Filing # 170093893 E-Filed 03/31/2023 12:44:52 PM
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`IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
`IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
`CIRCUIT CIVIL
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`MEIBEL SABOYA DIAZ,
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`PLAINTIFF,
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` Case No: 2023 CA 000499
`VS.
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`SEAWORLD PARKS &
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`ENTERTAINMENT
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`LLC D/B/A BUSCH GARDENS,
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`DEFENDANT.
`___________________________________________/
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`NOTICE OF SERVING PLAINTIFF’S
`REQUEST FOR PRODUCTION TO DEFENDANT
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`Plaintiff, by and through the undersigned attorney, and pursuant to F.R.C.P. 1.350, hereby
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`gives notice of serving Plaintiff’s Request for Production upon the Defendant(s), numbered 1
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`through 16, to be answered within the deadlines listed within the Florida Rules of Civil Procedure,
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`and as required by law.
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`[Certificate of Service on Next Page]
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`IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
`IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
`CIRCUIT CIVIL
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`MEIBEL SABOYA DIAZ,
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`PLAINTIFF,
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` Case No: 2023 CA 000499
`VS.
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`SEAWORLD PARKS &
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`ENTERTAINMENT
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`LLC D/B/A BUSCH GARDENS,
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`DEFENDANT.
`___________________________________________/
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`NOTICE OF SERVING PLAINTIFF’S
`REQUEST FOR PRODUCTION TO DEFENDANT
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`Plaintiff, by and through the undersigned attorney, and pursuant to F.R.C.P. 1.350, hereby
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`gives notice of serving Plaintiff’s Request for Production upon the Defendant(s), numbered 1
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`through 16, to be answered within the deadlines listed within the Florida Rules of Civil Procedure,
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`and as required by law.
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`[Certificate of Service on Next Page]
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`CERTIFICATE OF SERVICE
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`I HEREBY CERTIFY that a true and correct copy of the foregoing document has been
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`furnished by Electronic Mail in accordance with Fla. R. Jud. Admin. 2.516, or in accordance with
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`the relevant applicable Florida Rule of Civil Procedure, to the referenced party on the date below,
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`and at the following designated email service address(es):
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`ROBERT L. BLANK, B.C.S.
`CARIE L. HALL, ESQUIRE
`RYAN S. BROWN, ESQUIRE
`RUMBERGER, KIRK & CALDWELL, P.A.
`100 North Tampa Street, Suite 2000
`Post Office Box 3390
`Tampa, Florida 33601-3390
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`rblanksecy@rumberger.com
`docketingtpa@rumberger.com
`chall@rumberger.com
`challsecy@rumberger.com
`rbrown@rumberger.com
`rbrownsecy@rumberger.com
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`Dated March 31, 2023.
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`__________________________________
`Amy K. Kenyon, Esq.
`Florida Bar No.: 73526
`Kenyon Law Group, P.L.L.C.
`1215 Manatee Avenue West, Ste. 105
`Bradenton, Florida, 34205
`(941) 894-1234 phone
`(941) 882-6225 fax
`E-serve: eservice@kenyonlawfirm.com
`Attorney for PL Meibel E. Saboya Diaz
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`IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
`IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
`CIRCUIT CIVIL
`
`
`MEIBEL SABOYA DIAZ,
`
`PLAINTIFF,
`
`
` Case No: 2023 CA 000499
`VS.
`
`
`
`
`
`
`
`
`
`SEAWORLD PARKS &
`
`ENTERTAINMENT
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`LLC D/B/A BUSCH GARDENS,
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`
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`DEFENDANT.
`___________________________________________/
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`PLAINTIFF’S REQUEST FOR PRODUCTION TO DEFENDANT
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`Plaintiff, pursuant to Fla. R. Civ. P. 1.350, hereby requests the Defendant, SEAWORLD
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`PARKS & ENTERTAINMENT LLC, D/B/A BUSCH GARDENS, to produce the following
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`items at the law office of the Kenyon Law Group, PLLC, within the time period designated by
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`the rules:
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`1. Any and all statements of the Plaintiff taken and or in the possession of the defendant.
