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Filing # 127545776 E-Filed 05/26/2021 09:15:21 AM
0484592340.1 JL
Total Pages: 1
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
MARIA ALICIA GUZMAN, CASE NO.
50-2020-CA-007500-XXXX-MB
PLAINTIFF,
VS.
ANDREA D’ADDARIO AS CURATOR
OF THE ESTATE OF EDWARD JOSEPH
PARADISE,
DEFENDANT. |
DEFENDANT(S) REQUEST FOR PRODUCTION
Defendant(s), EDWARD JOSEPH PARADISE, by and through the undersigned counsel,
Tequest(s) Plaintiff(s), MARIA ALICIA GUZMAN, 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 subject accident.
2. Withholding statements, pay envelopes, deposit slips, or any other evidence of
income earned by Plaintiff(s) for the current calendar year.
3. Copies of any and all medical records, hospital records, emergency room records,
and records from any health care provider pertaining to the treatment of Plaintiff(s) for any
injuries sustained in the subject accident.
4. Copies of any and all medical records, hospital records, emergency room records,
health care provider records, X-ray films, CT films and MRI films pertaining to the treatment of
Plaintiffs) for any reason in the seven (7) years prior to the subject accident.
5. Copies of any and all medical records, hospital records, emergency room records,
health care provider records, X-ray films, CT films and MRI films pertaining to the treatment of
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6. Conies of any and all medical bills and/or statements for services rendered, paid or
unpaid, as a result of the subject accident, including any bills for drugs or other related expenses.
7. Copies of bills and/or estimates for the repair of Plaintiff's vehicle and any other
damaged property. If the vehicle was not repairable, in addition, attach estimates of the value of
the vehicle on the date of the alleged incident and estimates and/or receipts concerning salvage
value.
8. Any and all statements, including, but not limited to, recorded telephone interviews,
tapes, written statements, whether signed or unsigned, of Defendant(s) or any of their agents,
servants or employees, and all witnesses to the subject accident relative to the subject matter of
this action and/or any witnesses having knowledge regarding any and all facts and issues in the
instant litigation.
9. Any and all photographs, diagrams or sketches of the scene of the subject accident.
10. Any and all photographs of the vehicles involved in the incident before and after the
subject accident.
11. Any and all photographs of Plaintiff(s) depicting injuries to Plaintiff(s) sustained as
a result of the subject accident.
12. Any releases, "Mary Carter Agreements", and any other type of settlement
agreements between Plaintiff(s) and any other party which may have been responsible for the
damages claimed by Plaintiff(s).
13, Anv and all photographs, blow-uns, recordings, charts, granhs, sketches and anv
other tangible items or documentary evidence which you intend to use during the trial of instant
litigation and which have not been produced in response to any of the preceding paragraphs.
14. All incident reports filed by Plaintiff(s) for any purpose, including, but not limited
to, reports to employer and/or insurance company regarding the subject accident, if applicable,
and/or any other reporis filled out by Piatntift(s).
15. All documents, papers or evidence to be introduced at trial.
16. All expert reports from any experts who will testify at trial.
17. Copy of the front and back of Plaintiff(s)’s health insurance card.
18. Copy of the front and back of Plaintiff(s)’s Medicare and/or Medicare Advantage
Plan card.
19. Copy of the front and back of Plaintiff(s)’s Medicaid card.CASE NO. 50-2020-CA-007500-XXXX-MB
20. Anv and all documents, including a PIP log. evidencing insurance benefits paid for
or on behalf of Plaintiff as a result of the subject accident, including but not limited to insurance
payments, contractual adjustments and/or write-offs.
21. Any and all documents evidencing any and all liens, subrogated interests, and/or
collateral source subject to Florida Statute 768.76, being claimed as a result of the subject
accident, including but not limited to, written documentation from each designaied msurer, tien
holder and/or their designated representatives, stating the exact amount of their lien and/or
subrogated interest.
22. Any and all documents evidencing any and all other expenses, including but not
limited to wage loss, mileage, prescriptions, co-pays, and/or non-medical out-of-pocket expenses
alleged to have been incurred by Plaintiff(s) as a result of the subject accident.
