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Filing # 109494109 E-Filed 06/26/2020 06:02:48 PM
IN THE CIRCUIT COURT OF THE 17"
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE-19-024724
Civil Division: 04
EMMATINE WALLACE,
Plaintiff,
v.
ARC ELECTRIC, INC., a Florida Profit
Corporation and YOSBEL P. ALONSO,
Defendants.
/
DEFENDANTS, ARC ELECTRIC, INC.’S AND YOSBEL P. ALONSO’S FIRST
REQUESTS FOR PRODUCTION TO PLAINTIFF, EMMATINE WALLACE
Defendants, ARC ELECTRIC, INC. and YOSBEL P. ALONSO., by and through
undersigned counsel, and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, hereby
request that Plaintiff, EMMATINE WALLACE, produce the following at the offices of the
undersigned.
1. Any and all medical reports, medical records, forms, memorandum and other writings of
all medical doctors, chiropractors or other health care providers as a result of the incident
alleged herein.
2. Any and all medical reports, medical records, forms, memorandum and other writings of
all medical doctors, chiropractors or other health care providers who have rendered any
care or treatment to the Plaintiff during the last ten (10) years.
3. Any and all hospital records, including, but not limited to admissions records, admissions
summary, discharge summary and nurses' notes as a result of the incident alleged herein.
4. Any and all hospital records, including, but not limited to admissions records, admissions
summary, discharge summary and nurses' notes pertaining to Plaintiff during the last ten
(10) years.
Kubicki Draper + 9100 §, Dadeland Blvd., Suite 1800, Miami , Florida 33156 + T: (305) 374-1212 F: (305) 374-7846
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/26/2020 06:02:48 PM.****10.
11.
12.
14.
15
16.
17.
18.
CASE NO.: CACE-19-024724
True copies of any and all medical bills and/or statements for services rendered, paid or
unpaid and any and all evidence of payment by Plaintiff or on behalf of the Plaintiff of
any of the medical bills and/or statements as a result of the incident alleged herein.
All documentary evidence of benefits or payments to Plaintiff or on his behalf as defined
by Florida Statute Section 627.7372(2), and all other documentary evidence of benefits
paid under workman's compensation law and/or any other collateral sources.
Copies of all declaration sheets, explanation pamphlets and insurance policies providing
group and/or private health insurance benefits and automobile insurance benefits to
Plaintiff.
Copies of all declaration sheets, explanation pamphlets and insurance policies providing
disability benefits/income to Plaintiff herein.
Copies of the W-2 Withholding Tax Statements and any and all other business records or
income records and other evidence of 2015, 2016, 2017, 2018 and 2020 income.
Copies of 2015, 2016, 2017, 2018 and 2019 Federal Income Tax Returns.
Evidence of 2020 income to date.
Any and all photographs in the possession, custody or control of the Plaintiffs agents,
servants, or attorneys, showing the scene of the incident, the vehicles involved, and of
Plaintiff showing the alleged injuries following the incident and any other photographs
pertaining to the claims alleged herein.
. All ordinances, regulations, rules, statutes, codes, customs and practices and publications
upon which the claims herein are made.
Any and all statements, obtained by you, your agents or your attorneys, of Defendants,
his/her/their agents, servants and employees either recorded or written prior to, at the
time of, or subsequent to the subject incident.
. Any and all depositions given by Plaintiff in the last ten (10) years.
Any and all written communications and/or correspondence between Plaintiff and
Defendant.
Bills, receipts, or other evidence of expenses and out-of-pocket expenses incurred as a
result of the incident which is the subject of this litigation.
Any and all records from car accidents slip and fall incidents, trip and fall incidents, or
any other incident/accident occurrence that Plaintiff was involved in during the past ten
(10) years.
Kubicki Draper + 9100 South Dadeland Boulevard, Suite 1800, Miami, Florida 33156¢ T: (305) 374-1212 + F: (305) 374-7846CASE NO.: CACE-19-024724
19. Complete copies of any and all policies of insurance that may provide coverage in this
matter.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was served via e-
mail to all counsel of record on the attached Service List on this 26" day of June, 2020.
KUBICKI DRAPER
9100 South Dadeland Blvd.
Suite 1800
Miami, FL 33156
Telephone: (305) 982-6604
Facsimile: (305) 374-7846
Pleadings: FIC-KD@kubickidraper.com
By: __/s/ Francesca Ippolito-Craven
FRANCESCA IPPOLITO-CRAVEN
fic@kubickidraper.com
Florida Bar Number: 0145361
LISANDRA GUERRERO
Ig@kubickidraper.com
Florida Bar Number: 0098521
SERVICE LIST
Counsel for Plaintiff:
Yeemee Chan, Esq.
STEINGER, GREENE & FEINER, P.A.
