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Filing # 123568977 E-Filed 03/23/2021 09:53:30 AM
IN THE CIRCUIT COURT OF THE
15™ JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO. CACE-21-003836
STEVIE BAZILE, individually, and
WILSON JEAN LOUIS, her husband,
Plaintiff,
COMPLETE HIGHWAY IMPROVEMENT, INC.,
a Florida Corporation,
WESNER ABRAHAM, individually,
Defendants.
/
DEFENDANT, COMPLETE HIGHWAY IMPROVEMENT, INC. A FLORIDA
CORPORATION, REQUEST FOR PRODUCTION TO PLAINTIFF
The Defendant, COMPLETE HIGHWAY IMPROVEMENT, INC. a Florida Corporation,
by and through its undersigned counsel and pursuant to the Florida Rules of Civil Procedure,
hereby files its Request for Production of Documents to the Plaintiff, STEVIE BAZILE,
INDIVIDUALLY, and requests that the following documents are to be produced within thirty (30)
days from the date of this Request:
1. Any written memoranda, correspondence, statements or similar documents
between the Plaintiff and the Defendant, its employees, agents and/or representatives regarding
the subject incident.
2. Any written memoranda, correspondence, statements or similar documents
between the Plaintiff and. any third party, their employees, agents and/or representatives regarding
the subject incident
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/23/2021 09:53:30 AM.****Case Name: Stevie Bazile v. Complete Highway Improvement, et al.
Case No. CACE-21-003836
3. Any statements (as defined by the Florida Rules of Civil Procedure) concerning
this action or the subject matter of this action previously made by the Plaintiff and/or her
representatives regarding the subject incident.
4. Any statement(s) (as defined by the Florida Rules of Civil Procedure) concerning
this action or the subject matter of this action previously made by the Defendant, its employees,
agents or representatives regarding the subject incident.
5. Any invoices, paid or unpaid, regarding medical, hospital, and doctor services and
medications received by the Plaintiff regarding the injuries allegedly sustained by the Plaintiff as
alleged in this action.
6. Any medical reports from any health care provider who has treated and/or
examined the Plaintiff regarding the injuries allegedly sustained by the Plaintiff as alleged in this
action.
7. Any written memoranda, correspondence, statements or similar documents from
the Plaintiff's employer which substantiates or verifies the amount of time lost from work due to
the injuries that the Plaintiff allegedly sustained in the subject incident, and the amount of any
alleged lost wages.
8. Any photographs that do or may reveal injuries which the Plaintiff allegedly
sustained in the subject incident.
9. Any photographs relevant to the issue of liability and damages, including but not
limited to photographs of the scene of the accident.
10. Any documentary evidence that the Plaintiffintends to relate to the subject incident.
11. Any insurance policies which do or may provide benefits of any type to the Plaintiff
for the injuries allegedly sustained in the subject incident.Case Name: Stevie Bazile v. Complete Highway Improvement, et al.
Case No. CACE-21-003836
12. Any documents regarding payment of any medical bill or lost earnings by collateral
sources pursuant to the United States Social Security Act regarding the injuries that the Plaintiff
allegedly sustained in the subject incident.
13. Any documents regarding payment of any medical bill or lost earnings by collateral
sources pursuant to the Federal Income Disability Act regarding the injuries that the Plaintiff
allegedly sustained in the subject incident.
14. Any documents regarding payment of any medical bill or lost earnings by collateral
sources pursuant to any public programs regarding the injuries that the Plaintiff allegedly sustained
in the subject incident.
15. Any documents regarding payment of any medical bill or lost earnings by collateral
sources pursuant to any liability insurance policy that provides health benefits or income disability
coverage regarding the injuries that the Plaintiff allegedly sustained in the subject incident.
16. Any documents regarding payment of any medical bill or lost earnings by collateral
sources pursuant to any health, sickness or disability insurance regarding the injuries that the
Plaintiff allegedly sustained in the subject incident.
