On August 31, 2021 a
Response to Request for Production
was filed
involving a dispute between
Hincapie, Adriana,
Hincapie, Nicolas,
and
State Farm Mutual Automobile Insurance Company,
Wezkiewicz, Joseph Bernard, Iii,
for Auto Negligence
in the District Court of Broward County.
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Filing# 160546468 E-Filed 1 1/03/2022 10:29:48 AM
IN THE CIRCUIT COURT OF THE SEVENTEENTH
JUDICIAL CIRCUIT IN AND FOR BROWARD
COUNTY, FLORIDA
ADRIANA HINCAPIE AND NICOLAS CASE NO.: CACE 21-016648 (14)
HINCAPIE,
Plaintiffs,
VS.
JOSEPH BERNARD WEZKIEWICZ,
Defendant.
i
DEFENDANT'S RESPONSE TO PLAINTIFFS' SUPPLEMENTAL
REOUEST FOR PRODUCTION
COMES NOW the Defendant, JOSEPH BERNARD WEZKIEWICZ (hereinafter
"Defendant"), by and through his undersigned attorneys, files his Response to the Plaintiffs',ADRIANA
HINCAPIE AND NICOLAS HINCAPIE (hereinafter "Plaintiff'), Supplemental Request for
Production dated October 13, 2022, and states as follows:
1 Make available Orange 2018
the BMW
320I with VIN# WBA8B9G54JNU96893 for an
inspection and database download of the same vehicle.
As indicated in the Plaintiffs Answer to Interrogatory No. 24 dated 11/11/21, the vehicle
which the Defendant was driving was deemed a total loss and no longer in possession of the
Defendant.
I HEREBY CERTIFY that on November 3, 2022, the foregoing was electronicallyfiled with the
Florida Courts E-Filing Portal and that as a registeredparticipantof the Portal have effectuated service
I
through the Portal in compliance with Rule 2.516, Fla. R. Jud. Admin., on Karl W. Lahertew, B. C.S.
klabertew@rubensteinlaw.com, lbosch@rubensteinlaw.com, eservice(*rubensteinlaw.com,Rubenstein
Law, P.A., 9130 S. Dadeland Blvd., PH, Miami, FL 33156.
NICHOLAS J. RYAN & ASSOCIATES
110 S. E. 6th Street,Suite 2100
Fort Lauderdale, FL 33301
Telephone: (954) 627-9401
E-mail for service (FL R. Jud. Admin. 2.516):
flor.law-shericritelli.2980 19@statefarm.com
?
Juul.CiADU
Sheri L. Critelli,
Esq.
Florida Bar No.: 813508
Attorney for Defendant
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/03/2022 10:29:48 AM.****
Document Filed Date
November 03, 2022
Case Filing Date
August 31, 2021
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Filing# 160546468 E-Filed 1 1/03/2022 10:29:48 AM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA ADRIANA HINCAPIE AND NICOLAS CASE NO.: CACE 21-016648 (14) HINCAPIE, Plaintiffs, VS. JOSEPH BERNARD WEZKIEWICZ, Defendant. i DEFENDANT'S RESPONSE TO PLAINTIFFS' SUPPLEMENTAL REOUEST FOR PRODUCTION COMES NOW the Defendant, JOSEPH BERNARD WEZKIEWICZ (hereinafter "Defendant"), by and through his undersigned attorneys, files his Response to the Plaintiffs',ADRIANA HINCAPIE AND NICOLAS HINCAPIE (hereinafter "Plaintiff'), Supplemental Request for Production dated October 13, 2022, and states as follows: 1 Make available Orange 2018 the BMW 320I with VIN# WBA8B9G54JNU96893 for an inspection and database download of the same vehicle. As indicated in the Plaintiffs Answer to Interrogatory No. 24 dated 11/11/21, the vehicle which the Defendant was driving was deemed a total loss and no longer in possession of the Defendant. I HEREBY CERTIFY that on November 3, 2022, the foregoing was electronicallyfiled with the Florida Courts E-Filing Portal and that as a registeredparticipantof the Portal have effectuated service I through the Portal in compliance with Rule 2.516, Fla. R. Jud. Admin., on Karl W. Lahertew, B. C.S. klabertew@rubensteinlaw.com, lbosch@rubensteinlaw.com, eservice(*rubensteinlaw.com,Rubenstein Law, P.A., 9130 S. Dadeland Blvd., PH, Miami, FL 33156. NICHOLAS J. RYAN & ASSOCIATES 110 S. E. 6th Street,Suite 2100 Fort Lauderdale, FL 33301 Telephone: (954) 627-9401 E-mail for service (FL R. Jud. Admin. 2.516): flor.law-shericritelli.2980 19@statefarm.com ? Juul.CiADU Sheri L. Critelli, Esq. Florida Bar No.: 813508 Attorney for Defendant *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/03/2022 10:29:48 AM.****