On April 16, 2021 a
Party Discovery
was filed
involving a dispute between
Levy, Evelyn,
and
Thomas, Clerjean,
Uber Technologies,
for Auto Negligence
in the District Court of Broward County.
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Filing # 128808945 E-Filed 06/15/2021 04:11:28 PM
IN THE CIRCUIT COURT OF THE 177TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
EVELYN LEVY,
CASE NO.: CACE-21-007757(12)
Plaintiff,
VS.
CLERJEAN THOMAS,
Defendant.
REQUEST FOR PRODUCTION TO DEFENDANT, CLERJEAN THOMAS
The Plaintiff, EVELYN LEVY, by and through her undersigned counsel, moves
pursuantto Fla. R. Civ. P. 1.350 and requests that the Defendant, CLERJEANTHOMAS to
produce for inspection and/or copying to the undersigned the following:
1. All statements made by any occupants of the vehicles involved in the subject
accident.
2. All statements made by any witnesses to the subject accident.
3. All statements made by the Plaintiffs pertainingto or concerning the subjectmatter.
4. All photographs of the vehicles involved in the subject accident.
5. All photographs of the defendant depicting injuries received in the subject accident.
6. A copy of any and all insurance agreements, insurance policies or agreements of
any kind or nature under which any person or company carrying on an insurance
business may be liable to satisfy part or all of a judgment which may be entered in
this action or to indemnify or reimburse any payments made to satisfy any such
judgment or settlement, including but not limited to a certified copy of the
declarations sheet as to each such policy.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY thata true and correct copy of the foregoing was furnished via
electronicmail (email)this June 15, 2021 to: HINSHAW& CULBERTSON LLP., MatthewJ.
Walker, Esq. One East Broward Boulevard, Suite 1010, Fort Lauderdale, FL 33301@
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/15/2021 04:11:28 PM.****
By: s/Brett L. Borrow
Brett L. Borrow
Florida Bar No.- 0100341
Attorneys for Plaintiff
THE BORROW LAW FIRM
One Flagler Building
14 NE 1St Avenue, Suite 514
Miami, FL 33132
Telephone: (305) 859-1000
Facsimile:
(305) 718-0633
Primary E-Mail:
Secondary E-Mail:
Document Filed Date
June 15, 2021
Case Filing Date
April 16, 2021
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Filing # 128808945 E-Filed 06/15/2021 04:11:28 PM IN THE CIRCUIT COURT OF THE 177TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA EVELYN LEVY, CASE NO.: CACE-21-007757(12) Plaintiff, VS. CLERJEAN THOMAS, Defendant. REQUEST FOR PRODUCTION TO DEFENDANT, CLERJEAN THOMAS The Plaintiff, EVELYN LEVY, by and through her undersigned counsel, moves pursuantto Fla. R. Civ. P. 1.350 and requests that the Defendant, CLERJEANTHOMAS to produce for inspection and/or copying to the undersigned the following: 1. All statements made by any occupants of the vehicles involved in the subject accident. 2. All statements made by any witnesses to the subject accident. 3. All statements made by the Plaintiffs pertainingto or concerning the subjectmatter. 4. All photographs of the vehicles involved in the subject accident. 5. All photographs of the defendant depicting injuries received in the subject accident. 6. A copy of any and all insurance agreements, insurance policies or agreements of any kind or nature under which any person or company carrying on an insurance business may be liable to satisfy part or all of a judgment which may be entered in this action or to indemnify or reimburse any payments made to satisfy any such judgment or settlement, including but not limited to a certified copy of the declarations sheet as to each such policy. CERTIFICATE OF SERVICE I HEREBY CERTIFY thata true and correct copy of the foregoing was furnished via electronicmail (email)this June 15, 2021 to: HINSHAW& CULBERTSON LLP., MatthewJ. Walker, Esq. One East Broward Boulevard, Suite 1010, Fort Lauderdale, FL 33301@ *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/15/2021 04:11:28 PM.**** By: s/Brett L. Borrow Brett L. Borrow Florida Bar No.- 0100341 Attorneys for Plaintiff THE BORROW LAW FIRM One Flagler Building 14 NE 1St Avenue, Suite 514 Miami, FL 33132 Telephone: (305) 859-1000 Facsimile: (305) 718-0633 Primary E-Mail: Secondary E-Mail: