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Filing# 137592842 E-Filed 10/30/2021 11:17:09 PM
IN THE CIRCUIT COURT OF THE
17th JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY,
FLORIDA
CASE NO.: CACE-21-011888
ELIZABETH VICENTE,
Plaintiff,
V.
LAROSE EBANKS and
ENTERPRISE LEASING COMPANY
OF FLORIDA, LLC, a Foreign
Limited Liability
Company,
Defendants.
DEFENDANT, ENTERPRISE LEASING COMPANY OF FLORIDA, LLC'S
RESPONSES TO PLAINTIFF'S INITIAL REQUEST FOR PRODUCTION
Defendant, ENTERPRISE LEASING COMPANY OF FLORIDA, LLC,
by and through its undersigned counsel, and pursuant to Rule 1.350 of the
ELIZABETH
Florida Rules of Civil Procedure, hereby responds to Plaintiff,
VICENTE's Request to Produce, and states:
1. Any and all Policies of Insurance that you contend cover or may cover
any Defendant for the allegationscontained in Plaintiffs Complaint.
RESPONSE: Attached.
QUINTAIROS, PRIETO, WOOD & BOYER, PA .
ATTORNEYS AT LAW
9300 SOUTH DADEIAND BOULEVARD, 4?H FLOOR, MIAMI, FLORIDA 33156 * TEL: (305) 670-1101
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/30/2021 11:17:09 PM.****
Vicente v. Enterprise
Case No.: CACE-21-011888
2. Any and all documents which support the affirmative defenses in your
answer.
RESPONSE: None.
3. Any and all reports of expert witnesses who will testifyat time of trial
pertainingto any issue involved in this lawsuit.
RESPONSE: Undetermined at this time.
4. Any statements of the Plaintiff taken in connection with the above
lawsuit.
RESPONSE: None.
5. Any model, plat,map, drawing, motion picture,video tape, and color
digitalphotographs pertaining to any fact or issue involved in this
controversy depicting either the vehicles involved, the scene of the
accident and/or of any partiesinvolved.
RESPONSE: Attached.
6. A copy of the title and for the subject vehicle.
registration
RESPONSE: None in Defendant's possession.
7. A copy of your driver's license.
RESPONSE: Not applicable as Defendant is a corporate entity.
QUINTAIROS, PRIETO, WOOD & BOYER, PA .
ATTORNEYS AT LAW
9300 SOUTH DADEIAND BOULEVARD, 4'M FLOOR, MIAMI, FLORIDA 33156 * TEL: (305) 670-1101
Vicente v. Enterprise
Case No.: CACE-21-011888
8. Detailed cellular phone bill at the time of the accident, or in the
alternative,please complete the attached Authorization for Release of
Cellular Phone Records.
RESPONSE: Not applicable as Defendant is a corporate entity.
9. Any materials you intend to use at trial to impeach the parties,their
witnesses or experts, includingimpeachment material set forth in and
Northup v. Acken, 865 So.2d 1267 (Fla.2004).
RESPONSE: Undermined at this time. Therefore, none.
10. Any and all invoices and/or repair estimates and/or bills of any vehicles
involved in the subject accident.
RESPONSE: None in Defendant's possession.
11. The rental agreement, in effect at the time of the subject accident,
between LAROSE EBANKS and ENTERPRISE LEASING COMPANY
OF FLORIDA, LLC, for use of the subject vehicle involved in the
accident.
RESPONSE: Defendant attaches the rental receipt.
QUINTAIROS, PRIETO, WOOD & BOYER, PA .
ATTORNEYS AT LAW
9300 SOUTH DADEIAND BOULEVARD, 4'M FLOOR, MIAMI, FLORIDA 33156 * TEL: (305) 670-1101
Vicente v. Enterprise
Case No.: CACE-21-011888
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing
was furnished via the E-FilingPortal or E-Service this 30th day of October,
2021 to:
Plaintiff's Counsel:
Peter J. Ridge, Esq.
Law Offices of Anidjar & Levine, P.A.
300 S.E. 17 Street
,th
Fort Lauderdale Florida 33316
Tel.:954-525-0050
Fax: 954-525-0020
Email: pleadings@anl-law.corn
Counsel for Defendant, Larose Ebanks
Karissa Louise Owens
Rissman, Barrett,Hurt, Donahue, Mclain & Mangan, P.A
6451 North Federal Highway - Suite 400
Fort Lauderdale, FL 33308
/s/ George L. Fernandez
GEORGE L. FERNANDEZ, ESQ.
Florida Bar No.: 0002097
ANTHONY J. GONZALEZ, ESQ.
Florida Bar No.: 1002987
Quintairos, Prieto, Wood & Boyer, P.A.
Attorneys for Defendant,
Enterprise Leasing Company of Florida
Ath
9300 South Dadeland Boulevard -
4
Floor
Miami, Florida 33156
Tel.: 305-670-1101
Fax: 305-670-1161
qfernandez@QPWBLAW.com
anthony.gonzalez@QPWBLAW.com
bfetokakis-ferna ndez@QPWBLAW.com
rebecca.winer@QPWBLAW.com
QUINTAIROS, PRIETO, WOOD & BOYER, PA .
