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Filing # 157928132 E-Filed 09/22/2022 10:41:52 AM
IN THE CIRCUIT COURT OF THE
FOURTH JUDICIAL CIRCUIT, IN AND FOR
DUVAL COUNTY, FLORIDA
CASE NO.: 16-2022-CA-004328
DIVISION: CV-G
CLARENCE MITCHELL,
Plaintiff,
vs.
VICTORIA NIKALE GREEN, an individual,
JULENE TURBEVILLE, an individual, and
LINDSAY TYLER DENNIS, an individual,
Defendants.
DEFENDANT LINDSAY TYLER DENNIS’
REQUEST FOR PRODUCTION TO PLAINTIFF.
TO Clarence Mitchell
c/o Jessica L. Lanifero, Esquire
Morgan & Morgan, P.A.
501 Riverside Avenue, Suite 1200
Jacksonville, FL 32202
Defendant, Lindsay Tyler Dennis, pursuant to Rules 1.280 and 1.350, Florida Rules of
Civil Procedure, requests that you produce to Defendant’s undersigned attorneys, at their law
offices at 4811 Beach Boulevard, Suite 303, Jacksonville, FL 32207, certain items for inspection
and copying. Defendant requests that you produce the following:
1 All of your hospital and medical records (including x-ray, MRI, and CT scan films)
and reports regarding the injuries which you claim to have sustained as a result of
the accident alleged in your Complaint.
All of your hospital, medication, and medical bills regarding the injuries you claim
Page 1 of 4
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 09/22/2022 11:58:22 AM
to have sustained as a result of the accident alleged in your Complaint.
All other bills or documentary evidence of expenses which you claim to be related
to, and caused by, the accident alleged in your Complaint.
All medical records, and records of other healthcare providers from doctors,
hospitals or anyone else, who has rendered healthcare treatment to you for any
injury or medical condition that pre-existed the accident described in the
Complaint, but alleged to have been aggravated by the accident.
If you have applied for and/or received Medicare benefits, please sign the
authorization, original attached, requesting Medicare records.
If you have applied for and/or received Medicaid benefits, please sign the
authorization, original attached, requesting Medicaid records.
All federal income tax returns and all W-2 forms for the time period beginning five
years before the accident described in the Complaint and continuing to the present,
plus all records of earnings to date for this year.
Signed authorizations, originals (two) attached, requesting federal income tax
records for the time period beginning five years before the accident.
Photographs and negatives purporting to show your injuries, your automobile
following the accident alleged in your Complaint, or the scene of the accident
alleged in the Complaint.
10. A copy of the enrollment card, membership verification, or other documentation
indicating any medical insurance coverage.
ll All documents identified in your answers to interrogatories.
12. Photocopies of any driver’s licenses you hold or any other form of photographic
identification.
13 All documents evidencing payment of medical bills or lost earnings by collateral
sources or evidencing attempts by you to obtain payment from sources other than
this Defendant.
14 All estimates and bills for repair of any damage to the vehicles as a result of the
accident that is alleged in your Complaint.
15, All recorded, written, or transcribed statements made by witnesses to the accident
alleged in your Complaint.
Page 2 of 4
16 Signed authorization, original attached, requesting Social Security records.
17 If you have ever served in any branch of the military, please sign the authorization,
original attached, requesting military records.
18 Copies of all letters of protection, doctor’s lien, forbearance agreements, or any
similar documents you or your attorney has executed in favor of any
medical/healthcare provider.
19. All notices of lien that you have received from any entity for any reason.
In support of this request for production, Defendant states that the items listed above are in
the possession, custody, and control of Plaintiff, that those items constitute or contain matters
within the scope of Rule 1.280(b), Florida Rules of Civil Procedure, that Defendant needs those
items in the preparation of this case, and that Defendant is unable, without undue hardship, to
obtain the substantial equivalent of those items by other means.
O'HARA LAW FIRM,
Professional Association
feo
Brian M. Guter
Florida Bar No, 113681
Michael P. Regan, Jr.
Florida Bar No. 20311
4811 Beach Boulevard, Suite 303
Jacksonville, FL 32207
Telephone (904) 346-3166
Facsimile (904) 346-5445
Service E-Mail: eService @ oharalawfirm.com
Attorneys for Lindsay Tyler Dennis
Page 3 of 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy hereof has been furnished to Jessica L. Lanifero,
Esquire, Morgan & Morgan, P.A., 501 Riverside Avenue, Suite 1200, Jacksonville, FL 32202, via
e-service at jlanifero@forthepeople.com, cfitslaff@ forthepeople.com and
mjohnson
@ forthepeople.com and to Kendra B. Therrell, Esquire, Law Offices of Kubicki Draper,
76 South Laura Street, Suite 1400, Jacksonville, FL 32202, via e-service at
KBT-KD @kubickidraper.com, mpanganiban
@ forthepeople.com and rkisling@forthepeople.com
and to E. Holland Howanitz, Esquire, Wicker Smith O’Hara Mccoy & Ford P.A., 50 North Laura
Street, Suite 2700, Jacksonville, FL 32202, via e-service at JAXcrtpleadings@wickersmith.com
on this 22™ day of September, 2022.
b20x
Brian M. Guter
Michael P. Regan, Jr.
