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Filing # 141012515 E-Filed 12/28/2021 12:26:01 PM
IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT
IN AND FOR CITRUS COUNTY, FLORIDA.
CIVIL DIVISION
NORMAN L. CARTWRIGHT, IL,
Plaintiff,
v. CASE NO.: — 2021 CA 000537 A
R. T. BROWN, INC., d/b/a BROWN
FUNERAL HOME AND CREMATORY,
and CITRUS MEMORIAL HOSPITAL,
INC.,
Defendants.
DEFENDANT, R. T. BROWN, INC.’S, SUPPLEMENTAL
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, II], to produce for
inspection and/or copying at the offices of the undersigned within thirty (30) days, the following:
1. Deposition of Plaintiff, NORMAN L. CARTWRIGHT, III, taken October 20, 2020
and filed May 27, 2021 in Plaintiffs Worker’s Compensation Case, OJICC Case
Number 19-015831MAM.
2. Deposition of Dr. James Ronzo taken December 10, 2020 and filed May 27, 2021
in Plaintiff's Worker’s Compensation Case, OJCC Case Number 19-015831MAM.
3. Deposition of Dr. Amy Clunn taken December 18, 2020 and filed May 27, 2021 in
Plaintiff's Worker’s Compensation Case, OJCC Case Number 19-015831MAM.
4, Deposition of Dr. Robert Ulseth taken October 19, 2020 and filed May 27, 2021 in
Plaintiff's Worker’s Compensation Case, OJCC Case Number 19-015831MAM.
5. Deposition of Dr. Toumbis, filed October 27, 2020 in Plaintiffs Worker’s
Compensation Case, OJCC Case Number 19-01583 1MAM.
6. Deposition of Andrew Brown, filed November 26, 2019 in Plaintiffs Worker’s
Compensation Case, OJCC Case Number 19-01583 IMAM.
7. IME report by Dr. Clinton Davis dated 10/21/2020, filed May 27, 2021 in Plaintiff's
Worker’s Compensation Case, OJCC Case Number 19-015831MAM.
8. Plaintiff, NORMAN L. CARTWRIGHT, IIl’s, Worker’s Compensation Settlement
Agreement.Case No.: 2021 CA 000537 A
Defendant, R. T. Brown, Inc.’s
Request to Produce to Plaintiff
Page 2 of 2
9. Incident Report for subject incident of October 6, 2017. Plaintiff testified at his
deposition of December 8, 2021 that he received a copy of the Incident Report from
GA4S Secure Solutions Supervisor Rodney Bloomer.
10. Any and all depositions, sworn statements, recorded statements and transcribed
statements of Plaintiff, NORMAN L. CARTWRIGHT, II, in the possession of
Plaintiff or his attorneys.
CERTIFICATE OF SERVICE
1 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,
205 Burleigh Blvd. Tavares, FL 32778 te
m) and Joseph F. Kinman, Esquire,
A, KINMAN & BOCCHINO, 1706 E 11%
om), on this 2%" day of December, 2021.
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
FUNERAL HOME AND CREMATORY
JOSEPH T. METZGER, ESQUIRE
Florida Bar No. 894478
ERIN S. KUENZEL, ESQUIRE
Florida Bar No. 103167
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Filing # 141012515 E-Filed 12/28/2021 12:26:01 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR CITRUS COUNTY, FLORIDA. CIVIL DIVISION NORMAN L. CARTWRIGHT, IL, Plaintiff, v. CASE NO.: — 2021 CA 000537 A R. T. BROWN, INC., d/b/a BROWN FUNERAL HOME AND CREMATORY, and CITRUS MEMORIAL HOSPITAL, INC., Defendants. DEFENDANT, R. T. BROWN, INC.’S, SUPPLEMENTAL 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, II], to produce for inspection and/or copying at the offices of the undersigned within thirty (30) days, the following: 1. Deposition of Plaintiff, NORMAN L. CARTWRIGHT, III, taken October 20, 2020 and filed May 27, 2021 in Plaintiffs Worker’s Compensation Case, OJICC Case Number 19-015831MAM. 2. Deposition of Dr. James Ronzo taken December 10, 2020 and filed May 27, 2021 in Plaintiff's Worker’s Compensation Case, OJCC Case Number 19-015831MAM. 3. Deposition of Dr. Amy Clunn taken December 18, 2020 and filed May 27, 2021 in Plaintiff's Worker’s Compensation Case, OJCC Case Number 19-015831MAM. 4, Deposition of Dr. Robert Ulseth taken October 19, 2020 and filed May 27, 2021 in Plaintiff's Worker’s Compensation Case, OJCC Case Number 19-015831MAM. 5. Deposition of Dr. Toumbis, filed October 27, 2020 in Plaintiffs Worker’s Compensation Case, OJCC Case Number 19-01583 1MAM. 6. Deposition of Andrew Brown, filed November 26, 2019 in Plaintiffs Worker’s Compensation Case, OJCC Case Number 19-01583 IMAM. 7. IME report by Dr. Clinton Davis dated 10/21/2020, filed May 27, 2021 in Plaintiff's Worker’s Compensation Case, OJCC Case Number 19-015831MAM. 8. Plaintiff, NORMAN L. CARTWRIGHT, IIl’s, Worker’s Compensation Settlement Agreement.Case No.: 2021 CA 000537 A Defendant, R. T. Brown, Inc.’s Request to Produce to Plaintiff Page 2 of 2 9. Incident Report for subject incident of October 6, 2017. Plaintiff testified at his deposition of December 8, 2021 that he received a copy of the Incident Report from GA4S Secure Solutions Supervisor Rodney Bloomer. 10. Any and all depositions, sworn statements, recorded statements and transcribed statements of Plaintiff, NORMAN L. CARTWRIGHT, II, in the possession of Plaintiff or his attorneys. CERTIFICATE OF SERVICE 1 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, 205 Burleigh Blvd. Tavares, FL 32778 te m) and Joseph F. Kinman, Esquire, A, KINMAN & BOCCHINO, 1706 E 11% om), on this 2%" day of December, 2021. 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 FUNERAL HOME AND CREMATORY JOSEPH T. METZGER, ESQUIRE Florida Bar No. 894478 ERIN S. KUENZEL, ESQUIRE Florida Bar No. 103167