Party Discovery: NANCY STRACHAN vs ALLSTATE PROPERTY AND CASUALTY INSURANCE COMPANY

On December 17, 2022 a Party Discovery was filed involving a dispute between Nancy Strachan, and Allstate Property And Casualty Insurance Company, Geico Casualty Company, for AUTO NEGLIGENCE CASE Division: CV-A in the District Court of Duval County.

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Filing # 165437808 E-Filed 01/25/2023 01:12:02 PM

IN THE CIRCUIT COURT OF THE FOURTH
JUDICIAL CIRCUIT IN AND FOR DUVAL
COUNTY, FLORIDA

Case No.: 16-2022-CA-007207
Division:
NANCY STRACHAN,

Plaintiff,
v.

GEICO CASUALTY COMPANY, a
Foreign Profit Corporation, and
ALLSTATE PROPERTY AND
CASUALTY INSURANCE COMPANY, a
Foreign Profit Corporation,

Defendants.
____________________________/

DEFENDANT’S REQUEST TO PRODUCE TO PLAINTIFF,
NANCY STRACHAN

The Defendant, by and through the undersigned attorney, pursuant to Rule 1.350, Florida

Rules of Civil Procedure, requests that the Plaintiff, Nancy Strachan, produce the following

documents to the undersigned attorneys within thirty (30) days from the date of service of this

Request to Produce, for examination, inspection, and copying, and as grounds therefore, says that

the materials are in the custody or control of that party and are either relevant or material to the

issues in this cause:

1. All W-2 forms, 1099 forms and federal income tax returns, including all schedules,
filed the two years prior to the accident which is the subject of your complaint and
all years subsequent to the accident, and evidence of income for the current year.

2. Copies of all documents not identified in paragraph 1 that support any lost wage
claim in this action.

3. If you are claiming a loss of wages or lost earning capacity, a signed authorization,

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ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 01/26/2023 11:43:18 AM
an original of which is attached hereto, allowing Defendant to obtain Plaintiff's
Social Security Administration earnings records and a signed authorization, an
original of which is attached hereto, allowing Defendant to obtain Plaintiff’s tax
returns with the Internal Revenue Service.

4. Ledgers and/or, summaries (only) of all billing by any and all doctors, hospitals,
therapists, nurses, and other health care providers documenting medical expenses
allegedly incurred as a result of the subject incident described in the Complaint.

5. All plaintiff’s medical records in possession of Plaintiff or Plaintiff’s attorney.

6. Any and all repair estimates and repair records to the vehicles involved in the subject
accident.

7. Any and all x-rays, MRIs and/or CT scan and any other diagnostic studies of the
Plaintiff within the past ten years.

8. Any and all statements and/or correspondence obtained by you, your attorney, your
insurance carrier or anyone acting on your behalf from the Defendant regarding any
of the events or happenings referred to in the pleadings.

9. Any photographs, movies, or video of the plaintiff taken three years prior to the
accident up to the present date.

10. Any and all original color photographs or video of the vehicles, the accident scene or
the parties pertaining to the alleged subject incident which depict conditions which
no longer exist.

11. Any and all automobile declarations pages, insurance cards, and statements of
benefits for insurance policies which reflect coverages available to the Plaintiff at the
time of the subject accident.

12. A signed authorization, an original of which is attached hereto, allowing Defendant
to obtain Plaintiff’s medical records, including billing records.

13. All letters of protection (LOP's) issued by you or your attorney on your behalf to
health care providers, including all doctors, chiropractors, therapists, and diagnostic
testing facilities.

14. All letters sent by your attorney or on your behalf pursuant to Florida Statute Section
768.76 to the providers of collateral sources, including any and all health and
disability insurers.

15. All responses to the letters described in Request No. 14 received by you or your

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attorney on your behalf from any collateral source providers, including any and all
health and disability insurers.

16. A copy of the front and back of the Plaintiff's driver's license.

17. A copy of the front and back of the Plaintiff's health insurance card.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by

Electronic Mail on this, the 25th day of January, 2023 to the following designated service email

addresses: Said Farhat, Esq., Morgan & Morgan, sfarhat@forthepeople.com.

