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Filing # E-Filed 03/15/2021 11:52:41 AM
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IN AND FOR VOLUSIA COUNTY, FLORIDA
TAMMY BRADFORD,
individually, and as Personal
Representative of the Estate
of MICHAEL BLAZE BRADFORD,
deceased; and as Personal
Representative of the
Estate of WARREN MICHAEL BRADFORD,
Deceased
Plaintiff, Case No. 2019-10377 CIDL
vs.
MICHELIN NORTH AMERICA, INC.,
a foreign corporation and
DISCOUNT TIRE CO., a
Florida corporation
Defendant.
/
NOTICE OF PRODUCTION OF NON-PARTY
YOU ARE NOTIFIED that ten (10) days from the date of this notice, if no objection is
received from any party, RecordTrak, a Magna Legal Services Co, on behalf David M. Tarlow.,
Attorney for the Defendant, Discount Tire Co., will issue the attached subpoena directed to the
following non-party(s) to produce the items listed therein at the time and place specified in the
subpoena:
GEICO GENERAL INSURANCE COMPANY
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 15th day of March 2021, a true and correct copy of the
foregoing has been furnished by Eservice to Skip Lynch Esq., Attorney for Plaintiff„ Kaster, Lynch,
Farrar & Ball, LLP 125 NE 1ST Ave, Ocala Fl, 34478; skip@thetirelawyers.com,
brk@thetirelawyers.com, daneen@thetirelawyers.com and the original has been filed with the Court.
QUINTAIROS, PRIETO, WOOD &
BOYER, P.A.
Attorney for Discount Tire
2400 E. Commercial Blvd.
Suite 520
Fort Lauderdale, FL 33308
Telephone: (954) 523-7008
Facsimile: (954) 523-7009
By: /s/ David M. Tarlow
DAVID M. TARLOW
Florida Bar No.: 893684
Email: dtarlow.pleadings@qpwblaw.com
IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT,
IN AND FOR VOLUSIA COUNTY, FLORIDA
TAMMY BRADFORD,
individually, and as Personal
Representative of the Estate
of MICHAEL BLAZE BRADFORD,
deceased; and as Personal
Representative of the
Estate of WARREN MICHAEL BRADFORD,
Deceased
Plaintiff, Case No. 2019-10377 CIDL
vs.
MICHELIN NORTH AMERICA, INC.,
a foreign corporation and
DISCOUNT TIRE CO., a
Florida corporation
Defendant.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA, TO:
GEICO GENERAL INSURANCE COMPANY
ATTENTION: CFO l SERVICE OF PROCESS SECTION
200 E. GAINES ST
TALLAHASSEE, FL 32399
YOU ARE COMMANDED to mail to RecordTrak, Inc., A Magna Legal Services Company, at
651 Allendale Road, P.O. Box 61591, King of Prussia, PA 19406, within ten (10) days of receipt hereof,
the following: SEE ATTACHED EXHIBIT A.
Any and all insurance policies, insurance claim forms, medical/PIP payout sheets, medical payment
sheets, medical bills, canceled checks, and other documentation, health insurance records, including but
not limited to: claims, summaries, notes, investigatory and economic analysis materials, check stubs, of
whatever type or nature, which evidence coverage and/or payments made for the benefit of THIS WILL
NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN.
If you fail to:
(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena,
You may be in contempt of court. You are subpoenaed to appear by the following attorneys, and unless
excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as directed.
For the Court,
DAVID M. TARLOW
Attorney for Discount Tire
QUINTAIROS, PRIETO, WOOD &
BOYER, P.A.
2400 E. Commercial Blvd.
Suite 520
Fort Lauderdale, FL 33308
Telephone: (954) 523-7008
Facsimile: (954) 523-7009
By: /s/ David M. Tarlow
DAVID M. TARLOW
Florida Bar No.: 893684
Email: dtarlow.pleadings@qpwblaw.com
EXHIBIT A
RE: TAMMY BRADFORD, INDIVIDUALLY, AND AS PERSONAL REPR vs. MICHELIN NORTH
AMERICA, INC., A FOREIGN CORPORATIO
NO. 2019-10377 CIDL
FILE #: 351066; TAG 11
LOCATION: GEICO GENERAL INSURANCE COMPANY
RECORDS PERTAIN TO: WARREN BRADFORD SS #: , DOB: AKA:
1 . Complete, legible copies of the entire claim file, including but not limited to all PIP related records, property damage records,
correspondence, memoranda, color photos, payment records, invoices, estimates, police reports, operator reports, and the like,
pertaining to a motor vehicle accident involving WARREN BRADFORD on TUNE 1, 2017.
