On July 17, 2015 a
Party Discovery
was filed
involving a dispute between
Vera, Luis,
and
Evans, Richard,
for Neg - Premises Liability Residential
in the District Court of Broward County.
Preview
Case Number: CACE-15-012685 Division: 12
Filing # 29775820 E-Filed 07/17/2015 11:06:15 AM
IN THE CIRCUIT COURT OF THE 177!
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.
LUIS VERA,
Plaintiff,
v.
RICHARD EVANS,
Defendant.
/
REQUEST TO PRODUCE
The Plaintiff, LUIS VERA, through undersigned counsel, and pursuant to 1.350 of the
Florida Rules of Civil Procedure, hereby requests you to produce at the Law Office of Jose M.
Francisco, P.A., within the time period as prescribed by 1.350 of the Florida Rules of Civil
Procedure, the originals for inspection and/or copying, or if the originals are not in your possession,
legible copies of the following documents, items, and things:
1, Certified and complete copies, including the declaration sheet, endorsements, and
amendments, of all liability or other insurance policies that may provide coverage to or provide
benefits that was in effect or may have been in effect, at the time of the subject accident.
2. Any and all accident or incident reports obtained or filed by the Defendant with
Tespect to the incident alleges in the Complaint.
3. Any and all photographs taken pertaining to the incident which is the subject matter
of this suit.
4. Any and all statements taken in any form from the plaintiff whether written or
recorded.
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 7/17/2015 11:06:12 AM.****5. Any and all statements taken in any form from any witnesses bearing knowledge of
facts relevant and material to the claims and defenses in the instant litigation.
6. Any surveys, drawings or similar documents, showing the premises and area which
are the subject matter of this lawsuit.
7. Copies of any and all leases, documents, Contracts, agreements between the plaintiff
and defendant.
8. Any and all video of the Plaintiff at the Defendant’s premises which pertains to the
allegations in Plaintiff's complaint.
It is hereby requested that the aforesaid production be made available within forty-five (45)
days from the date of service at the offices of JOSE M. FRANCISCO, P.A. Inspection will be
made by visual observation, examination and/or copying.
JOSE M. FRANCISCO, P.A.
Attomeys for Plaintiff
5757 Blue Lagoon Drive
Suite 230
Miami, Florida 33126
Tel: (305) 649-2213 Ext. 2010
Primary: li Hpationatiomey2@ imfla
Secondary: litigati
BY:
Document Filed Date
July 17, 2015
Case Filing Date
July 17, 2015
Category
Neg - Premises Liability Residential
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Preview
Case Number: CACE-15-012685 Division: 12 Filing # 29775820 E-Filed 07/17/2015 11:06:15 AM IN THE CIRCUIT COURT OF THE 177! JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. LUIS VERA, Plaintiff, v. RICHARD EVANS, Defendant. / REQUEST TO PRODUCE The Plaintiff, LUIS VERA, through undersigned counsel, and pursuant to 1.350 of the Florida Rules of Civil Procedure, hereby requests you to produce at the Law Office of Jose M. Francisco, P.A., within the time period as prescribed by 1.350 of the Florida Rules of Civil Procedure, the originals for inspection and/or copying, or if the originals are not in your possession, legible copies of the following documents, items, and things: 1, Certified and complete copies, including the declaration sheet, endorsements, and amendments, of all liability or other insurance policies that may provide coverage to or provide benefits that was in effect or may have been in effect, at the time of the subject accident. 2. Any and all accident or incident reports obtained or filed by the Defendant with Tespect to the incident alleges in the Complaint. 3. Any and all photographs taken pertaining to the incident which is the subject matter of this suit. 4. Any and all statements taken in any form from the plaintiff whether written or recorded. *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 7/17/2015 11:06:12 AM.****5. Any and all statements taken in any form from any witnesses bearing knowledge of facts relevant and material to the claims and defenses in the instant litigation. 6. Any surveys, drawings or similar documents, showing the premises and area which are the subject matter of this lawsuit. 7. Copies of any and all leases, documents, Contracts, agreements between the plaintiff and defendant. 8. Any and all video of the Plaintiff at the Defendant’s premises which pertains to the allegations in Plaintiff's complaint. It is hereby requested that the aforesaid production be made available within forty-five (45) days from the date of service at the offices of JOSE M. FRANCISCO, P.A. Inspection will be made by visual observation, examination and/or copying. JOSE M. FRANCISCO, P.A. Attomeys for Plaintiff 5757 Blue Lagoon Drive Suite 230 Miami, Florida 33126 Tel: (305) 649-2213 Ext. 2010 Primary: li Hpationatiomey2@ imfla Secondary: litigati BY: