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IN THE CIRCUIT COURT OF THE NINTH JUDICIAL
CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA
CIVIL DIVISION
CASE NO.: 2008-CA-010981-O
SANDRA ALICEA,
Plaintiff,
Lydia Gardner
vs.
GEORGE CHATER,
2009 Jun 12 04:38 PM
Defendant.
_______________________________/
REQUEST FOR PRODUCTION DIRECTED TO PLAINTIFF SANDRA ALICEA
Pursuant to Florida Rule of Civil Procedure 1.350, Defendant, GEORGE CHATER, by
and through the undersigned counsel, hereby requests that the Plaintiff, SANDRA ALICEA,
eFiled in the Office of Clerk of Court, Orange County Florida
produce and permit the Defendant to inspect and copy each of the following:
1. Medical bills including, but not limited to, doctors, hospitals and prescriptions relating to any
of the claims contained in your lawsuit.
2. Repair bills and/or estimates on the vehicle(s) involved in the subject accident.
3. The Plaintiff’s income tax returns for two calendar years prior to the subject automobile
accident through the present, including W-2 forms. (An authorization to obtain this
information from the IRS is attached. If you are unable to produce all documentation, please
have your client execute the enclosed authorization).
4. Hospital records concerning any and all hospitalizations which Plaintiff claims resulted from
the accident, which is the subject of your Complaint.
5. Medical reports, records and opinions or other written memoranda from doctors, nurses,
other medical practitioners or expert witnesses containing information concerning the injuries
and/or damages allegedly sustained by the Plaintiff, as a result of the accident that is the
subject of your complaint.
6. Photographs of any vehicles involved in the subject incident in their damaged condition, and
photographs of the scene of the accident, along with any photographs of the Plaintiff in his
injured condition. (Please provide reprints, not photocopies).
7. X-ray films, CAT scan photographs, thermogram photographs, Magnetic Resonance Image
photographs and all other visually displayed studies of the Plaintiff’s injuries.
8. Copies of all personal diaries or other notes kept by the Plaintiff, from the date of the
accident that is the subject of your complaint until the present.
9. Records of any prescriptions relating to the injuries alleged to have resulted from the
accident, which is the subject of your complaint.
10. Copies of all medical records of any type for the Plaintiff for treatment or diagnosis before
the date of the accident, which is the subject of your complaint.
11. Copies of all documents of any type which support Plaintiff’s claim that he lost any wages as
a result of the injuries sustained in the accident which is the subject of your complaint.
12. Copies of all documents which evidence payment, from any source, of any medical bills or
lost wages alleged to have been incurred or sustained as a result of the accident that is the
subject of your complaint.
13. Copies of all medical and health care insurance policies, including but not limited to PIP,
Medical Payments coverage or Medicare, which were in effect at the time of the accident that
is the subject of your complaint or which have been in effect at any time after your accident.
14. Copies of any statements made by the Defendant, which are in your possession, custody or
control.
15. A copy of Plaintiff’s driver’s license which was in effect at the time of the accident that is the
subject of your complaint.
16. Records of any social security disability benefits, which Plaintiff has received in the past ten
years.
17. Records of any applications for any type of disability benefits made by or on behalf of the
Plaintiff as a result of injuries sustained in the accident, which is the subject of your
complaint.
18. A copy of Plaintiff’s social security earnings, claims and benefits history. (If you are unable
to produce these records, please have your client execute the attached authorizations to obtain
them from the Social Security Administration).
19. Copies of any and all invoices for any costs related to this case, which have been expended
and/or incurred.
It is requested that the aforesaid production be made within thirty (30) days from the date
of this request to Terryl Blackmon Walker, Esq.. Inspection will be made by visual observation,
examination and/or copying.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY, that on June 12, 2009, I electronically filed the foregoing with the
Clerk of Courts by using the ECF system, which will send a notice of electronic filing to the
following: HARRAN E. UDELL, ESQ., Attorneys for Plaintiff, P.O. Box 4979, 20 N. Orange
Ave., 9th Floor, Orlando, FL 32802-4979.
_/S/ Terryl Blackmon Walker____________
TERRYL BLACKMON WALKER, ESQ.
