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Filing # 157400828 E-Filed 09/14/2022 01:57:43 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY, FLORIDA
CASE NO: 2020 CA 001106 AN
HON. MARGARET H. SCHREIBER
XIAO SHENG YUE,
Plaintiff,
vs.
CYNTHIA M FOERSTER AND
CHAPP, INC.,
Defendants. /
PLAINTIFF'S RESPONSE TO DEFENDANT'S REQUEST FOR PRODUCTION
COMES NOW the Plaintiff, XIAO SHENG YUE, by and through the undersigned attorneys,
and in response to the Defendants', CYNTHIA M FOERSTER AND CHAPP, INC., Request For
Production served on or about February 17, 2022, and states as follows:
1. Copies of all doctor, hospital, therapy, nursing and other medical bills or other
expenses, including costs of prescriptions, incurred because of the incident described in the
Complaint, since the date of last production.
RESPONSE: Attached.
2. Copies of all medical records, hospital records, chiropractic records, osteopathic records,
faith healer’s records, X-Ray reports, MRI Scan reports, CT-Scan reports, nurses notes, physical
therapy records, and any other non-privileged medical information in Plaintiff’s possession,
including copies of any radiographic materials such as X-Ray films, CT Films, MRI Films, etc., for
treatment of Plaintiff for any injuries sustained because of the incident described in the Complaint,
since the date of last production.
RESPONSE: Attached.
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3. Copies of all medical records, hospital records, chiropractic records, osteopathic
records, faith healer’s records, X-Ray reports, MRI Scan reports, CT-Scan reports, nurses notes,
physical therapy records, and any other non-privileged medical information in Plaintiff’s
possession, including copies of any radiographic materials such as X-Ray films, CT Films, MRI
Films, etc., for treatment of Plaintiff for any reason since the incident described in the Complaint,
since the date of last production.
RESPONSE: None in Plaintiff’s possession.
4. Copies of all bills, statements and receipts relating to any non-medical expenses
claimed as damages in this lawsuit which have not been produced in response to the preceding
paragraphs, since the date of last production.
RESPONSE: None.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on September 14, 2022, I electronically filed the foregoing with
the Clerk of the Courts by using the Florida Courts eFiling Portal which will forward a copy to:
Jorge Santeiro, Jr., Esquire, Law Offices of Santeiro & Garrison, 6300 University Parkway, Ste
101, Sarasota, FL 34240, via email at jsanteiro@fcci-group.com; ssmith5@fcci-group.com;
legalservice@fcci-group.com.
/s/ Manuel Stefan, Esq.
Manuel “Manny” Stefan, Esq.
Florida Bar No.: 0103389
MORGAN & MORGAN, P.A.
4495 South Semoran Blvd.
Orlando, FL 32822
Telephone No.: (407) 452-6982
Facsimile No.: (407) 572-0124
Primary email: MStefan@forthepeople.com
Secondary email: cvictor@forthepeople.com
Attorney for Plaintiff
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Filing # 157400828 E-Filed 09/14/2022 01:57:43 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO: 2020 CA 001106 AN HON. MARGARET H. SCHREIBER XIAO SHENG YUE, Plaintiff, vs. CYNTHIA M FOERSTER AND CHAPP, INC., Defendants. / PLAINTIFF'S RESPONSE TO DEFENDANT'S REQUEST FOR PRODUCTION COMES NOW the Plaintiff, XIAO SHENG YUE, by and through the undersigned attorneys, and in response to the Defendants', CYNTHIA M FOERSTER AND CHAPP, INC., Request For Production served on or about February 17, 2022, and states as follows: 1. Copies of all doctor, hospital, therapy, nursing and other medical bills or other expenses, including costs of prescriptions, incurred because of the incident described in the Complaint, since the date of last production. RESPONSE: Attached. 2. Copies of all medical records, hospital records, chiropractic records, osteopathic records, faith healer’s records, X-Ray reports, MRI Scan reports, CT-Scan reports, nurses notes, physical therapy records, and any other non-privileged medical information in Plaintiff’s possession, including copies of any radiographic materials such as X-Ray films, CT Films, MRI Films, etc., for treatment of Plaintiff for any injuries sustained because of the incident described in the Complaint, since the date of last production. RESPONSE: Attached. 1 3. Copies of all medical records, hospital records, chiropractic records, osteopathic records, faith healer’s records, X-Ray reports, MRI Scan reports, CT-Scan reports, nurses notes, physical therapy records, and any other non-privileged medical information in Plaintiff’s possession, including copies of any radiographic materials such as X-Ray films, CT Films, MRI Films, etc., for treatment of Plaintiff for any reason since the incident described in the Complaint, since the date of last production. RESPONSE: None in Plaintiff’s possession. 4. Copies of all bills, statements and receipts relating to any non-medical expenses claimed as damages in this lawsuit which have not been produced in response to the preceding paragraphs, since the date of last production. RESPONSE: None. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on September 14, 2022, I electronically filed the foregoing with the Clerk of the Courts by using the Florida Courts eFiling Portal which will forward a copy to: Jorge Santeiro, Jr., Esquire, Law Offices of Santeiro & Garrison, 6300 University Parkway, Ste 101, Sarasota, FL 34240, via email at jsanteiro@fcci-group.com; ssmith5@fcci-group.com; legalservice@fcci-group.com. /s/ Manuel Stefan, Esq. Manuel “Manny” Stefan, Esq. Florida Bar No.: 0103389 MORGAN & MORGAN, P.A. 4495 South Semoran Blvd. Orlando, FL 32822 Telephone No.: (407) 452-6982 Facsimile No.: (407) 572-0124 Primary email: MStefan@forthepeople.com Secondary email: cvictor@forthepeople.com Attorney for Plaintiff 2