23. Copies of all monthly statements, bills, invoices, and records of all incoming and
outgoing calls and text messages, for any and all cellular phones and/or any kind of wireless
devices, notebooks, iPads, etc. you owned and/or you had on you and/or inside the subject
vehicle at the time of the crash, limited to the 24-hour period encompassing the date of the
subject accident.
24. Copy of marriage certificate if a derivative claim is being made for loss of
consortium, loss of service, or any other claim by your spouse as a result of personal injury to
yourself alleged to be as a result of the subject accident.
THEREBY CERTIFY that on the 25 day of May 2021,CASE NO. 50-2020-CA-007500-XXXX-MB
pursuant to Administrative Order No. AOSC13-49, a cony of the foregoing Defendant(s)
Request for Production has been electronically filed and served using the Florida Courts E-Filing
Portal to:
Attorney for Plaintiff
Carlos J. Jimenez, P.L.
1880 N Congress Ave., Ste 315
Boynton Beach, FL 33426
(Tel: 561 253-0434; Fax: 561 253-0435)
eservice@247injurylaw.com
Carlos J. Jimenez, Esq.
FBN: 0636746
LAW OFFICES OF ROBERT J. SMITH
TIN OD 4a, Gt Gen 1000
11V 01 Uul OL OIG 1ovU
Ft. Lauderdale, FL 33301-5015
Telephone: (954) 767-1387
Toll Free: (877) 250-9958 ext 7671387
Attorney Direct: (954) 767-1394
Fax: (877) 838-0840
/\ Wt
fp —
Ye ectronically Signed
JOSEPH MARYUMA
FL Bar No. 28102
Attorney for Defendant(s)
EDWARD JOSEPH PARADISE
PRINCIPAL E-MAIL ADDRESS:
FTLAUDERDALELEGAL@ALLSTATE.COM
Personal E-mail Address
(NOT for Service of Pleadings and Documents):
Joe.Maryuma@allstate.com
Preview
Filing # 127545776 E-Filed 05/26/2021 09:15:21 AM 0484592340.1 JL Total Pages: 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION MARIA ALICIA GUZMAN, CASE NO. 50-2020-CA-007500-XXXX-MB PLAINTIFF, VS. ANDREA D’ADDARIO AS CURATOR OF THE ESTATE OF EDWARD JOSEPH PARADISE, DEFENDANT. | DEFENDANT(S) REQUEST FOR PRODUCTION Defendant(s), EDWARD JOSEPH PARADISE, by and through the undersigned counsel, Tequest(s) Plaintiff(s), MARIA ALICIA GUZMAN, 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 subject accident. 2. Withholding statements, pay envelopes, deposit slips, or any other evidence of income earned by Plaintiff(s) for the current calendar year. 3. Copies of any and all medical records, hospital records, emergency room records, and records from any health care provider pertaining to the treatment of Plaintiff(s) for any injuries sustained in the subject accident. 4. Copies of any and all medical records, hospital records, emergency room records, health care provider records, X-ray films, CT films and MRI films pertaining to the treatment of Plaintiffs) for any reason in the seven (7) years prior to the subject accident. 5. Copies of any and all medical records, hospital records, emergency room records, health care provider records, X-ray films, CT films and MRI films pertaining to the treatment of Dlaintiffic\ far anu reacan cineca the onhiact arcidant FAGIUUUG\O,) LOL GUY PUuoUL SUICY UY OUUJUUL UUCLMait, CHEN. DAIAARCACUAAIINTY Cl INeGEDU ARDIIV7ZA FLED AEINGINNAA NOW4E-94 ANA Pm. PAL DLA VUUINE TT, FL, vUOL I mDnueey, ULLIAN, Yoreuizue! ug. iu. 1 miCASE NO. 50-2020-CA-007500-XXXX-MB 6. Conies of any and all medical bills and/or statements for services rendered, paid or unpaid, as a result of the subject accident, including any bills for drugs or other related expenses. 7. Copies of bills and/or estimates for the repair of Plaintiff's vehicle and any other damaged property. If the vehicle was not repairable, in addition, attach estimates of the value of the vehicle on the date of the alleged incident and estimates and/or receipts concerning salvage value. 8. Any and all statements, including, but not limited to, recorded telephone interviews, tapes, written statements, whether signed or unsigned, of Defendant(s) or any of their agents, servants or employees, and all witnesses to the subject accident relative to the subject matter of this action and/or any witnesses having knowledge regarding any and all facts and issues in the instant litigation. 