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`2. Any and all photographs, films, movies, video-tapes or other pictures of the Plaintiff,
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`the injury scene and the subject premises (on the walkway near the SkeiKra ride) at Defendant’s
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`premises on November 2, 2019 and any date thereafter.
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`3. Any and all insurance policies (in full and certified under oath in accordance with the
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`law) that may provide coverage to you for the facts and circumstances alleged in the complaint.
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`This request includes but is not limited to any and all addenda, riders, amendments, conditions
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`thereto, as well as any and all declaration sheets or pages.
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`4. Any and all written or recorded statements made by any witness, defendant, and
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`employee or agent of Defendant, in reference to the subject incident or in reference to the injuries
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`received as a result of the subject incident.
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`5. Any and all contracts between the defendants and any company or person responsible
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`for operating, securing or maintaining a slip resistant surface for defendant near the SkeiKra ride
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`where Plaintiff is alleged to have fallen, as such contracts existed between November 2, 2017 and
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`November 2, 2019.
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`6. Copies of any and all lawsuits filed against you for alleged personal injuries or
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`negligence specifically relating to the Plaintiff falling on the walkway near the SkeiKra ride.
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`7. Any and all incident reports, photographs, video tapes, audio tapes, diagrams,
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`illustrations, reproductions, witness statements, memoranda, forms, notes, correspondence, and
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`any and all other documents which describe, refer to or depict any person and or Plaintiff falling
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`on the walkway near the SkeiKra ride, and which occurred within three years before the subject
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`incident and through the present date as of the time Defendant responds to this request.
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`8. Any and all records, logs, diaries, calendars, work orders, invoices, receipts and any and
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`all other documents which describe or refer to any cleaning or maintenance to the walkway near
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`the SheiKra ride, in or around the area where the Plaintiff fell, and which were generated or
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`received at any time within three years before the subject incident and to the present date.
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`9. Any and all manuals, employee handbooks, brochures, training videos, and literature
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`which describes or refers to rules, regulations, or policies of the Defendant in regard to Defendant
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`or its agents cleaning or maintaining the walkway near the SheiKra ride, in or around the area
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`where the Plaintiff fell, from three years before the subject incident to the present date.
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`10. Any and all documents, including but not limited to invoices, work orders, purchase
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`orders, payment records, check stubs, cancelled checks, and agreements, which relate or refer to
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`any maintenance, repair, modification or reconstruction which occurred at any time within the last
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`three years to the walkway near the SheiKra ride, in or around the area where the Plaintiff fell.
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`11. Any and all memos or notices distributed to employees at any time in the last four years
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`regarding cleaning and maintaining the walkway near the SheiKra ride, in or around the area where
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`the Plaintiff fell.
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` 12. Any and all time cards, payroll records, employee rosters, and other records which
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`show, indicate or refer to the names, addresses, and titles of employees who were in or near the
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`area of the incident on or about the time of the subject incident.
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` 13. Any and all correspondence generated by or received from the liability insurance
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`company or the insurance agent for the Defendant in reference to coverage or coverage dispute in
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`reference to the subject incident.
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`14. Any and all notices, forms, citations, letters, and any and all other writings received
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`from or sent to any local, state, or federal officials, agencies, administration or department
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`generated at any time from five (5) years ago through the date on which these documents are
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`produced, and which relate directly or indirectly to the Defendant’s or it agents cleaning,
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`maintenance, repair or safety of the walkway near the SheiKra ride, in or around the area where
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`the Plaintiff fell. The agencies, administrations or departments referred to in this request include
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`but are not limited to the OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION
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`(OSHA), and The United States Public Health Service (U.S.P.H.S.).
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`15. Copies of all claim files maintained by you in the ordinary course of business for the
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`subject
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`incident,
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`including any and all
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`incident reports,
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`internal memoranda, and/or
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`correspondence concerning the subject incident.
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`16. Copies of any and all incident reports, internal memorandum and correspondence
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`concerning similar incidents that have occurred on the Defendant's premises in the past two years.
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