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Filing# 155847823 E-Filed 08/22/2022 05:51:10 PM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
JESSICA NICOLE GREGORY, CASE NO.: CACE21008836(21)
Plaintiff.
VS.
KESLEY MESALIEN AND
PROGRESSIVE SELECT INSURANCE
COMPANY,
Defendants.
i
DEFENDANT'S UPDATED REOUEST FOR PRODUCTION
PURSUANT TO RULE 1.350, Defendant, KESLEY MESALIEN (hereinafter"Defendant"), by
and through the undersigned attorneys, requests the Plaintiff,JESSICA NICOLE GREGORY (hereinafter
to translate or prepare in reasonably useable form and produce those documents and items
"Plaintiff'),
enumerated below at the office of the undersigned counsel and that the same be done within thirty(30) days
in accordance with said Rule.
1 Copies of any additional Federal Income Tax Returns, W-2 Statements and/or any other
business and/or income records, evidencing the Plaintiff' s income since the date of the
Plaintiff' s last response and/or which were not previouslyproduced by the Plaintiff.
2. Copies of any and all additional bills and/or estimates of repair to the vehicle and/or
damaged property and the cost of temporary or pennanent replacement thereof which were
not previously produced by the Plaintiff.
3. Copies of any and all additional medical or related bills,paid or owing, allegedlyresulting
from the within accident or occurrence which were not previously produced by the
Plaintiff.
4. Copies of any and all additional medical reports, doctors' reports, or reports rendered by
experts applicableto any and of this cause which were not previouslyproduced
all issues
by the Plaintiff.
5. Any and all additional statements, written or otherwise, made by any Defendant in this
matter which was not previously produced by the Plaintiff.
6. Copies of any and all additional photographs (laser copies), graphs, charts and other
documentary evidence of the scene, parties or vehicles involved in or pertaining to the
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/22/2022 05:51:10 PM.****
subjectaccident,occurrence or issues of this cause which were not previouslyproduced by
the Plaintiff.
7. Copies of any and all additional insurance policiesproviding benefits or coverage to the
for any claimed injuryor damage from the subjectaccident or occurrence which
Plaintiff(s)
were not previously produced by the Plaintiff.
8 Copies of any and all additional records of payments by collateral sources for damages
claimed by the Plaintiff as a result of the subject accident which were not previously
produced by the Plaintiff.
9. Copies of any and all additional medical bills incurred by the Plaintiff as a result of the
subjectaccident which were not previouslyproduced by the Plaintiff.
10. Copies of any and medical records relatingto the Plaintiff' s medical treatment to date
all
for the subjectaccident which were not previously produced by the Plaintiff.
This Defendant would show that hers is unable to obtain the materials requested without undue
expense and hardship. The articles are in the sole or exclusive possession of the Plaintiff,their agents or
attorneys, and as such these items are necessary for the Defendant to properly prepare this case.
I HEREBY CERTIFY that on August 23,2022, the foregoing was electronicallyfiled with the
Florida Courts E-Filing Portal and that as a registeredparticipantof the Portal I have effectuated service
through the Portal in compliance with Rule 2.516, Fla. R. Jud. Admin., on Alexandra M. Taboada-McGill,
Esq. ftlauderdalehc@progressive.com,ataboadl@progressive.com, Law Offices of Michael W. Carroll,
3230 West Commercial Blvd., Suite 400, Fort Lauderdale, FL 33309 and Robert C. Solomon, Esq.
solomon@sslegalfirm.com, candace@sslegalfirm.com, bedoya@sslegalfirm.com, Law Office of Saban &
Solomon, 150 North University Drive, Suite 200, Plantation,FL 33324.
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-lisabaligian.294019@statefarm.com
Lisa J. Baligian,Esq.
