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Filing# 165800234 E-Filed 01/31/2023 10:56:35 AM
INTHE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT IN
AND FOR BROWARD COUNTY, FLORIDA
ADRIANA HINCAPIE and
NICHOLAS HINCAPIE, CASE NO: CACE 21-016648 (14)
Plaintiffs,
V.
JOSEPH BERNARD WEZKIEWICZ, JR-,
JOSEPH BERNARD WEZKIEWICZ, IH, and
STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY,
A ForeignCorporation,
Defendants.
i
PLAINTIFF'S NOTICE OF PRODUCTION FROM NON PARTY
(Pursuant to Fla.R.Civ.P. 1.351)
YOU ARE HEREBY NOTIFED that after ten (10) days from the date of service of this
Notice, and if no objectionis received from any party, the undersigned will issue the attached
Subpoena(s)directed to the followingRecords Custodian(s):
1. Florida Department of Highway Safety and Motor Vehicles
c/o FHP Crash Records
Division of Motorist Services
2900 Apalachee Parkway
Mail Stop 28
Tallahassee,Florida 32399
The above listed are not a party to this lawsuit and are requestedto produce the items listed
at the time and placespecifiedin the attached Subpoena(s).
If you wish to receive copiesofthese documents, pleaseadvise the undersigned,in writing,
and same will be provided, at a cost for photocopies,upon receipt.
PLEASE BE GOVERNED ACCORDINGLY.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/31/2023 10:56:30 AM.****
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 31'
I St
day of January 2023, I filed the
electronically
foregoing with the Clerk of Courts using the Florida e-portalsystem which will send electronic
notice to all counsel of record.
RUBENSTEIN LAW, P.A.
Attorneys for Plaintiff
9130 S. Dadeland Blvd, PH
Miami, FL 33156
Tel: (305) 661-6000
Fax: (407) 987-6630
Email: klabertew@rubensteinlaw.corn
lbosch@rubensteinlaw.com
eservice(*rubensteinlaw.com
By: -is/Karl W. Labertew
Karl W. Labertew, B.C.S.
Florida Bar No.. 0615234
-2-
INTHE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT IN
AND FOR BROWARD COUNTY, FLORIDA
ADRIANA HINCAPIE and
NICHOLAS HINCAPIE, CASE NO: CACE 21-016648 (14)
Plaintiffs,
V.
JOSEPH BERNARD WEZKIEWICZ, JR-,
JOSEPH BERNARD WEZKIEWICZ, IH, and
STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY,
A ForeignCorporation,
Defendants.
i
SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS
WITHOUT DEPOSITION PURSUANT TO F.R.C.P. 1.351
THE STATE OF FLORIDA:
TO: Florida Department of Highway Safety and Motor Vehicles
c/o FHP
Crash Records
Division of Motorist Services
2900 Apalachee Parkway
Mail Stop 28
Tallahassee, Florida 32399
YOU ARE HEREBY COMMANDED to produce without depositionat Rubenstein
Law, P.A., located at 9130 S. Dadeland Blvd, Penthouse Suite, Miami, FL 33156, within ten
(10) days from the date of service of this document, the following:
CAD Report for HSMV Crash Report Number #88372915 in Broward
County.
- Date/Time of Crash: 26/Jul/2020 02:20 PM
-
Date of Report: 26/Jul/2020 03:10 PM
-
Inv. Agency Report Number: FHPL20OFF040654
-
Reporting Officer: TPR M.T. Bain #1445
These items will be inspectedand may be copied at that time. You will not be requiredto
surrender the originalitems. You may comply with this Subpoena by providinglegible copiesof
the items to be produced to the attorney whose name appears on this Subpoena on or before the
scheduled date of production. You may condition the preparationof the copies upon the payment
in advance of the reasonable cost of preparation. You mav mail or deliver the copies to the
attornev whose name appears on this Subpoena and therebv eliminate vour appearance at
the time and place specified above. You have the rightto objectto the productionpursuant to
thisSubpoena at any time before productionby givingwritten notice to the attorney whose name
appears on this Subpoena.
IF YOU FAIL TO APPEAR, YOU MAY BE HELD IN CONTEMPT OF COURT.
You subpoenaed to appear by the following attorneys and unless excused from
are this
subpoena by these attorneys or the Court, you shall respond to this subpoena as directed.
DATED ON: ,2022.
RUBENSTEIN LAW, P.A.
Attorneys for Plaintiff
9130 S. Dadeland Blvd, PH
Miami, FL 33156
Tel: (305) 661-6000
Fax: (407) 987-6630
Email: klabertew@rubensteinlaw.corn
lbosch@rubensteinlaw.com
eservice(*rubensteinlaw.com
By: -is/Karl W. Labertew
Karl W. Labertew, B.C.S.
