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Filing # 59666985 E-Filed 07/28/2017 02:32:51 PM
IN THE CIRCUIT COURT OF THE 17"
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
RONALD VOHS, CASE NO.: 17-007673 CACE 05
Plaintiff,
Vv.
JOSIMAR’S CLEANING SERVICES
CORP., INDUSTRIAL CABLE
COMMUNICATIONS SERVICES, INC.,
AND COMCAST OF COLORADO/FLORIDA/
MICHIGAN/NEW MEXICO/PENNSYLVANIA
/WASHINGTON, LLC.,
Defendants.
/
DEFENDANT’S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF RONALD
VOHS
COMES NOW, the Defendant, COMCAST OF COLORADO / FLORIDA /
MICHIGAN / NEW MEXICO / PENNSYLVANIA / WASHINGTON, LLC., by and through
the undersigned Counsel and pursuant to Fla. R. Civ. P. 1.350, hereby propounds the attached
Request for Production to Plainiff, requests that Plaintiff, RONALD VOHS, to translate or prepare
in reasonably useable form and produce those documents that items numerated and checked at the
offices of the undersigned Counsel and that the same be done within thirty (30) days in accordance
with said Rule.
1. Complete Federal Income Tax Returns with all attached schedules and Forms (such
as W-2 Forms) for the five years preceding the year of the accident which is the subject matter of
this lawsuit.
2. Complete Federal Income Tax Returns with all attached schedules and forms for
the year of the accident which is the subject matter of this lawsuit.
3. Complete Federal Income Tax Returns with all attached schedules and Forms for
each of the years since the year of the accident which is the subject matter of this lawsuit.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 7/28/2017 2:32:50 PM.****4. Proof of all earned income and proof of all non-earned income for any year that a
Federal Income Tax Return has not been filed.
5. Complete medical records of each physician that examined or treated the Plaintiff
and which were made during the course of examining of treating the Plaintiff.
6. Complete copies of reports prepared by each physician that examined or treated the
Plaintiff.
7. Complete hospital records pertaining to the Plaintiff.
8. All medical bills incurred as a result of the accident which is the subject matter of
the litigation.
9. All photographs which depict conditions which have changed since the
photographs were taken.
10. All photographs which the Plaintiff intends to place into evidence or use at trial.
11. All statements of the Defendant, including, but not limited to, statements taken from
agents, servants, or employees of the Defendant.
12. All statements which the Plaintiff intends to place into evidence or use at trial.
13. All statements pertaining to issues in this litigation, the substantial equivalent of
which cannot be obtained by the Defendant without undue hardship.
14. All statements not produced in response to the preceding three paragraphs.
15. Bills, receipts, or other evidence of expenses incurred as a result of the accident
which is the subject of this litigation.
16. All documents supporting the claim for money damages in this lawsuit and not
produced in response to the preceding paragraphs.
17. As to each type of insurance in force in favor of the Plaintiff, including, but not
limited to, medical insurance, hospitalization insurance, Medicare, Medicaid, disability insurance,
medical payments insurance, personal injury protection, health insurance and accident insurance:
a) Copies of each such contract or policy;b) The Identification Card of each such contract policy;
c) The Declaration Sheet of each such contract or policy;
d) Each and every application for benefits made by the Plaintiff(s) under any
of the policies, whether pertaining to the accident which is the subject of this litigation or
not; and
e) All records of payments, checks, check stubs, memos and correspondence
relating to payments made under any of the policies referred to above.
18. A report of each person whom the Plaintiff expects to call as an expert witness at
trial.
19, Letter authorizing the Social Security Administration as a collateral source, to
provide complete information and disclosure of any and all claims, disabilities or payments
received by the Plaintiff. Such letter should specify that the Social Security Administration is
authorized to release all documents protected under 5 U.S.C., Section 552(a); 42 U.S.C., Section
1306(a), and 20 C.F.R., Section 401.300.
20. Copies of any and all documents and/or items that impute negligence on behalf of
this Defendant.CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished
via electronic mail this 28" day of July, 2017, to: Yeemee Chan, Esq., Steinger, Iscoe & Greene,
P.A., 2400 E. Commercial Blvd., Suite 900, Ft. Lauderdale, FL 33308.
RUDD & DIAMOND, P.A.