17. Any documents regarding payment of any medical bill or lost earnings by collateral
sources pursuant to any contractual or voluntary wage continuation plan provided by employers
or other system intended to provide wages during a period of disability regarding the injuries that
the Plaintiff allegedly sustained in the subject incident.
18. Any documents regarding payment of any medical bill or lost earnings by collateral
sources pursuant to any Workers Compensation coverage regarding the injuries that the Plaintiff
allegedly sustained in the subject incident.Case Name: Stevie Bazile v. Complete Highway Improvement, et al.
Case No. CACE-21-003836
19. Any and all tax returns for the past five years indication the Plaintiff's earnings for
that period.
20. | Acopy of any Medicare card that has been issued to you, any communications from
Medicare that you are entitled to or may become eligible for Medicare benefits, any claims or
applications submitted to any government agency for health or disability benefits and any
explanation of benefits notice or similar communications received from the Center for Medicare
and Medicaid Services.
21. Any and all documents which support any damages which you claim to have
sustained as a result of the subject incident.
22. Any and all written reports by you or any witnesses to any entity regarding the
subject auto accident.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing has been filed with the Clerk of Court
via the Florida Courts E-Filing Portal to Ian D. Pinkert, Esq., ian@hsptrial.com of HALPERN
SANTOS & PINKERT, P.A., 150 Alhambra Circle, Suite 1100, Coral Gables, FL 33134, on this
234 day of March 2021.
SHENDELL & POLLOCK, P.L.
2700 North Military Trail, Suite 150
Boca Raton, Florida 33431-1809
Tel: 561 241-2323
Fax: 561-241-2330
By: /s/ Brett R. Bloch
Brett R. Bloch, Esq.
Florida Bar No. 0490891
Elizabeth M. Kehoe, Esq.
Florida Bar No. 127571
brett@shendellpollock.com
lisak@shendellpollock.com
stephanie@shendellpollock.comCase Name: Stevie Bazile v. Complete Highway Improvement, et al.
Case No. CACE-21-003836
grs@shendellpollock.com
Preview
Filing # 123568977 E-Filed 03/23/2021 09:53:30 AM IN THE CIRCUIT COURT OF THE 15™ JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. CACE-21-003836 STEVIE BAZILE, individually, and WILSON JEAN LOUIS, her husband, Plaintiff, COMPLETE HIGHWAY IMPROVEMENT, INC., a Florida Corporation, WESNER ABRAHAM, individually, Defendants. / DEFENDANT, COMPLETE HIGHWAY IMPROVEMENT, INC. A FLORIDA CORPORATION, REQUEST FOR PRODUCTION TO PLAINTIFF The Defendant, COMPLETE HIGHWAY IMPROVEMENT, INC. a Florida Corporation, by and through its undersigned counsel and pursuant to the Florida Rules of Civil Procedure, hereby files its Request for Production of Documents to the Plaintiff, STEVIE BAZILE, INDIVIDUALLY, and requests that the following documents are to be produced within thirty (30) days from the date of this Request: 1. Any written memoranda, correspondence, statements or similar documents between the Plaintiff and the Defendant, its employees, agents and/or representatives regarding the subject incident. 2. Any written memoranda, correspondence, statements or similar documents between the Plaintiff and. any third party, their employees, agents and/or representatives regarding the subject incident *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/23/2021 09:53:30 AM.****Case Name: Stevie Bazile v. Complete Highway Improvement, et al. Case No. CACE-21-003836 3. Any statements (as defined by the Florida Rules of Civil Procedure) concerning this action or the subject matter of this action previously made by the Plaintiff and/or her representatives regarding the subject incident. 4. Any statement(s) (as defined by the Florida Rules of Civil Procedure) concerning this action or the subject matter of this action previously made by the Defendant, its employees, agents or representatives regarding the subject incident. 5. Any invoices, paid or unpaid, regarding medical, hospital, and doctor services and medications received by the Plaintiff regarding the injuries allegedly sustained by the Plaintiff as alleged in this action. 6. Any medical reports from any health care provider who has treated and/or examined the Plaintiff regarding the injuries allegedly sustained by the Plaintiff as alleged in this action. 7. Any written memoranda, correspondence, statements or similar documents from the Plaintiff's employer which substantiates or verifies the amount of time lost from work due to the injuries that the Plaintiff allegedly sustained in the subject incident, and the amount of any alleged lost wages. 8. Any photographs that do or may reveal injuries which the Plaintiff allegedly sustained in the subject incident. 9. Any photographs relevant to the issue of liability and damages, including but not limited to photographs of the scene of the accident. 10. Any documentary evidence that the Plaintiffintends to relate to the subject incident. 11. Any insurance policies which do or may provide benefits of any type to the Plaintiff for the injuries allegedly sustained in the subject incident.Case Name: Stevie Bazile v. Complete Highway Improvement, et al. Case No. CACE-21-003836 12. Any documents regarding payment of any medical bill or lost earnings by collateral sources pursuant to the United States Social Security Act regarding the injuries that the Plaintiff allegedly sustained in the subject incident. 13. Any documents regarding payment of any medical bill or lost earnings by collateral sources pursuant to the Federal Income Disability Act regarding the injuries that the Plaintiff allegedly sustained in the subject incident. 14. Any documents regarding payment of any medical bill or lost earnings by collateral sources pursuant to any public programs regarding the injuries that the Plaintiff allegedly sustained in the subject incident. 15. Any documents regarding payment of any medical bill or lost earnings by collateral sources pursuant to any liability insurance policy that provides health benefits or income disability coverage regarding the injuries that the Plaintiff allegedly sustained in the subject incident. 16. Any documents regarding payment of any medical bill or lost earnings by collateral sources pursuant to any health, sickness or disability insurance regarding the injuries that the Plaintiff allegedly sustained in the subject incident. 17. Any documents regarding payment of any medical bill or lost earnings by collateral sources pursuant to any contractual or voluntary wage continuation plan provided by employers or other system intended to provide wages during a period of disability regarding the injuries that the Plaintiff allegedly sustained in the subject incident. 18. Any documents regarding payment of any medical bill or lost earnings by collateral sources pursuant to any Workers Compensation coverage regarding the injuries that the Plaintiff allegedly sustained in the subject incident.Case Name: Stevie Bazile v. Complete Highway Improvement, et al. Case No. CACE-21-003836 19. Any and all tax returns for the past five years indication the Plaintiff's earnings for that period. 20. | Acopy of any Medicare card that has been issued to you, any communications from Medicare that you are entitled to or may become eligible for Medicare benefits, any claims or applications submitted to any government agency for health or disability benefits and any explanation of benefits notice or similar communications received from the Center for Medicare and Medicaid Services. 21. Any and all documents which support any damages which you claim to have sustained as a result of the subject incident. 22. Any and all written reports by you or any witnesses to any entity regarding the subject auto accident. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been filed with the Clerk of Court via the Florida Courts E-Filing Portal to Ian D. Pinkert, Esq., ian@hsptrial.com of HALPERN SANTOS & PINKERT, P.A., 150 Alhambra Circle, Suite 1100, Coral Gables, FL 33134, on this 234 day of March 2021. SHENDELL & POLLOCK, P.L. 2700 North Military Trail, Suite 150 Boca Raton, Florida 33431-1809 Tel: 561 241-2323 Fax: 561-241-2330 By: /s/ Brett R. Bloch Brett R. Bloch, Esq. Florida Bar No. 0490891 Elizabeth M. Kehoe, Esq. Florida Bar No. 127571 brett@shendellpollock.com lisak@shendellpollock.com stephanie@shendellpollock.comCase Name: Stevie Bazile v. Complete Highway Improvement, et al. Case No. CACE-21-003836 grs@shendellpollock.com