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Filing # 130117887 E-Filed 07/06/2021 03:49:05 PM
IN THE CIRCUIT COURT OF THE
QIETRONTE WIMIATAT CTDOTITT TNT
Fil LOGIN ID JUDIUIAL ULNUULL LY
AND FOR PALM BEACH COUNTY,
FLORIDA.
CASE NO.: 502021CA007517XXXX MB AJ
JAMES N. MANOLAKOS,
Plaintiff,
v.
RONALD PAUL HIMEBACK,
Defendant,
/
DEFENDANT’S
FIRST REQUEST TO PRODUCE TO PLAINTIFF
Defendant, RONALD PAUL HIMEBACK, hereby requests, pursuant to Rule
1.350, Florida Rules of Civil Procedure, that Plaintiff, JAMES N. MANOLAKOS,
produce and permit the inspection and copying of the following documents and papers
within thirty (30) days, at the office of the undersigned attorney for the defendant:
1. All medical bills or statements for medical treatment, medications or other
related items, the cost of which is claimed to have been incurred by Plaintiff, JAMES N.
MANOLAKOS, as a result of the injuries allegedly sustained by plaintiff.
2. Any and all records of hospitals in which Plaintiff, JAMES N.
MANOLAKOS; has heen hosnitalized or received treatment allegedly as a result of the
incident herein involved or, in the alternative, written authorizations to obtain same.
3. Color reprints (not photocopies) of all photographs of Plaintiff, JAMES
N. MANOLAKOS., injuries taken by plaintiff, attorneys, investigators, agents or
servants which are in any manner related to the subject matter of this lawsuit.
CHEN. DAIAARCACUAAIINTY Cl INeGEDU ARDIIV7ZN FLED AT7INGINNA N2.A0-NE DNA
Pty. PAL DUA VUUINE TT, PL, JUOL IE mDNUeey, ULUIAN, Ulruueue |! Ultg.u itJames N. Manolakos v. Ronald Paul Himeback
Case No, 502021 CA QO7S17N NX MB AT
Defendant’s First Request to Produce to Plaintiff
4. Any and all photographs or video tapes of the accident scene taken by
plaintiff, attorneys, investigators, agents or servants which are in any manner related to
the subject matter of this lawsuit for which plaintiff does not claim a privilege.
5. Copies of medical reports received by Plaintiff, JAMES N.
MANOLAKOS, attorneys, investigators, agents, servants or employees, from doctors,
physicians or anyone else who has rendered treatment to plaintiff, for injuries incurred as
a result of the incident which is the subject matter of this lawsuit.
6. Copies of all medical records received by Plaintiff, JAMES N.
MANOLAKOS, attomeys, investigators, agents or servants or employees from any
doctor, physician or member of the healing arts who has examined the physical or mental
condition of plaintiff subsequent to the accident which is the subject matter of this
lawsuit, and who may be called as a witness on behalf of the plaintiff at the trial of this
cause.
7. All written statements by plaintiff concerning this action or its subject
matter, or a stenographic mechanical, electrical or other recording or transcript or a
statement that is a substantial verbatim recital or an oral statement.
8. All written statements by the defendant, its directors, officers or
employees, concerning this action or its subject matter, or a stenographic mechanical,
electrical or other recording or transcription or a statement that is a substantial verbatim
recital or an oral statement.James N. Manolakos v. Ronald Paul Himeback
Casa Na 509091 CA NNIEVIVY YY MR AT
Defendant’s First Request to Produce to Plaintiff
9. Copies of all releases, agreements or other documents evidencing payment
by any person, insurance company, or other entity to Plaintiff, JAMES N.
MANOLAKOS, as compensation for or in satisfaction of any of the damages sustained
by plaintiff in the incident which is the subject of this lawsuit.
10. Retained copies or other suitable copies of income tax returns, W-2 forms
and 1099 forms of Plaintiff, JAMES N. MANOLAKOS, for the past five (5) years, or in
the alternative, provide a duly executed Internal Revenue Form 4506 Request for Copy or
Transcript of Tax Form for said years (form attached).
11. Copy of all driver’s licenses issued to you and presently in effect and/or in
effect at the time of the incident involved in this lawsuit.
12. Copies (front and back) of any and all identification cards of the Plaintiff,
JAMES N. MANOLAKOS, relating to health insurance coverage, automobile insurance
coverage, employment benefits, Medicare and/or Medicaid coverage and Social Security
benefits depicting the name, address, policy number, ciaim number(s), identification
number of any insurance companies and/or employers which will or may provide the
plaintiff with coverage and/or benefits for the subject incident.
13. Please provide your cellular phone number and name and address of
carrier on November 8, 2020.
CERTIFICATE OF SERVICE NEXT PAGEJames N. Manolakos v. Ronald Paul Himeback
Cace No 509071 CA ANTS1TXXXY MR AT
Defendant’s First Request to Produce to Plaintiff
I HEREBY CERTIFY that a true and correct coy of the above and foregoing has
been served via electronic mail to: DIEGO C. ASENCIO, ESQ., Diego C. Asencio,
P.A., Attorney for Plaintiff, 4440 PGA Boulevard, Suite 600, Palm Beach, Gardens, FL
33410; Email:diego634c@aol.com, on this { say of July, 2021.
OLDS & STEPHENS, P.A.
312—11™ Street
West Palm Beach, FL 33491
Telephone: 561.832.6814
Fax: 561.832.4766
Atto dant
BY:
ON STEPHENS, .