2727 NW 62" Street
Fort Lauderdale, FL 33309
ychan@injurylawyers.com
sgarcia@injurylawyers.com
btoyota@injurylawyers.com
Kubicki Draper + 9100 South Dadeland Boulevard, Suite 1800, Miami, Florida 33156¢ T: (305) 374-1212 + F: (305) 374-7846
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Filing # 109494109 E-Filed 06/26/2020 06:02:48 PM IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-19-024724 Civil Division: 04 EMMATINE WALLACE, Plaintiff, v. ARC ELECTRIC, INC., a Florida Profit Corporation and YOSBEL P. ALONSO, Defendants. / DEFENDANTS, ARC ELECTRIC, INC.’S AND YOSBEL P. ALONSO’S FIRST REQUESTS FOR PRODUCTION TO PLAINTIFF, EMMATINE WALLACE Defendants, ARC ELECTRIC, INC. and YOSBEL P. ALONSO., by and through undersigned counsel, and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, hereby request that Plaintiff, EMMATINE WALLACE, produce the following at the offices of the undersigned. 1. Any and all medical reports, medical records, forms, memorandum and other writings of all medical doctors, chiropractors or other health care providers as a result of the incident alleged herein. 2. Any and all medical reports, medical records, forms, memorandum and other writings of all medical doctors, chiropractors or other health care providers who have rendered any care or treatment to the Plaintiff during the last ten (10) years. 3. Any and all hospital records, including, but not limited to admissions records, admissions summary, discharge summary and nurses' notes as a result of the incident alleged herein. 4. Any and all hospital records, including, but not limited to admissions records, admissions summary, discharge summary and nurses' notes pertaining to Plaintiff during the last ten (10) years. Kubicki Draper + 9100 §, Dadeland Blvd., Suite 1800, Miami , Florida 33156 + T: (305) 374-1212 F: (305) 374-7846 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/26/2020 06:02:48 PM.****10. 11. 12. 14. 15 16. 17. 18. CASE NO.: CACE-19-024724 True copies of any and all medical bills and/or statements for services rendered, paid or unpaid and any and all evidence of payment by Plaintiff or on behalf of the Plaintiff of any of the medical bills and/or statements as a result of the incident alleged herein. All documentary evidence of benefits or payments to Plaintiff or on his behalf as defined by Florida Statute Section 627.7372(2), and all other documentary evidence of benefits paid under workman's compensation law and/or any other collateral sources. Copies of all declaration sheets, explanation pamphlets and insurance policies providing group and/or private health insurance benefits and automobile insurance benefits to Plaintiff. Copies of all declaration sheets, explanation pamphlets and insurance policies providing disability benefits/income to Plaintiff herein. Copies of the W-2 Withholding Tax Statements and any and all other business records or income records and other evidence of 2015, 2016, 2017, 2018 and 2020 income. Copies of 2015, 2016, 2017, 2018 and 2019 Federal Income Tax Returns. Evidence of 2020 income to date. Any and all photographs in the possession, custody or control of the Plaintiffs agents, servants, or attorneys, showing the scene of the incident, the vehicles involved, and of Plaintiff showing the alleged injuries following the incident and any other photographs pertaining to the claims alleged herein. . All ordinances, regulations, rules, statutes, codes, customs and practices and publications upon which the claims herein are made. Any and all statements, obtained by you, your agents or your attorneys, of Defendants, his/her/their agents, servants and employees either recorded or written prior to, at the time of, or subsequent to the subject incident. . Any and all depositions given by Plaintiff in the last ten (10) years. Any and all written communications and/or correspondence between Plaintiff and Defendant. Bills, receipts, or other evidence of expenses and out-of-pocket expenses incurred as a result of the incident which is the subject of this litigation. Any and all records from car accidents slip and fall incidents, trip and fall incidents, or any other incident/accident occurrence that Plaintiff was involved in during the past ten (10) years. Kubicki Draper + 9100 South Dadeland Boulevard, Suite 1800, Miami, Florida 33156¢ T: (305) 374-1212 + F: (305) 374-7846CASE NO.: CACE-19-024724 19. Complete copies of any and all policies of insurance that may provide coverage in this matter. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was served via e- mail to all counsel of record on the attached Service List on this 26" day of June, 2020. KUBICKI DRAPER 9100 South Dadeland Blvd. Suite 1800 Miami, FL 33156 Telephone: (305) 982-6604 Facsimile: (305) 374-7846 Pleadings: FIC-KD@kubickidraper.com By: __/s/ Francesca Ippolito-Craven FRANCESCA IPPOLITO-CRAVEN fic@kubickidraper.com Florida Bar Number: 0145361 LISANDRA GUERRERO Ig@kubickidraper.com Florida Bar Number: 0098521 SERVICE LIST Counsel for Plaintiff: Yeemee Chan, Esq. STEINGER, GREENE & FEINER, P.A. 2727 NW 62" Street Fort Lauderdale, FL 33309 ychan@injurylawyers.com sgarcia@injurylawyers.com btoyota@injurylawyers.com Kubicki Draper + 9100 South Dadeland Boulevard, Suite 1800, Miami, Florida 33156¢ T: (305) 374-1212 + F: (305) 374-7846