Law Office of Aurora D. Brown

Daniel Lake, Esq.
(Employees of GEICO General Insurance)
Florida Bar No.: 381240
200 West Forsyth Street, Suite 1020
Jacksonville, Florida 32202
Phone: 904-355-1921
Facsimile: 904-354-7041
Attorney for Defendant
Service Email: jaxgeico@geico.com

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AUTHORIZATION FOR RELEASE OF MEDICAL RECORDS

TO:

I hereby authorize you to release to Law Office of Aurora D. Brown 200 West Forsyth
Street, Suite 1020 Jacksonville, Florida 32202: All records relating to medical treatment, and
testing, care or examination of Nancy Strachan , including but not limited to, emergency room
records, reports, x-ray films, x-ray reports, bills, notes, progress reports, evaluations, memoranda,
patient information, and/or any other documents of any nature whatsoever pertaining to the care and
treatment of Nancy Strachan , from the date of inception of your records to the present. Social
Security No. ________________________ . Date of Birth: _____________________ .
In compliance with the new HIPAA rules, I certify that I have been provided with written
notice of the intent to obtain the above-described medical records and that the notice provided
sufficient information about the litigation or proceeding to permit me to raise any objection to the
production of the requested documents and that I waive any objection I may have to the production
of the requested documents. I acknowledge that the purpose of the Authorization is to permit
Defendant(s) in a motor vehicle accident lawsuit to obtain my records for use in the litigation. I
acknowledge that the records obtained by this Authorization are to be used for the purposes of the
said litigation only. By using this Authorization to obtain my medical records, the person to whom
the records are to be disclosed is restricted to redisclosing the records only to the extent required for
the litigation and evaluation of my claims.
Treatment, payment, enrollment or eligibility for benefits may not be conditioned on
obtaining the Authorization.
I acknowledge that I may revoke this Authorization in writing at any time. Unless sooner
revoked, this Authorization will expire one year from date of execution.

__________________________________________
Nancy Strachan
STATE OF FLORIDA )
COUNTY OF DUVAL )

The foregoing instrument was acknowledged before me on this the day of
, 2023, by Nancy Strachan, who is personally known to me or who has produced
____________________________ as identification.
(SEAL) ____________________________________
NOTARY PUBLIC
Commission No.
My Commission Expires ________________
____________________________________
NAME: (PRINTED)

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Form SSA-7050-F4 (03-2019) UF Page 2 of 4
REQUEST FOR SOCIAL SECURITY EARNINGS INFORMATION
1. Provide your name as it appears on your most recent Social Security card or the name of the individual whose
earnings you are requesting.
First Name: Middle Initial

Last Name:

Social Security Number (SSN) - - One SSN per request

Date of Birth / / Date of Death: / /
Other Name(s) Used
(Include Maiden Name)

2. What kind of earnings information do you need? (Choose ONE of the following types of earnings or SSA must return this request.)

Itemized Statement of Earnings $91.00 Year(s) Requested: to
(Includes the names and addresses of employers)
Year(s) Requested: to
If you check this box, tell us why you need this information below.

Check this box if you want the earnings information
CERTIFIED for an additional $34.00 fee.

Certified Yearly Totals of Earnings $34.00 Year(s) Requested: to
(Does not include the names and addresses of employers)
Yearly earnings totals are FREE to the public if you do not Year(s) Requested: to
require certification. To obtain FREE yearly totals of
earnings, visit our website at www.ssa.gov/myaccount.

3. If you would like this information sent to someone else, please fill in the information below.
I authorize the Social Security Administration to release the earnings information to:

Name

Address State

City Zip Code

4. I am the individual to whom the record pertains (or a person authorized to sign on behalf of that individual). I
understand that any false representation to knowingly and willfully obtain information from Social Security records is
punishable by a fine of not more than $5,000 or one year in prison.
Signature AND Printed Name of Individual or Legal Guardian SSA must receive this form within 120 days from the date signed.