Florida Bar No. 604208
email:dstephens@oslegal.com
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Filing # 130117887 E-Filed 07/06/2021 03:49:05 PM IN THE CIRCUIT COURT OF THE QIETRONTE WIMIATAT CTDOTITT TNT Fil LOGIN ID JUDIUIAL ULNUULL LY AND FOR PALM BEACH COUNTY, FLORIDA. CASE NO.: 502021CA007517XXXX MB AJ JAMES N. MANOLAKOS, Plaintiff, v. RONALD PAUL HIMEBACK, Defendant, / DEFENDANT’S FIRST REQUEST TO PRODUCE TO PLAINTIFF Defendant, RONALD PAUL HIMEBACK, hereby requests, pursuant to Rule 1.350, Florida Rules of Civil Procedure, that Plaintiff, JAMES N. MANOLAKOS, produce and permit the inspection and copying of the following documents and papers within thirty (30) days, at the office of the undersigned attorney for the defendant: 1. All medical bills or statements for medical treatment, medications or other related items, the cost of which is claimed to have been incurred by Plaintiff, JAMES N. MANOLAKOS, as a result of the injuries allegedly sustained by plaintiff. 2. Any and all records of hospitals in which Plaintiff, JAMES N. MANOLAKOS; has heen hosnitalized or received treatment allegedly as a result of the incident herein involved or, in the alternative, written authorizations to obtain same. 3. Color reprints (not photocopies) of all photographs of Plaintiff, JAMES N. MANOLAKOS., injuries taken by plaintiff, attorneys, investigators, agents or servants which are in any manner related to the subject matter of this lawsuit. CHEN. DAIAARCACUAAIINTY Cl INeGEDU ARDIIV7ZN FLED AT7INGINNA N2.A0-NE DNA Pty. PAL DUA VUUINE TT, PL, JUOL IE mDNUeey, ULUIAN, Ulruueue |! Ultg.u itJames N. Manolakos v. Ronald Paul Himeback Case No, 502021 CA QO7S17N NX MB AT Defendant’s First Request to Produce to Plaintiff 4. Any and all photographs or video tapes of the accident scene taken by plaintiff, attorneys, investigators, agents or servants which are in any manner related to the subject matter of this lawsuit for which plaintiff does not claim a privilege. 5. Copies of medical reports received by Plaintiff, JAMES N. MANOLAKOS, attorneys, investigators, agents, servants or employees, from doctors, physicians or anyone else who has rendered treatment to plaintiff, for injuries incurred as a result of the incident which is the subject matter of this lawsuit. 6. Copies of all medical records received by Plaintiff, JAMES N. MANOLAKOS, attomeys, investigators, agents or servants or employees from any doctor, physician or member of the healing arts who has examined the physical or mental condition of plaintiff subsequent to the accident which is the subject matter of this lawsuit, and who may be called as a witness on behalf of the plaintiff at the trial of this cause. 7. All written statements by plaintiff concerning this action or its subject matter, or a stenographic mechanical, electrical or other recording or transcript or a statement that is a substantial verbatim recital or an oral statement. 8. All written statements by the defendant, its directors, officers or employees, concerning this action or its subject matter, or a stenographic mechanical, electrical or other recording or transcription or a statement that is a substantial verbatim recital or an oral statement.James N. Manolakos v. Ronald Paul Himeback Casa Na 509091 CA NNIEVIVY YY MR AT Defendant’s First Request to Produce to Plaintiff 9. Copies of all releases, agreements or other documents evidencing payment by any person, insurance company, or other entity to Plaintiff, JAMES N. MANOLAKOS, as compensation for or in satisfaction of any of the damages sustained by plaintiff in the incident which is the subject of this lawsuit. 10. Retained copies or other suitable copies of income tax returns, W-2 forms and 1099 forms of Plaintiff, JAMES N. MANOLAKOS, for the past five (5) years, or in the alternative, provide a duly executed Internal Revenue Form 4506 Request for Copy or Transcript of Tax Form for said years (form attached). 11. Copy of all driver’s licenses issued to you and presently in effect and/or in effect at the time of the incident involved in this lawsuit. 12. Copies (front and back) of any and all identification cards of the Plaintiff, JAMES N. MANOLAKOS, relating to health insurance coverage, automobile insurance coverage, employment benefits, Medicare and/or Medicaid coverage and Social Security benefits depicting the name, address, policy number, ciaim number(s), identification number of any insurance companies and/or employers which will or may provide the plaintiff with coverage and/or benefits for the subject incident. 13. Please provide your cellular phone number and name and address of carrier on November 8, 2020. CERTIFICATE OF SERVICE NEXT PAGEJames N. Manolakos v. Ronald Paul Himeback Cace No 509071 CA ANTS1TXXXY MR AT Defendant’s First Request to Produce to Plaintiff I HEREBY CERTIFY that a true and correct coy of the above and foregoing has been served via electronic mail to: DIEGO C. ASENCIO, ESQ., Diego C. Asencio, P.A., Attorney for Plaintiff, 4440 PGA Boulevard, Suite 600, Palm Beach, Gardens, FL 33410; Email:diego634c@aol.com, on this { say of July, 2021. OLDS & STEPHENS, P.A. 312—11™ Street West Palm Beach, FL 33491 Telephone: 561.832.6814 Fax: 561.832.4766 Atto dant BY: ON STEPHENS, . Florida Bar No. 604208 email:dstephens@oslegal.com