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IN THE CIRCUIT COURT OF THE 15”
JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA
PETER DEGREGORY, III, CASE NO.: 502008CA002189XXXXMB
Division: AF
Plaintiff,
VS.
DISCOVERY PROPERTY & CASULATY
INSURANCE COMPANY, STATE FARM
MUTUAL AUTOMOBILE INSURANCE
COMPANY and FABIOLA ESPINOSA
O34
Defendant.
/
REQUEST FOR PRODUCTION
COMES NOW the Defendant, FABIOLA ESPINOSA, by and through undersigned
HESOLNY G2 e240
attorney, and pursuant to Fla.R.Civ.P. 1.350 requests the Plaintiff, PETER DEGREGORY, III, to
produce and permit the inspection, copying or photographing by or on behalf of this Defendant
of the following items within the time period permitted by said rule at the following location:
Law Office of Vivian M. Knapp, 1450 Centrepark Blvd., Suite 250, West Palm Beach, Florida
33401:
1. Copies of complete Federal Income Tax returns for the past seven (7) years,
together with records of earnings of the Plaintiff for the past seven (7) years. This request
includes all W-2 forms, S Corporation Tax Returns; Partnership Tax Returns; C Corporation Tax
Returns of which Plaintiff has any interest and all schedules thereto, as well as duly executed
Authorizations for Request for Copy of Tax Returns. (See Exhibit “A”).
2. All bills and statements for medical treatment, devices and medicines, the cost of
which is claimed to have been incurred as a result of the injuries sustained in this cause by the
Plaintiff.3. Any and all bills of hospitals in which Plaintiff has been a patient or received
treatment allegedly as a result of the injuries sustained in this cause by Plaintiff.
4. Repair estimates and repair bills for damages to Plaintiff's property allegedly
sustained as a result of the accident which is the subject of this cause. This request includes paid
and unpaid bills.
5. Any and all hospital records of Plaintiff for the accident which is the subject of
this cause.
6. Any and all medical records and written reports of physicians examining or
treating the Plaintiff, including radiologists. This request does not include those records made at
the specific request of the counsel for the Plaintiff or in the preparation of the Plaintiff's case for
trial.
7. Copies of all photographs of personal property involved in this accident showing
conditions after the accident which is the subject of this cause.
8. Copies of all photographs taken of Plaintiff that depict Plaintiff's injuries,
including but not limited to X-Rays, MRI and CT scan films and other radiographic studies.
9. Copies of photographs of the accident scene which is the subject of this cause.
10. Any statements made by Defendant, written and recorded. This request includes
audio and videotapes of the Defendant.
11. Any and all photographs taken by or on behalf of the Plaintiff and his respective
agents, servants, employees, and investigators regarding any of the facts and issues in this case.
12. Any and all rental and leasing bills incurred as a direct result of the accident
which is the subject of this action.13. With regard to insurance available to Plaintiff, all contracts of insurance along
with the Declaration Sheets of all insurance in effect on the date of the accident which is the
subject of this cause ("Insurance” is defined as medical, automobile, hospitalization, Medicaid,
Medicare, disability, health, and accident).
14. All applications for insurance benefits made by the Plaintiff under the insurance
policies covered by Paragraph 13 above.
15. Any documents evidencing payment of medical bills or lost earnings by collateral
sources. This request includes but is not limited to: Records of payments, checks and duplicate
checks, check stubs, and all writings relating to any payments made under the insurance policies
covered by paragraph 13 above as a result of the accident which is the subject of this cause.
16. | Any indemnity agreement entered into by the Plaintiff which falls under the
provisions of Fla.R.Civ.P. 1.280(b)(2).
17. Any transcript from traffic court pertaining to this matter.
18. Any and all reports prepared by experts expected to testify at trial (“Experts” not
limited to medical doctors) Mims v. Casademont, 464 So.2d 643 (Fla. 3d DCA 1985).
19. Copies of any releases given by the Plaintiff to any Co-Defendant and/or any
tortfeasor.
20. Any and all Social Security Benefit Summaries in your possessi (i n
HR: and 2005, as well as duly executed Authorizations for Social Security Benefit
Summaries (see Exhibit “B”).CERTIFICATE OF SERVICE
1 HEREBY CERTIFY a true and correct copy of the foregoing has been furnished via
facsimile and/or U.S. Mail to: WILLIAM JAMES MCAFEE, ESQUIRE, 1645 Palm Beach Lakes
Blvd, 9" Floor, West Palm Beach, Florida 33401 on this oO. day of February, 2008.