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Filing # E-Filed 03/15/2021 11:52:41 AM 111 X X Illi 4,....,11\4,...., L.I1 X 4,....A.-I LI 1\ X l_/12 X X Illi 0 Ili V 12-il 1 X XX j LI 1/14,....,11-t1.1 4,....,11\4,...., LI X X , IN AND FOR VOLUSIA COUNTY, FLORIDA TAMMY BRADFORD, individually, and as Personal Representative of the Estate of MICHAEL BLAZE BRADFORD, deceased; and as Personal Representative of the Estate of WARREN MICHAEL BRADFORD, Deceased Plaintiff, Case No. 2019-10377 CIDL vs. MICHELIN NORTH AMERICA, INC., a foreign corporation and DISCOUNT TIRE CO., a Florida corporation Defendant. / NOTICE OF PRODUCTION OF NON-PARTY YOU ARE NOTIFIED that ten (10) days from the date of this notice, if no objection is received from any party, RecordTrak, a Magna Legal Services Co, on behalf David M. Tarlow., Attorney for the Defendant, Discount Tire Co., will issue the attached subpoena directed to the following non-party(s) to produce the items listed therein at the time and place specified in the subpoena: GEICO GENERAL INSURANCE COMPANY CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 15th day of March 2021, a true and correct copy of the foregoing has been furnished by Eservice to Skip Lynch Esq., Attorney for Plaintiff„ Kaster, Lynch, Farrar & Ball, LLP 125 NE 1ST Ave, Ocala Fl, 34478; skip@thetirelawyers.com, brk@thetirelawyers.com, daneen@thetirelawyers.com and the original has been filed with the Court. QUINTAIROS, PRIETO, WOOD & BOYER, P.A. Attorney for Discount Tire 2400 E. Commercial Blvd. Suite 520 Fort Lauderdale, FL 33308 Telephone: (954) 523-7008 Facsimile: (954) 523-7009 By: /s/ David M. Tarlow DAVID M. TARLOW Florida Bar No.: 893684 Email: dtarlow.pleadings@qpwblaw.com IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT, IN AND FOR VOLUSIA COUNTY, FLORIDA TAMMY BRADFORD, individually, and as Personal Representative of the Estate of MICHAEL BLAZE BRADFORD, deceased; and as Personal Representative of the Estate of WARREN MICHAEL BRADFORD, Deceased Plaintiff, Case No. 2019-10377 CIDL vs. MICHELIN NORTH AMERICA, INC., a foreign corporation and DISCOUNT TIRE CO., a Florida corporation Defendant. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA, TO: GEICO GENERAL INSURANCE COMPANY ATTENTION: CFO l SERVICE OF PROCESS SECTION 200 E. GAINES ST TALLAHASSEE, FL 32399 YOU ARE COMMANDED to mail to RecordTrak, Inc., A Magna Legal Services Company, at 651 Allendale Road, P.O. Box 61591, King of Prussia, PA 19406, within ten (10) days of receipt hereof, the following: SEE ATTACHED EXHIBIT A. Any and all insurance policies, insurance claim forms, medical/PIP payout sheets, medical payment sheets, medical bills, canceled checks, and other documentation, health insurance records, including but not limited to: claims, summaries, notes, investigatory and economic analysis materials, check stubs, of whatever type or nature, which evidence coverage and/or payments made for the benefit of THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. If you fail to: (1) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena, You may be in contempt of court. You are subpoenaed to appear by the following attorneys, and unless excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as directed. For the Court, DAVID M. TARLOW Attorney for Discount Tire QUINTAIROS, PRIETO, WOOD & BOYER, P.A. 2400 E. Commercial Blvd. Suite 520 Fort Lauderdale, FL 33308 Telephone: (954) 523-7008 Facsimile: (954) 523-7009 By: /s/ David M. Tarlow DAVID M. TARLOW Florida Bar No.: 893684 Email: dtarlow.pleadings@qpwblaw.com EXHIBIT A RE: TAMMY BRADFORD, INDIVIDUALLY, AND AS PERSONAL REPR vs. MICHELIN NORTH AMERICA, INC., A FOREIGN CORPORATIO NO. 2019-10377 CIDL FILE #: 351066; TAG 11 LOCATION: GEICO GENERAL INSURANCE COMPANY RECORDS PERTAIN TO: WARREN BRADFORD SS #: , DOB: AKA: 1 . Complete, legible copies of the entire claim file, including but not limited to all PIP related records, property damage records, correspondence, memoranda, color photos, payment records, invoices, estimates, police reports, operator reports, and the like, pertaining to a motor vehicle accident involving WARREN BRADFORD on TUNE 1, 2017.