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Filing # 45063564 E-Filed 08/10/2016 03:26:36 PM
IN THE CIRCUIT COURT OF THE
11TH JUDICIAL CIRCUIT IN AND
FOR MIAMI-DADE COUNTY, FLORIDA
CASE NO: 16-000016CA24
ROSA RODRIGUEZ,
v.
Plaintiff,
‘THE TJX COMPANIES, INC.
ve
Defendant,
LIFETIME BRANDS, INC.
Third-Party Defendant
/
REQUEST FOR PRODUCTION
The Defendant, LIFETIME BRANDS, INC., pursuant to the applicable Rules of Civil
Procedure hereby requests that the Plaintiff, ROSA RODRIGUEZ, produce for inspection and/or
copying within thirty (30) days of service of this Request, the following:
1.
wn
Any and all medical bills, medical records and reports of treating and/or examining
physicians who have rendered medical treatment or examined the Plaintiff, ROSA
RODRIGUEZ, following the accident of March 17, 2015.
Complete copies of Federal Income Tax Returns for the five (5) years before the date of the
alleged accident and for all years after the accident including records reflecting income thus
far for the current year or an authorization to obtain same from the Director of the Bureau
of Internal Revenue.
Any article of clothing, accessories or shoes worn on the date of this incident.
Any and all photographs, diagrams, video tapes or discs in the possession of the Plaintiff and
his/her counsel reflecting injury to the Plaintiff, ROSA RODRIGUEZ.
Any and all photographs, diagrams, video tapes or discs reflecting the conditions at the time
and/or the scene of the accident.
Copy of Plaintiff's driver license, front and back.
Case No.: 16-000016CA24
Request for Production
Page 1 of 310.
11
12.
13.
14.
15.
16.
17.
18.
19.
20
The insurance policy, including declaration sheets, endorsements, exhibits and addendum
thereto, for any and all insurance policies that provide or may provide benefits to or on
behalf of the Plaintiff as of the time of the subject accident.
Any and all statements, affidavits or reports made by any and all eyewitnesses to the
accident.
All documents including but not limited to insurance forms, receipts, statements, computer
print outs, correspondence and other documents reflecting payments made by or on behalf
of the Plaintiff for damages claimed, including medical bills and lost wages, as a result of the
alleged accident.
Records, reports and bills from or business cards of all health care providers which the
Plaintiff has seen, for treatment or consultation, in the last five years for any reason.
- Records of all household income, including private and public benefits received since the
accident from whatever source.
Records of all prior injuries and incidents whether on the job or not.
Records of all subsequent injuries and incidents, whether related to this accident at hand or
otherwise.
A complete list of earnings information which can be obtained from the Social Security
Administration by filing form SSA-7050-F4, or in the alternative, a completed form SSA-
7050-F4 so that the undersigned may obtain said earnings information, a copy of which will
be provided to you upon request.
Copies of any and all police reports and/or incident reports and Fire Rescue regarding the
accident described in the Complaint.
Copies of any and all Workers’ Compensation Settlement Agreements.
All records including but not limited to bills and invoices reflecting payments made to
experts in this case paid by Plaintiff's attorneys whether related to this case or otherwise for a
three year period prior to this alleged accident.
Any bills or documents not covered above which Plaintiff expects to introduce into evidence
at the time of trial to establish any other expenses which resulted from the incident.
All other bills or documents not covered in Number 18 which Plaintiff expects to introduce
into evidence at the time of trial to establish any other expenses which resulted from the
incident.
. All reports from experts pertaining to this case.
Case No.: 16-000016CA24
Request for Production
Page 2 of 321. All MRI’s, CT Scans, x-rays, radiographs and radiographic reports as to the injuries at issue
in this case.
22. CD’s and/or laser copies of any and all digitally recorded photographs relating to this
incident.
23. All reports from governmental and/or public agencies regarding the incident/accident at
issue.
24. A copy of the cash register receipt and all other evidence of purchases at Defendant's store
or restaurant for the alleged date of accident.
CERTIFICATE OF SERVICE
I certify that the foregoing document has been furnished to Cole, Scott & Kissane, P.A.,
Esquire, Cole, Scott & Kissane Bldg., Suite 1400, 9150 S. Dadeland Boulevard, Miami, FL 33256,
Primary E-Mail: Ben.Esco@csklegal.com, Secondary E-mail: Elisabeth.Espinosa@esklegal.com; and
Monica Medina, Esquire, Jose M. Francisco, P.A., 5757 Blue Lagoon Drive, Suite 230, Miami, FL.
33126, Primary = E-Mail: litigationattorney2@jmflawyers.com, Secondary — E-mail:
litigationsec2@jmflawyers.com by e-mail on this 10‘ day of August, 2016.
Law Offices of J. Christopher Norris
Two Datran Center - Suite 1520
9130 S. Dadeland Boulevard
Miami, FL 33156
Telephone: (305) 670-9339
Attorney for Defendant, Lifetime Brands, Inc.