ATTORNEYS AT LAW
9300 SOUTH DADEIAND BOULEVARD, 4'M FLOOR, MIAMI, FLORIDA 33156 * TEL: (305) 670-1101
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Filing# 137592842 E-Filed 10/30/2021 11:17:09 PM IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-21-011888 ELIZABETH VICENTE, Plaintiff, V. LAROSE EBANKS and ENTERPRISE LEASING COMPANY OF FLORIDA, LLC, a Foreign Limited Liability Company, Defendants. DEFENDANT, ENTERPRISE LEASING COMPANY OF FLORIDA, LLC'S RESPONSES TO PLAINTIFF'S INITIAL REQUEST FOR PRODUCTION Defendant, ENTERPRISE LEASING COMPANY OF FLORIDA, LLC, by and through its undersigned counsel, and pursuant to Rule 1.350 of the ELIZABETH Florida Rules of Civil Procedure, hereby responds to Plaintiff, VICENTE's Request to Produce, and states: 1. Any and all Policies of Insurance that you contend cover or may cover any Defendant for the allegationscontained in Plaintiffs Complaint. RESPONSE: Attached. QUINTAIROS, PRIETO, WOOD & BOYER, PA . ATTORNEYS AT LAW 9300 SOUTH DADEIAND BOULEVARD, 4?H FLOOR, MIAMI, FLORIDA 33156 * TEL: (305) 670-1101 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/30/2021 11:17:09 PM.**** Vicente v. Enterprise Case No.: CACE-21-011888 2. Any and all documents which support the affirmative defenses in your answer. RESPONSE: None. 3. Any and all reports of expert witnesses who will testifyat time of trial pertainingto any issue involved in this lawsuit. RESPONSE: Undetermined at this time. 4. Any statements of the Plaintiff taken in connection with the above lawsuit. RESPONSE: None. 5. Any model, plat,map, drawing, motion picture,video tape, and color digitalphotographs pertaining to any fact or issue involved in this controversy depicting either the vehicles involved, the scene of the accident and/or of any partiesinvolved. RESPONSE: Attached. 6. A copy of the title and for the subject vehicle. registration RESPONSE: None in Defendant's possession. 7. A copy of your driver's license. RESPONSE: Not applicable as Defendant is a corporate entity. QUINTAIROS, PRIETO, WOOD & BOYER, PA . ATTORNEYS AT LAW 9300 SOUTH DADEIAND BOULEVARD, 4'M FLOOR, MIAMI, FLORIDA 33156 * TEL: (305) 670-1101 Vicente v. Enterprise Case No.: CACE-21-011888 8. Detailed cellular phone bill at the time of the accident, or in the alternative,please complete the attached Authorization for Release of Cellular Phone Records. RESPONSE: Not applicable as Defendant is a corporate entity. 9. Any materials you intend to use at trial to impeach the parties,their witnesses or experts, includingimpeachment material set forth in and Northup v. Acken, 865 So.2d 1267 (Fla.2004). RESPONSE: Undermined at this time. Therefore, none. 10. Any and all invoices and/or repair estimates and/or bills of any vehicles involved in the subject accident. RESPONSE: None in Defendant's possession. 11. The rental agreement, in effect at the time of the subject accident, between LAROSE EBANKS and ENTERPRISE LEASING COMPANY OF FLORIDA, LLC, for use of the subject vehicle involved in the accident. RESPONSE: Defendant attaches the rental receipt. QUINTAIROS, PRIETO, WOOD & BOYER, PA . ATTORNEYS AT LAW 9300 SOUTH DADEIAND BOULEVARD, 4'M FLOOR, MIAMI, FLORIDA 33156 * TEL: (305) 670-1101 Vicente v. Enterprise Case No.: CACE-21-011888 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via the E-FilingPortal or E-Service this 30th day of October, 2021 to: Plaintiff's Counsel: Peter J. Ridge, Esq. Law Offices of Anidjar & Levine, P.A. 300 S.E. 17 Street ,th Fort Lauderdale Florida 33316 Tel.:954-525-0050 Fax: 954-525-0020 Email: pleadings@anl-law.corn Counsel for Defendant, Larose Ebanks Karissa Louise Owens Rissman, Barrett,Hurt, Donahue, Mclain & Mangan, P.A 6451 North Federal Highway - Suite 400 Fort Lauderdale, FL 33308 /s/ George L. Fernandez GEORGE L. FERNANDEZ, ESQ. Florida Bar No.: 0002097 ANTHONY J. GONZALEZ, ESQ. Florida Bar No.: 1002987 Quintairos, Prieto, Wood & Boyer, P.A. Attorneys for Defendant, Enterprise Leasing Company of Florida Ath 9300 South Dadeland Boulevard - 4 Floor Miami, Florida 33156 Tel.: 305-670-1101 Fax: 305-670-1161 qfernandez@QPWBLAW.com anthony.gonzalez@QPWBLAW.com bfetokakis-ferna ndez@QPWBLAW.com rebecca.winer@QPWBLAW.com QUINTAIROS, PRIETO, WOOD & BOYER, PA . ATTORNEYS AT LAW 9300 SOUTH DADEIAND BOULEVARD, 4'M FLOOR, MIAMI, FLORIDA 33156 * TEL: (305) 670-1101