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PLAINTIFFS RESPONSE TO DEFENDANT=S  REQUEST FOR PRODUCE- case 3

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

CASE NO:  XX

ALEXANDER WILLIAMS,

 

Plaintiff,

vs.

PATIO INC.

 

Defendants.

_______________________                        /

PLAINTIFFS RESPONSE TO DEFENDANT=S  REQUEST FOR PRODUCE

The Plaintiff, ALEXANDER WILLIAMS, by and through undersigned, files this Response to Defendant=s Request for Production dated XX, 20__.

  1. Copies of any and all medical reports and/or records from any and all medical health care provider, including physicians (including doctors of chiropractic medicine), hospitals, out-patient facilities, diagnostic testing facilities or providers, therapists or anyone else of the healing arts who has rendered treatment to or examined you subsequent to the herein accident/incident which is the subject matter of this lawsuit. (This would include both treating physicians as well as independent medical exams.)

XX

  1. Produce copies of Plaintiff’s Federal Income Tax Returns, including W-2 forms, for the years XX and any records reflecting your income thus far for the year XX or an authorization to obtain same from the Director of the Internal Revenue Service.

XX

  1. If you have made a claim for Social Security Disability or unemployment compensation benefits since the accident in question, produce any and all documents in your possession relative to the claim including all correspondence, applications, medical records sent in support of the application, etc.

XX

  1. A copy of your birth certificate and/or voter’s registration card.

XX

  1. A copy of your current driver’s license.

XX

  1. True copies of all bills and/or invoices relating to any other expenses that you claim you have incurred as a result of this accident/incident, including, but not limited to, property damage claim estimates, household assistance, out-of-pocket expenses, rental car bills, etc.

XX

 

  1. True copies of all reports, evaluations, recommendations and/or analysis submitted by any expert which relate to or cover the accident/incident which is the subject matter of this lawsuit and/or any injuries, damages or losses allegedly caused by the accident/incident.

XX

  1. True copies of any and all bills incurred as a result of evaluation, examination, consultation, treatment, testing or any other related services performed by any and all medical health providers, including but not limited to doctors (including chiropractors), hospitals, pharmacies, nurses, therapists and emergency/ambulance services, and any members of the healing arts and related fields, i.e., prosthetics, supports, etc., as a result of the injuries which you allegedly sustained in the subject accident.

XX

 

  1. True copies of any and all writings, recordings, memorandums, notes, depositions, and all other material reflecting statements made by the Defendant in this cause.

XX

  1. Laser color copies of all photographs reflecting any and all injuries you sustained as a result of the subject accident.

XX

  1. Laser color copies of all photographs of the scene of the incident as depicted on or about the date of the subject accident.

XX

  1. Copies of any and all records indicating collateral sources paid or payable to you or any assignee or paid on your behalf as a result of the accident which is the subject matter of this action. (collateral sources being those defined in Florida Statute 768.76).

XX

  1. Legible copies of all applications filled out by you, your attorney or any other representative, for Personal Injury/Protection benefits, and/or other insurance coverage which will pay for any of your damages and/or wages as alleged in your Complaint.

XX

  1. If claim is made for wage loss or loss of earning capacity, true copies of each and ever document, chart, paper, graph, employment record, payroll record, time sheets and/or other writings of any type evidencing each and every day or partial day you claim to have missed from work as a result of the accident/incident, which is the subject matter of this lawsuit.

XX

  1. Copies of any and all checks, PIP payout sheets and/or other writings that indicate the amount of money, if any, that you have received as reimbursement for lost wages, medical bills (or other bills) from your personal injury protection policy or any other collateral sources.

XX

  1. Copies of any and all reports, charts, graphs, or other writings from any vocational specialist, rehabilitative consultants and/or other experts that have assisted you or evaluated you with regard to damages claimed in this lawsuit.

XX

  1. Copies of all diagnostic test results, including, but not limited to, x-rays, CT scans, thermograms, MRI films, EMG, NCS, and other electrical studies that were performed as a result of the accident which is the subject-matter of this lawsuit.

 XX

  1. Copies of the front and back of any and all insurance identification cards, union employment identification cards which would depict the name, address, policy number, claim number, identification number of any insurance companies and/or employers which will provide you with any benefits to compensate you for any of the damages that you are alleging as a result of the accident/incident, which is the subject matter of this lawsuit.

XX

  1. If claim is made for wage loss or loss of earning capacity, legible copies of any and all statements, documents, correspondence, charts, or other writings of any type taken from Plaintiff’s employers and/or their agents pertaining to employment, wage loss, loss of future earning capacity or the loss of the ability to earn money in the future, which would support your allegations in the Complaint.

XX

  1. Copies of any and all “Mary Carter” Agreements, releases, or other documents and/or agreements of any type that have been endorsed by you and any other person and/or corporation, arising out of and related to the accident which is the subject matter of this Complaint.

XX

  1. Copies of any and all automobile, life, medical and health, or disability insurance policies covering you in this lawsuit that were in full force and effect on the date of the accident which is the subject matter of this lawsuit.

XX

  1. Copies of any documents relating to the following insurance policies that were in effect on the date of accident/incident and under which you were deemed an insured pursuant to policy language and/or state or federal law: automobile insurance, life insurance, income disability insurance and/or medical and health insurance.

XX

  1. Copies of any documents relating to your medical and health insurance policies and/or carriers within the past fifteen (15) years.

XX

  1. Copies of any and all medical reports and/or records from any and all medical health care provider, including physicians (including doctors of chiropractic medicine), hospitals, out-patient facilities, diagnostic/testing facilities or providers, therapists, or anyone else of the healing arts who has conducted any type of evaluation, examination, treatment or testing upon you, which occurred during the ten (10) years prior to the accident which is the subject matter of this lawsuit.

XX

 

  1. Copies of any and all medical reports and/or records from any and all medical health care provider, including physicians (including doctors of chiropractic medicine), hospitals, out-patient facilities, diagnostic testing facilities or providers, therapists, or anyone else of the healing arts who has conducted any type of calculation, examination, treatment or testing upon you, which occurred subsequent to the accident which is the subject matter of this lawsuit but involved services that were not related to the injuries that allegedly resulted from the subject accident.

XX

  1. Copies of all correspondence between you, your agents, servants and/or employees and Defendant, its agents, servants and/or employees.

XX

  1. Copies of any and all statements taken of any witnesses (written or recorded) as a result of the accident/incident which is the subject matter of this lawsuit.

XX

  1. Copies of any and all “Statements”, within the meaning and definitions in Rule 1.280 (b), Florida Rules of Civil Procedure, of the Defendant, the agents and employees of the Defendant.

XX

  1. Copies of all documentation evidencing that this accident was caused in whole or in part by others whom the Defendant had no dominion, custody or control.

 XX

 

CERTIFICATE OF SERVICE

IT IS HEREBY CERTIFIED that on this ____ day of XX, 20__, a true and correct copy of the foregoing was mailed to:  XX

 

LAW OFFICE OF ALAN D. SACKRIN

Attorney for Plaintiff(s)

2100 East Hallandale Beach Blvd.

Suite 200

Hallandale Beach, FL  33009

 

By______________________________

ALAN D. SACKRIN

Florida Bar No. 349070

 

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The pleading above is a sample document related to a specific set of facts and circumstances and should not be used or relied upon for any personal injury matter. This document is being provided for illustrative purposes only. We recommend and urge you to consult with an experienced personal injury lawyer for professional advice as each case is unique.

 

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