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Filing # 200308092 E-Filed 06/11/2024 02:44:42 PM
07153 12807.1
Total Pages: 4
IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT
IN AND FOR MANATEE COUNTY, FLORIDA
CIVIL DIVISION
FRANCESCA OTERO-VARGAS CASE NO.
2024-CA-000231
PLAINTIFF,
VS.
ZACHARY MANLEY AND GEICO GENERAL
INSURANCE COMPANY,
DEFENDANTS.
DEFENDANT(S) REQUEST FOR PRODUCTION
Defendant(s), ZACHARY MANLEY, by and through the undersigned counsel, request(s)
Plaintiff(s), FRANCESCA OTERO-VARGAS, _ pursuant to Florida Rule of Civil
Procedure 1.350, to produce the following items within thirty (30) days of this Request to the
undersigned attorneys:
1 Copies of all tax returns, W-2 Forms, and any other evidence of income for all years
to date, beginning with the three (3) years preceding the subject accident.
2. Withholding statements, pay envelopes, deposit slips, and any other evidence of
income earned by Plaintiff(s) for the current calendar year.
3. Copies of any and all medical records, hospital records, emergency room records,
and records from any health care provider pertaining to the treatment of Plaintiff(s) for any
injurics sustained in the subject accident.
4. Copies of any and all medical records, hospital records, emergency room records,
health care provider records, X-ray films, CT films and MRI films pertaining to the treatment of
Plaintiff(s) for any reason in the seven (7) years prior to the subject accident.
5. Copies of any and all medical records, hospital records, emergency room records,
health care provider records, X-ray films, CT films and MRI films pertaining to the treatment of
Plaintiff(s) for any reason since the subject accident.
6. Copies of any and all medical bills and/or statements for services rendered, paid or
unpaid, as a result of the subject accident, including any bills for drugs or other related expenses.
*2024CA000231 AX" 200308092 Filed at Manatee County Clerk 06/11/2024 02:44:42 PM EDT
CASE NO, 2024-CA-000231
7. Copies of bills and/or estimates for the repair of Plaintiff's vehicle and any other
damaged property. If the vehicle was not repairable, in addition, attach estimates of the value of
the vehicle on the date of the alleged incident and estimates and/or receipts concerning salvage
value.
8. Any and all statements, including, but not limited to, recorded telephone interviews,
tapes, written statements, whether signed or unsigned, of Defendant(s) or any of their agents,
servants or employees, and all witnesses to the subject accident relative to the subject matter of
this action and/or any witnesses having knowledge regarding any and all facts and issucs in the
instant litigation.
9. Any and all photographs, diagrams or sketches of the scene of the subject accident.
10. Any and all photographs of the vehicles involved in the incident before and after the
subject accident.
11. Any and all photographs of Plaintiff(s) depicting injuries to Plaintiff(s) sustained as
a result of the subject accident.
12. Any releases, "Mary Carter Agreements", and any other type of settlement
agreements between Plaintifi(s) and any other party which may have been responsible for the
damages claimed by Plaintiff(s).
13. Any and all photographs, blow-ups, recordings, charts, graphs, sketches and any
other tangible items or documentary evidence which you intend to use during the trial of instant
litigation and which have not been produced in response to any ofthe preceding paragraphs.
14. All incident reports filed by Plaintiff(s) for any purpose, including, but not limited
to, reports to employer and/or insurance company regarding the subject accident, if applicable,
and/or any other reports filled out by Plaintiff(s).
1S All documents, papers or evidence to be introduced at trial.
16 All expert reports from any experts who will testify at trial.
17 Copy of the front and back of Plaintiff(s)’s health insurance card.
18. Copy of the front and back of Plaintiff(s)’s Medicare and/or Medicare Advantage
Plan card.
19. Copy of the front and back of Plaintiff(s)’s Medicaid card.
2
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CASE NO, 2024-CA-000231
20. Any and all documents, including a PIP log, evidencing insurance benefits paid for
or on behalf of Plaintiff as a result of the subject accident, including but not limited to insurance
payments, contractual adjustments and/or write-offs.
21. Any and all documents evidencing any and all liens, subrogated interests, and/or
collateral source subject to Florida Statute 768.76, being claimed as a result of the subject
accident, including but not limited to, written documentation from each designated insurer, lien
holder and/or their designated representatives, stating the exact amount of their lien and/or
subrogated interest.