Page 4 of 4
MEDICARE AUTHORIZATION FORM
**ALL SECTIONS REQUIRED * *
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E1 Release records in timeframe from start date ane va to end date:
include all records
NY residents only:
G exclude information about alcohol and drug abuse, mental health treatment, and HIV
tndicate whether authorization release is for a one-time disclosure, or Identify a future date or event when the authorization will expire.
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Select one option: Cexpiration upon specified date Cc).
Dl expiration upon specified event
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Reniaa RUT Meleleless ou R Do not sign this form unless all applicable tines have been completed. OMB No. 1545-0429
(March 2019)
> Request may be rejected if the form Is incomplete or illegible.
pibeal Rovsnse‘theService
Treasury » For more information about Form 4506, visit www.irs.gov/form4506.
Tip. You may be able to get your tax retum or retum information from other sources. if you had your tax retum completed by a paid preparer, they
should be able to provide you a copy of tha retum. The IRS can provide a Tax Retum 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
requires. See Form 4506-T, Request for Transcript of Tax Retum, or qi request transcripts by using our automated self-help service
tools. Please visit us at IRS.gov and cli lick on “Get a Tax Transcript..." or ‘call 1-80010-908-9946.
Ya Name shown on tax retum. If a joint return, enter the name shown first. 1b First social security number on tax return,
Individual taxpayer Identification number, or
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Caution: If the tax retum is being malted to a third party, ensure that you have filled in lines6 and 7 before signing. Sign and date the form once you
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§, the IRS has no contro! aver 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 retum requested. Form 1040, 1120, 941, etc, and all attachments as originally submitted to the IRS, including Form(s) W-2,
schedules, or amended retums. es of Forms 1040, 1040A, and 1040EZ are generally available for 7 from filing before they are
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type of retum, you must complete another Form 4506.
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Yearor period requested. Enter the ending date of the year or period, using the mm/dd/yyyy format. I
elght yearsor periods, you must attach another Form 4506.
you are equesing
move than
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Cost for each retum: . : $ 50.00
b ‘Numberof retums requested ontine 7 : . :
c Total cost, Multiply line 8a byline 8b. . . + $
9 If we cannot find the tax retum, we will refund the fee. Te refund should go to the third party ated on tne, ch eck here . : O
Caution: Do not sign this form unless all applicable tines have been completed.
‘Signature of taxpayer(s). 1 declare that | am either the ayer whose name is shown on line 1a or 2a, or a person auiiorized to obtain the tax retum
requested. If the request applies to a joint retum, at least one spouse must sign. If signed by a corporate officer, 1 percent or more shareholder, er,
member, guardian, tax matters partner, executor, receiver, tor, trustee, or party other than the taxpayer, | certify that | have the authorityto
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D Signatory attests that he/she has read the attestation clause and upon so reading
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Sign » ‘Signature (sea instructions)
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» ‘Tile (line ta above ls a corporation, partnership,
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For Privacy
Act and Paperwork Reduction Act Notice, see page 2. No, 417216 Form 4506 (Rev. 3-2019)
Form 4506 (Rev. 3-2019) Page 2
references aro,to the Internal Revenue Code Chart for all other returns Corporations. Generally, Form 4506 canbe
untessot signed by: (1) an officer having togal authority to bind
tt you fived in. . (2) any person designated by
Future Developments or your business: Mall to: board of directors or other governing body, or (3)
For the latest Information about Form 4506 and its was In: ‘or employeeon jon requestby
go to win. govltomés06. ‘officer
and attested to the secretaryor
information ‘about any recent developments affecting
other officer,
A bona fide. ider of record
Alabama, Alaska, owning 1 percent or more of the
Form 4506, Form 4506-T and Form 4506T-EZ willbe may submit a Form 4506 but must
posted
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How long will it take? it trey oko upto 75 Michigan, Minnesota, trustee, guardian, executor, recelver, or
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‘Missouri, Montana, Note: If you are Helrat law, Next
of kin, or
ip. Roa Forin S506-F,- Request for Transcript of Tax Nebraska, Nevada, New
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Roum, toi
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information, 2 intormatons 1099 information,
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‘New Mexico, New York, tntemal pevene Service Interast
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Whereto and mail Form 4506
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requesting Form 1040 that {itigation, and citles, states, the District
of Columbia,
RAIVS Team
iets Ete Com 8 en your So U.S. commonwealths possessionsfor use
Stop 6716 AUSC in administering their tax laws. We may also
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of the Austin, TX 73301 Une 3, Enter your curren ityou
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rN
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