On July 08, 1985 a
was filed
involving a dispute between
Cortez Dominguez, Vivian,
and
Adventist Health System Sunbelt, Inc.,
Florida Hospital Medical Group, Inc.,
Omana, Juan Javier,
for CIRCUIT CIVIL
in the District Court of Osceola County.
Preview
Filing # 178405666 E-Filed 07/27/2023 04:39:47 PM
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT, IN AND
FOR OSCEOLA COUNTY, FLORIDA
CASE NO.: 2021-CA-001958 MP
VIVIAN CORTEZ DOMINGUEZ,
Plaintiff,
vs.
JUAN JAVIER OMANA, M.D., FLORIDA
HOSPITAL MEDICAL GROUP d/b/a
ADVENTHEALTH MEDICAL GROUP
GENERAL SURGERY AT KISSIMMEE and
ADVENTIST HEALTH SYSTEM/SUNBELT,
INC. d/b/a ADVENTHEALTH KISSIMMEE,
Defendants.
___________________________________/
DEFENDANT, FLORIDA HOSPITAL MEDICAL GROUP, INC. d/b/a ADVENTHEALTH
MEDICAL GROUP GENERAL SURGERY AT KISSIMMEE’S
REQUEST TO PRODUCE TO PLAINTIFF
Pursuant to Florida Rule of Civil Procedure 1.350, Defendant, FLORIDA
HOSPITAL MEDICAL GROUP, INC. d/b/a ADVENTHEALTH MEDICAL GROUP
GENERAL SURGERY AT KISSIMMEE, by and through the undersigned attorneys,
hereby requests that Plaintiff produce for inspection and copying within thirty days of the
date of service hereof each of the following documents:
1. Any documents concerning Plaintiff, VIVIAN CORTEZ DOMINGUEZ, that have
been sent to or received from:
a) The Social Security Administration;
b) The Department of Health and Human Services;
c) The Centers for Medicare and Medicaid Services (CMS);
d) CMS’ coordination of benefits contractor (COBS);
e) Any state or federal agency regarding Medicare benefits or Social
Security Disability Income (SSDI) payment.
2. Please produce all letters of protection and similar agreements that Plaintiff has
entered into with treating physicians and other healthcare providers that have
treated Plaintiff for the injuries described in the Complaint or claimed in this
case.
It is requested that the aforesaid production be made at the offices of Estes,
Ingram, Foels & Gibbs, P.A., 2600 Lake Lucien Drive, Suite 330, Maitland, FL 32751.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on July 27, 2023, the foregoing was filed with the Florida
Court Efiling Portal which will provide eservice to the following: PETE PLACENCIA, ESQ.
Law Offices of Pete Placencia, PL, 11329 Little Road, New Port Richey, FL 34654
efile@sunshinejustice.com.
s/CLAYTON M. WILLIAMS
CLAYTON M. WILLIAMS
Florida Bar No.: 092603
DINELIA A. CONCEPCION
Florida Bar No.: 104953
Primary Email: cmw@eifg-law.com
dac@eifg-law.com
Secondary Email: smh@eifg-law.com
da@eifg-law.com
cf@eifg-law.com
ESTES, INGRAM, FOELS & GIBBS, P.A.
2600 Lake Lucien Drive, Suite 330
Maitland, FL 32751
(407) 481-9449
Attorneys for JUAN J. OMANA, M.D.,
FLORIDA HOSPITAL MEDICAL GROUP, INC.
d/b/a ADVENTHEALTH MEDICAL GROUP
GENERAL SURGERY AT KISSIMMEE and
ADVENTIST HEALTH SYSTEM/SUNBELT,
INC. d/b/a ADVENTHEALTH KISSIMMEE
Document Filed Date
December 02, 2023
Case Filing Date
July 08, 1985
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing # 178405666 E-Filed 07/27/2023 04:39:47 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO.: 2021-CA-001958 MP VIVIAN CORTEZ DOMINGUEZ, Plaintiff, vs. JUAN JAVIER OMANA, M.D., FLORIDA HOSPITAL MEDICAL GROUP d/b/a ADVENTHEALTH MEDICAL GROUP GENERAL SURGERY AT KISSIMMEE and ADVENTIST HEALTH SYSTEM/SUNBELT, INC. d/b/a ADVENTHEALTH KISSIMMEE, Defendants. ___________________________________/ DEFENDANT, FLORIDA HOSPITAL MEDICAL GROUP, INC. d/b/a ADVENTHEALTH MEDICAL GROUP GENERAL SURGERY AT KISSIMMEE’S REQUEST TO PRODUCE TO PLAINTIFF Pursuant to Florida Rule of Civil Procedure 1.350, Defendant, FLORIDA HOSPITAL MEDICAL GROUP, INC. d/b/a ADVENTHEALTH MEDICAL GROUP GENERAL SURGERY AT KISSIMMEE, by and through the undersigned attorneys, hereby requests that Plaintiff produce for inspection and copying within thirty days of the date of service hereof each of the following documents: 1. Any documents concerning Plaintiff, VIVIAN CORTEZ DOMINGUEZ, that have been sent to or received from: a) The Social Security Administration; b) The Department of Health and Human Services; c) The Centers for Medicare and Medicaid Services (CMS); d) CMS’ coordination of benefits contractor (COBS); e) Any state or federal agency regarding Medicare benefits or Social Security Disability Income (SSDI) payment. 2. Please produce all letters of protection and similar agreements that Plaintiff has entered into with treating physicians and other healthcare providers that have treated Plaintiff for the injuries described in the Complaint or claimed in this case. It is requested that the aforesaid production be made at the offices of Estes, Ingram, Foels & Gibbs, P.A., 2600 Lake Lucien Drive, Suite 330, Maitland, FL 32751. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on July 27, 2023, the foregoing was filed with the Florida Court Efiling Portal which will provide eservice to the following: PETE PLACENCIA, ESQ. Law Offices of Pete Placencia, PL, 11329 Little Road, New Port Richey, FL 34654 efile@sunshinejustice.com. s/CLAYTON M. WILLIAMS CLAYTON M. WILLIAMS Florida Bar No.: 092603 DINELIA A. CONCEPCION Florida Bar No.: 104953 Primary Email: cmw@eifg-law.com dac@eifg-law.com Secondary Email: smh@eifg-law.com da@eifg-law.com cf@eifg-law.com ESTES, INGRAM, FOELS & GIBBS, P.A. 2600 Lake Lucien Drive, Suite 330 Maitland, FL 32751 (407) 481-9449 Attorneys for JUAN J. OMANA, M.D., FLORIDA HOSPITAL MEDICAL GROUP, INC. d/b/a ADVENTHEALTH MEDICAL GROUP GENERAL SURGERY AT KISSIMMEE and ADVENTIST HEALTH SYSTEM/SUNBELT, INC. d/b/a ADVENTHEALTH KISSIMMEE