On December 02, 2019 a
Request for Production - Party: Defendant Colon, Neida
was filed
involving a dispute between
Ardila, Nelly,
and
Colon, Neida,
for Auto Negligence
in the District Court of Broward County.
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Case Number: CACE-19-024739 Division: 12
Filing # 99658921 E-Filed 12/02/2019 04:17:21 PM
IN THE CIRCUIT COURT OF THE 1774
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO.:
NELLY ARDILA,
Plaintiffs,
vs.
NEIDA COLON
Defendants.
FS
REQUEST FOR PRODUCTION TO DEFENDANT,
NEIDA COLON
COMES NOW, the Plaintiff, NELLY ARDILA, by and through her undersigned
counsel, and pursuant to the applicable Rules of Civil Procedure, request the Defendant,
NEIDA COLON, to produce the following for inspection and/or copying at the offices of
the undersigned attorney within the allowed time as follows:
|. Bills and/or estimates of repairs to vehicle and/or damage to property.
2. Any and all statements of the Plaintiff revealing knowledge of facts relevant
and material to the claims and defenses in the instant litigation.
3. Any and all photographs, movies, charts, and other documentary evidence of
the scene involved in or pertaining to the subject accident, occurrences or issues
involved in this cause.
4. Any and all photographs, movies, charts, and other documentary evidence of
the parties involved in or pertaining to the subject accident, occurrences or issues
involved in this cause.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/02/2019 04:17:20 PM.****5. Any and all photographs, movies, charts, and other documentary evidence of
the vehicles involved in or pertaining to the subject accident, occurrences or issues
involved in this cause.
6. Any and all insurance policies providing benefits or coverage to the Defendant
for any claimed injury or damage from the subject accident or occurrence.
7. Any Transcript from Traffic Court or any other Court involving the subject
matter of the instant litigation and/or the present name, address and telephone number
of the court reporter present at said court.
8. Any and all photographs and/or movies of the Plaintiff, resulting from
surveillance and/or investigation of the Plaintiff.
9. A copy of the subject vehicle title or, if it is a leased vehicle, a copy of the
subject vehicle lease.
10. A copy of your driver's license.
11. Copies of any statements of witnesses.
12. Photographs of vehicles involved in the crash.
13. Any photographs you took at the scene of the crash.
14. Any video of the scene of the crash.
15. Statements of the Plaintiff.
16. Any indemnification agreements
17. Copies of any tickets or citations you received for the subject accident.
As grounds for the foregoing Request, the Plaintiffs are unable, without undue
hardship, to obtain the substantial equivalent of same by other means.WE HEREBY CERTIFY that a true copy hereof was served together with
Complaint and Summons upon the Defendant.
DATED this December 2, 2019.
LAW OFFICE OF CARLOS O. GOMEZ, P.A.
Counsel for Plaintiff
102 East 49" Street
Hialeah, Florida 33013
Telephone: (305) 698-3421
Facsimile: (305) 698-1930
Primary E-mail: cogomezpa@aol.com
Secondary E-mail: sandor@cogomezlaw.com
By: __ /s/Carlos O. Gomez
CARLOS OMAR GOMEZ
FBN: 140554
Document Filed Date
December 02, 2019
Case Filing Date
December 02, 2019
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Case Number: CACE-19-024739 Division: 12 Filing # 99658921 E-Filed 12/02/2019 04:17:21 PM IN THE CIRCUIT COURT OF THE 1774 JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO.: NELLY ARDILA, Plaintiffs, vs. NEIDA COLON Defendants. FS REQUEST FOR PRODUCTION TO DEFENDANT, NEIDA COLON COMES NOW, the Plaintiff, NELLY ARDILA, by and through her undersigned counsel, and pursuant to the applicable Rules of Civil Procedure, request the Defendant, NEIDA COLON, to produce the following for inspection and/or copying at the offices of the undersigned attorney within the allowed time as follows: |. Bills and/or estimates of repairs to vehicle and/or damage to property. 2. Any and all statements of the Plaintiff revealing knowledge of facts relevant and material to the claims and defenses in the instant litigation. 3. Any and all photographs, movies, charts, and other documentary evidence of the scene involved in or pertaining to the subject accident, occurrences or issues involved in this cause. 4. Any and all photographs, movies, charts, and other documentary evidence of the parties involved in or pertaining to the subject accident, occurrences or issues involved in this cause. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/02/2019 04:17:20 PM.****5. Any and all photographs, movies, charts, and other documentary evidence of the vehicles involved in or pertaining to the subject accident, occurrences or issues involved in this cause. 6. Any and all insurance policies providing benefits or coverage to the Defendant for any claimed injury or damage from the subject accident or occurrence. 7. Any Transcript from Traffic Court or any other Court involving the subject matter of the instant litigation and/or the present name, address and telephone number of the court reporter present at said court. 8. Any and all photographs and/or movies of the Plaintiff, resulting from surveillance and/or investigation of the Plaintiff. 9. A copy of the subject vehicle title or, if it is a leased vehicle, a copy of the subject vehicle lease. 10. A copy of your driver's license. 11. Copies of any statements of witnesses. 12. Photographs of vehicles involved in the crash. 13. Any photographs you took at the scene of the crash. 14. Any video of the scene of the crash. 15. Statements of the Plaintiff. 16. Any indemnification agreements 17. Copies of any tickets or citations you received for the subject accident. As grounds for the foregoing Request, the Plaintiffs are unable, without undue hardship, to obtain the substantial equivalent of same by other means.WE HEREBY CERTIFY that a true copy hereof was served together with Complaint and Summons upon the Defendant. DATED this December 2, 2019. LAW OFFICE OF CARLOS O. GOMEZ, P.A. Counsel for Plaintiff 102 East 49" Street Hialeah, Florida 33013 Telephone: (305) 698-3421 Facsimile: (305) 698-1930 Primary E-mail: cogomezpa@aol.com Secondary E-mail: sandor@cogomezlaw.com By: __ /s/Carlos O. Gomez CARLOS OMAR GOMEZ FBN: 140554