On October 18, 2019 a
Request for Production - DEFENDANTParty: Plaintiff Thomas, Katina
was filed
involving a dispute between
Thomas, Katina,
and
Depeine, John,
for Auto Negligence
in the District Court of Broward County.
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Case Number: CACE-19-021558 Division: 05
Filing # 97503005 E-Filed 10/18/2019 11:07:24 AM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
KATINA THOMAS CASE NO.:
Plaintiff,
vs.
JOHN DEPEINE
Defendant,
FIRST REQUEST FOR PRODUCTION TO DEFENDANT
COMES NOW, the Plaintiff, KATINA THOMAS, by and through undersigned
counsel, and pursuant to Florida Rules of Civil Procedure, Rule 1.350, and files this First
Request for Production to Defendant, JOHN DEPEINE, and requests the Defendant produce the
items listed below in accordance with Rule 1.350:
1.
Any and all Policies of Insurance that you contend cover or may cover any
Defendant for the allegations contained in Plaintiffs' Complaint.
Any and all documents which support the affirmative defenses in your answer,
Any and all reports of expert witnesses who will testify at time of trial pertaining
to any issue involved in this lawsuit.
Any statements of the Plaintiffs taken in connection with the above lawsuit.
Any model, plat, map, drawing, motion picture, video tape, or photograph
pertaining to any fact or issue involved in this controversy.
A copy of the title and registration for the subject vehicle.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/18/2019 11:07:22 AM.****7. Any materials you intend to use at trial to impeach the parties, their witnesses or
experts, including impeachment material set forth in and Northup v. Acken 865
So.2d 1267 (Fla. 2004).
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served
together with the Summons and Complaint in this action, upon the Defendant in the above styled
cause.
THOMAS & PEARL, P.A.
Attorneys for Plaintiff
2404 NE 9th Street
Fort Lauderdale, Florida 33304
Telephone: (954) 563-9225
Facsimile: (954) 563-9497
litdept@thomas: ,.com
By: , ae
IVIN B. DENNIS, ESQ.
Florida Bar No: 829110
Document Filed Date
October 18, 2019
Case Filing Date
October 18, 2019
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Case Number: CACE-19-021558 Division: 05 Filing # 97503005 E-Filed 10/18/2019 11:07:24 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA KATINA THOMAS CASE NO.: Plaintiff, vs. JOHN DEPEINE Defendant, FIRST REQUEST FOR PRODUCTION TO DEFENDANT COMES NOW, the Plaintiff, KATINA THOMAS, by and through undersigned counsel, and pursuant to Florida Rules of Civil Procedure, Rule 1.350, and files this First Request for Production to Defendant, JOHN DEPEINE, and requests the Defendant produce the items listed below in accordance with Rule 1.350: 1. Any and all Policies of Insurance that you contend cover or may cover any Defendant for the allegations contained in Plaintiffs' Complaint. Any and all documents which support the affirmative defenses in your answer, Any and all reports of expert witnesses who will testify at time of trial pertaining to any issue involved in this lawsuit. Any statements of the Plaintiffs taken in connection with the above lawsuit. Any model, plat, map, drawing, motion picture, video tape, or photograph pertaining to any fact or issue involved in this controversy. A copy of the title and registration for the subject vehicle. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/18/2019 11:07:22 AM.****7. Any materials you intend to use at trial to impeach the parties, their witnesses or experts, including impeachment material set forth in and Northup v. Acken 865 So.2d 1267 (Fla. 2004). I HEREBY CERTIFY that a true and correct copy of the foregoing has been served together with the Summons and Complaint in this action, upon the Defendant in the above styled cause. THOMAS & PEARL, P.A. Attorneys for Plaintiff 2404 NE 9th Street Fort Lauderdale, Florida 33304 Telephone: (954) 563-9225 Facsimile: (954) 563-9497 litdept@thomas: ,.com By: , ae IVIN B. DENNIS, ESQ. Florida Bar No: 829110