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Filing # 116505753 E-Filed 11/11/2020 02:46:47 PM
IN THE CIRCUIT COURT OF THE 1774
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE-20-016553 (25)
RHETT CADY and EDILANE CADY,
Plaintiffs,
v.
JOHN KIDD,
Defendant.
/
DEFENDANT’S REQUEST TO PRODUCE TO PLAINTIFFS
COMES NOW the Defendant, JOHN KIDD, pursuant to Rule 1.350, hereby
requests the Plaintiffs, RHETT CADY and EDILANE CADE, to produce for inspection,
copying or photographing by Defendant, the following documents showing that Plaintiffs
have possession, custody and/or control of each of the documents, and that each of them
constitutes evidence without which Defendant cannot safely proceed to trial, all as seen
more fully from inspection of the pleading herein.
1. Copies of all tax returns, W-2 forms, and any other evidence of income for
all years to date, beginning with the four (4) years preceding the incident in this cause.
2. Withholding statements, pay envelopes, deposit slips and any other
evidence of income earned by Plaintiff, RHETT CADY, for the current calendar year.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/11/2020 02:46:46 PM.****Cady v Kidd
CASE NO.: CACE-20-016553 (25)
Page 2
3. Copies of any and all medical records, hospital records, emergency room
records and records from any health care provider pertaining to the treatment of Plaintiff,
RHETT CADY, for any injuries sustained in the incident in this cause.
4. Copies of any and all medical records, hospital records, emergency room
records and records from any health care provider pertaining to the treatment of the
Plaintiff, RHETT CADY, for any reason in the five (5) years prior to the incident in this
cause.
5. Copies of any and all medical bills and statements for services rendered,
paid or unpaid, as a result of the incident in this cause, including any bills for drugs or
other related expenses.
6. Copies of any and all medical reports, hospital reports, emergency room
reports, consultations and reports from any health care provider pertaining to the
treatment of Plaintiff, RHETT CADY, for any injuries sustained in the incident in this
cause.
7. Any and all statements, including, but not limited to, recorded telephone
interviews, tapes, written statements, whether signed or unsigned, of all witnesses to the
incident relative to the subject matter of this action and any witnesses having knowledge
regarding any and all facts and issues in the instant litigation.
8. Any and all photographs of Plaintiff, RHETT CADY, depicting injuries to
Plaintiff, RHETT CADY, sustained as a result of the incident in this cause.
9. Any and all photographs of the scene of the subject incident.
10. Any and all photographs of the vehicles involved in the subject accident.Cady v Kidd
CASE NO.: CACE-20-016553 (25)
Page 3
11. Any releases, “Mary Carter Agreements”, and any other type of settlement
agreements between Plaintiff, RHETT CADY, and any other party which may have been
tesponsible for damages claimed by Plaintiff, RHETT CADY.
12. Any and all photographs, blow-ups, recordings, charts, graphs, sketches
and any other tangible items or documentary evidence which you intend to use during the
trial of this cause and which have not been produced in response to any of the preceding
paragraphs.
13. All policies of insurance providing collateral source payments to Plaintiff,
RHETT CADY, including, but not limited to, health insurance, disability insurance, and
employment related insurance.
14. All claim forms submitted by Plaintiff, RHETT CADY, pursuant to the
policies of insurance referred to in Paragraph 12 above.
15. All statements, including, but not limited to, recorded telephone interviews,
tapes, written statements, signed or unsigned, of Defendant, JOHN KIDD, or any of her
agents, servants or employees relative to the incident in this cause and any other issue
which involves the instant litigation (This Request also includes the actual audio
recording taken of the Defendant, JOHN KIDD, prior to the filing of this lawsuit).
16. All incident reports filed by Plaintiff, RHETT CADY, for any purpose,
including, but not limited to, reports to employer and insurance company regarding the
incident, if applicable, and any other reports filled out by Plaintiff, RHETT CADY.Cady v Kidd
CASE NO.: CACE-20-016553 (25)
Page 4
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished via electronic mail this 11" day of November, 2020, to: Donald T. Norton, Esq.,
dnorton@anselmiller.com, arivera@anselmiller.com; and William G. Wolk, Esq.,
wwolk@eatonwolk.com, cmartinez@eatonwolk.com.
GREEN, ACKERMAN & MATZNER, P.A.
Attorneys for Defendant
1200 North Federal Highway, Suite 301
Boca Raton, FL 33432
Primary: RAckerman@gaflaw.com
Secondary: RAAssist@gaflaw.com
Telephone:—{561) 347-2400
Faesimilex_ 4561) 955-9555
: -t-l- lL,
RAND ACKERMAN, ESQ.
