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Case Number: CACE-18-000492 Division: 05
Filing # 66237628 E-Filed 01/08/2018 02:44:16 PM
IN THE CIRCUIT COURT OF THE 17™
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.:
JAIME MURCIA, Individually and as Personal
Representative of the Estate of DIANA MURCIA,
Plaintiff,
Vv.
RAYFIELD FAMILY LITERACY, INC. d/b/a
RAYFIELD LITERACY CENTER,
Defendant.
PLAINTIFF’S FIRST REQUEST FOR PRODUCTION TO
DEFENDANT RAYFIELD FAMILY LITERACY, INC. d/b/a RAYFIELD LITERACY
CENTER
Plaintiff, JAIME MURCIA, Individually and as Personal Representative for the Estate of
DIANA MURCIA, pursuant to the Florida Rule of Civil Procedure 1.350, requests Defendant,
RAYFIELD FAMILY LITERACY, INC. d/b/a RAYFIELD LITERACY CENTER (“Defendant
RAYFIELD”), to produce for inspection and/or copying within forty-five (45) days after service
of this request, the following:
1 All contracts and/or agreements between Defendant RAYFIELD and DIANA
MURCIA and/or her guardians which were in effect at any time since December 2016.
22 All contracts and/or agreements between Defendant RAYFIELD and the State of
Florida which were in effect at any time since December 2016.
3 All indemnity agreements between the Defendant RAYFIELD and the State of
Florida, which were in effect at any time since December 2013.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 1/8/2018 2:44:14 PM.****
4 All original medical records, medical bills, correspondence, complete charts, student
file, patient file, or any other tangible data, metadata, or audit trails which pertains or relates in any
way to the care and treatment of DIANA MURCIA at Defendant RAYFIELD in December 2016.
5 Any and all rules, regulations, bylaws, policies, procedures, protocols or other
written documentation pertaining to Defendant RAYFIELD which were in effect at any time
during 2016. (An index to the policies and procedures may be provided from which a selection
can be made).
6 Any and all policies of insurance, including insurance declarations, which covers or
may cover Defendant RAYFIELD for the allegations set forth in Plaintiffs complaint. (Please
provide the entire policy not simply a declaration page).
7 Any and all rules, regulations, bylaws, policies, procedures, protocols or other written
documentation pertaining to dining procedures at Defendant RAYFIELD which were in effect at any
time during the year 2016. (An index to the policies and procedures may be provided from which a
selection can be made).
8 Any and all rules, regulations, bylaws, policies, procedures, protocols or other written
documentation pertaining to CPR or emergency response protocols or procedures at Defendant
RAYFIELD which were in effect at any time during the year 2016. (An index to the policies and
procedures may be provided from which a selection can be made).
9 Any and all rules, regulations, bylaws, policies, procedures, protocols or other written
documentation pertaining to CCTV or video surveillance at Defendant RAYFIELD which were in
effect at any time during the year 2016. (An index to the policies and procedures may be provided
from which a selection can be made).
10. Any and all rules, regulations, bylaws, policies, procedures, protocols or other written
documentation pertaining to supervision at Defendant RAYFIELD which were in effect at any time
during the year 2016. (An index to the policies and procedures may be provided from which a
selection can be made).
11. Any and all rules, regulations, bylaws, policies, procedures, protocols or other written
documentation pertaining to teacher to student ratio at Defendant RAYFIELD which were in effect
at any time during the year 2016. (An index to the policies and procedures may be provided from
which a selection can be made).
12. Any and all rules, regulations, bylaws, policies, procedures, protocols or other written
documentation pertaining to food or beverage consumption at Defendant RAYFIELD which were in
effect at any time during the year 2016. (An index to the policies and procedures may be provided
from which a selection can be made).
13. All rules, regulations, bylaws, policies, procedures, protocols or other written
documentation pertaining to communication in effect at Defendant RAYFIELD at any time during
the year 2016.
14. Any and all videos, CCTV surveillance and logbooks for the same for the day of
December 5, 2016 at Defendant RAYFIELD’s 2210 Pierce Street, Hollywood, Florida facility.
15. Any and all videos, CCTV surveillance and logbooks for the same that show the
incident on December 5, 2016 for which the Plaintiff's complaint alleges.
