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Case Number: CACE-18-000390 Division: 25
Filing # 66174335 E-Filed 01/05/2018 03:14:51 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
NORALYS GUZMAN,
CASE NO.:
Plaintiff,
Vs.
AYESHA MOHAMMED, owner,
and NIGHAT AZIZ TAHSEEN , driver,
Defendants.
PLAINTIFF’S REQUEST FOR PRODUCTION TO
DEFENDANT, NIGHAT AZIZ TAHSEEN
COMES NOW, the Plaintiff, NORALYS GUZMAN, by and through his undersigned
attorneys, and hereby request, pursuant to Rule 1.350 of the Florida Rules of Civil Procedure,
that the Defendant, NIGHAT AZIZ TAHSEEN, produce and permit said Plaintiff to inspect and
to copy each of the following documents:
1.
Any and all photographs of the Plaintiffs vehicle which was involved in the
subject accident. Please provide color photographs if in your possession.
Any and all photographs of the Defendant’s vehicle which was involved in the
subject accident. Please provide color photographs if in your possession.
Any and all photographs of any other vehicles besides the Plaintiff's and
Defendant’s vehicles which were involved in the subject accident. Please provide
color photographs if in your possession.
Any and all photographs of the scene of the incident. Please provide color
photographs if in your possession.
Any and all photographs of the Plaintiff. Please provide color photographs if in
your possession.
Any and all repair estimates, bills, and/or work orders pertaining to the
Defendant’s vehicle that was involved in the subject incident documenting the
damage to the vehicle in this accident.
*4* FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 1/5/2018 3:14:49 PM.****10.
12.
13.
14,
15.
16.
19.
Any and all repair estimates, bills, and/or work orders pertaining to the vehicle the
Plaintiff was in at the time of subject incident documenting the damage to the
vehicle in this accident.
Any and all repair estimates, bills, and/or work orders pertaining to the
Defendant’s vehicle that was involved in the subject accident documenting any
repairs made to the vehicle prior to the subject accident for the last 3 years.
Any and all statement(s) of any witnesses to the subject incident.
Any and all audio or video recordings of statement(s) given by the Plaintiff.
Any and all transcripts of statement(s) given by the Plaintiff.
A copy of the Defendant’s policy of insurance.
A copy of the Defendant’s driver’s license.
Any and all reports documenting the subject accident.
All surveillance material of the Plaintiff including, videotapes, CDs, DVD, or
other video recordings, photographs, reports, summaries, notes, time records and
billing.
A copy of Defendant’s cellular phone bill for the month of the subject incident
including itemized calls for the date of the accident described in the Complaint.
All medical records, reports, or bills concerning the Plaintiff from before the date
of loss.
The Defendant’s vehicle that was involved in this accident. (Please contact our
office so that we can schedule an inspection immediately. If the vehicle is no
longer in your possession, please identify where the vehicle can be located and
provide the name, address, and phone number of the person(s) in possession,
custody, or control).
Any and all documents showing ownership of the vehicle Defendant was driving
at the time of the subject accident, including, but not limited to, the Title and
Registration.I] HEREBY CERTIFY that a true and correct copy of the foregoing has been served with the
complaint.
KANNER & PINTALUGA, PA
Attorneys for the Plaintiff
925 S. Federal Highway, Sixth Floor
Boca Raton, FL 33432
Phone: (561) 424-0032
Fax: (844) 818-5452
Service ead
a
13 (@kpattorney.com
FBN: 125505
Preview
Case Number: CACE-18-000390 Division: 25 Filing # 66174335 E-Filed 01/05/2018 03:14:51 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA NORALYS GUZMAN, CASE NO.: Plaintiff, Vs. AYESHA MOHAMMED, owner, and NIGHAT AZIZ TAHSEEN , driver, Defendants. PLAINTIFF’S REQUEST FOR PRODUCTION TO DEFENDANT, NIGHAT AZIZ TAHSEEN COMES NOW, the Plaintiff, NORALYS GUZMAN, by and through his undersigned attorneys, and hereby request, pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, that the Defendant, NIGHAT AZIZ TAHSEEN, produce and permit said Plaintiff to inspect and to copy each of the following documents: 1. Any and all photographs of the Plaintiffs vehicle which was involved in the subject accident. Please provide color photographs if in your possession. Any and all photographs of the Defendant’s vehicle which was involved in the subject accident. Please provide color photographs if in your possession. Any and all photographs of any other vehicles besides the Plaintiff's and Defendant’s vehicles which were involved in the subject accident. Please provide color photographs if in your possession. Any and all photographs of the scene of the incident. Please provide color photographs if in your possession. Any and all photographs of the Plaintiff. Please provide color photographs if in your possession. Any and all repair estimates, bills, and/or work orders pertaining to the Defendant’s vehicle that was involved in the subject incident documenting the damage to the vehicle in this accident. *4* FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 1/5/2018 3:14:49 PM.****10. 12. 13. 14, 15. 16. 19. Any and all repair estimates, bills, and/or work orders pertaining to the vehicle the Plaintiff was in at the time of subject incident documenting the damage to the vehicle in this accident. Any and all repair estimates, bills, and/or work orders pertaining to the Defendant’s vehicle that was involved in the subject accident documenting any repairs made to the vehicle prior to the subject accident for the last 3 years. Any and all statement(s) of any witnesses to the subject incident. Any and all audio or video recordings of statement(s) given by the Plaintiff. Any and all transcripts of statement(s) given by the Plaintiff. A copy of the Defendant’s policy of insurance. A copy of the Defendant’s driver’s license. Any and all reports documenting the subject accident. All surveillance material of the Plaintiff including, videotapes, CDs, DVD, or other video recordings, photographs, reports, summaries, notes, time records and billing. A copy of Defendant’s cellular phone bill for the month of the subject incident including itemized calls for the date of the accident described in the Complaint. All medical records, reports, or bills concerning the Plaintiff from before the date of loss. The Defendant’s vehicle that was involved in this accident. (Please contact our office so that we can schedule an inspection immediately. If the vehicle is no longer in your possession, please identify where the vehicle can be located and provide the name, address, and phone number of the person(s) in possession, custody, or control). Any and all documents showing ownership of the vehicle Defendant was driving at the time of the subject accident, including, but not limited to, the Title and Registration.I] HEREBY CERTIFY that a true and correct copy of the foregoing has been served with the complaint. KANNER & PINTALUGA, PA Attorneys for the Plaintiff 925 S. Federal Highway, Sixth Floor Boca Raton, FL 33432 Phone: (561) 424-0032 Fax: (844) 818-5452 Service ead a 13 (@kpattorney.com FBN: 125505