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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 reports, medical records, hospital records, pharmacy records,
radiology reports and films (including x-rays, CT scans, MRIs, ultrasounds, EMG
studies, etc.), and any medical bills, for any treatment received by Plaintiff in the
five (5) years before the accident that is the subject of the Complaint.
3. Copies of the W-2 Withholding Tax Statements and any and all other business
records or income records and other evidence of Plaintiff's income for the last five
(5) years.
4. Copies of Plaintiff's Federal Income Tax Returns for the years 2014 through 2019.
*** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 11/12/2020 12:48:09 PM ***10.
11.
12.
13.
14.
15.
16.
17.
Evidence of Plaintiff's income to date for the year 2020.
Any and all photographs of any vehicle alleged in the within accident, of the
scene of the within accident, of the Plaintiff showing the alleged injuries
following the within accident and any other photographs pertaining to the claims
alleged in Plaintiffs' Complaint filed herein if planned to use at trial.
Any and all statements, written or oral, given by any party and/or witnesses.
Any and all repair bills, estimates, or statements regarding repair to Plaintiff's
vehicle as a result of this accident.
Any expert reports prepared by experts intended to be used at trial.
Any accident reports or police reports in your possession regarding the accident
alleged in the complaint.
Any PIP/medpay application filed with your insurance carrier as a result of the
accident alleged in the complaint.
Records on Plaintiff for any medical and/or psychiatric treatment for the last five
(5) years which are in Plaintiff's possession or control.
Copies of any and all insurance policies, contracts or agreements pursuant to
which health benefits or lost wages have been paid or are payable to Plaintiff as a
result of the incident complained of.
Regarding the Plaintiffs lost wages, please furnish copies of all notes, memos,
ledger sheets, time records, wage records or writings of any kind showing any job
since this incident that Plaintiff has not been able to obtain or fulfill because of
this incident, and any writings of any kind whatsoever which in any way pertain
to lost wages or lost earning capacity resulting from the subject incident
Please provide a completed Form SSA-7050-F4, attached to this Request, so that
a complete list of earnings information may be obtained. Said information will
then be provided to you once same is received.
Copies of all documents, insurance payment ledgers, correspondence, checks,
pictures, and other writing received or sent to Plaintiff's own insurance carrier in
relation to the subject incident.
Any and all documents showing payments made to Plaintiff by the United States
Social Security Administration or payments made pursuant to the United States
Social Security Act, or any Federal, State or Local Income Disability Act; and any
and all documents showing payments to Plaintiff by any other public programproviding medical payment benefits, disability protection benefits, or any other
similar benefits.
18. Any and all documents showing payments made to Plaintiff for medical care and
lost wages by collateral sources such as personal insurance benefits, medical
payment benefits and/or other collateral sources as defined in Section 627.736(3)
of the Florida Statutes.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY, that a true and correct copy of the foregoing was sent via E-service to
Thomas H. Leeder, Esq. and Collins S. Delperco, Esq., Leeder Law, 8551 west Sunrise Blvd.,
Suite 202, Plantation, Florida 33322, pleadings@leederlaw.com, Counsel for Plaintiff, this 12th day
of November, 2020.
KUBICKI DRAPER
Attorney for Defendant
515 N. Flagler Drive
Suite 1800
West Palm Beach, FL 33401
Telephone: (561) 615-4332
DMD-KD@kubickidraper.com
BY: /s/ David M. Drahos
David Drahos, Esq.
Florida Bar No.: 25907
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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 reports, medical records, hospital records, pharmacy records, radiology reports and films (including x-rays, CT scans, MRIs, ultrasounds, EMG studies, etc.), and any medical bills, for any treatment received by Plaintiff in the five (5) years before the accident that is the subject of the Complaint. 3. Copies of the W-2 Withholding Tax Statements and any and all other business records or income records and other evidence of Plaintiff's income for the last five (5) years. 4. Copies of Plaintiff's Federal Income Tax Returns for the years 2014 through 2019. *** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 11/12/2020 12:48:09 PM ***10. 11. 12. 13. 14. 15. 16. 17. Evidence of Plaintiff's income to date for the year 2020. Any and all photographs of any vehicle alleged in the within accident, of the scene of the within accident, of the Plaintiff showing the alleged injuries following the within accident and any other photographs pertaining to the claims alleged in Plaintiffs' Complaint filed herein if planned to use at trial. Any and all statements, written or oral, given by any party and/or witnesses. Any and all repair bills, estimates, or statements regarding repair to Plaintiff's vehicle as a result of this accident. Any expert reports prepared by experts intended to be used at trial. Any accident reports or police reports in your possession regarding the accident alleged in the complaint. Any PIP/medpay application filed with your insurance carrier as a result of the accident alleged in the complaint. Records on Plaintiff for any medical and/or psychiatric treatment for the last five (5) years which are in Plaintiff's possession or control. Copies of any and all insurance policies, contracts or agreements pursuant to which health benefits or lost wages have been paid or are payable to Plaintiff as a result of the incident complained of. Regarding the Plaintiffs lost wages, please furnish copies of all notes, memos, ledger sheets, time records, wage records or writings of any kind showing any job since this incident that Plaintiff has not been able to obtain or fulfill because of this incident, and any writings of any kind whatsoever which in any way pertain to lost wages or lost earning capacity resulting from the subject incident Please provide a completed Form SSA-7050-F4, attached to this Request, so that a complete list of earnings information may be obtained. Said information will then be provided to you once same is received. Copies of all documents, insurance payment ledgers, correspondence, checks, pictures, and other writing received or sent to Plaintiff's own insurance carrier in relation to the subject incident. Any and all documents showing payments made to Plaintiff by the United States Social Security Administration or payments made pursuant to the United States Social Security Act, or any Federal, State or Local Income Disability Act; and any and all documents showing payments to Plaintiff by any other public programproviding medical payment benefits, disability protection benefits, or any other similar benefits. 18. Any and all documents showing payments made to Plaintiff for medical care and lost wages by collateral sources such as personal insurance benefits, medical payment benefits and/or other collateral sources as defined in Section 627.736(3) of the Florida Statutes. CERTIFICATE OF SERVICE I HEREBY CERTIFY, that a true and correct copy of the foregoing was sent via E-service to Thomas H. Leeder, Esq. and Collins S. Delperco, Esq., Leeder Law, 8551 west Sunrise Blvd., Suite 202, Plantation, Florida 33322, pleadings@leederlaw.com, Counsel for Plaintiff, this 12th day of November, 2020. KUBICKI DRAPER Attorney for Defendant 515 N. Flagler Drive Suite 1800 West Palm Beach, FL 33401 Telephone: (561) 615-4332 DMD-KD@kubickidraper.com BY: /s/ David M. Drahos David Drahos, Esq. Florida Bar No.: 25907