Florida Bar No.. 0615234
-2-
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Filing# 165800234 E-Filed 01/31/2023 10:56:35 AM INTHE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA ADRIANA HINCAPIE and NICHOLAS HINCAPIE, CASE NO: CACE 21-016648 (14) Plaintiffs, V. JOSEPH BERNARD WEZKIEWICZ, JR-, JOSEPH BERNARD WEZKIEWICZ, IH, and STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, A ForeignCorporation, Defendants. i PLAINTIFF'S NOTICE OF PRODUCTION FROM NON PARTY (Pursuant to Fla.R.Civ.P. 1.351) YOU ARE HEREBY NOTIFED that after ten (10) days from the date of service of this Notice, and if no objectionis received from any party, the undersigned will issue the attached Subpoena(s)directed to the followingRecords Custodian(s): 1. Florida Department of Highway Safety and Motor Vehicles c/o FHP Crash Records Division of Motorist Services 2900 Apalachee Parkway Mail Stop 28 Tallahassee,Florida 32399 The above listed are not a party to this lawsuit and are requestedto produce the items listed at the time and placespecifiedin the attached Subpoena(s). If you wish to receive copiesofthese documents, pleaseadvise the undersigned,in writing, and same will be provided, at a cost for photocopies,upon receipt. PLEASE BE GOVERNED ACCORDINGLY. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/31/2023 10:56:30 AM.**** CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 31' I St day of January 2023, I filed the electronically foregoing with the Clerk of Courts using the Florida e-portalsystem which will send electronic notice to all counsel of record. RUBENSTEIN LAW, P.A. Attorneys for Plaintiff 9130 S. Dadeland Blvd, PH Miami, FL 33156 Tel: (305) 661-6000 Fax: (407) 987-6630 Email: klabertew@rubensteinlaw.corn lbosch@rubensteinlaw.com eservice(*rubensteinlaw.com By: -is/Karl W. Labertew Karl W. Labertew, B.C.S. Florida Bar No.. 0615234 -2- INTHE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA ADRIANA HINCAPIE and NICHOLAS HINCAPIE, CASE NO: CACE 21-016648 (14) Plaintiffs, V. JOSEPH BERNARD WEZKIEWICZ, JR-, JOSEPH BERNARD WEZKIEWICZ, IH, and STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, A ForeignCorporation, Defendants. i SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS WITHOUT DEPOSITION PURSUANT TO F.R.C.P. 1.351 THE STATE OF FLORIDA: TO: Florida Department of Highway Safety and Motor Vehicles c/o FHP Crash Records Division of Motorist Services 2900 Apalachee Parkway Mail Stop 28 Tallahassee, Florida 32399 YOU ARE HEREBY COMMANDED to produce without depositionat Rubenstein Law, P.A., located at 9130 S. Dadeland Blvd, Penthouse Suite, Miami, FL 33156, within ten (10) days from the date of service of this document, the following: CAD Report for HSMV Crash Report Number #88372915 in Broward County. - Date/Time of Crash: 26/Jul/2020 02:20 PM - Date of Report: 26/Jul/2020 03:10 PM - Inv. Agency Report Number: FHPL20OFF040654 - Reporting Officer: TPR M.T. Bain #1445 These items will be inspectedand may be copied at that time. You will not be requiredto surrender the originalitems. You may comply with this Subpoena by providinglegible copiesof the items to be produced to the attorney whose name appears on this Subpoena on or before the scheduled date of production. You may condition the preparationof the copies upon the payment in advance of the reasonable cost of preparation. You mav mail or deliver the copies to the attornev whose name appears on this Subpoena and therebv eliminate vour appearance at the time and place specified above. You have the rightto objectto the productionpursuant to thisSubpoena at any time before productionby givingwritten notice to the attorney whose name appears on this Subpoena. IF YOU FAIL TO APPEAR, YOU MAY BE HELD IN CONTEMPT OF COURT. You subpoenaed to appear by the following attorneys and unless excused from are this subpoena by these attorneys or the Court, you shall respond to this subpoena as directed. DATED ON: ,2022. RUBENSTEIN LAW, P.A. Attorneys for Plaintiff 9130 S. Dadeland Blvd, PH Miami, FL 33156 Tel: (305) 661-6000 Fax: (407) 987-6630 Email: klabertew@rubensteinlaw.corn lbosch@rubensteinlaw.com eservice(*rubensteinlaw.com By: -is/Karl W. Labertew Karl W. Labertew, B.C.S. Florida Bar No.. 0615234 -2-