22. Any and all documents evidencing any and all other expenses, including but not
limited to wage loss, mileage, prescriptions, co-pays, and/or non-medical out-of-pocket expenses
alleged to have been incurred by Plaintiff(s) as a result of the subject accident.
23. Copies of all monthly statements, bills, invoices, and records of all incoming and
outgoing calls and text messages, for any and all cellular phones and/or any kind of wireless
devices, notebooks, iPads, ete. you owned and/or you had on you and/or inside the subject
vehicle at the time of the crash, limited to the 24-hour period encompassing the date of the
subject accident.
24. Copy of marriage certificate if a derivative claim is being made for loss of
consortium, loss of service, or any other claim by your spouse as a result of personal injury to
yourself alleged to be as a result of the subject accident.
IT HEREBY CERTIFY that on the qm day of June . 2024,
3
*2024CA000231 AX" 200308092 Filed at Manatee County Clerk 06/11/2024 02:44:42 PM EDT
CASE NO, 2024-CA-000231
pursuant to Administrative Order No. AOSC13-49, a copy of the foregoing Defendant(s)
Request for Production has been electronically filed and served using the Florida Courts E-Filing
Portal to:
R. Ryan Sainz, Esquire
Florida Bar #: 105536
MORGAN & MORGAN TAMPA P.A.
2222 S Tamiami Trail
Sarasota, FL 34239
(813) 577-4739
(813) 318-5192
rrspleadings@forthepeople.com
draidon@forthepeople.com
Attorney for Plaintiff
LAW OFFICES OF DOLINA LORDEUS LASCAZE
Mailing Address Only:
4443 Lyons Road, Suite 206
Coconut Creek, FL 33073
Attorney Direct: (813) 476-1452
Fax: (877) 838-0840
Lh forhe
By:
DONNA FERRELL
FL Bar No. 62481
Attorncy for Defendant(s)
ZACHARY MANLEY
PRINCIPAL E-MAIL ADDRESS:
TAMPALEGAL@ALLSTATE.COM
Personal E-mail Address
(NOT for Service of Pleadings and Documents)
Donna.Ferrell@allstate.com
4
*2024CA000231 AX" 200308092 Filed at Manatee County Clerk 06/11/2024 02:44:42 PM EDT
Preview
Filing # 200308092 E-Filed 06/11/2024 02:44:42 PM 07153 12807.1 Total Pages: 4 IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR MANATEE COUNTY, FLORIDA CIVIL DIVISION FRANCESCA OTERO-VARGAS CASE NO. 2024-CA-000231 PLAINTIFF, VS. ZACHARY MANLEY AND GEICO GENERAL INSURANCE COMPANY, DEFENDANTS. DEFENDANT(S) REQUEST FOR PRODUCTION Defendant(s), ZACHARY MANLEY, by and through the undersigned counsel, request(s) Plaintiff(s), FRANCESCA OTERO-VARGAS, _ pursuant to Florida Rule of Civil Procedure 1.350, to produce the following items within thirty (30) days of this Request to the undersigned attorneys: 1 Copies of all tax returns, W-2 Forms, and any other evidence of income for all years to date, beginning with the three (3) years preceding the subject accident. 2. Withholding statements, pay envelopes, deposit slips, and any other evidence of income earned by Plaintiff(s) for the current calendar year. 3. Copies of any and all medical records, hospital records, emergency room records, and records from any health care provider pertaining to the treatment of Plaintiff(s) for any injurics sustained in the subject accident. 4. Copies of any and all medical records, hospital records, emergency room records, health care provider records, X-ray films, CT films and MRI films pertaining to the treatment of Plaintiff(s) for any reason in the seven (7) years prior to the subject accident. 5. Copies of any and all medical records, hospital records, emergency room records, health care provider records, X-ray films, CT films and MRI films pertaining to the treatment of Plaintiff(s) for any reason since the subject accident. 6. Copies of any and all medical bills and/or statements for services rendered, paid or unpaid, as a result of the subject accident, including any bills for drugs or other related expenses. *2024CA000231 AX" 200308092 Filed at Manatee County Clerk 06/11/2024 02:44:42 PM EDT CASE NO, 2024-CA-000231 7. Copies of bills and/or estimates for the repair of Plaintiff's vehicle and any other damaged property. If the vehicle was not repairable, in addition, attach estimates of the value of the vehicle on the date of the alleged incident and estimates and/or receipts concerning salvage value. 