. CARTWRIGHT, II’s, driver’s license.
3, Please produce Income Tax Returns for the years 2016, 2017, 2018, 2019, and
2020.
4. The original of all drawings, charts, drafts, photographs, movies, tapes, film (to
include first generation negative) of any matter relating to the subject matter of this lawsuit which
are in the possession of you, your attorneys, investigators, agents, servants, employees, or to which
you have access.
5. Please produce all medical reports and records rendered by Plaintiff's treating and
examining physicians as a result of the incident alleged in the Complaint.Case No.: 2021 CA 000537 A
Request to Produce to Plaintiff
Page 2 of 4
6. Please produce an itemized copy of any and all bills, invoices, charges for items of
special damage claimed by Plaintiff, to be recoverable in the above styled cause, including:
(a) Hospitals;
(b) Physicians;
(c) Doctors, or other practitioners of the healing arts;
(d) —_ Nurses, registered or practical;
(e) Drugs and medications;
(f) Appliances incident to medical care;
(g) Ambulances and other modes of transportation related to medical
services; and
(h) Any other bills, statements, or costs, alleged to be chargeable as an item of
special damage in the above captioned case.
7. Photographs taken by you, your attorneys, investigators, agents, servants, or
employees which depict:
(a) Any of the injuries allegedly sustained by Plaintiff, NORMAN L.
CARTWRIGHT, III, as a result of the incident of October ‘6, 2017, as
particularized in Plaintiffs Complaint.
(b) The scene of the accident taken on the date of the accident or thereafter.
8. All medical records and reports received by you, your attorneys, investigators,
agents, servant or employees from hospitals, doctors, physicians, or other practitioners of the
healing arts who have examined and/or rendered treatment to Plaintiff, NORMAN L.
CARTWRIGHT, III, for injuries incurred as a result of the accident which is the subject matter of
this litigation.
9, All medical records and reports received by you, your attorneys, investigators,
agents, servants or employees from hospitals, doctors, physicians, or other practitioners of the
healing arts who have examined and/or rendered treatment regarding Plaintiff, NORMAN L.
CARTWRIGHT, III’s, physical or mental condition subsequent to the accident which is the subject
matter of this litigation, but not related to the subject accident.Case No.: 2021 CA 000537 A
Request to Produce to Plaintiff
Page 3 of 4
10. All medical records and reports received by you, your attorneys, investigators,
agents, servants or employees from hospitals, doctors, physicians, or other practitioners of the
healing arts who have examined and/or rendered treatment regarding Plaintiff, NORMAN L.
CARTWRIGHT, III’s, physical or mental condition prior to the accident which is the subject
matter of this litigation.
11. All statements, correspondence, depositions, or other written materials authored by
Defendant(s) or any of its agents or employees which are in your possession.
12. A recent photograph of Plaintiff, NORMAN L. CARTWRIGHT, III.
13. All non-medical expert reports or summaries in your possession pertaining to the
allegations in your complaint for individuals who are anticipated to testify at time of trial.
14. Please produce 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
automobile accident 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 other similar insurance benefits,Case No.: 2021 CA 000537 A
Request to Produce to Plaintiff
Page 4 of 4
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; and
(i) All payments made to you, or on your behalf, as a result of the
incident described in your Complaint, by or pursuant to, Workers
Compensation insurance.
15. A copy of any and all incident or accident report(s) related to the accident set forth
in the Complaint.
16. All documents of whatever nature you anticipate introducing at trial.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
via E-Portal to: Thomas D. Hippelheuser, Esquire, LAW OFFICES OF BRENT C. MILLER,
PA, 205 E. Burleigh Blvd. Tavares, FL 32778 (tom@bemillerlaw.com
METZGER LAW GROUP, P.A.
