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Case Number: CACE-20-017866 Division: 14
Filing # 115665609 E-Filed 10/27/2020 11:44:29 AM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO:
NANCY PARK,
Plaintiff,
vs.
BRI 1835 TCS, LLC,
a Florida Limited Liability Company,
Defendant
/
PLAINTIFF’S FIRST REQUEST FOR PRODUCTION
TO DEFENDANT, BRI 1835 TCS, LLC
COMES NOW, the Plaintiff, NANCY PARK, by and through undersigned counsel, and pursuant to
Florida Rules of Civil Procedure, Rule 1.350, hereby files this First Request for Production to Defendant,
BRI 1835 TCS, LLC, and requests the Defendant produce the items listed below in accordance with Rule 1.350:
it Any and all Policies of Insurance, which you contend cover or may cover any Defendant for
the allegations contained in the Plaintiff's Complaint.
2. Any and all documents which support the affirmative defenses in your answer.
3. Any and all reports of expert witnesses who will testify at time of trial pertaining to any issue
involved in this lawsuit.
4, Any statements of the Plaintiff taken in connection with the above lawsuit.
5. Any and all models, plats, maps, drawings, motion pictures, video tapes, and color digital
photographs (in their original format) pertaining to any fact or issue involved in this controversy, including
depicting the scene of the incident and/or any of the parties involved.
6. A blank or redacted incident form which mirrors the incident report that was prepared by the
Defendant in response to the underlying incident.
7. All building plans, permits, work orders, contracts, receipts, invoices, correspondence, and
other documents that indicate what work has been performed at the subject location where the herein alleged
trip and fall incident occurred, including contracts for maintenance services, when and/or by whom, for the
1
The Law Offices of Anidjar & Levine, P.A.
300 SE 17% Street, Fort Lauderdale, Florida 33316 (954) 525-0050
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/27/2020 11:44:27 AM.****three (3) year period up to and including the date of the incident.
8. Any documents reflecting policies or procedures related to safety, inspection of the premises
and/or looking for unsafe conditions, including a hidden and abrupt change in elevation of the parking lot
grounds, in effect on the date of the incident at the subject property.
9. Any correspondence, memoranda, or other documents concerming the condition of the area
where the Plaintiff fell.
10. Any and all documents evidencing when the subject premises was last inspected by the
Defendant’s employees on or before the date and time of the subject incident.
ll. Any and all documents evidencing the person or entity that last inspected the subject premises
on or before the date and time of the subject incident.
12. Any and all documents which indicate the manner and/or how the subject premises were last
inspected on or before the date and time of the subject incident.
13. The time sheets/cards of all employees, including the building/property manager(s), who were
working for the Defendant, BRI 1835 TCS, LLC, at the subject property on the date of the incident.
14, Any and all incident reports regarding the subject incident involving the Plaintiff at the subject
property on December 18, 2017.
15. Any materials you intend to use at trial to impeach the parties, their witnesses or experts,
including impeachment material set forth in Northup v. Acken, 865 So. 2d 1267 (Fla. 2004).
2
The Law Offices of Anidjar & Levine, P.A,
300 SE 17% Street, Fort Lauderdale, Florida 33316 (954) 525-0050CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served upon the Defendant,
together with the Summons and Complaint in the above-styled cause.
LAW OFFICES OF ANIDJAR & LEVINE, P.A.
Counsel for Plaintiff
300 SE 17 Street
Fort Lauderdale, FL 33316
Tel: (954) 525-0050/ Fax: (954) 525-0020
E-service at: pleadings@anl-law.com ~
a
By:
GLEN B. LEVINE, ESQ.,
FBN 0144355
DANITZA GONZALEZ, ESQ.,
FBN 107502
3
The Law Offices of Anidjat & Levine, P.A.
300 SE 17% Street, Fort Lauderdale, Florida 33316 (954) 525-0050
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Case Number: CACE-20-017866 Division: 14 Filing # 115665609 E-Filed 10/27/2020 11:44:29 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO: NANCY PARK, Plaintiff, vs. BRI 1835 TCS, LLC, a Florida Limited Liability Company, Defendant / PLAINTIFF’S FIRST REQUEST FOR PRODUCTION TO DEFENDANT, BRI 1835 TCS, LLC COMES NOW, the Plaintiff, NANCY PARK, by and through undersigned counsel, and pursuant to Florida Rules of Civil Procedure, Rule 1.350, hereby files this First Request for Production to Defendant, BRI 1835 TCS, LLC, and requests the Defendant produce the items listed below in accordance with Rule 1.350: it Any and all Policies of Insurance, which you contend cover or may cover any Defendant for the allegations contained in the Plaintiff's Complaint. 2. Any and all documents which support the affirmative defenses in your answer. 3. Any and all reports of expert witnesses who will testify at time of trial pertaining to any issue involved in this lawsuit. 4, Any statements of the Plaintiff taken in connection with the above lawsuit. 5. Any and all models, plats, maps, drawings, motion pictures, video tapes, and color digital photographs (in their original format) pertaining to any fact or issue involved in this controversy, including depicting the scene of the incident and/or any of the parties involved. 6. A blank or redacted incident form which mirrors the incident report that was prepared by the Defendant in response to the underlying incident. 7. All building plans, permits, work orders, contracts, receipts, invoices, correspondence, and other documents that indicate what work has been performed at the subject location where the herein alleged trip and fall incident occurred, including contracts for maintenance services, when and/or by whom, for the 1 The Law Offices of Anidjar & Levine, P.A. 300 SE 17% Street, Fort Lauderdale, Florida 33316 (954) 525-0050 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/27/2020 11:44:27 AM.****three (3) year period up to and including the date of the incident. 8. Any documents reflecting policies or procedures related to safety, inspection of the premises and/or looking for unsafe conditions, including a hidden and abrupt change in elevation of the parking lot grounds, in effect on the date of the incident at the subject property. 9. Any correspondence, memoranda, or other documents concerming the condition of the area where the Plaintiff fell. 10. Any and all documents evidencing when the subject premises was last inspected by the Defendant’s employees on or before the date and time of the subject incident. ll. Any and all documents evidencing the person or entity that last inspected the subject premises on or before the date and time of the subject incident. 12. Any and all documents which indicate the manner and/or how the subject premises were last inspected on or before the date and time of the subject incident. 13. The time sheets/cards of all employees, including the building/property manager(s), who were working for the Defendant, BRI 1835 TCS, LLC, at the subject property on the date of the incident. 14, Any and all incident reports regarding the subject incident involving the Plaintiff at the subject property on December 18, 2017. 15. Any materials you intend to use at trial to impeach the parties, their witnesses or experts, including impeachment material set forth in Northup v. Acken, 865 So. 2d 1267 (Fla. 2004). 2 The Law Offices of Anidjar & Levine, P.A, 300 SE 17% Street, Fort Lauderdale, Florida 33316 (954) 525-0050CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served upon the Defendant, together with the Summons and Complaint in the above-styled cause. LAW OFFICES OF ANIDJAR & LEVINE, P.A. Counsel for Plaintiff 300 SE 17 Street Fort Lauderdale, FL 33316 Tel: (954) 525-0050/ Fax: (954) 525-0020 E-service at: pleadings@anl-law.com ~ a By: GLEN B. LEVINE, ESQ., FBN 0144355 DANITZA GONZALEZ, ESQ., FBN 107502 3 The Law Offices of Anidjat & Levine, P.A. 300 SE 17% Street, Fort Lauderdale, Florida 33316 (954) 525-0050