9. Any and all photographs, diagrams or sketches of the scene of the subject accident. 10. Any and all photographs of the vehicles involved in the incident before and after the subject accident. 11. Any and all photographs of Plaintiff(s) depicting injuries to Plaintiff(s) sustained as a result of the subject accident. 12. Any releases, "Mary Carter Agreements", and any other type of settlement agreements between Plaintiff(s) and any other party which may have been responsible for the damages claimed by Plaintiff(s). 13, Anv and all photographs, blow-uns, recordings, charts, granhs, sketches and anv other tangible items or documentary evidence which you intend to use during the trial of instant litigation and which have not been produced in response to any of the preceding paragraphs. 14. All incident reports filed by Plaintiff(s) for any purpose, including, but not limited to, reports to employer and/or insurance company regarding the subject accident, if applicable, and/or any other reporis filled out by Piatntift(s). 15. All documents, papers or evidence to be introduced at trial. 16. All expert reports from any experts who will testify at trial. 17. Copy of the front and back of Plaintiff(s)’s health insurance card. 18. Copy of the front and back of Plaintiff(s)’s Medicare and/or Medicare Advantage Plan card. 19. Copy of the front and back of Plaintiff(s)’s Medicaid card.CASE NO. 50-2020-CA-007500-XXXX-MB 20. Anv and all documents, including a PIP log. evidencing insurance benefits paid for or on behalf of Plaintiff as a result of the subject accident, including but not limited to insurance payments, contractual adjustments and/or write-offs. 21. Any and all documents evidencing any and all liens, subrogated interests, and/or collateral source subject to Florida Statute 768.76, being claimed as a result of the subject accident, including but not limited to, written documentation from each designaied msurer, tien holder and/or their designated representatives, stating the exact amount of their lien and/or subrogated interest. 22. Any and all documents evidencing any and all other expenses, including but not limited to wage loss, mileage, prescriptions, co-pays, and/or non-medical out-of-pocket expenses alleged to have been incurred by Plaintiff(s) as a result of the subject accident. 23. Copies of all monthly statements, bills, invoices, and records of all incoming and outgoing calls and text messages, for any and all cellular phones and/or any kind of wireless devices, notebooks, iPads, etc. you owned and/or you had on you and/or inside the subject vehicle at the time of the crash, limited to the 24-hour period encompassing the date of the subject accident. 24. Copy of marriage certificate if a derivative claim is being made for loss of consortium, loss of service, or any other claim by your spouse as a result of personal injury to yourself alleged to be as a result of the subject accident. THEREBY CERTIFY that on the 25 day of May 2021,CASE NO. 50-2020-CA-007500-XXXX-MB pursuant to Administrative Order No. AOSC13-49, a cony of the foregoing Defendant(s) Request for Production has been electronically filed and served using the Florida Courts E-Filing Portal to: Attorney for Plaintiff Carlos J. Jimenez, P.L. 1880 N Congress Ave., Ste 315 Boynton Beach, FL 33426 (Tel: 561 253-0434; Fax: 561 253-0435) eservice@247injurylaw.com Carlos J. Jimenez, Esq. FBN: 0636746 LAW OFFICES OF ROBERT J. SMITH TIN OD 4a, Gt Gen 1000 11V 01 Uul OL OIG 1ovU Ft. Lauderdale, FL 33301-5015 Telephone: (954) 767-1387 Toll Free: (877) 250-9958 ext 7671387 Attorney Direct: (954) 767-1394 Fax: (877) 838-0840 /\ Wt fp — Ye ectronically Signed JOSEPH MARYUMA FL Bar No. 28102 Attorney for Defendant(s) EDWARD JOSEPH PARADISE PRINCIPAL E-MAIL ADDRESS: FTLAUDERDALELEGAL@ALLSTATE.COM Personal E-mail Address (NOT for Service of Pleadings and Documents): Joe.Maryuma@allstate.com