Date: / /

Relationship (if applicable, you must attach proof) Daytime Phone:
State
Address
Zip Code
City
Witness must sign this form ONLY if the above signature is by marked (X). If signed by mark (X), two witnesses to the signing who know the
signee must sign below and provide their full addresses. Please print the signee’s name next to the mark (X) on the signature line above.
1. Signature of Witness 2. Signature of Witness

Address (Number and Street, City, State and Zip Code) Address (Number and Street, City, State and Zip Code)

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Form SSA-7050-F4 (03-2019) UF Page 2 of 4

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Form 4506 Request for Copy of Tax Return
(March 2019)
uDo not sign this form unless all applicable lines have been completed. OMB No. 1545-0429
Department of the Treasury Request may be rejected if the form is incomplete or illegible.
Internal Revenue Service uFor more information about Form 4506, visit www.irs.gov/form4506.
Tip: You may be able to get your tax return or return information from other sources. If you had your tax return completed by a paid preparer, they should
be able to provide you a copy of the return. The IRS can provide a Tax Return Transcript for many returns free of charge. The transcript provides most
of the line entries from the original tax return and usually contains the information that a third party (such as a mortgage company) requires. See Form
4506-T, Request for Transcript of Tax Return, or you can quickly request transcripts by using our automated self-help service tools. Please visit us at
IRS.gov and click on “Get a Tax Transcript" or call 1-800-908-9946.
1a Name shown on tax return. If a joint return, enter the name shown 1b First social security number on tax return,
first. individual taxpayer identification number, or
employer identification number (see instructions)

2a If a joint return, enter spouse’s name shown on tax return. 2b Second social security number or individual taxpayer
identification number if joint tax return

3 Current name, address (including apt., room, or suite no.), city, state, and ZIP code (see instructions)

4 Previous address shown on the last return filed if different from line 3 (see instructions)

5 If the tax return is to be mailed to a third party (such as a mortgage company), enter the third party’s name, address and telephone number.

Caution: If the tax return is being mailed to a third party, ensure that you have filled in lines 6 and 7 before signing. Sign and date the form once you have
filled in these lines. Completing these steps helps to protect your privacy. Once the IRS discloses your tax return to the third party listed on line 5, the IRS
has no control over what the third party does with the information. If you would like to limit the third party's authority to disclose your return information, you
can specify this limitation in your written agreement with the third party.

6 Tax return requested Form 1040, 1120, 941, etc. and all attachments as originally submitted to the IRS, including Form(s) W-2, schedules, or
amended returns. Copies of Forms 1040, 1040A, and 1040EZ are generally available for 7 years from filing before they are destroyed by law. Other
returns may be available for a longer period of time. Enter only one return number. If you need more than one type of return, you must complete
another Form 4506. ▶

Note. If the copies must be certified for court or administrative proceedings, check here . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

7 Year or period requested. Enter the ending date of the year period, using the mm/dd/yyyy format. If you are requesting more than eight years or
periods, you must attach another Form 4506.
/ / / / / / / /
/ / / / / / / /

8 Fee. There is a $50 fee for each return requested. Full payment must be included with your request or
it will be rejected. Make your check or money order payable to “United States Treasury." Enter
your SSN, ITIN or EIN and “Form 4506 request" on your check or money order.
a Cost for each return . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $
b Number of returns requested on line 7 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
c Total cost. Multiply line 8a by line 8b . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $

9 If we cannot find the tax return, we will refund the fee. If the refund should go to the third party listed on line 5, check here . . . . . . . . . . . . . . . . .
Caution. Do not sign this form unless all applicable lines have been completed.
Signature of taxpayer(s). I declare that I am either the taxpayer whose name is shown on line 1a or 2a, or a person authorized to obtain the tax return
requested. If the request applies to a joint return, at least one spouse must sign. If signed by a corporate officer, 1 percent or more shareholder, partner,
managing member, guardian, tax matters partner, executor, receiver, administrator, trustee, or party other than the taxpayer, I certify that I have the
authority to execute Form 4506 on behalf of the taxpayer. Note. This form must be received by IRS within 120 days of the signature date.
Signatory attests that he/she has read the attestation clause and upon so reading Phone number of taxpayer on
declares that he/she has the authority to sign the Firm 4506. See instructions. line 1a or 2a

