REQUEST TO PRODUCE - BASHJAWISH, MOHAMMED V CIVIL, AGATHE

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On June 1, 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 # 113319645 E-Filed 09/14/2020 02:21:46 PM

BUA Cane LY

FOR PALM BEACH COUNTY,
FLORIDA

Case No.: 502020CA008464 AD

MOHAMMED BASHJAWISH, HANEDI
BASHJAWISH, SOPHIA BASHJAWISH, and
RIHANNA BASHJAWISH, a minor by and
through her natural parent and guardian,
MOHAMMED BASHJAWISH,

Plaintiffs),
Vv.

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

Defendant(s).

REQUEST TO PRODUCE

The Defendant, GEICO General Insurance Company, pursuant to Rule 1.350,
requests the Plaintiff, Mohammed Bashjawish, by and through his undersigned attorney, to
produce for inspection, copying, or photographing by Defendant the following documents:

1. Copies of income tax returns, W-2 forms, 1099 forms and any and all other
evidence of income for the five (5) years prior to current year, together with a record of
earnings to date in current year.

2. If you are self-employed or derive any income from a business in which you
had an ownership interest, including any sole pr…