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Filing # 85270370 E-Filed 02/21/2019 10:10:38 AM
IN THE CIRCUIT COURT OF THE FIFTHTEETH JUDICIAL
CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO: 2018-CA-015498-XXXX-MB
ERROLL INNISS,
Plaintiff,
vs.
THE FLORIDA HIGHWAY PATROL,
A division of FLORIDA DEPARTMENT
OF HIGHWAY SAFETY & MOTOR
VEHICLES, an Agency of the State of
Florida, and TROOPER RICKY LEE
MAYO,
Defendants.
/
DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO PLAINTIFF
COME NOW Defendants, THE FLORIDA HIGHWAY PATROL, A division of
FLORIDA DEPARTMENT OF HIGHWAY SAFETY & MOTOR VEHICLES, an Agency of
the State of Florida, and TROOPER RICKY LEE MAYO, by and through the
undersigned counsel, and hereby request that Plaintiff, ERROL INNISS, produce the
following items within the time allotted pursuant to Rule 1.350 of Florida Rules of Civil
Procedure:
1. All income tax returns, including all attachments, for the five (5) years
immediately preceding the year of the accident, through the present; or in the
alternative, please execute and return the attached request provided by the IRS.
2. All W-2 forms or other payroll receipts, for the five (5) years immediately
preceding the year of the accident, through the present.
*** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 02/21/2019 10:10:38 AM ***CASE NO: 2018-CA-015498
Page 2 of 4
3. All medical records, including x-rays, CAT scans and/or MRIs (and including
any psychological profiles or reports) relating to the alleged injuries sustained by Plaintiff in
the incident described in the complaint.
4. All drawings, maps, video tapes, motion pictures, laser copies of
photographs, or other visual representations relating to the accident scene, injuries, or any
other issue in this suit.
5. All statements taken of any party to this suit which relate in any way to the
incident described in the complaint.
6. All statements taken of any non-party witness which relate in any way to the
incident described in the complaint.
T. All medical records, including x-rays, CAT scans and/or MRIs (and including
any psychological profiles or reports) in Plaintiffs possession or control regarding any
condition or treatment undergone by Plaintiff in the last ten years, not related to the injuries
sustained in the incident described in the complaint.
8. All bills, receipts, statements or other documents evidencing all expenses
incurred by Plaintiff in connection with the incident described in the complaint.
9. Any and all correspondence, memoranda, notes, or other written
communications between Plaintiff (or their counsel) and Defendants (or their insurer)
relating to the incident described in the complaint.
10. Any and all correspondence, memoranda, notes, or other written
communications between Plaintiff and any non-parties to this suit, relating to the incident
described in the complaint.
11. | Any and all reports of, and written communications with, experts expected to
testify at trial of this cause.CASE NO: 2018-CA-015498
Page 3 of 4
12. Any and all curriculum vitae for experts expected to testify at trial of this
cause.
13. Any and all police reports, accident reports, or other reports prepared by any
law enforcement or other investigative agencies, relating to the incident described in the
complaint.
14. Any and all reports prepared by fire rescue, paramedics, ambulance service,
or other emergency response service.
15. Copy of the Plaintiffs marriage license or marriage certificate, if applicable.
16. Any documents evidencing payments received, from any source, as a result
of the alleged injuries.
17. Any and all insurance policies, declaration pages, claims documents,
agreements, reports, correspondence or other communications with any insurance carrier,
including without limitation cancelled checks or other documents showing any payments
received from said carrier relating to the injuries arising from the allegations in the
Complaint to this action.
18. Legible copy of the front and back of Plaintiff's driver's license.
19. Copies of any and all medical providers’ letters of protection.
20. Copies of any and all cell phone bills, with all transaction activity, including
but not limited to telephone calls received or sent, text messages received or sent and
data usage for the dates of April 18, 2016 for any and all cell phones own, operated or
maintained by ERROLL INNISS on April 18, 2016.
[Certificate of Service on following page]CASE NO: 2018-CA-015498
Page 4 of 4
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true copy of the foregoing has been furnished by
electronic mail only via the E-Portal to Brett m. Steinberg, Esq. of Steinberg Law, P.A., 10
S.E. 1* Ave, Ste. C, Delray Beach, FL 33444 on this 21st day of February, 2019.
BOBO, CIOTOLI, WHITE & RUSSELL, P.A.
Counsel for FLORIDA HIGHWAY PATROL and
TROPPER RICKY LEE MAYO.
11641 Kew Gardens Avenue
Suite 101
Palm Beach Gardens, Florida 33410
Tel. No.: 561-684-6600
Fax No.: 561-622-6288
Primary: pleadingsnpb@bobolaw.com
Secondary: dunlap@bobolaw.com
/s/David C. Dunham, Esq.
By:
James L. White, III, Esq.