Florida Bar No.: 956181
Attorney for Defendant, Kesley Mesalien
Attorneys and StaffofNicholas J. Ryan &
Associates are Employees of
the Law Department of State Farm Mutual Automobile Insurance
Company
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Filing# 155847823 E-Filed 08/22/2022 05:51:10 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA JESSICA NICOLE GREGORY, CASE NO.: CACE21008836(21) Plaintiff. VS. KESLEY MESALIEN AND PROGRESSIVE SELECT INSURANCE COMPANY, Defendants. i DEFENDANT'S UPDATED REOUEST FOR PRODUCTION PURSUANT TO RULE 1.350, Defendant, KESLEY MESALIEN (hereinafter"Defendant"), by and through the undersigned attorneys, requests the Plaintiff,JESSICA NICOLE GREGORY (hereinafter to translate or prepare in reasonably useable form and produce those documents and items "Plaintiff'), enumerated below at the office of the undersigned counsel and that the same be done within thirty(30) days in accordance with said Rule. 1 Copies of any additional Federal Income Tax Returns, W-2 Statements and/or any other business and/or income records, evidencing the Plaintiff' s income since the date of the Plaintiff' s last response and/or which were not previouslyproduced by the Plaintiff. 2. Copies of any and all additional bills and/or estimates of repair to the vehicle and/or damaged property and the cost of temporary or pennanent replacement thereof which were not previously produced by the Plaintiff. 3. Copies of any and all additional medical or related bills,paid or owing, allegedlyresulting from the within accident or occurrence which were not previously produced by the Plaintiff. 4. Copies of any and all additional medical reports, doctors' reports, or reports rendered by experts applicableto any and of this cause which were not previouslyproduced all issues by the Plaintiff. 5. Any and all additional statements, written or otherwise, made by any Defendant in this matter which was not previously produced by the Plaintiff. 6. Copies of any and all additional photographs (laser copies), graphs, charts and other documentary evidence of the scene, parties or vehicles involved in or pertaining to the *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/22/2022 05:51:10 PM.**** subjectaccident,occurrence or issues of this cause which were not previouslyproduced by the Plaintiff. 7. Copies of any and all additional insurance policiesproviding benefits or coverage to the for any claimed injuryor damage from the subjectaccident or occurrence which Plaintiff(s) were not previously produced by the Plaintiff. 8 Copies of any and all additional records of payments by collateral sources for damages claimed by the Plaintiff as a result of the subject accident which were not previously produced by the Plaintiff. 9. Copies of any and all additional medical bills incurred by the Plaintiff as a result of the subjectaccident which were not previouslyproduced by the Plaintiff. 10. Copies of any and medical records relatingto the Plaintiff' s medical treatment to date all for the subjectaccident which were not previously produced by the Plaintiff. This Defendant would show that hers is unable to obtain the materials requested without undue expense and hardship. The articles are in the sole or exclusive possession of the Plaintiff,their agents or attorneys, and as such these items are necessary for the Defendant to properly prepare this case. I HEREBY CERTIFY that on August 23,2022, the foregoing was electronicallyfiled with the Florida Courts E-Filing Portal and that as a registeredparticipantof the Portal I have effectuated service through the Portal in compliance with Rule 2.516, Fla. R. Jud. Admin., on Alexandra M. Taboada-McGill, Esq. ftlauderdalehc@progressive.com,ataboadl@progressive.com, Law Offices of Michael W. Carroll, 3230 West Commercial Blvd., Suite 400, Fort Lauderdale, FL 33309 and Robert C. Solomon, Esq. solomon@sslegalfirm.com, candace@sslegalfirm.com, bedoya@sslegalfirm.com, Law Office of Saban & Solomon, 150 North University Drive, Suite 200, Plantation,FL 33324. 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-lisabaligian.294019@statefarm.com Lisa J. Baligian,Esq. Florida Bar No.: 956181 Attorney for Defendant, Kesley Mesalien Attorneys and StaffofNicholas J. Ryan & Associates are Employees of the Law Department of State Farm Mutual Automobile Insurance Company