On July 16, 2020 a
Party Discovery
was filed
involving a dispute between
Maria Alicia Guzman,
and
Edward Joseph Paradise,
Estate Of Edward Joseph Paradise Deceased,
for AUTO NEGLIGENCE
in the District Court of Palm Beach County.
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Filing # 129423638 E-Filed 06/24/2021 12:01:39 PM
IN THE CIRCUIT COURT OF THE
15TH JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY, FLORIDA
CASE NO.: 50-2020-CA-007500-XXXXMB (AK)
MARIA ALICIA GUZMAN,
Plaintiff,
vs.
ANDREA D’ADDARIO AS CURATOR.
OF THE ESTATE OF EDWARD JOSEPH PARADISE,
Defendant.
/
IFFS’ REQUEST FOR PRODUCTION
TO DEFENDANT
COMES NOW the Plaintiff, MARIA ALICIA GUZMAN, by and through her undersigned
counsel and hereby requests the Defendant, ANDREA D’ADDARIO AS CURATOR OF THE
ESTATE OF EDWARD JOSEPH PARADISE, produce and permit Plaintiff to inspect and to copy
each of the following documents pursuant to Rule 1.350 of the Florida Rules of Civil Procedure:
1. A copy of all bills and/or estimates of repairs to vehicles and/or damaged property
arising out of the incidents described in the Complaint.
2. Any and all reports rendered by experts applicable to any and all issues in the case
intended to be used at trial.
3. Any and all statements of Plaintiff, Plaintiff's agents and employees or witnesses
bearing on knowledge of facts relevant and material to the claims and defenses in the instant
litigation.
4. Any and all statements of third parties, witnesses and/or Defendants, Defendants’
agents bearing on knowledge of facts relevant and material to the claims and defenses in the instant
litigation.
5. Any and all photographs, movies, charts, graphs and other documentary evidence
of the scene, parties or vehicles involved in or pertaining to the subject accident.
*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 06/24/2021 12:01:39 PM ***6. Copies of any and all insurance policies providing benefits or coverage to
Defendants for any claimed injury or damage from the subject accident or occurrence.
7. Any and all photographs and/or movies of the Plaintiff resulting from surveillance
and/or investigation of the Plaintiff intended to be used at trial.
8. All ordinances, regulations, rules, statutes, customs and practices and publications
upon which your defenses herein are made.
9. All documents and items specified in your Answers to Interrogatories as coming
within Rule 1.340, Florida Rules of Civil Procedure, exercising the option to produce records in
lieu of compilation of summary based on records and reports.
10. Any and all witness statements and/or statements of the parties either written or
taped.
11. Any and all applicable insurance policies whether excess or primary.
12. A copy of your driver’s license.
13. Photocopy of the registration of the vehicle owned by the Defendant(s) at the time
of the incident described in the Complaint.
CERTIFICATE OF SERVICE.
I HEREBY CERTIFY that on the 24" day of June, 2021 the foregoing was electronically filed
with the Florida Courts e-Filing Portal and that as a registered participant of the portal I have
effectuated service through the portal in compliance with Rule 2.516, Fla. R. Jud. Admin., on
Joseph Maryuma Esq., at Ftlauderdalelegal@allstate.com
LAW OFFICES OF CARLOS J. JIMENEZ, P.L.
Attorneys for the Plaintiff
1880 North Congress Avenue, Suite 315
Boynton Beach, FL 33426
Telephone: (561) 253-0434 / Facsimile: (561) 253-0435
eservice@247InjuryLaw.com
Electronically Signed
By:
CARLOS J. JIMENEZ
Florida Bar No. 0636746
SCOTT GOLDSTEIN
Florida Bar No. 0540951
Document Filed Date
January 23, 2024
Case Filing Date
July 16, 2020
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Filing # 129423638 E-Filed 06/24/2021 12:01:39 PM IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 50-2020-CA-007500-XXXXMB (AK) MARIA ALICIA GUZMAN, Plaintiff, vs. ANDREA D’ADDARIO AS CURATOR. OF THE ESTATE OF EDWARD JOSEPH PARADISE, Defendant. / IFFS’ REQUEST FOR PRODUCTION TO DEFENDANT COMES NOW the Plaintiff, MARIA ALICIA GUZMAN, by and through her undersigned counsel and hereby requests the Defendant, ANDREA D’ADDARIO AS CURATOR OF THE ESTATE OF EDWARD JOSEPH PARADISE, produce and permit Plaintiff to inspect and to copy each of the following documents pursuant to Rule 1.350 of the Florida Rules of Civil Procedure: 1. A copy of all bills and/or estimates of repairs to vehicles and/or damaged property arising out of the incidents described in the Complaint. 2. Any and all reports rendered by experts applicable to any and all issues in the case intended to be used at trial. 3. Any and all statements of Plaintiff, Plaintiff's agents and employees or witnesses bearing on knowledge of facts relevant and material to the claims and defenses in the instant litigation. 4. Any and all statements of third parties, witnesses and/or Defendants, Defendants’ agents bearing on knowledge of facts relevant and material to the claims and defenses in the instant litigation. 5. Any and all photographs, movies, charts, graphs and other documentary evidence of the scene, parties or vehicles involved in or pertaining to the subject accident. *** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 06/24/2021 12:01:39 PM ***6. Copies of any and all insurance policies providing benefits or coverage to Defendants for any claimed injury or damage from the subject accident or occurrence. 7. Any and all photographs and/or movies of the Plaintiff resulting from surveillance and/or investigation of the Plaintiff intended to be used at trial. 8. All ordinances, regulations, rules, statutes, customs and practices and publications upon which your defenses herein are made. 9. All documents and items specified in your Answers to Interrogatories as coming within Rule 1.340, Florida Rules of Civil Procedure, exercising the option to produce records in lieu of compilation of summary based on records and reports. 10. Any and all witness statements and/or statements of the parties either written or taped. 11. Any and all applicable insurance policies whether excess or primary. 12. A copy of your driver’s license. 13. Photocopy of the registration of the vehicle owned by the Defendant(s) at the time of the incident described in the Complaint. CERTIFICATE OF SERVICE. I HEREBY CERTIFY that on the 24" day of June, 2021 the foregoing was electronically filed with the Florida Courts e-Filing Portal and that as a registered participant of the portal I have effectuated service through the portal in compliance with Rule 2.516, Fla. R. Jud. Admin., on Joseph Maryuma Esq., at Ftlauderdalelegal@allstate.com LAW OFFICES OF CARLOS J. JIMENEZ, P.L. Attorneys for the Plaintiff 1880 North Congress Avenue, Suite 315 Boynton Beach, FL 33426 Telephone: (561) 253-0434 / Facsimile: (561) 253-0435 eservice@247InjuryLaw.com Electronically Signed By: CARLOS J. JIMENEZ Florida Bar No. 0636746 SCOTT GOLDSTEIN Florida Bar No. 0540951