3018 W. Horatio St.
Tampa, FL 33609
(813) 288-2650
(813) 288-2670 Fax
Attorneys for the Defendant,
R. T. BROWN, INC., d/b/a BROWN
FUNERA HOME AND CREMATORY
‘
Ny
JOSEPH T. METZGER, ESQUIRE
Florida Bar No. 894478
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Filing # 134021747 E-Filed 09/03/2021 01:10:23 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR CITRUS COUNTY, FLORIDA CIVIL DIVISION NORMAN L., CARTWRIGHT, III, Plaintiff, v. CASENO.: 2021 CA 000537 A R. T. BROWN, INC., d/b/a BROWN FUNERAL HOME AND CREMATORY, and CITRUS MEMORIAL HOSPITAL, INC., Defendants. / DEFENDANT’S REQUEST TO PRODUCE TO PLAINTIFF Defendant, R. T. BROWN, INC., d/b/a BROWN FUNERAL HOME AND CREMATORY, by and through the undersigned attorneys, pursuant to Florida Rule of Civil Procedure 1.350 respectfully requests Plaintiff, NORMAN L. CARTWRIGHT, IIL, to produce for inspection and/or copying at the offices of the undersigned within thirty (30) days, the following: 1. A true copy of Plaintiff, NORMAN L. CARTWRIGHT, III’s, birth certificate. 2. A copy of Plaintiff, NORMAN L. CARTWRIGHT, II’s, driver’s license. 3, Please produce Income Tax Returns for the years 2016, 2017, 2018, 2019, and 2020. 4. The original of all drawings, charts, drafts, photographs, movies, tapes, film (to include first generation negative) of any matter relating to the subject matter of this lawsuit which are in the possession of you, your attorneys, investigators, agents, servants, employees, or to which you have access. 5. Please produce all medical reports and records rendered by Plaintiff's treating and examining physicians as a result of the incident alleged in the Complaint.Case No.: 2021 CA 000537 A Request to Produce to Plaintiff Page 2 of 4 6. Please produce an itemized copy of any and all bills, invoices, charges for items of special damage claimed by Plaintiff, to be recoverable in the above styled cause, including: (a) Hospitals; (b) Physicians; (c) Doctors, or other practitioners of the healing arts; (d) —_ Nurses, registered or practical; (e) Drugs and medications; (f) Appliances incident to medical care; (g) Ambulances and other modes of transportation related to medical services; and (h) Any other bills, statements, or costs, alleged to be chargeable as an item of special damage in the above captioned case. 7. Photographs taken by you, your attorneys, investigators, agents, servants, or employees which depict: (a) Any of the injuries allegedly sustained by Plaintiff, NORMAN L. CARTWRIGHT, III, as a result of the incident of October ‘6, 2017, as particularized in Plaintiffs Complaint. (b) The scene of the accident taken on the date of the accident or thereafter. 8. All medical records and reports received by you, your attorneys, investigators, agents, servant or employees from hospitals, doctors, physicians, or other practitioners of the healing arts who have examined and/or rendered treatment to Plaintiff, NORMAN L. CARTWRIGHT, III, for injuries incurred as a result of the accident which is the subject matter of this litigation. 9, All medical records and reports received by you, your attorneys, investigators, agents, servants or employees from hospitals, doctors, physicians, or other practitioners of the healing arts who have examined and/or rendered treatment regarding Plaintiff, NORMAN L. CARTWRIGHT, III’s, physical or mental condition subsequent to the accident which is the subject matter of this litigation, but not related to the subject accident.Case No.: 2021 CA 000537 A Request to Produce to Plaintiff Page 3 of 4 10. All medical records and reports received by you, your attorneys, investigators, agents, servants or employees from hospitals, doctors, physicians, or other practitioners of the healing arts who have examined and/or rendered treatment regarding Plaintiff, NORMAN L. CARTWRIGHT, III’s, physical or mental condition prior to the accident which is the subject matter of this litigation. 11. All statements, correspondence, depositions, or other written materials authored by Defendant(s) or any of its agents or employees which are in your possession. 12. A recent photograph of Plaintiff, NORMAN L. CARTWRIGHT, III. 13. All non-medical expert reports or summaries in your possession pertaining to the allegations in your complaint for individuals who are anticipated to testify at time of trial. 14. Please produce 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 automobile accident 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 other similar insurance benefits,Case No.: 2021 CA 000537 A Request to Produce to Plaintiff Page 4 of 4 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; and (i) All payments made to you, or on your behalf, as a result of the incident described in your Complaint, by or pursuant to, Workers Compensation insurance. 15. A copy of any and all incident or accident report(s) related to the accident set forth in the Complaint. 16. All documents of whatever nature you anticipate introducing at trial. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via E-Portal to: Thomas D. Hippelheuser, Esquire, LAW OFFICES OF BRENT C. MILLER, PA, 205 E. Burleigh Blvd. Tavares, FL 32778 (tom@bemillerlaw.com METZGER LAW GROUP, P.A. 3018 W. Horatio St. Tampa, FL 33609 (813) 288-2650 (813) 288-2670 Fax Attorneys for the Defendant, R. T. BROWN, INC., d/b/a BROWN FUNERA HOME AND CREMATORY ‘ Ny JOSEPH T. METZGER, ESQUIRE Florida Bar No. 894478