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Filing # 127767790 E-Filed 05/28/2021 02:16:08 PM
th
IN THE CIRCUIT
COURT, 17
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.:
JUSTIN BLEVINS,
Plaintiff.
VS.
ORVILL WEIR,
CAMBRIDGE SECURITY SERVICES
CORP., a Fla Corp., and WESTON
APARTMENTS CORP., d/Wa WESTON
PLACE APARTMENTS, a Fla Corp.,
Defendants.
i
FIRST REOUEST FOR PRODUCTION TO DEFENDANT,
ORVILL WEIR
COMES NOW, the Plaintiff, JUSTIN BLEVINS, by and through undersigned counsel, and
pursuantto Florida Rules of Civil Procedure,Rule 1.350, and files this First Request for Production
to Defendant, ORVILL WEIR, and requests the Defendant produce the items listed below in
accordance with Rule 1.350:
1. Any and all Policies of Insurance that you contend cover or may cover any Defendant for
the allegations contained in Plaintiffs' Complaint.
2. Any and all documents which support the affirmativedefenses 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 Plaintiffs taken in connection with the above lawsuit.
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/28/2021 02:16:05 PM.****
5. Any model, plat, map, drawing, motion picture, video tape, and color digital photographs
pertaining to any fact or issue involved in this controversy depicting either the vehicles
involved, the scene of the accident and/or of any parties involved.
6. A copy of the title and registration for the subject vehicle.
7. A copy of your driver's license.
8. Detailed cellular phone bill at the time ofthe accident, or in the alternative, please complete
the attached Authorization for Release of Cellular Phone Records.
9. Any materials you intend to use at trial to impeach the parties, their witnesses or experts,
including impeachment material set forth in and Northup v. Acken 865 So.2d 1267 (Fla.
2004).
10. Any and all invoices and/or repair estimates and/or bills of any vehicles involved in the
subject accident.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served
together with the Summons and Complaint in this action, upon the Defendant in the above styled
cause.
LAW OFFICES OF ANIDJAR & LEVINE, P.A.
Attorneyfor Plaintiffs
300 SE 17th Street
Fort Lauderdale, Florida 33316
Phone: (954) 525-095{YFax: (954) 525-0020
E-Service at: p
1(Aanl-law.com
By:
.YXIX
LV/YII
ELIE AD(IJDJAR, ESQ.
FBN
912+91
V
AUTHORIZATIONFOR THE RELEASE OF RECORDS
TO:
RE: Defendant:
DOB:
SSN:
Wireless Phone No.:
You are hereby authorized and directed to release to the law firm of:
LAW OFFICES OF ANIDJAR & LEVINE
,th
300 SE 171 Street
Fort Lauderdale, Florida 33316
(954) 525-0050
THE FOLLOWING REOUEST:
ANY AND ALL OUTGOING AND INCOMING CALLS REGARDING
WIRELESS TELEPHONE NUMBER FOR THE DATE OF
SERVICE OF PERTAINING TO
I understand that the information described above may be redisclosed by the person or
group that I hereby give the above provider and its contract representativespermission to share
my information with, and that my information would no longer be protected by the federal
regulations. Therefore, I release the above provider, its workforce members, and its contract
representatives from allliability arising from the disclosureof my information pursuant to this
agreement. I understand that I may inspect or request copies of any information disclosed by this
request for disclosure. I understand that I may revoke this authorization by notifying the above
provider through its contract representative, in writing, knowing that previously disclosed
informationwould not be subject to my revocationrequest. I understand that I may refuse to
sign this authorizationand that my refusal to sign will not affect my ability to obtain services.
This authorizationwill expire one (1) year from date on which it is signed.
UNDER PENALTY OF PERJURY, I SWEAR OR AFFIRM THAT THE FOREGOING
AUTHORIZATIONFOR THE RELEASE OF RECORDS IS TRUE AND COMPLETE.
Signature
STATE OF FLORIDA )
: SS
COUNTY OF
The foregoing instrumentwas acknowledged before me, an officer duly authorizedin the
State and County aforesaid, to take acknowledgmentsthis day of
2021,by , who:
[ ] ispersonally known to me; or
[ ] has produced a Florida Driver's License
No. as identification; and who:
[ I did or
[ ] did not take an oath.
