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PLAINTIFF=S RESPONSE TO DEFENDANT=S REQUEST TO PRODUCE – case 5

PLAINTIFF=S RESPONSE TO DEFENDANT=S REQUEST TO PRODUCE

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

CASE NO. XX

ROBERT JONES,

 

Plaintiff,

vs.

 

AMUSEMENT PARKS, LLC.,

 

Defendant.

_______________________________________/

PLAINTIFF=S RESPONSE TO DEFENDANT=S REQUEST TO PRODUCE

The Plaintiff, ROBERT JONES, through undersigned counsel, responds to Defendant=s, AMUSEMENT PARKS, LLC., Request to Produce, dated XX, 20__, as follows:

 

  1. i) Copies of federal income tax returns, including W-2 withholding statements, and any other business records and income records and any other evidence of income for five (5) years before the incident alleged in this cause, and all years since that time, together with evidence of income to the current date.

XX

  1. ii) All evidence of income earned in the last five years, including but not limited to, the present year.

XX

iii)       All medical or related bills, paid or owing, and other documentation, including receipts, cancelled checks or similar documents related to any treatment or examination resulting from the incident herein.

XX

  1. iv) All bills, statements, invoices or similar documents representing other claims of special damages claimed by you in this cause.

XX

  1. v) Copies of any and all PIP drafts, worker compensation payments or other documentation, as well as any and all copies of payments or other documentation made by collateral sources, reflecting benefits paid on behalf of plaintiff for medical treatment, lost wages and/or property damage.

 

XX

 

  1. vi) Any and all hospital, clinic emergency room records, x-rays, tomography studies, medical reports, doctors’ reports, and reports rendered by experts applicable to any and all issues in this cause.

 

XX

 

vii)      Any and all medical reports, records and bills from any doctor or hospital, incurred by plaintiff for any injury sustained in subsequent accidents to the accident claimed herein.

XX

  1. Any and all medical reports, records and bills from any doctor or hospital, incurred by plaintiff for any injury sustained in previous accidents to the accident claimed herein.

XX

  1. Any and all written or recorded statements taken from parties or witnesses, lay or expert, concerning any issue in this cause.

XX

  1. Any and all photographs, films, slides, graphs, charts, and other documentary evidence of the scene, parties or other property involved in or pertaining to the subject accident, occurrence or issues in this cause.

XX

  1. Any and all diagrams, charts, maps or descriptions of the accident scene involved in this accident.

XX

  1. Any and all insurance policies providing benefits or coverage to the plaintiff or any claimed injury or damage and the claim forms and records related to same from the subject accident or occurrence.

XX

  1. Any and all releases, settlement agreements, “Mary Carter” agreements between the plaintiff and any other parties or their insurers, as well as any and all oral covenants or agreements of any sort whatsoever with respect to any issue in this cause.

XX

  1. A written summary of all oral “Mary Carter” agreements between the plaintiff and any other parties or their insurers, as well as any and all oral covenants or agreements of any sort whatsoever with respect to any issues in this cause.

XX

  1. All records or files pertaining to any claims made by the plaintiff against any other party or their insurers on account of any other accident or occurrence whether prior or subsequent to the subject cause.

XX

  1. Execution of the social security release form attached hereto.

XX

  1. Execution of the 8821 form attached hereto.

XX

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy has been mailed and/or faxed this _____ day of XX, 20__ to: XX

LAW OFFICE OF ALAN D. SACKRIN

Attorney for Plaintiff

2100 East Hallandale Beach Blvd. /Ste 200

Hallandale Beach, FL  33009

 

By:                                                             

ALAN D. SACKRIN

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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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