REQUEST TO PRODUCE

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On January 16, 100 an auto negligence case was filed by Wendy Smiley, represented by Aaron D Neifeld, against Keith Warner, Kim Warner, Silvia Nascimento, and Standard Fire Insurance Company, represented by Charles Reid Bierer, Gabriel C Dobrin, and Robert C Okon, in the jurisdiction of Palm Beach County. Judge Bradley G. Harper presiding.

                        
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                          Filing # 125653446 E-Filed 04/27/2021 10:07:52 AM

0476169586.1 MPR
Total Pages: 1

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
WENDY SMILEY, CASE NO.
50-2021-CA-004024-XXXX-MB
PLAINTIFF,
VS.

KIM WARNER, KEITH WARNER,
SILVIA NASCIMENTO, AND THE

 

STANDARD FIRE INSURANCE
COMAPNY, A FOREIGN PROFIT
CORPORATION,
DEFENDANTS.
DEFENDANT(S) REQ FOR PRODUCTION

Defendants, KIM WARNER, KEITH WARNER, by and through the undersigned
counsel, request Plaintiff, WENDY SMILEY, pursuant to Florida Rule of Civil
Procedure 1.350, to produce the following items within thirty (30) days of this Request to the
undersigned attorneys:

1. Copies of all tax returns, W-2 Forms, or any other evidence of income for all years
to date, beginning with the three (3) years preceding the within incident.

2. Withholding statements, pay envelopes, deposit slips, or any other evidence of
income earned by Plaintiff(s) for the current calendar year.

3. Cop…