NOTARY PUBLIC. STATE OF FLORIDA
AT LARGE
My Commission Expires:
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Filing # 127767790 E-Filed 05/28/2021 02:16:08 PM th IN THE CIRCUIT COURT, 17 JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: JUSTIN BLEVINS, Plaintiff. VS. ORVILL WEIR, CAMBRIDGE SECURITY SERVICES CORP., a Fla Corp., and WESTON APARTMENTS CORP., d/Wa WESTON PLACE APARTMENTS, a Fla Corp., Defendants. i FIRST REOUEST FOR PRODUCTION TO DEFENDANT, ORVILL WEIR COMES NOW, the Plaintiff, JUSTIN BLEVINS, by and through undersigned counsel, and pursuantto Florida Rules of Civil Procedure,Rule 1.350, and files this First Request for Production to Defendant, ORVILL WEIR, and requests the Defendant produce the items listed below in accordance with Rule 1.350: 1. Any and all Policies of Insurance that you contend cover or may cover any Defendant for the allegations contained in Plaintiffs' Complaint. 2. Any and all documents which support the affirmativedefenses 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 Plaintiffs taken in connection with the above lawsuit. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/28/2021 02:16:05 PM.**** 5. Any model, plat, map, drawing, motion picture, video tape, and color digital photographs pertaining to any fact or issue involved in this controversy depicting either the vehicles involved, the scene of the accident and/or of any parties involved. 6. A copy of the title and registration for the subject vehicle. 7. A copy of your driver's license. 8. Detailed cellular phone bill at the time ofthe accident, or in the alternative, please complete the attached Authorization for Release of Cellular Phone Records. 9. Any materials you intend to use at trial to impeach the parties, their witnesses or experts, including impeachment material set forth in and Northup v. Acken 865 So.2d 1267 (Fla. 2004). 10. Any and all invoices and/or repair estimates and/or bills of any vehicles involved in the subject accident. I HEREBY CERTIFY that a true and correct copy of the foregoing has been served together with the Summons and Complaint in this action, upon the Defendant in the above styled cause. LAW OFFICES OF ANIDJAR & LEVINE, P.A. Attorneyfor Plaintiffs 300 SE 17th Street Fort Lauderdale, Florida 33316 Phone: (954) 525-095{YFax: (954) 525-0020 E-Service at: p 1(Aanl-law.com By: .YXIX LV/YII ELIE AD(IJDJAR, ESQ. FBN 912+91 V AUTHORIZATIONFOR THE RELEASE OF RECORDS TO: RE: Defendant: DOB: SSN: Wireless Phone No.: You are hereby authorized and directed to release to the law firm of: LAW OFFICES OF ANIDJAR & LEVINE ,th 300 SE 171 Street Fort Lauderdale, Florida 33316 (954) 525-0050 THE FOLLOWING REOUEST: ANY AND ALL OUTGOING AND INCOMING CALLS REGARDING WIRELESS TELEPHONE NUMBER FOR THE DATE OF SERVICE OF PERTAINING TO I understand that the information described above may be redisclosed by the person or group that I hereby give the above provider and its contract representativespermission to share my information with, and that my information would no longer be protected by the federal regulations. Therefore, I release the above provider, its workforce members, and its contract representatives from allliability arising from the disclosureof my information pursuant to this agreement. I understand that I may inspect or request copies of any information disclosed by this request for disclosure. I understand that I may revoke this authorization by notifying the above provider through its contract representative, in writing, knowing that previously disclosed informationwould not be subject to my revocationrequest. I understand that I may refuse to sign this authorizationand that my refusal to sign will not affect my ability to obtain services. This authorizationwill expire one (1) year from date on which it is signed. UNDER PENALTY OF PERJURY, I SWEAR OR AFFIRM THAT THE FOREGOING AUTHORIZATIONFOR THE RELEASE OF RECORDS IS TRUE AND COMPLETE. Signature STATE OF FLORIDA ) : SS COUNTY OF The foregoing instrumentwas acknowledged before me, an officer duly authorizedin the State and County aforesaid, to take acknowledgmentsthis day of 2021,by , who: [ ] ispersonally known to me; or [ ] has produced a Florida Driver's License No. as identification; and who: [ I did or [ ] did not take an oath. NOTARY PUBLIC. STATE OF FLORIDA AT LARGE My Commission Expires: