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Filing # 133861444 E-Filed 09/01/2021 02:40:55 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.
i
DEFENDANT'S, LAROSE EBANKS RESPONSE TO
PLAINTIFF'S REQUEST FOR PRODUCTION
Defendant, LAROSE EBANKS, by and through the undersigned counsel and pursuant to
Rule 1.350 of the Florida Rules of Civil Procedure, hereby files his response to Plaintiff's,
ELIZABETH VICENTE Request for Production served with the Complaint on or about June 28,
2021, and states as follows:
1. Any and all Policies of Insurance that you contend cover or may cover any
Defendant for the allegations contained in Plaintiff's Complaint.
RESPONSE:
See declarations page for the applicable policy attached as "Exhibit E" and bates
stamped as "DEC-PAGE-000001."
2. Any and all documentswhich support the affirmative defenses in your answer.
RESPONSE:
Objection. This request is vague, overly broad and unduly burdensome.
3. Any and all reports of expert witnesses who will testify at time of trial pertaining to any
issue involved in this lawsuit.
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/01/2021 02:40:55 PM.****
RESPONSE:
Unknown at this time. This request is premature as discovery has only just begun
4. Any statements ofthe Plaintifftakenin connection with the above lawsuit.
RESPONSE:
None currently in Defendant's possession.
5. Any model, plat, map, drawing, motion picture, video tape, and color digital photographs
pertaining to any fact or issue involved in this controversy depicting either vehicles
involved, the scene ofthe accident and/or of any parties involved.
RESPONSE:
Please see two (2) photographs of the 2019 Ford E350 attached as Exhibit "A" and
bates stamped as Please see thirty-
one (31) photographs of the 2012 Toyota Yaris attached as Exhibit "B" and bates
dl
stamped as
6. A copy ofthe title and registration for the subject vehicle.
RESPONSE:
None in this Defendant's possession.
7. A copy ofyour driver's license.
RESPONSE:
This information has been requested and will be produced in separate
correspondence so as not to be part of a public record.
8. Detailed cellular phone bill at the time of the accident, or in the alternative, please
complete the attached Authorizationfor Release of Cellular Phone Records.
RESPONSE:
None currently in Defendant's possession.
9. Any materials you intend to use at trial to impeach the parties, their witnesses or experts,
including impeachment material set forth in and Northup v. Acken 865 So.2d 1267
(Fla.2004).
RESPONSE:
2
Unknown at this time. This request is premature as discovery has only just begun.
10. Any and all invoices and/or repair estimates and/or bills of any vehicles involved in the
subject accident.
RESPONSE:
Please see the attached property damage estimate for the 2019 Ford E350 attached
as Exhibit "C" and bates stamped as
000002." Please see the attached property damage estimate for the 2012 Toyota
,,
Yaris attached as Exhibit "D and bated stamped as
,,
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:
None currently in Defendant's possession.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on September 1, 2021, I electronically filed the foregoing with
the Clerk ofthe Court using the Florida E-Portal system, whereby a true and correct copy hereofhas
been furnishedvia email to: Peter J. Ridge, Esq., Anidjar & Levine, P.A.
George Fernandez, Esq. and Anthony
Gonzalez,
/s/Karissa L. Owens
KARISSA L. OWENS, ESQ.
Florida Bar No.. 0579971
Email:
RISSMAN, BARRETT, HURT,
DONAHUE, McLAIN & MANGAN, P.A.
6451 North Federal Highway, Suite 400
Fort Lauderdale, FL 33308
Telephone: (954) 526-5480
Facsimile: (954) 745-7258
AttorneyMDefendant,
Larose Ebanks
KLO/VMP/msk#831
3
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Filing # 133861444 E-Filed 09/01/2021 02:40:55 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. i DEFENDANT'S, LAROSE EBANKS RESPONSE TO PLAINTIFF'S REQUEST FOR PRODUCTION Defendant, LAROSE EBANKS, by and through the undersigned counsel and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, hereby files his response to Plaintiff's, ELIZABETH VICENTE Request for Production served with the Complaint on or about June 28, 2021, and states as follows: 1. Any and all Policies of Insurance that you contend cover or may cover any Defendant for the allegations contained in Plaintiff's Complaint. RESPONSE: See declarations page for the applicable policy attached as "Exhibit E" and bates stamped as "DEC-PAGE-000001." 2. Any and all documentswhich support the affirmative defenses in your answer. RESPONSE: Objection. This request is vague, overly broad and unduly burdensome. 3. Any and all reports of expert witnesses who will testify at time of trial pertaining to any issue involved in this lawsuit. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/01/2021 02:40:55 PM.**** RESPONSE: Unknown at this time. This request is premature as discovery has only just begun 4. Any statements ofthe Plaintifftakenin connection with the above lawsuit. RESPONSE: None currently in Defendant's possession. 5. Any model, plat, map, drawing, motion picture, video tape, and color digital photographs pertaining to any fact or issue involved in this controversy depicting either vehicles involved, the scene ofthe accident and/or of any parties involved. RESPONSE: Please see two (2) photographs of the 2019 Ford E350 attached as Exhibit "A" and bates stamped as Please see thirty- one (31) photographs of the 2012 Toyota Yaris attached as Exhibit "B" and bates dl stamped as 6. A copy ofthe title and registration for the subject vehicle. RESPONSE: None in this Defendant's possession. 7. A copy ofyour driver's license. RESPONSE: This information has been requested and will be produced in separate correspondence so as not to be part of a public record. 8. Detailed cellular phone bill at the time of the accident, or in the alternative, please complete the attached Authorizationfor Release of Cellular Phone Records. RESPONSE: None currently in Defendant's possession. 9. Any materials you intend to use at trial to impeach the parties, their witnesses or experts, including impeachment material set forth in and Northup v. Acken 865 So.2d 1267 (Fla.2004). RESPONSE: 2 Unknown at this time. This request is premature as discovery has only just begun. 10. Any and all invoices and/or repair estimates and/or bills of any vehicles involved in the subject accident. RESPONSE: Please see the attached property damage estimate for the 2019 Ford E350 attached as Exhibit "C" and bates stamped as 000002." Please see the attached property damage estimate for the 2012 Toyota ,, Yaris attached as Exhibit "D and bated stamped as ,, 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: None currently in Defendant's possession. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on September 1, 2021, I electronically filed the foregoing with the Clerk ofthe Court using the Florida E-Portal system, whereby a true and correct copy hereofhas been furnishedvia email to: Peter J. Ridge, Esq., Anidjar & Levine, P.A. George Fernandez, Esq. and Anthony Gonzalez, /s/Karissa L. Owens KARISSA L. OWENS, ESQ. Florida Bar No.. 0579971 Email: RISSMAN, BARRETT, HURT, DONAHUE, McLAIN & MANGAN, P.A. 6451 North Federal Highway, Suite 400 Fort Lauderdale, FL 33308 Telephone: (954) 526-5480 Facsimile: (954) 745-7258 AttorneyMDefendant, Larose Ebanks KLO/VMP/msk#831 3