Sign Signature (see instructions) Date
Here
Title (if line 1a above is a corporation, partnership, estate, or trust)

Spouse’s signature Date

For Privacy Act and Paperwork Reduction Act Notice, see page 2. Cat No. 41721E Form 4506 (Rev. 3-2019)

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Form 4506 (Rev 3-2019) Page 2

Ohio, Pennsylvania, Rhode Individuals. Copies of jointly filed tax returns may be
Section references are to the Internal Revenue Code Island, South Carolina, furnished to either spouse. Only one signature is
unless otherwise noted. Vermont, Virginia, West required. Sign Form 4506 exactly as your name
Virginia appeared on the original return. If you changed your
Future Developments name, also sign your current name.
For the latest information about Form 4506 and its
instructions, go to www.irs.gov/form4506. Information Chart for all other returns Corporations. Generally, Form 4506 can be signed
about any recent developments affecting Form 4506, by: (1) an officer having legal authority to bind the
Form 4506T and Form 4506T-EZ will be posted on that corporation, (2) any person designated by the board of
page. If you lived in or your Mail to:
directors or other governing body, or (3) any officer or
business was in: employee on written request by any principal officer and
General Instructions Alabama, Alaska, Arizona, attested to by the secretary or other officer. A bona fide
Caution. Do not sign this form unless all applicable Arkansas, California, shareholder of record owning 1 percent or more of the
lines have been completed. Colorado, Connecticut, Internal Revenue Service outstanding stock of the corporation may submit a Form
Delaware, District of RAIVS Team P.O. Box 9941 4506 but must provide documentation to support the
Purpose of form. Use Form 4506 to request a Columbia, Florida, Georgia, Mail Stop 6734 Ogden, UT requester’s right to receive the information.
copy of your tax return. You can also designate (on Hawaii, Idaho, Illinois, 84409
line 5) a third party to receive the tax return. Indiana, Iowa, Kansas, Partnerships. Generally, Form 4506 can be
Kentucky, Louisiana, Maine, signed by any person who was a member of the
How long will it take? It may take up to 75
Maryland, Massachusetts, partnership during any part of the tax period
calendar days for us to process your request.
Michigan, Minnesota, requested on line 7.
Tip. Use Form 4506-T, Request for Transcript of Mississippi, Missouri,
Tax Return, to request tax return transcripts, tax Montana, Nebraska, Nevada, All others. See section 6103(e) if the taxpayer
account information, W-2 information, 1099 New Hampshire, New Jersey, has died, is insolvent, is a dissolved corporation, or
information, verification of non-filing, and records of New Mexico, New York, North if a trustee, guardian, executor, receiver, or
account. Carolina, North Dakota, administrator is acting for the taxpayer.
Ohio, Oklahoma, Oregon,
Automated transcript request. You can quickly Pennsylvania, Rhode Island,
request transcripts by using our automated self- Note: If you are Heir at law, Next of kin, or
South Carolina, South Beneficiary you must be able to establish a material
help service tools. Please visit us at IRS.gov and
click on “Get a Tax Transcript" or call 1-800-908- Dakota, Tennessee, Texas, interest in the estate or trust.
9946. Utah, Vermont, Virginia,
Washington, West Virginia, Documentation. For entities other than
Where to file. Attach payment and mail Form 4506 Wisconsin, Wyoming, a individuals, you must attach the authorization
to the address below for the state you lived in, or foreign country, American document. For example, this could be the letter
the state your business was in, when that return Samoa, Puerto Rico, Guam, from the principal officer authorizing an employee of
was filed. There are two address charts: one for the Commonwealth of the the corporation or the letters testamentary
individual returns (Form 1040 series) and one for all Northern Mariana Islands, the
other returns. authorizing an individual to act for an estate.
US Virgin Islands, or A.P.O.
If you are requesting a return for more than or F.P.O. address Signature by a representative. A representative
one year and the chart below shows two different can sign Form 4506 for a taxpayer only if this
addresses, send your request to the address based Specific Instructions authority has been specifically delegated to the
on the address of your most recent return. representative on Form 2848, line 5. Form 2848
Line 1b. Enter your employer identification number showing the delegation must be attached to Form