Florida Bar No.: 0325030
E-mail: white@bobolaw.com
David C. Dunham, Esquire
Florida Bar Number: 0989990
E-mail: dunham@bobolaw.com
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Filing # 85270370 E-Filed 02/21/2019 10:10:38 AM IN THE CIRCUIT COURT OF THE FIFTHTEETH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 2018-CA-015498-XXXX-MB ERROLL INNISS, Plaintiff, vs. THE FLORIDA HIGHWAY PATROL, A division of FLORIDA DEPARTMENT OF HIGHWAY SAFETY & MOTOR VEHICLES, an Agency of the State of Florida, and TROOPER RICKY LEE MAYO, Defendants. / DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO PLAINTIFF COME NOW Defendants, THE FLORIDA HIGHWAY PATROL, A division of FLORIDA DEPARTMENT OF HIGHWAY SAFETY & MOTOR VEHICLES, an Agency of the State of Florida, and TROOPER RICKY LEE MAYO, by and through the undersigned counsel, and hereby request that Plaintiff, ERROL INNISS, produce the following items within the time allotted pursuant to Rule 1.350 of Florida Rules of Civil Procedure: 1. All income tax returns, including all attachments, for the five (5) years immediately preceding the year of the accident, through the present; or in the alternative, please execute and return the attached request provided by the IRS. 2. All W-2 forms or other payroll receipts, for the five (5) years immediately preceding the year of the accident, through the present. *** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 02/21/2019 10:10:38 AM ***CASE NO: 2018-CA-015498 Page 2 of 4 3. All medical records, including x-rays, CAT scans and/or MRIs (and including any psychological profiles or reports) relating to the alleged injuries sustained by Plaintiff in the incident described in the complaint. 4. All drawings, maps, video tapes, motion pictures, laser copies of photographs, or other visual representations relating to the accident scene, injuries, or any other issue in this suit. 5. All statements taken of any party to this suit which relate in any way to the incident described in the complaint. 6. All statements taken of any non-party witness which relate in any way to the incident described in the complaint. T. All medical records, including x-rays, CAT scans and/or MRIs (and including any psychological profiles or reports) in Plaintiffs possession or control regarding any condition or treatment undergone by Plaintiff in the last ten years, not related to the injuries sustained in the incident described in the complaint. 8. All bills, receipts, statements or other documents evidencing all expenses incurred by Plaintiff in connection with the incident described in the complaint. 9. Any and all correspondence, memoranda, notes, or other written communications between Plaintiff (or their counsel) and Defendants (or their insurer) relating to the incident described in the complaint. 10. Any and all correspondence, memoranda, notes, or other written communications between Plaintiff and any non-parties to this suit, relating to the incident described in the complaint. 11. | Any and all reports of, and written communications with, experts expected to testify at trial of this cause.CASE NO: 2018-CA-015498 Page 3 of 4 12. Any and all curriculum vitae for experts expected to testify at trial of this cause. 13. Any and all police reports, accident reports, or other reports prepared by any law enforcement or other investigative agencies, relating to the incident described in the complaint. 14. Any and all reports prepared by fire rescue, paramedics, ambulance service, or other emergency response service. 15. Copy of the Plaintiffs marriage license or marriage certificate, if applicable. 16. Any documents evidencing payments received, from any source, as a result of the alleged injuries. 17. Any and all insurance policies, declaration pages, claims documents, agreements, reports, correspondence or other communications with any insurance carrier, including without limitation cancelled checks or other documents showing any payments received from said carrier relating to the injuries arising from the allegations in the Complaint to this action. 18. Legible copy of the front and back of Plaintiff's driver's license. 19. Copies of any and all medical providers’ letters of protection. 20. Copies of any and all cell phone bills, with all transaction activity, including but not limited to telephone calls received or sent, text messages received or sent and data usage for the dates of April 18, 2016 for any and all cell phones own, operated or maintained by ERROLL INNISS on April 18, 2016. [Certificate of Service on following page]CASE NO: 2018-CA-015498 Page 4 of 4 CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true copy of the foregoing has been furnished by electronic mail only via the E-Portal to Brett m. Steinberg, Esq. of Steinberg Law, P.A., 10 S.E. 1* Ave, Ste. C, Delray Beach, FL 33444 on this 21st day of February, 2019. BOBO, CIOTOLI, WHITE & RUSSELL, P.A. Counsel for FLORIDA HIGHWAY PATROL and TROPPER RICKY LEE MAYO. 11641 Kew Gardens Avenue Suite 101 Palm Beach Gardens, Florida 33410 Tel. No.: 561-684-6600 Fax No.: 561-622-6288 Primary: pleadingsnpb@bobolaw.com Secondary: dunlap@bobolaw.com /s/David C. Dunham, Esq. By: James L. White, III, Esq. Florida Bar No.: 0325030 E-mail: white@bobolaw.com David C. Dunham, Esquire Florida Bar Number: 0989990 E-mail: dunham@bobolaw.com