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Filing # 144151628 E-Filed 02/17/2022 04:26:24 PM
IN THE CIRCUIT COURT OF THE 11TH
JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CASE NO.: 2021-023186-CA-01
JOHNNY H. HERNANDEZ MARQUEZ,
an individual,
Plaintiff,
vs.
SEAN A. BAUTISTA an individual,
AND STEVEN MARTINEZ, an individual.
Defendants.
__________________________________/
REQUEST FOR PRODUCTION TO DEFENDANT, SEAN A. BAUTISTA
The Plaintiff/s, by and through her undersigned counsel, and pursuant to 1.350 of the Florida Rules
of Civil Procedure hereby request/s you to produce to the office of the undersigned, within the time
period as prescribed by 1.350 of the Florida Rules of Civil Procedure, legible copies of the following
documents, items, and things:
1. Copies of any and all policies of liability insurance which were in full force and effect on the
date of the subject accident, providing coverage for the accident which formed the subject matter of
the complaint for Damages and Demand for Jury Trial. All such policies of insurance must include
all applicable endorsements, riders, conditions and exclusions thereof, and all documents which are
part of said policies. This request requires the production of any and all primary, excess, umbrella
and/or reinsurance policies.
2. Copies of any and all statements taken in any form (i.e., written, recorded, etc.) from
the Plaintiff.
3. Any "statements" within the meaning and definition of F.R.C.P. 1.280 of any
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independent witnesses bearing knowledge of facts relevant and material to the claims and defenses in
the instant litigation.
4. Copies of any and all estimates, repair bills or other such documents reflecting the
damage sustained by any of the vehicles involved in the subject accident.
5. Copies of any and all photographs reflecting the damages sustained by any of the
vehicles involved in the subject accident.
6. Any and all surveillance films or photographs of the Plaintiff.
7. Any and all photographs of the accident scene.
8. Any and all requests for repairs, invoices, receipts, contracts, correspondence, records
of repair, bills, complaints, concerning those damages sustained in the subject accident.
9. Copies of any and all reports prepared by experts, expected or intended to testify at
the time of trial on your behalf.
10. Any drawings, graphs, charts or writings in the possession, custody and/or control of
the Defendant, or his agents, servants or attorneys, showing the scene of the accident.
11. Traffic or other court transcripts involving the subject accident.
12. Any and all documents, items and things used to answer the Interrogatories
propounded to you.
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the forgoing was furnished on this
17th of February, 2022 to: Timothy W. Harrington, Esq. via e-service at:
MiamiHC@Progressive.com and ThHarrin3@Progressive.com
Gal Sinclair, Esq.
7950 W. Flagler Street, Suite 107
Miami, FL. 33256-5627
Ph: (305) 262-1600, Fax 1-800-918-9466
Direct E-mail: gal@galsinclairlaw.com
BY: ___ s/ Gal Sinclair_________
Gal Sinclair, Esq.,
FBN 195952
.
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Filing # 144151628 E-Filed 02/17/2022 04:26:24 PM IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NO.: 2021-023186-CA-01 JOHNNY H. HERNANDEZ MARQUEZ, an individual, Plaintiff, vs. SEAN A. BAUTISTA an individual, AND STEVEN MARTINEZ, an individual. Defendants. __________________________________/ REQUEST FOR PRODUCTION TO DEFENDANT, SEAN A. BAUTISTA The Plaintiff/s, by and through her undersigned counsel, and pursuant to 1.350 of the Florida Rules of Civil Procedure hereby request/s you to produce to the office of the undersigned, within the time period as prescribed by 1.350 of the Florida Rules of Civil Procedure, legible copies of the following documents, items, and things: 1. Copies of any and all policies of liability insurance which were in full force and effect on the date of the subject accident, providing coverage for the accident which formed the subject matter of the complaint for Damages and Demand for Jury Trial. All such policies of insurance must include all applicable endorsements, riders, conditions and exclusions thereof, and all documents which are part of said policies. This request requires the production of any and all primary, excess, umbrella and/or reinsurance policies. 2. Copies of any and all statements taken in any form (i.e., written, recorded, etc.) from the Plaintiff. 3. Any "statements" within the meaning and definition of F.R.C.P. 1.280 of any 2 independent witnesses bearing knowledge of facts relevant and material to the claims and defenses in the instant litigation. 4. Copies of any and all estimates, repair bills or other such documents reflecting the damage sustained by any of the vehicles involved in the subject accident. 5. Copies of any and all photographs reflecting the damages sustained by any of the vehicles involved in the subject accident. 6. Any and all surveillance films or photographs of the Plaintiff. 7. Any and all photographs of the accident scene. 8. Any and all requests for repairs, invoices, receipts, contracts, correspondence, records of repair, bills, complaints, concerning those damages sustained in the subject accident. 9. Copies of any and all reports prepared by experts, expected or intended to testify at the time of trial on your behalf. 10. Any drawings, graphs, charts or writings in the possession, custody and/or control of the Defendant, or his agents, servants or attorneys, showing the scene of the accident. 11. Traffic or other court transcripts involving the subject accident. 12. Any and all documents, items and things used to answer the Interrogatories propounded to you. 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the forgoing was furnished on this 17th of February, 2022 to: Timothy W. Harrington, Esq. via e-service at: MiamiHC@Progressive.com and ThHarrin3@Progressive.com Gal Sinclair, Esq. 7950 W. Flagler Street, Suite 107 Miami, FL. 33256-5627 Ph: (305) 262-1600, Fax 1-800-918-9466 Direct E-mail: gal@galsinclairlaw.com BY: ___ s/ Gal Sinclair_________ Gal Sinclair, Esq., FBN 195952 .