REQUEST TO PRODUCE
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO. XX
AMUSEMENT PARKS, LLC.,
REQUEST TO PRODUCE
The Defendant, AMUSEMENT PARKS, LLC., by and through its undersigned counsel and respectfully requests the Plaintiff, ROBERT JONES, pursuant to Florida Rules of Civil Procedure, Rule 1.350, to produce the following for inspection and/or copying IN OUR OFFICE OR AN OTHERWISE DESIGNATED PLACE, within thirty-five (35) days from the date of this Request.
SCHEDULE “A” – – DEFINITIONS AND INSTRUCTIONS
The term “documents” refers to any written, recorded or other reproducible manifestation of communication of language, including but not limited to, the particular items listed: correspondence, letters, contracts, advertisements, agreements, appointment records, audio records, transcriptions of audio recordings, balance sheets, bills, bills of lading, blanks, books, books of account, by-laws, cablegrams, certificates, charters, charts, checks, communications, computer programs, computer printouts, computer readouts, computer tapes, dada compilation which can be translated through detection devices, delivery records, entries, estimates, expense reports, field notes, film, financial analysis, financial statements, forms graphs handbooks, income statements, indices, instruments, intra office and inter office communications and memoranda, invoices, itemizations, journals, licenses, manuals, maps, meeting records, memoranda of all conversations, including telephone calls, minutes, notes, order forms, orders, opinions, patents, patent applications, payroll records, permits, photocopies, photographs, planographs, plans, press releases, proofs, prospectus, publications, receipts, recordings, records, records of account, reports, requisitions, resolutions, sketches, specifications, statements, statistical records, studies, summaries, systems analysis, tapes, telegrams, tests, time records, training manuals, transcripts, evaluations, video recordings, warehouse receipts, writings or work papers and all non-identical copies thereof which are in the possession, custody or control of the plaintiff, her attorneys, or representatives, or any other person or entity action principally on the behalf of the Plaintiff.
The term “correspondence” refers to any “documents” as that term is defined above, that have been exchanged from one person or entity to another person or entity or which were intended to be exchanged or repaired in order to be so communicated from one person or entity to another, whether or not such correspondence was actually exchanged, mailed or posted.
SCHEDULE “B” – – REQUESTED DOCUMENTS
- 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.
- ii) All evidence of income earned in the last five years, including but not limited to, the present year.
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.
- iv) All bills, statements, invoices or similar documents representing other claims of special damages claimed by you in this cause.
- 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.
- 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.
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.
- 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.
- Any and all written or recorded statements taken from parties or witnesses, lay or expert, concerning any issue in this cause.
- 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.
- Any and all diagrams, charts, maps or descriptions of the accident scene involved in this accident.
- 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.
- 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.
- 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.
- 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.
- Execution of the social security release form attached hereto.
- Execution of the 8821 form attached hereto.
Counsel for Defendent
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the Request to Produce was sent via U.S. Mail on this ____ day of XX, 20__ to: Alan D. Sackrin, Esq., 2100 E. Hallandale Beach Blvd.., S-200, Hallandale Beach, FL 33009.
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