Chart for individual returns (EIN) if you are requesting a copy of a business 4506.
(Form 1040 series) return. Otherwise, enter the first social security
number (SSN) or your individual taxpayer
identification number (ITIN) Shown on the return. Privacy Act and Paperwork Reduction Act
If you filed an individual Mail to: Notice. We ask for the information on this form to
For example, if you are requesting Form 1040 that
return and lived in: establish your right to gain access to the requested
includes Schedule C (Form 1040), enter your SSN.
return(s) under the Internal Revenue Code. We
Alabama, Kentucky, Line 3. Enter your current address. If you use a need this information to properly identify the
Louisiana, Mississippi, P.O. box, please include it on this line 3. return(s) and respond to your request. If you
Tennessee, Texas, a foreign Internal Revenue Service request a copy of a tax return, sections 6103 and
Line 4. Enter the address shown on the last return 6109 require you to provide this information,
country, American Samoa, RAIVS Team
filed if different from the address entered on line 3. including your SSN or EIN, to process your request.
Puerto Rico, Guam, the Stop 6716 AUSC
If you do not provide this information, we may not
Commonwealth of the Austin, TX 73301 be able to process your request. Providing false or
Northern Mariana Islands, the Note: If the addresses on lines 3 and 4 are different
and you have not changed your address with the fraudulent information may subject you to penalties.
U.S. Virgin Islands, or A.P.O.
IRS, file Form 8822, Change of Address. For a
or F.P.O. address business address, file Form 8822-B, Change of Routine uses of this information include giving it to
Address or Responsible Party — Business. the Department of Justice for civil and criminal
Alaska, Arizona, Arkansas, litigation, and cities, states, the District of Columbia,
California, Colorado, Hawaii, and U.S. commonwealths and possessions for use
Signature and date. Form 4506 must be signed
in administering their tax laws. We may also
Idaho, Illinois, Indiana, Iowa, Internal Revenue Service and dated by the taxpayer listed on line 1a or 2a. disclose this information to other countries under a
Kansas, Michigan, Minnesota, RAIVS Team IF you completed line 5 requesting the return to be tax treaty, to federal and state agencies to enforce
Montana, Nebraska, Nevada, Stop 37106 sent to a third party, the IRS must receive Form federal nontax criminal laws, or to federal law
New Mexico, North Dakota, Fresno, CA 93888 4506 within 120 days of the date signed by the enforcement and intelligence agencies to combat
Oklahoma, Oregon, South taxpayer or it will be rejected. Ensure that all terrorism.
Dakota, Utah, Washington, applicable lines are completed before signing.
Wisconsin, Wyoming You are not required to provide the information
You must check the box in the signature requested on a form that is subject to the
Paperwork Reduction Act unless the form displays
Connecticut, Delaware, area to acknowledge you have the
a valid OMB control number. Books or records
District of Columbia, Florida, authority to sign and request the
relating to a form or its instructions must be
Georgia, Maine, Maryland, Internal Revenue Service information. The form will not be retained as long as their contents may become
Massachusetts, Missouri, RAIVS Team processed and returned to you if the box is unchecked. material in the administration of any Internal
New Hampshire, New Jersey, Stop 6705 S-2 Revenue law. Generally, tax returns and return
New York, North Carolina, Kansas City, MO 64999

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information are confidential, as required by section
6103.

The time needed to complete and file Form 4506
will vary depending on individual circumstances.
The estimated average time is: Learning about the
law or the form, 10 min.; Preparing the form, 16
min.; and Copying, assembling, and sending the
form to the IRS, 20 min.

If you have comments concerning the accuracy of
these time estimates or suggestions for making
Form 4506 simpler, we would be happy to hear
from you. You can write to:

Internal Revenue Service
Tax Forms and Publications Division
1111 Constitution Ave. NW, IR-6526
Washington, DC 20224.

Do not send the form to this address. Instead, see
Where to file on this page

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Case Info

Judge

WALLACE, III, WADDELL A. Track Judge’s New Case

Case No.

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Document Filed Date

January 25, 2023

Case Filing Date

December 17, 2022

County

Parties

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