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Filing # 191712806 E-Filed 02/12/2024 07:55:37 AM
0652550542.2 UMM
Total Pages: 1
IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT
IN AND FOR MANATEE COUNTY, FLORIDA
CIVIL DIVISION
KENNETH H. SCOTT, CASE NO.
2024CA0090
PLAINTIFF,
VS.
ALLSTATE INSURANCE COMPANY,
A FOREIGN PROFIT CORPORATION,
DEFENDANT.
DEFENDANT’S REQUEST FOR PRODUCTION
Defendant, ALLSTATE INSURANCE COMPANY, by and through the undersigned
counsel, requests Plaintiff, KENNETH H. SCOTT, 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, or 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, or 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.
"2024CA000090AX" 191712806 Filed at Manatee County Clerk 02/12/2024 07:55:36 AM EST
7. Copics 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 issues 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.
ll. 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 scttlement
agreements between Plaintiff(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 of the 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}.
15 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.
20. Any and all documents, including a PIP log, evidencing insurance benefits paid for
or on behalf of Plaintiffas 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
"2024CA000090AX" 191712806 Filed at Manatee County Clerk 02/12/2024 07:55:36 AM EST
accident, including but not limited to, written documentation from cach 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, cte. 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.
1 HEREBY CERTIFY that on the 12th day of February , 2024,
"2024CA000090AX" 191712806 Filed at Manatee County Clerk 02/12/2024 07:55:36 AM EST
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:
Edward M. Murphy, Esquire
Florida Bar No. 0067792
LEGLER, MURPHY & BATTAGLIA, LLP
2411 Manatee Avenue West
Bradenton, FL 34205
Tel: (941) 748-5599
Fax: (941) 747-2371
ed@allinjurieslaw.com
hannah@allinjurieslaw.com
Attorney for Plaintiff
LAW OFFICES OF DOLINA LORDEUS LASCAZE
Mailing Address Only:
4443 Lyons Road, Suite 206
Coconut Creek, FL 33073
Attorney Direct: (727) 295-8499
Fax: (877) 838-0840
By /s/ Wendy B. Accardi
WENDY B. ACCARDI
FL Bar No. 587028
Attorney for Defendant
ALLSTATE INSURANCE COMPANY
PRINCIPAL E-MAIL ADDRESS:
TAMPALEGAL@ALLSTATE.COM
Personal E-mail Address
(NOT for Service of Pleadings and Documents):
Wendy.Accardi@allstate.com
"2024CA000090AX" 191712806 Filed at Manatee County Clerk 02/12/2024 07:55:36 AM EST
Preview
Filing # 191712806 E-Filed 02/12/2024 07:55:37 AM 0652550542.2 UMM Total Pages: 1 IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR MANATEE COUNTY, FLORIDA CIVIL DIVISION KENNETH H. SCOTT, CASE NO. 2024CA0090 PLAINTIFF, VS. ALLSTATE INSURANCE COMPANY, A FOREIGN PROFIT CORPORATION, DEFENDANT. DEFENDANT’S REQUEST FOR PRODUCTION Defendant, ALLSTATE INSURANCE COMPANY, by and through the undersigned counsel, requests Plaintiff, KENNETH H. SCOTT, 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, or 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, or 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. "2024CA000090AX" 191712806 Filed at Manatee County Clerk 02/12/2024 07:55:36 AM EST 7. Copics 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 issues 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. ll. 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 scttlement agreements between Plaintiff(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 of the 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}. 15 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. 20. Any and all documents, including a PIP log, evidencing insurance benefits paid for or on behalf of Plaintiffas 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 "2024CA000090AX" 191712806 Filed at Manatee County Clerk 02/12/2024 07:55:36 AM EST accident, including but not limited to, written documentation from cach 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, cte. 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. 1 HEREBY CERTIFY that on the 12th day of February , 2024, "2024CA000090AX" 191712806 Filed at Manatee County Clerk 02/12/2024 07:55:36 AM EST 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: Edward M. Murphy, Esquire Florida Bar No. 0067792 LEGLER, MURPHY & BATTAGLIA, LLP 2411 Manatee Avenue West Bradenton, FL 34205 Tel: (941) 748-5599 Fax: (941) 747-2371 ed@allinjurieslaw.com hannah@allinjurieslaw.com Attorney for Plaintiff LAW OFFICES OF DOLINA LORDEUS LASCAZE Mailing Address Only: 4443 Lyons Road, Suite 206 Coconut Creek, FL 33073 Attorney Direct: (727) 295-8499 Fax: (877) 838-0840 By /s/ Wendy B. Accardi WENDY B. ACCARDI FL Bar No. 587028 Attorney for Defendant ALLSTATE INSURANCE COMPANY PRINCIPAL E-MAIL ADDRESS: TAMPALEGAL@ALLSTATE.COM Personal E-mail Address (NOT for Service of Pleadings and Documents): Wendy.Accardi@allstate.com "2024CA000090AX" 191712806 Filed at Manatee County Clerk 02/12/2024 07:55:36 AM EST