16. Any and all incident or accident reports that pertain to Diana Murcia for her entire
admission with Defendant RAYFIELD.
17. Any and all incident or accident reports written, recorded and or submitted for the
incident for which Plaintiff's complaint alleges.
18. Any and all recordings, interviews, or statements made for the incident for which
Plaintiff's complaint alleges.
19. Any and all reprimand, suspension, termination, or probation reports, letters, or
documents that were generated as a result of the incident for which Plaintiff's complaint alleges.
20. All rules, regulations, bylaws, policies, procedures, protocols or other written
documentation regarding, referring or relating to the chain of command at Defendant RAYFIELD
in effect at any time in 2016.
21. All duty rosters, schedules or other documents reflecting the names and addresses of
all employees, subcontractors, or independent contractors and other RAYFIELD personnel who
participated in the care, treatment, supervision or teaching of DIANA MURCIA in December 2016.
22. Any bills or statements for services rendered to or on behalf of DIANA MURCIA by
Defendant RAYFIELD in December 2016, together with all documentation reflecting payment of
such bills.
23. All tangible documents, records, appointment papers, applications, or any other
matters pertaining to DIANA MURCIA, which have not been produced pursuant to any of the
paragraphs contained herein.
24. All records of any meetings, discussions, and/or communications by or between
any Defendant RAYFIELD personnel, employees, agents, or someone else pertaining in any way
to the facts as described within Plaintiff's Complaint.
25. All recordings (audio, digital, or video), transcripts, notes, memos, agenda, outlines,
and/or minutes of any meeting held to discuss any of the events or facts described within Plaintiff's
Complaint.
DATED this 8th day of January, 2018.
RATZAN LAW GROUP
Attorneys for Plaintiff
1450 Brickell Avenue
Suite 2600
Miami, Florida 33131
Telephone: (305) 374-6366
By:/s/_Stuart N. Ratzan
Stuart N. Ratzan
Florida Bar No.: 911445
Stuarl@ratzanlawgroup.com
Stuart J. Weissman
Florida Bar No.: 57909
StuartW @ratzanlawgroup.com
Evan B. Gilead
Florida Bar No.: 95971
Evan(@ratzanlawgroup.com
Preview
Case Number: CACE-18-000492 Division: 05 Filing # 66237628 E-Filed 01/08/2018 02:44:16 PM IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: JAIME MURCIA, Individually and as Personal Representative of the Estate of DIANA MURCIA, Plaintiff, Vv. RAYFIELD FAMILY LITERACY, INC. d/b/a RAYFIELD LITERACY CENTER, Defendant. PLAINTIFF’S FIRST REQUEST FOR PRODUCTION TO DEFENDANT RAYFIELD FAMILY LITERACY, INC. d/b/a RAYFIELD LITERACY CENTER Plaintiff, JAIME MURCIA, Individually and as Personal Representative for the Estate of DIANA MURCIA, pursuant to the Florida Rule of Civil Procedure 1.350, requests Defendant, RAYFIELD FAMILY LITERACY, INC. d/b/a RAYFIELD LITERACY CENTER (“Defendant RAYFIELD”), to produce for inspection and/or copying within forty-five (45) days after service of this request, the following: 1 All contracts and/or agreements between Defendant RAYFIELD and DIANA MURCIA and/or her guardians which were in effect at any time since December 2016. 22 All contracts and/or agreements between Defendant RAYFIELD and the State of Florida which were in effect at any time since December 2016. 3 All indemnity agreements between the Defendant RAYFIELD and the State of Florida, which were in effect at any time since December 2013. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 1/8/2018 2:44:14 PM.**** 4 All original medical records, medical bills, correspondence, complete charts, student file, patient file, or any other tangible data, metadata, or audit trails which pertains or relates in any way to the care and treatment of DIANA MURCIA at Defendant RAYFIELD in December 2016. 5 Any and all rules, regulations, bylaws, policies, procedures, protocols or other written documentation pertaining to Defendant RAYFIELD which were in effect at any time during 2016. (An index to the policies and procedures may be provided from which a selection can be made). 6 Any and all policies of insurance, including insurance declarations, which covers or may cover Defendant RAYFIELD for the allegations set forth in Plaintiffs complaint. (Please provide the entire policy not simply a declaration page). 