On January 17, 2018 a
Request to Produce
was filed
involving a dispute between
Echeverry, Karen,
and
Howard, Michael R,
for Auto Negligence
in the District Court of Broward County.
Preview
Filing # 82364346 E-Filed 12/19/2018 03:24:22 PM
SF-14563
JGLiemm IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
KAREN ECHEVERRY,
CASE NO.: CACE18001290 (13)
Plaintiff,
v.
MICHAEL R. HOWARD,
Defendant.
/
SUPPLEMENTAL REQUEST TO PRODUCE
COMES NOW the Defendant, MICHAEL R. HOWARD, by and through his
undersigned attorneys, and respectfully requests that the Plaintiff, KAREN ECHEVERRY,
pursuant to Florida Rules of Civil Procedure, Rule 1.350, produce the following for
inspection and/or copying in our office, or an otherwise designated place, within thirty (30)
days from the date of this Request:
1. Any and all medical and/or hospital records, reports, charts, bills, x-rays,
treatment records, therapy records and other medical documents concerning treatment
rendered to Plaintiff, in the possession of you, your agents, servants and/or attorney not
previously furnished to Defendant.
2. Any and all income tax returns, W2 Wage and Tax Statements and/or other
evidence of income not previously furnished to Defendant.
3. Any and all employment applications completed by you in the possession of
you, your agents, servants and/or attorneys, not previously furnished to Defendant (within
the last ten years).
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/19/2018 3:24:22 PM.****4. Any and all applications for health and/or life insurance completed within the
last ten (10) years, within the possession of you, your agents, servants and/or attorneys,
not previously furnished to the Defendant.
5. Any and all policies and declarations pages for insurance purchased by you,
your agents, servants and/or attorneys regarding the service of any proposal for settlement
in this case.
6. All materials relied upon for purposes of impeachment of any listed expert
or fact witness listed by the defendant not previously furnished.
| HEREBY CERTIFY that a true and correct copy of the above and foregoing has
been sent by e-mail on this the VO" ay of December, 2018, to: Evan R. Krakower, Esq.,
Attorney for Plaintiff, evanrkrakowerpa@yahoo.com.
BERNSTEIN, CHACKMAN, LISS
Attorneys for Defendant Howard
4000 Hollywood Blvd., Suite 610 North
Hollywood, FL 33021
(954) 986-9600 - Broward
(305) 940-1900 - Dade
(954) 929-1 165-F x
Florida Bar No.: 0008941
Steven A. Woods
Florida Bar No.: 178845
jonathan@belrlaw.com
swoods@belrlaw.com
emartinez@beiriaw.com
erin@belrlaw.com
G:\WP\SF-14563\rtp supp pit.wpd
Document Filed Date
December 19, 2018
Case Filing Date
January 17, 2018
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Filing # 82364346 E-Filed 12/19/2018 03:24:22 PM SF-14563 JGLiemm IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA KAREN ECHEVERRY, CASE NO.: CACE18001290 (13) Plaintiff, v. MICHAEL R. HOWARD, Defendant. / SUPPLEMENTAL REQUEST TO PRODUCE COMES NOW the Defendant, MICHAEL R. HOWARD, by and through his undersigned attorneys, and respectfully requests that the Plaintiff, KAREN ECHEVERRY, pursuant to Florida Rules of Civil Procedure, Rule 1.350, produce the following for inspection and/or copying in our office, or an otherwise designated place, within thirty (30) days from the date of this Request: 1. Any and all medical and/or hospital records, reports, charts, bills, x-rays, treatment records, therapy records and other medical documents concerning treatment rendered to Plaintiff, in the possession of you, your agents, servants and/or attorney not previously furnished to Defendant. 2. Any and all income tax returns, W2 Wage and Tax Statements and/or other evidence of income not previously furnished to Defendant. 3. Any and all employment applications completed by you in the possession of you, your agents, servants and/or attorneys, not previously furnished to Defendant (within the last ten years). *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/19/2018 3:24:22 PM.****4. Any and all applications for health and/or life insurance completed within the last ten (10) years, within the possession of you, your agents, servants and/or attorneys, not previously furnished to the Defendant. 5. Any and all policies and declarations pages for insurance purchased by you, your agents, servants and/or attorneys regarding the service of any proposal for settlement in this case. 6. All materials relied upon for purposes of impeachment of any listed expert or fact witness listed by the defendant not previously furnished. | HEREBY CERTIFY that a true and correct copy of the above and foregoing has been sent by e-mail on this the VO" ay of December, 2018, to: Evan R. Krakower, Esq., Attorney for Plaintiff, evanrkrakowerpa@yahoo.com. BERNSTEIN, CHACKMAN, LISS Attorneys for Defendant Howard 4000 Hollywood Blvd., Suite 610 North Hollywood, FL 33021 (954) 986-9600 - Broward (305) 940-1900 - Dade (954) 929-1 165-F x Florida Bar No.: 0008941 Steven A. Woods Florida Bar No.: 178845 jonathan@belrlaw.com swoods@belrlaw.com emartinez@beiriaw.com erin@belrlaw.com G:\WP\SF-14563\rtp supp pit.wpd