REY REDLICH, FBN #34075
Primary E-mail (eservice only): MiamiLegalMail@LibertyMutual.com
Secondary E-mail: Rey.Redlich@Libertymutual.Com
Case No.: 16-000016CA24
Request for Production
Page 3 of 3
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Filing # 45063564 E-Filed 08/10/2016 03:26:36 PM IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NO: 16-000016CA24 ROSA RODRIGUEZ, v. Plaintiff, ‘THE TJX COMPANIES, INC. ve Defendant, LIFETIME BRANDS, INC. Third-Party Defendant / REQUEST FOR PRODUCTION The Defendant, LIFETIME BRANDS, INC., pursuant to the applicable Rules of Civil Procedure hereby requests that the Plaintiff, ROSA RODRIGUEZ, produce for inspection and/or copying within thirty (30) days of service of this Request, the following: 1. wn Any and all medical bills, medical records and reports of treating and/or examining physicians who have rendered medical treatment or examined the Plaintiff, ROSA RODRIGUEZ, following the accident of March 17, 2015. Complete copies of Federal Income Tax Returns for the five (5) years before the date of the alleged accident and for all years after the accident including records reflecting income thus far for the current year or an authorization to obtain same from the Director of the Bureau of Internal Revenue. Any article of clothing, accessories or shoes worn on the date of this incident. Any and all photographs, diagrams, video tapes or discs in the possession of the Plaintiff and his/her counsel reflecting injury to the Plaintiff, ROSA RODRIGUEZ. Any and all photographs, diagrams, video tapes or discs reflecting the conditions at the time and/or the scene of the accident. Copy of Plaintiff's driver license, front and back. Case No.: 16-000016CA24 Request for Production Page 1 of 310. 11 12. 13. 14. 15. 16. 17. 18. 19. 20 The insurance policy, including declaration sheets, endorsements, exhibits and addendum thereto, for any and all insurance policies that provide or may provide benefits to or on behalf of the Plaintiff as of the time of the subject accident. Any and all statements, affidavits or reports made by any and all eyewitnesses to the accident. All documents including but not limited to insurance forms, receipts, statements, computer print outs, correspondence and other documents reflecting payments made by or on behalf of the Plaintiff for damages claimed, including medical bills and lost wages, as a result of the alleged accident. Records, reports and bills from or business cards of all health care providers which the Plaintiff has seen, for treatment or consultation, in the last five years for any reason. - Records of all household income, including private and public benefits received since the accident from whatever source. Records of all prior injuries and incidents whether on the job or not. Records of all subsequent injuries and incidents, whether related to this accident at hand or otherwise. A complete list of earnings information which can be obtained from the Social Security Administration by filing form SSA-7050-F4, or in the alternative, a completed form SSA- 7050-F4 so that the undersigned may obtain said earnings information, a copy of which will be provided to you upon request. Copies of any and all police reports and/or incident reports and Fire Rescue regarding the accident described in the Complaint. Copies of any and all Workers’ Compensation Settlement Agreements. All records including but not limited to bills and invoices reflecting payments made to experts in this case paid by Plaintiff's attorneys whether related to this case or otherwise for a three year period prior to this alleged accident. Any bills or documents not covered above which Plaintiff expects to introduce into evidence at the time of trial to establish any other expenses which resulted from the incident. All other bills or documents not covered in Number 18 which Plaintiff expects to introduce into evidence at the time of trial to establish any other expenses which resulted from the incident. . All reports from experts pertaining to this case. Case No.: 16-000016CA24 Request for Production Page 2 of 321. All MRI’s, CT Scans, x-rays, radiographs and radiographic reports as to the injuries at issue in this case. 22. CD’s and/or laser copies of any and all digitally recorded photographs relating to this incident. 23. All reports from governmental and/or public agencies regarding the incident/accident at issue. 24. A copy of the cash register receipt and all other evidence of purchases at Defendant's store or restaurant for the alleged date of accident. CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to Cole, Scott & Kissane, P.A., Esquire, Cole, Scott & Kissane Bldg., Suite 1400, 9150 S. Dadeland Boulevard, Miami, FL 33256, Primary E-Mail: Ben.Esco@csklegal.com, Secondary E-mail: Elisabeth.Espinosa@esklegal.com; and Monica Medina, Esquire, Jose M. Francisco, P.A., 5757 Blue Lagoon Drive, Suite 230, Miami, FL. 33126, Primary = E-Mail: litigationattorney2@jmflawyers.com, Secondary — E-mail: litigationsec2@jmflawyers.com by e-mail on this 10‘ day of August, 2016. Law Offices of J. Christopher Norris Two Datran Center - Suite 1520 9130 S. Dadeland Boulevard Miami, FL 33156 Telephone: (305) 670-9339 Attorney for Defendant, Lifetime Brands, Inc. REY REDLICH, FBN #34075 Primary E-mail (eservice only): MiamiLegalMail@LibertyMutual.com Secondary E-mail: Rey.Redlich@Libertymutual.Com Case No.: 16-000016CA24 Request for Production Page 3 of 3