Fla.Bar No. 327573
' By:
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Filing # 116505753 E-Filed 11/11/2020 02:46:47 PM IN THE CIRCUIT COURT OF THE 1774 JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-20-016553 (25) RHETT CADY and EDILANE CADY, Plaintiffs, v. JOHN KIDD, Defendant. / DEFENDANT’S REQUEST TO PRODUCE TO PLAINTIFFS COMES NOW the Defendant, JOHN KIDD, pursuant to Rule 1.350, hereby requests the Plaintiffs, RHETT CADY and EDILANE CADE, to produce for inspection, copying or photographing by Defendant, the following documents showing that Plaintiffs have possession, custody and/or control of each of the documents, and that each of them constitutes evidence without which Defendant cannot safely proceed to trial, all as seen more fully from inspection of the pleading herein. 1. Copies of all tax returns, W-2 forms, and any other evidence of income for all years to date, beginning with the four (4) years preceding the incident in this cause. 2. Withholding statements, pay envelopes, deposit slips and any other evidence of income earned by Plaintiff, RHETT CADY, for the current calendar year. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/11/2020 02:46:46 PM.****Cady v Kidd CASE NO.: CACE-20-016553 (25) Page 2 3. Copies of any and all medical records, hospital records, emergency room records and records from any health care provider pertaining to the treatment of Plaintiff, RHETT CADY, for any injuries sustained in the incident in this cause. 4. Copies of any and all medical records, hospital records, emergency room records and records from any health care provider pertaining to the treatment of the Plaintiff, RHETT CADY, for any reason in the five (5) years prior to the incident in this cause. 5. Copies of any and all medical bills and statements for services rendered, paid or unpaid, as a result of the incident in this cause, including any bills for drugs or other related expenses. 6. Copies of any and all medical reports, hospital reports, emergency room reports, consultations and reports from any health care provider pertaining to the treatment of Plaintiff, RHETT CADY, for any injuries sustained in the incident in this cause. 7. Any and all statements, including, but not limited to, recorded telephone interviews, tapes, written statements, whether signed or unsigned, of all witnesses to the incident relative to the subject matter of this action and any witnesses having knowledge regarding any and all facts and issues in the instant litigation. 8. Any and all photographs of Plaintiff, RHETT CADY, depicting injuries to Plaintiff, RHETT CADY, sustained as a result of the incident in this cause. 9. Any and all photographs of the scene of the subject incident. 10. Any and all photographs of the vehicles involved in the subject accident.Cady v Kidd CASE NO.: CACE-20-016553 (25) Page 3 11. Any releases, “Mary Carter Agreements”, and any other type of settlement agreements between Plaintiff, RHETT CADY, and any other party which may have been tesponsible for damages claimed by Plaintiff, RHETT CADY. 12. Any and all photographs, blow-ups, recordings, charts, graphs, sketches and any other tangible items or documentary evidence which you intend to use during the trial of this cause and which have not been produced in response to any of the preceding paragraphs. 13. All policies of insurance providing collateral source payments to Plaintiff, RHETT CADY, including, but not limited to, health insurance, disability insurance, and employment related insurance. 14. All claim forms submitted by Plaintiff, RHETT CADY, pursuant to the policies of insurance referred to in Paragraph 12 above. 15. All statements, including, but not limited to, recorded telephone interviews, tapes, written statements, signed or unsigned, of Defendant, JOHN KIDD, or any of her agents, servants or employees relative to the incident in this cause and any other issue which involves the instant litigation (This Request also includes the actual audio recording taken of the Defendant, JOHN KIDD, prior to the filing of this lawsuit). 16. All incident reports filed by Plaintiff, RHETT CADY, for any purpose, including, but not limited to, reports to employer and insurance company regarding the incident, if applicable, and any other reports filled out by Plaintiff, RHETT CADY.Cady v Kidd CASE NO.: CACE-20-016553 (25) Page 4 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via electronic mail this 11" day of November, 2020, to: Donald T. Norton, Esq., dnorton@anselmiller.com, arivera@anselmiller.com; and William G. Wolk, Esq., wwolk@eatonwolk.com, cmartinez@eatonwolk.com. GREEN, ACKERMAN & MATZNER, P.A. Attorneys for Defendant 1200 North Federal Highway, Suite 301 Boca Raton, FL 33432 Primary: RAckerman@gaflaw.com Secondary: RAAssist@gaflaw.com Telephone:—{561) 347-2400 Faesimilex_ 4561) 955-9555 : -t-l- lL, RAND ACKERMAN, ESQ. Fla.Bar No. 327573 ' By: