On May 01, 2021 a
Request for Production - Party: Plaintiff Gregory, Jessica Nicole
was filed
involving a dispute between
Gregory, Jessica Nicole,
and
Mesalien, Kesley,
Progressive Select Insurance Company,
for Auto Negligence
in the District Court of Broward County.
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Case Number: CACE-21-008836 Division: 21
Filing # 125986570 E-Filed 05/01/2021 03:59:31 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
JESSICA NICOLE GREGORY, CASE NO.:
Plaintiff,
VS.
KESLEY MESALIEN and
PROGRESSIVE SELECT INSURANCE COMPANY,
Defendants.
/
PLAINTIFF’S REQUEST FOR PRODUCTION (UM)
COMES NOW the Plaintiff, JESSICA NICOLE GREGORY, by and through her
undersigned attorney, pursuant to the Florida Rules of Civil Procedure 1.350, and requests the
Defendant, PROGRESSIVE SELECT INSURANCE COMPANY, to produce where applicable the
following items for inspection and/or copying within forty five (45) days from the service of this
Request for Production.
1. A copy of all statements taken of or from the Plaintiff.
2. A copy of all statements taken from any witnesses with regard to any issue raised in
this lawsuit.
3. A copy of all photographs and/or videotapes depicting the Plaintiff.
4. A copy of all photographs and/or videotapes depicting the scene of the subject
accident.
5. A copy of all photographs and/or videotapes depicting any of the vehicles involved
in the subject accident.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/01/2021 03:59:28 PM.****6. A copy of all other photographs and/or videotapes which relate to any of the issues
raised in this lawsuit.
7. A copy of all bills and/or estimates for the repair of any of the vehicles involved in
the subject accident.
8. A copy of all insurance policies which provide, or may provide, coverage for any of
the claims raised in the subject lawsuit.
9. A copy of all incident reports or accident reports concerning the subject lawsuit.
10. A copy of all medical records or reports from all medical providers who have
examined the Plaintiff on behalf of, or at the request of, the defendant herein.
I HEREBY CERTIFY that a copy of the foregoing was served upon the defendant with
the Complaint filed herein.
LAW OFFICE OF SABAN & SOLOMON
150 N. University Dr., Suite 200
Plantation, Florida 33324
P: (954) 577-2878
F: (954) 577-2215
s/ Robert Solomon
ROBERT C. SOLOMON, ESQ.
FBN: 27054
Document Filed Date
May 01, 2021
Case Filing Date
May 01, 2021
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Case Number: CACE-21-008836 Division: 21 Filing # 125986570 E-Filed 05/01/2021 03:59:31 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA JESSICA NICOLE GREGORY, CASE NO.: Plaintiff, VS. KESLEY MESALIEN and PROGRESSIVE SELECT INSURANCE COMPANY, Defendants. / PLAINTIFF’S REQUEST FOR PRODUCTION (UM) COMES NOW the Plaintiff, JESSICA NICOLE GREGORY, by and through her undersigned attorney, pursuant to the Florida Rules of Civil Procedure 1.350, and requests the Defendant, PROGRESSIVE SELECT INSURANCE COMPANY, to produce where applicable the following items for inspection and/or copying within forty five (45) days from the service of this Request for Production. 1. A copy of all statements taken of or from the Plaintiff. 2. A copy of all statements taken from any witnesses with regard to any issue raised in this lawsuit. 3. A copy of all photographs and/or videotapes depicting the Plaintiff. 4. A copy of all photographs and/or videotapes depicting the scene of the subject accident. 5. A copy of all photographs and/or videotapes depicting any of the vehicles involved in the subject accident. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/01/2021 03:59:28 PM.****6. A copy of all other photographs and/or videotapes which relate to any of the issues raised in this lawsuit. 7. A copy of all bills and/or estimates for the repair of any of the vehicles involved in the subject accident. 8. A copy of all insurance policies which provide, or may provide, coverage for any of the claims raised in the subject lawsuit. 9. A copy of all incident reports or accident reports concerning the subject lawsuit. 10. A copy of all medical records or reports from all medical providers who have examined the Plaintiff on behalf of, or at the request of, the defendant herein. I HEREBY CERTIFY that a copy of the foregoing was served upon the defendant with the Complaint filed herein. LAW OFFICE OF SABAN & SOLOMON 150 N. University Dr., Suite 200 Plantation, Florida 33324 P: (954) 577-2878 F: (954) 577-2215 s/ Robert Solomon ROBERT C. SOLOMON, ESQ. FBN: 27054