Preview
Filing # 131728027 E-Filed 07/30/2021 10:43:59 AM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT,
IN AND FOR OSCEOLA COUNTY, FLORIDA
XIAO SHENG YUE,
Plaintiff,
CASE NO.: 2020-CA-1106AN
v.
CYNTHIA M. FOERSTER AND
CHAPP, INC.,
Defendants.
/
DEFENDANTS, CYNTHIA M. FOERSTER AND CHAPP, INC.’S REQUEST FOR
UPDATED PRODUCTION TO PLAINTIFF
Defendants, CYNTHIA M. FOERSTER and CHAPP, INC., by and through undersigned
counsel and pursuant to Fla. R. Civ. P. 1.350, hereby request that Plaintiff produce for inspection
and/or copying the following documents, which shall be produced at the office of the undersigned
counsel within thirty (30) days from the date of service of this Request:
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.
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 Plaintiffs
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.
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 Plaintiffs
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.
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.
Legible copies of the above, furnished on or before the date fixed for production, if
accompanied by a Certificate of Compliance or similar document indicting that the copies
furnished are copies of all such documents available, will be deemed in compliance with this
request.
Defendants would show that they are unable to obtain the materials requested without
undue expense and hardship. The articles are in the sole or exclusive possession of the Plaintiff,
his agents or attorneys, and as such these items are necessary for the Defendant to properly
prepare this case for trial.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that, on this 30th day of July, 2021, I electronically filed the
foregoing with the Clerk of the Court via the Florida Courts’ e-Filing Portal, pursuant to and in
compliance with Rule 2.516, Florida Rules of Judicial Administration, which completes service
by furnishing a true and correct copy of the foregoing via electronic mail to all counsel of record.
LAW OFFICES OF SANTEIRO & GARRISON
/s/ Jorge Santeiro
Jorge Santeiro
FBN 66230
6300 University Parkway
Suite 101
Sarasota, FL 34240
Tel: (800) 226-3224, Ext. 1021
Primary: jsanteiro@fcci-group.com
Secondary: ssnuthS@icci-group.com
Secondary: legalservice@feci-group.com
Attorney for Defendants
Preview
Filing # 131728027 E-Filed 07/30/2021 10:43:59 AM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA XIAO SHENG YUE, Plaintiff, CASE NO.: 2020-CA-1106AN v. CYNTHIA M. FOERSTER AND CHAPP, INC., Defendants. / DEFENDANTS, CYNTHIA M. FOERSTER AND CHAPP, INC.’S REQUEST FOR UPDATED PRODUCTION TO PLAINTIFF Defendants, CYNTHIA M. FOERSTER and CHAPP, INC., by and through undersigned counsel and pursuant to Fla. R. Civ. P. 1.350, hereby request that Plaintiff produce for inspection and/or copying the following documents, which shall be produced at the office of the undersigned counsel within thirty (30) days from the date of service of this Request: 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. 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 Plaintiffs 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. 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 Plaintiffs 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. 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. Legible copies of the above, furnished on or before the date fixed for production, if accompanied by a Certificate of Compliance or similar document indicting that the copies furnished are copies of all such documents available, will be deemed in compliance with this request. Defendants would show that they are unable to obtain the materials requested without undue expense and hardship. The articles are in the sole or exclusive possession of the Plaintiff, his agents or attorneys, and as such these items are necessary for the Defendant to properly prepare this case for trial. CERTIFICATE OF SERVICE I HEREBY CERTIFY that, on this 30th day of July, 2021, I electronically filed the foregoing with the Clerk of the Court via the Florida Courts’ e-Filing Portal, pursuant to and in compliance with Rule 2.516, Florida Rules of Judicial Administration, which completes service by furnishing a true and correct copy of the foregoing via electronic mail to all counsel of record. LAW OFFICES OF SANTEIRO & GARRISON /s/ Jorge Santeiro Jorge Santeiro FBN 66230 6300 University Parkway Suite 101 Sarasota, FL 34240 Tel: (800) 226-3224, Ext. 1021 Primary: jsanteiro@fcci-group.com Secondary: ssnuthS@icci-group.com Secondary: legalservice@feci-group.com Attorney for Defendants