8. Any and all statements, including, but not limited to, recorded telephone interviews, tapes, written statements, whether signed or unsigned, of Defendant(s) or any of their agents, servants or employees, and all witnesses to the subject accident relative to the subject matter of this action and/or any witnesses having knowledge regarding any and all facts and issucs in the instant litigation. 9. Any and all photographs, diagrams or sketches of the scene of the subject accident. 10. Any and all photographs of the vehicles involved in the incident before and after the subject accident. 11. Any and all photographs of Plaintiff(s) depicting injuries to Plaintiff(s) sustained as a result of the subject accident. 12. Any releases, "Mary Carter Agreements", and any other type of settlement agreements between Plaintifi(s) and any other party which may have been responsible for the damages claimed by Plaintiff(s). 13. Any and all photographs, blow-ups, recordings, charts, graphs, sketches and any other tangible items or documentary evidence which you intend to use during the trial of instant litigation and which have not been produced in response to any ofthe preceding paragraphs. 14. All incident reports filed by Plaintiff(s) for any purpose, including, but not limited to, reports to employer and/or insurance company regarding the subject accident, if applicable, and/or any other reports filled out by Plaintiff(s). 1S All documents, papers or evidence to be introduced at trial. 16 All expert reports from any experts who will testify at trial. 17 Copy of the front and back of Plaintiff(s)’s health insurance card. 18. Copy of the front and back of Plaintiff(s)’s Medicare and/or Medicare Advantage Plan card. 19. Copy of the front and back of Plaintiff(s)’s Medicaid card. 2 *2024CA000231 AX" 200308092 Filed at Manatee County Clerk 06/11/2024 02:44:42 PM EDT CASE NO, 2024-CA-000231 20. Any and all documents, including a PIP log, evidencing insurance benefits paid for or on behalf of Plaintiff as a result of the subject accident, including but not limited to insurance payments, contractual adjustments and/or write-offs. 21. Any and all documents evidencing any and all liens, subrogated interests, and/or collateral source subject to Florida Statute 768.76, being claimed as a result of the subject accident, including but not limited to, written documentation from each designated insurer, lien holder and/or their designated representatives, stating the exact amount of their lien and/or subrogated interest. 22. Any and all documents evidencing any and all other expenses, including but not limited to wage loss, mileage, prescriptions, co-pays, and/or non-medical out-of-pocket expenses alleged to have been incurred by Plaintiff(s) as a result of the subject accident. 23. Copies of all monthly statements, bills, invoices, and records of all incoming and outgoing calls and text messages, for any and all cellular phones and/or any kind of wireless devices, notebooks, iPads, ete. you owned and/or you had on you and/or inside the subject vehicle at the time of the crash, limited to the 24-hour period encompassing the date of the subject accident. 24. Copy of marriage certificate if a derivative claim is being made for loss of consortium, loss of service, or any other claim by your spouse as a result of personal injury to yourself alleged to be as a result of the subject accident. IT HEREBY CERTIFY that on the qm day of June . 2024, 3 *2024CA000231 AX" 200308092 Filed at Manatee County Clerk 06/11/2024 02:44:42 PM EDT CASE NO, 2024-CA-000231 pursuant to Administrative Order No. AOSC13-49, a copy of the foregoing Defendant(s) Request for Production has been electronically filed and served using the Florida Courts E-Filing Portal to: R. Ryan Sainz, Esquire Florida Bar #: 105536 MORGAN & MORGAN TAMPA P.A. 2222 S Tamiami Trail Sarasota, FL 34239 (813) 577-4739 (813) 318-5192 rrspleadings@forthepeople.com draidon@forthepeople.com Attorney for Plaintiff LAW OFFICES OF DOLINA LORDEUS LASCAZE Mailing Address Only: 4443 Lyons Road, Suite 206 Coconut Creek, FL 33073 Attorney Direct: (813) 476-1452 Fax: (877) 838-0840 Lh forhe By: DONNA FERRELL FL Bar No. 62481 Attorncy for Defendant(s) ZACHARY MANLEY PRINCIPAL E-MAIL ADDRESS: TAMPALEGAL@ALLSTATE.COM Personal E-mail Address (NOT for Service of Pleadings and Documents) Donna.Ferrell@allstate.com 4 *2024CA000231 AX" 200308092 Filed at Manatee County Clerk 06/11/2024 02:44:42 PM EDT