LAW OFFICE OF VIVIAN M. KNAPP
Attorneys for Defendant, Espinosa
1450 Centrepark Blvd., Suite 250
West Palm Beach, FL 33401
561-616-7417
Fax: 561-616-7430
By:
ETH ANN TANSEY, ESQUIRE
Florida Bar No: 0105449
“Salaried Employees of Progressive Casualty Insurance Company”
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IN THE CIRCUIT COURT OF THE 15” JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA PETER DEGREGORY, III, CASE NO.: 502008CA002189XXXXMB Division: AF Plaintiff, VS. DISCOVERY PROPERTY & CASULATY INSURANCE COMPANY, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY and FABIOLA ESPINOSA O34 Defendant. / REQUEST FOR PRODUCTION COMES NOW the Defendant, FABIOLA ESPINOSA, by and through undersigned HESOLNY G2 e240 attorney, and pursuant to Fla.R.Civ.P. 1.350 requests the Plaintiff, PETER DEGREGORY, III, to produce and permit the inspection, copying or photographing by or on behalf of this Defendant of the following items within the time period permitted by said rule at the following location: Law Office of Vivian M. Knapp, 1450 Centrepark Blvd., Suite 250, West Palm Beach, Florida 33401: 1. Copies of complete Federal Income Tax returns for the past seven (7) years, together with records of earnings of the Plaintiff for the past seven (7) years. This request includes all W-2 forms, S Corporation Tax Returns; Partnership Tax Returns; C Corporation Tax Returns of which Plaintiff has any interest and all schedules thereto, as well as duly executed Authorizations for Request for Copy of Tax Returns. (See Exhibit “A”). 2. All bills and statements for medical treatment, devices and medicines, the cost of which is claimed to have been incurred as a result of the injuries sustained in this cause by the Plaintiff.3. Any and all bills of hospitals in which Plaintiff has been a patient or received treatment allegedly as a result of the injuries sustained in this cause by Plaintiff. 4. Repair estimates and repair bills for damages to Plaintiff's property allegedly sustained as a result of the accident which is the subject of this cause. This request includes paid and unpaid bills. 5. Any and all hospital records of Plaintiff for the accident which is the subject of this cause. 6. Any and all medical records and written reports of physicians examining or treating the Plaintiff, including radiologists. This request does not include those records made at the specific request of the counsel for the Plaintiff or in the preparation of the Plaintiff's case for trial. 7. Copies of all photographs of personal property involved in this accident showing conditions after the accident which is the subject of this cause. 8. Copies of all photographs taken of Plaintiff that depict Plaintiff's injuries, including but not limited to X-Rays, MRI and CT scan films and other radiographic studies. 9. Copies of photographs of the accident scene which is the subject of this cause. 10. Any statements made by Defendant, written and recorded. This request includes audio and videotapes of the Defendant. 11. Any and all photographs taken by or on behalf of the Plaintiff and his respective agents, servants, employees, and investigators regarding any of the facts and issues in this case. 12. Any and all rental and leasing bills incurred as a direct result of the accident which is the subject of this action.13. With regard to insurance available to Plaintiff, all contracts of insurance along with the Declaration Sheets of all insurance in effect on the date of the accident which is the subject of this cause ("Insurance” is defined as medical, automobile, hospitalization, Medicaid, Medicare, disability, health, and accident). 14. All applications for insurance benefits made by the Plaintiff under the insurance policies covered by Paragraph 13 above. 15. Any documents evidencing payment of medical bills or lost earnings by collateral sources. This request includes but is not limited to: Records of payments, checks and duplicate checks, check stubs, and all writings relating to any payments made under the insurance policies covered by paragraph 13 above as a result of the accident which is the subject of this cause. 16. | Any indemnity agreement entered into by the Plaintiff which falls under the provisions of Fla.R.Civ.P. 1.280(b)(2). 17. Any transcript from traffic court pertaining to this matter. 18. Any and all reports prepared by experts expected to testify at trial (“Experts” not limited to medical doctors) Mims v. Casademont, 464 So.2d 643 (Fla. 3d DCA 1985). 19. Copies of any releases given by the Plaintiff to any Co-Defendant and/or any tortfeasor. 20. Any and all Social Security Benefit Summaries in your possessi (i n HR: and 2005, as well as duly executed Authorizations for Social Security Benefit Summaries (see Exhibit “B”).CERTIFICATE OF SERVICE 1 HEREBY CERTIFY a true and correct copy of the foregoing has been furnished via facsimile and/or U.S. Mail to: WILLIAM JAMES MCAFEE, ESQUIRE, 1645 Palm Beach Lakes Blvd, 9" Floor, West Palm Beach, Florida 33401 on this oO. day of February, 2008. LAW OFFICE OF VIVIAN M. KNAPP Attorneys for Defendant, Espinosa 1450 Centrepark Blvd., Suite 250 West Palm Beach, FL 33401 561-616-7417 Fax: 561-616-7430 By: ETH ANN TANSEY, ESQUIRE Florida Bar No: 0105449 “Salaried Employees of Progressive Casualty Insurance Company”