Party Discovery: Karen Jameison Plaintiff vs. Family Dollar Stores of Florida LLC Defendant

• 
• 
• 
• 
• 
• 
• 
• 

						
                                
Preview
                                Filing # 134802183 E-Filed 09/17/2021 12:41:22 PM
 IN THE CIRCUIT COURT OF THE SEVENTEENTHJUDICIAL CIRCUIT
 IN AND FOR BROWARD COUNTY, STATE OF FLORIDA
 CIVIL DIVISION
 KAREN JAMEISON,
 Plaintiff,
 CASE NO: CACE-21-016212
 V
 FAMILY DOLLAR STORES
 OF FLORIDA, LLC,
 Defendants.
 i
 DEFENDANT FAMILY DOLLAR STORES OF FLORIDA, LLC'S
 FIRST REQUEST FOR PRODUCTION TO PLAINTIFF
 Defendant, Family Dollar Stores of Florida, LLC, through undersigned counsel, and
 pursuantto Rule 1.350, Florida Rules of Civil Procedure, requests that Plaintiff, Karen Jameison,
 produce the following items for inspection and/or copying, said items to be produced at the
 Offices of Defendant's attorneys located at 101 East Kennedy Boulevard, Suite 3700, Tampa,
 Florida, within 30 days from the date of service:
 1.
 Federal Income Tax Returns and W-2 Forms for 2015 through 2020.
 2.
 Itemized medical bills incurred by Plaintiff as a result of the subjectincident.
 3.
 All written or recorded statements made by any witnesses to the subject incident.
 4.
 All medicalreports rendered by Plaintiffstreating and examining physicians.
 5.
 A copy of any and all statements (as defined in the Rules of Civil Procedure)
 concerning this action or the subject matter ofthis action previously made by the Defendant.
 6.
 Any and all photographstaken at the scene of the subject incident described in the
 Complaint which do or might reveal marks, damage or conditions that existed on the date of the
 subject incident, but which no longer exist at said scene or which probably no longer exist at said
 scene.
 7.
 Any property in the possession of the Plaintiff on the date of the subject incident
 described in the Complaint which was involved in the subject incident and which contain marks
 1
 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/17/2021 12:41:21 PM.****
 or damage as a result of the subject incident, or if such property no longer contains such marks or
 damage in the same condition as it did on the date of the subject incident, then produce copies of
 any and all photographs showing marks or damage.
 8.
 Any and all photographs depicting Plaintiff's claimed injuries and present
 condition.
 9-
 Photographs ofthe shoes wornby Plaintiff at the time ofthe subject incident.
 10.
 Any and all documents and or photographs that you contend support Plaintiff's
 negligenceclaim.
 11.
 A copy of any Conditional Payment Letter from Medicaid or Medicare for
 treatment of injuries alleged to be caused by the subjectincident.
 HILL WARD HENDERSON
 /s/ Sherilee J. Samuel
 Sherilee J. Samuel, (Fla. Bar No. 017499)
 Cory J. Person, (Fla. Bar No. 32950)
 Nicole D. Walsh, (Fla. Bar No. 111961)
 3700 Bank ofAmerica Plaza
 101 East Kennedy Boulevard
 Tampa, FL 33602
 Ph. 813.221.3900
 Fax 813.221.2900
 Attorneysfor Defendant Family Dollar Storesof
 Florida, LLC
 CERTIFICATE OF SERVICE
 I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
 via e-mail this 17th day of September, 2021 via the Florida Courts E-Filing Portal to Charles
 Mustell,
 Esquire,
 attorney
 for
 Plaintiff,
 at:
 and
 The Mustell Law Firm, Chase Bank Building, 3550 Biscayne Blvd.,
 Suite 406, Miami FL 33137.
 /s/ Sherilee J. Samuel
 Attorney
 15897043v1