Attorneys for Defendant, Comcast
4000 Hollywood Blvd.
Presidential Circle, Suite 120-N
Hollywood, FL 33021
Tel. (954) 961-5059
Fax. (954) 961-8953
service@rudddiamond.com
By: /s/
Michael P. Rudd
FL Bar No.: 782416
And
Peter A. Diamond
17.11718/PAD/sm FL Bar No.: 0180051
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Filing # 59666985 E-Filed 07/28/2017 02:32:51 PM IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA RONALD VOHS, CASE NO.: 17-007673 CACE 05 Plaintiff, Vv. JOSIMAR’S CLEANING SERVICES CORP., INDUSTRIAL CABLE COMMUNICATIONS SERVICES, INC., AND COMCAST OF COLORADO/FLORIDA/ MICHIGAN/NEW MEXICO/PENNSYLVANIA /WASHINGTON, LLC., Defendants. / DEFENDANT’S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF RONALD VOHS COMES NOW, the Defendant, COMCAST OF COLORADO / FLORIDA / MICHIGAN / NEW MEXICO / PENNSYLVANIA / WASHINGTON, LLC., by and through the undersigned Counsel and pursuant to Fla. R. Civ. P. 1.350, hereby propounds the attached Request for Production to Plainiff, requests that Plaintiff, RONALD VOHS, to translate or prepare in reasonably useable form and produce those documents that items numerated and checked at the offices of the undersigned Counsel and that the same be done within thirty (30) days in accordance with said Rule. 1. Complete Federal Income Tax Returns with all attached schedules and Forms (such as W-2 Forms) for the five years preceding the year of the accident which is the subject matter of this lawsuit. 2. Complete Federal Income Tax Returns with all attached schedules and forms for the year of the accident which is the subject matter of this lawsuit. 3. Complete Federal Income Tax Returns with all attached schedules and Forms for each of the years since the year of the accident which is the subject matter of this lawsuit. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 7/28/2017 2:32:50 PM.****4. Proof of all earned income and proof of all non-earned income for any year that a Federal Income Tax Return has not been filed. 5. Complete medical records of each physician that examined or treated the Plaintiff and which were made during the course of examining of treating the Plaintiff. 6. Complete copies of reports prepared by each physician that examined or treated the Plaintiff. 7. Complete hospital records pertaining to the Plaintiff. 8. All medical bills incurred as a result of the accident which is the subject matter of the litigation. 9. All photographs which depict conditions which have changed since the photographs were taken. 10. All photographs which the Plaintiff intends to place into evidence or use at trial. 11. All statements of the Defendant, including, but not limited to, statements taken from agents, servants, or employees of the Defendant. 12. All statements which the Plaintiff intends to place into evidence or use at trial. 13. All statements pertaining to issues in this litigation, the substantial equivalent of which cannot be obtained by the Defendant without undue hardship. 14. All statements not produced in response to the preceding three paragraphs. 15. Bills, receipts, or other evidence of expenses incurred as a result of the accident which is the subject of this litigation. 16. All documents supporting the claim for money damages in this lawsuit and not produced in response to the preceding paragraphs. 17. As to each type of insurance in force in favor of the Plaintiff, including, but not limited to, medical insurance, hospitalization insurance, Medicare, Medicaid, disability insurance, medical payments insurance, personal injury protection, health insurance and accident insurance: a) Copies of each such contract or policy;b) The Identification Card of each such contract policy; c) The Declaration Sheet of each such contract or policy; d) Each and every application for benefits made by the Plaintiff(s) under any of the policies, whether pertaining to the accident which is the subject of this litigation or not; and e) All records of payments, checks, check stubs, memos and correspondence relating to payments made under any of the policies referred to above. 18. A report of each person whom the Plaintiff expects to call as an expert witness at trial. 19, Letter authorizing the Social Security Administration as a collateral source, to provide complete information and disclosure of any and all claims, disabilities or payments received by the Plaintiff. Such letter should specify that the Social Security Administration is authorized to release all documents protected under 5 U.S.C., Section 552(a); 42 U.S.C., Section 1306(a), and 20 C.F.R., Section 401.300. 20. Copies of any and all documents and/or items that impute negligence on behalf of this Defendant.CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via electronic mail this 28" day of July, 2017, to: Yeemee Chan, Esq., Steinger, Iscoe & Greene, P.A., 2400 E. Commercial Blvd., Suite 900, Ft. Lauderdale, FL 33308. RUDD & DIAMOND, P.A. Attorneys for Defendant, Comcast 4000 Hollywood Blvd. Presidential Circle, Suite 120-N Hollywood, FL 33021 Tel. (954) 961-5059 Fax. (954) 961-8953 service@rudddiamond.com By: /s/ Michael P. Rudd FL Bar No.: 782416 And Peter A. Diamond 17.11718/PAD/sm FL Bar No.: 0180051