Request to Produce - TO DEFENDANTParty: Plaintiff Bianculli, Kristin - Kristin Bianculli Plaintiff vs. Progressive American Insurance Company Defendant

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On May 28, 2021 a 3 case was filed by Bianculli, Kristin, represented by Zoeller, William D, against Progressive American Insurance Company, represented by Paradela, Robert E, Esq., in the jurisdiction of Broward County. Judge Bidwill, Martin J. presiding.

                        
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                           Filing # 127733320 E-Filed 05/28/2021 10:02:08 AM
 19564.1
 IN THE CIRCUIT COURT OF THE
 SEVENTEENTH JUDICIAL CIRCUIT
 IN AND FOR BROWARD COUNTY, FLORIDA
 CASE NO.:
 KRISTIN BIANCULLI,
 Plaintiff.
 V
 PROGRESSIVEAMERICAN INSURANCE COMPANY
 Defendant.
 PLAINTIFF'S
 REOUEST TO PRODUCE TO DEFENDANT
 COME NOW the Plaintiff KRISTIN BIANCULLI, by and through her undersigned
 attorney, pursuant to the Florida Rules of Civil Procedure, hereby requests the Defendant, GEICO
 GENERAL INSURANCE COMPANY, to produce the following at the office ofthe undersigned, for
 inspection and/or copying, within the time prescribed by Rule 1.340, Florida Rules of Civil
 Procedure:
 1.
 Copies of any and all liability insurance policies and any and all excess or umbrella
 liability insurance policies providing coverage on the Plaintiffs' vehicles, including all
 applicable declaration pages.
 2.
 Any and all statements given by PROGRESSIVE AMERICAN INSURANCE
 COMPANY to any person other than attorney or insure…