Florida Bar No.: 0148555
Law Offices of B. Todd Parnell
1030 West Canton Avenue, Suite 110
Winter Park, Florida 32789
(407) 975-5820 / Fax: (407) 647-0152
Attorney for Defendant
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IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CIVIL DIVISION CASE NO.: 2008-CA-010981-O SANDRA ALICEA, Plaintiff, Lydia Gardner vs. GEORGE CHATER, 2009 Jun 12 04:38 PM Defendant. _______________________________/ REQUEST FOR PRODUCTION DIRECTED TO PLAINTIFF SANDRA ALICEA Pursuant to Florida Rule of Civil Procedure 1.350, Defendant, GEORGE CHATER, by and through the undersigned counsel, hereby requests that the Plaintiff, SANDRA ALICEA, eFiled in the Office of Clerk of Court, Orange County Florida produce and permit the Defendant to inspect and copy each of the following: 1. Medical bills including, but not limited to, doctors, hospitals and prescriptions relating to any of the claims contained in your lawsuit. 2. Repair bills and/or estimates on the vehicle(s) involved in the subject accident. 3. The Plaintiff’s income tax returns for two calendar years prior to the subject automobile accident through the present, including W-2 forms. (An authorization to obtain this information from the IRS is attached. If you are unable to produce all documentation, please have your client execute the enclosed authorization). 4. Hospital records concerning any and all hospitalizations which Plaintiff claims resulted from the accident, which is the subject of your Complaint. 5. Medical reports, records and opinions or other written memoranda from doctors, nurses, other medical practitioners or expert witnesses containing information concerning the injuries and/or damages allegedly sustained by the Plaintiff, as a result of the accident that is the subject of your complaint. 6. Photographs of any vehicles involved in the subject incident in their damaged condition, and photographs of the scene of the accident, along with any photographs of the Plaintiff in his injured condition. (Please provide reprints, not photocopies). 7. X-ray films, CAT scan photographs, thermogram photographs, Magnetic Resonance Image photographs and all other visually displayed studies of the Plaintiff’s injuries. 8. Copies of all personal diaries or other notes kept by the Plaintiff, from the date of the accident that is the subject of your complaint until the present. 9. Records of any prescriptions relating to the injuries alleged to have resulted from the accident, which is the subject of your complaint. 10. Copies of all medical records of any type for the Plaintiff for treatment or diagnosis before the date of the accident, which is the subject of your complaint. 11. Copies of all documents of any type which support Plaintiff’s claim that he lost any wages as a result of the injuries sustained in the accident which is the subject of your complaint. 12. Copies of all documents which evidence payment, from any source, of any medical bills or lost wages alleged to have been incurred or sustained as a result of the accident that is the subject of your complaint. 13. Copies of all medical and health care insurance policies, including but not limited to PIP, Medical Payments coverage or Medicare, which were in effect at the time of the accident that is the subject of your complaint or which have been in effect at any time after your accident. 14. Copies of any statements made by the Defendant, which are in your possession, custody or control. 15. A copy of Plaintiff’s driver’s license which was in effect at the time of the accident that is the subject of your complaint. 16. Records of any social security disability benefits, which Plaintiff has received in the past ten years. 17. Records of any applications for any type of disability benefits made by or on behalf of the Plaintiff as a result of injuries sustained in the accident, which is the subject of your complaint. 18. A copy of Plaintiff’s social security earnings, claims and benefits history. (If you are unable to produce these records, please have your client execute the attached authorizations to obtain them from the Social Security Administration). 19. Copies of any and all invoices for any costs related to this case, which have been expended and/or incurred. It is requested that the aforesaid production be made within thirty (30) days from the date of this request to Terryl Blackmon Walker, Esq.. Inspection will be made by visual observation, examination and/or copying. CERTIFICATE OF SERVICE I HEREBY CERTIFY, that on June 12, 2009, I electronically filed the foregoing with the Clerk of Courts by using the ECF system, which will send a notice of electronic filing to the following: HARRAN E. UDELL, ESQ., Attorneys for Plaintiff, P.O. Box 4979, 20 N. Orange Ave., 9th Floor, Orlando, FL 32802-4979. _/S/ Terryl Blackmon Walker____________ TERRYL BLACKMON WALKER, ESQ. Florida Bar No.: 0148555 Law Offices of B. Todd Parnell 1030 West Canton Avenue, Suite 110 Winter Park, Florida 32789 (407) 975-5820 / Fax: (407) 647-0152 Attorney for Defendant