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Request for Production of Documents

IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA

CASE NO. 00xxxx (xx)

M.A. and R.A.,
                          Plaintiffs,
  v.

C.A.G.,
E.P.L. and
NATIONWIDE MUTUAL FIRE INSURANCE COMPANY,
Defendants.
________________________________/

REQUEST FOR PRODUCTION TO DEFENDANT, E.P.L.

The Plaintiffs, M.A. and R.A., request the Defendant, E.P.L., to produce, pursuant to Fla.R.Civ.P. 1.350 to the Law Office of Alan D. Sackrin, the following:

1. Photographs of the vehicle, or parts thereof, that Defendant, E.P.L., was operating at the time of the subject collision depicting the damage it sustained as a result of the subject collision.

2. Any statements of the Plaintiffs taken by or on behalf of the defendant or his insurer or reproductions of any recorded statements of the plaintiffs.

3. Statements of any witnesses taken by or on behalf of the defendant or his insurer or reproductions of any recorded statement of the plaintiffs.

4. Declaration sheet of each liability policy issued to E.P.L. in effect as of [date].

5. Copy of the certificate of title or registration for the vehicle Defendant, E.P.L., was driving which was involved in the subject motor vehicle accident.

IT IS HEREBY CERTIFIED that a true and correct copy of the foregoing has been served with the complaint herein.

LAW OFFICE OF ALAN D. SACKRIN
Attorney for Plaintiff(s)
2100 East Hallandale Beach Blvd.
Suite 200
Hallandale Beach, FL 33009
Telephone: (954) 455-0800
Facsimile: (954) 455-9649

By______________________________
   ALAN D. SACKRIN 
   Florida Bar No. 349070

  /kb



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