On June 17, 2021 a
Party Discovery
was filed
involving a dispute between
James N Manolakos,
and
City Of West Palm Beach,
Ronald Paul Himeback,
Safeco Insurance Company Of Illinois,
for AUTO NEGLIGENCE
in the District Court of Palm Beach County.
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Filing # 138218513 E-Filed 11/09/2021 04:12:24 PM
IN THE CIRCUIT COURT OF THE
15'™ JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY, FLORIDA
CASE NO: 502021CA007517XXXX MB AJ
JAMES N. MANOLAKOS,
Plaintiff,
vs.
RONALD PAUL HIMEBACK,
Defendant.
/
SUPPLEME) L_REQUEST FOR PRODUCTION TO PLAINTIFF
Pursuant to Fla. R. Civ.P., 1.350, the Plaintiff, JAMES N. MANOLAKOS, is hereby
requested to produce to the Defendant, RONALD PAUL HIMEBACK, within the time required
by Rules 1.080 and 1.350, at the offices of the undersigned counsel, the following:
1. Any documentation stating that Mr. Himeback was not permitted to be operating the City
of West Palm Beach vehicle as a volunteer on the date and time of the accident
2. Any documentation referencing that Mr. Himeback was “asked to stand down because of
severe weather” on the date and time of the accident.
3. Any statements by anyone stating that Mr. Himeback was not permitted to be operating
the City of West Palm Beach vehicle as a volunteer on the date and time of the accident
4. Any statements by anyone stating that Mr. Himeback was “asked to stand down because
of severe weather” on the date and time of the accident.
*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 11/09/2021 04:12:24 PM ***5. If the plaintiff denies any of the Requests for Admissions, provide documentation
including but not limited to rules, regulations, statements, and/or emails, texts, or the like
that supports the denial.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was efiled to:
DIEGO ASENCIO, ESQUIRE, Attomey for Plaintiff, Diego C. Asencio, PA, 4440 PGA
Blvd., Suite 600, Palm Beach Gardens, FL 33410, diego634c@aol.com; and LONNIELL
OLDS, ESQUIRE, Attorney for Defendant, Olds & Stephens, 312-11" Street, West Palm
Beach, FL 33491, lolds@oslegal.com; agagnon@oslegal.com; on this the 9th day of November,
2021.
ROBINSON, PECARO & MIER, P.A.
Attorneys for Defendant
510 Shotgun Road, Suite 404
Sunrise, Florida 33326
Telephone: (954) 252-7197
Facsimile: (954) 252-7199
Email: ppecaro@lawdrive.com
gigi@lawdrive.com
By__/S/ PAUL R. PECARO
PAUL PECARO
Florida Bar No. 821489
Document Filed Date
November 09, 2021
Case Filing Date
June 17, 2021
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Filing # 138218513 E-Filed 11/09/2021 04:12:24 PM IN THE CIRCUIT COURT OF THE 15'™ JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 502021CA007517XXXX MB AJ JAMES N. MANOLAKOS, Plaintiff, vs. RONALD PAUL HIMEBACK, Defendant. / SUPPLEME) L_REQUEST FOR PRODUCTION TO PLAINTIFF Pursuant to Fla. R. Civ.P., 1.350, the Plaintiff, JAMES N. MANOLAKOS, is hereby requested to produce to the Defendant, RONALD PAUL HIMEBACK, within the time required by Rules 1.080 and 1.350, at the offices of the undersigned counsel, the following: 1. Any documentation stating that Mr. Himeback was not permitted to be operating the City of West Palm Beach vehicle as a volunteer on the date and time of the accident 2. Any documentation referencing that Mr. Himeback was “asked to stand down because of severe weather” on the date and time of the accident. 3. Any statements by anyone stating that Mr. Himeback was not permitted to be operating the City of West Palm Beach vehicle as a volunteer on the date and time of the accident 4. Any statements by anyone stating that Mr. Himeback was “asked to stand down because of severe weather” on the date and time of the accident. *** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 11/09/2021 04:12:24 PM ***5. If the plaintiff denies any of the Requests for Admissions, provide documentation including but not limited to rules, regulations, statements, and/or emails, texts, or the like that supports the denial. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was efiled to: DIEGO ASENCIO, ESQUIRE, Attomey for Plaintiff, Diego C. Asencio, PA, 4440 PGA Blvd., Suite 600, Palm Beach Gardens, FL 33410, diego634c@aol.com; and LONNIELL OLDS, ESQUIRE, Attorney for Defendant, Olds & Stephens, 312-11" Street, West Palm Beach, FL 33491, lolds@oslegal.com; agagnon@oslegal.com; on this the 9th day of November, 2021. ROBINSON, PECARO & MIER, P.A. Attorneys for Defendant 510 Shotgun Road, Suite 404 Sunrise, Florida 33326 Telephone: (954) 252-7197 Facsimile: (954) 252-7199 Email: ppecaro@lawdrive.com gigi@lawdrive.com By__/S/ PAUL R. PECARO PAUL PECARO Florida Bar No. 821489