REQUEST TO PRODUCE

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On June 16, 1974 an auto negligence case was filed by Hanedi Bashjawish, Mohammed Bashjawish, Rihanna Bashjawish, and Sophia Bashjawish, represented by Collins S Delpercio, against Agathe Civil, and Geico General Insurance Company, represented by Marni Klein Adams, in the jurisdiction of Palm Beach County. Judge Jaimie R. Goodman presiding.

                        
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                          Filing # 116555236 E-Filed 11/12/2020 12:48:09 PM

IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH, FLORIDA

CASE NO.: 50 2020 CA 008464
MOHAMMED BASHJAWISH, HANEDI BASHJAWISH,
SOPHIA BACHJAWISH and RIHANNA BASJAWISH, a
minor by and through her natural parent and guardian,
MOHAMMED BASHJAWISH,
Plaintiffs,

v.

AGATHE CIVIL and GEICO GENERAL INSURANCE
COMPANY, a foreign profit corporation,

Defendants.
/

 

DEFENDANT’S FIRST REQUEST
FOR PRODUCTION TO PLAINTIFF, HANEDI BASHJAWISH

 

Defendant, AGATHE CIVIL, by and through her undersigned attorneys, and pursuant to
F.R.C.P. 1.350, request the Plaintiff, HANEDI BASHJAWISH, produce the following at the
offices of the undersigned:

1. Any and all medical reports, medical records, hospital records, pharmacy records,
radiology reports and films (including x-rays, CT scans, MRIs, ultrasounds, EMG
studies), and any medical bills (paid or owing), as a result of the accident in the
Complaint.

2. Any and all medical repo…