7 Any and all rules, regulations, bylaws, policies, procedures, protocols or other written documentation pertaining to dining procedures at Defendant RAYFIELD which were in effect at any time during the year 2016. (An index to the policies and procedures may be provided from which a selection can be made). 8 Any and all rules, regulations, bylaws, policies, procedures, protocols or other written documentation pertaining to CPR or emergency response protocols or procedures at Defendant RAYFIELD which were in effect at any time during the year 2016. (An index to the policies and procedures may be provided from which a selection can be made). 9 Any and all rules, regulations, bylaws, policies, procedures, protocols or other written documentation pertaining to CCTV or video surveillance at Defendant RAYFIELD which were in effect at any time during the year 2016. (An index to the policies and procedures may be provided from which a selection can be made). 10. Any and all rules, regulations, bylaws, policies, procedures, protocols or other written documentation pertaining to supervision at Defendant RAYFIELD which were in effect at any time during the year 2016. (An index to the policies and procedures may be provided from which a selection can be made). 11. Any and all rules, regulations, bylaws, policies, procedures, protocols or other written documentation pertaining to teacher to student ratio at Defendant RAYFIELD which were in effect at any time during the year 2016. (An index to the policies and procedures may be provided from which a selection can be made). 12. Any and all rules, regulations, bylaws, policies, procedures, protocols or other written documentation pertaining to food or beverage consumption at Defendant RAYFIELD which were in effect at any time during the year 2016. (An index to the policies and procedures may be provided from which a selection can be made). 13. All rules, regulations, bylaws, policies, procedures, protocols or other written documentation pertaining to communication in effect at Defendant RAYFIELD at any time during the year 2016. 14. Any and all videos, CCTV surveillance and logbooks for the same for the day of December 5, 2016 at Defendant RAYFIELD’s 2210 Pierce Street, Hollywood, Florida facility. 15. Any and all videos, CCTV surveillance and logbooks for the same that show the incident on December 5, 2016 for which the Plaintiff's complaint alleges. 16. Any and all incident or accident reports that pertain to Diana Murcia for her entire admission with Defendant RAYFIELD. 17. Any and all incident or accident reports written, recorded and or submitted for the incident for which Plaintiff's complaint alleges. 18. Any and all recordings, interviews, or statements made for the incident for which Plaintiff's complaint alleges. 19. Any and all reprimand, suspension, termination, or probation reports, letters, or documents that were generated as a result of the incident for which Plaintiff's complaint alleges. 20. All rules, regulations, bylaws, policies, procedures, protocols or other written documentation regarding, referring or relating to the chain of command at Defendant RAYFIELD in effect at any time in 2016. 21. All duty rosters, schedules or other documents reflecting the names and addresses of all employees, subcontractors, or independent contractors and other RAYFIELD personnel who participated in the care, treatment, supervision or teaching of DIANA MURCIA in December 2016. 22. Any bills or statements for services rendered to or on behalf of DIANA MURCIA by Defendant RAYFIELD in December 2016, together with all documentation reflecting payment of such bills. 23. All tangible documents, records, appointment papers, applications, or any other matters pertaining to DIANA MURCIA, which have not been produced pursuant to any of the paragraphs contained herein. 24. All records of any meetings, discussions, and/or communications by or between any Defendant RAYFIELD personnel, employees, agents, or someone else pertaining in any way to the facts as described within Plaintiff's Complaint. 25. All recordings (audio, digital, or video), transcripts, notes, memos, agenda, outlines, and/or minutes of any meeting held to discuss any of the events or facts described within Plaintiff's Complaint. DATED this 8th day of January, 2018. RATZAN LAW GROUP Attorneys for Plaintiff 1450 Brickell Avenue Suite 2600 Miami, Florida 33131 Telephone: (305) 374-6366 By:/s/_Stuart N. Ratzan Stuart N. Ratzan Florida Bar No.: 911445 Stuarl@ratzanlawgroup.com Stuart J. Weissman Florida Bar No.: 57909 StuartW @ratzanlawgroup.com Evan B. Gilead Florida Bar No.: 95971 Evan(@ratzanlawgroup.com