Preview
Filing # 123336793 E-Filed 03/18/2021 01:26:47 PM
0575498034.1
Total Pages: 1
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
SAMUEL DUKE BENNETT AND SONJA CASE NO.
BOUCHARD-BENNETT, HIS WIFE, 50 2020-CA-009605
PLAINTIFF,
VS.
FERNANDO HERNANDEZ JR. AND GEORGE
BRITTAIN LAND DESIGN, INC.,
DEFENDANTS.
DEFENDANT, GEORGE BRITTAIN LAND DESIGN INC’S
REQUEST FOR PRODUCTION
Defendant, GEORGE BRITTAIN LAND DESIGN, INC., by and through the
undersigned counsel, requests Plaintiff, SAMUEL DUKE BENNETT, 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 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 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
Plaintiff 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
Plaintiff for any reason since the subject accident.
*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 03/18/2021 01:26:47 PM ***CASE NO. 50 2020-CA-009605
6. Copies 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 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 depicting injuries to Plaintiff sustained as a
result of the subject accident.
12. Any releases, "Mary Carter Agreements", and any other type of settlement
agreements between Plaintiff and any other party which may have been responsible for the
damages claimed by Plaintiff.
13. Any and all photographs, blow-ups, recordings, charts, graphs, sketches and any
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 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 reports filled out by Plaintiff.
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 health insurance card.
18. Copy of the front and back of Plaintiff's Medicare and/or Medicare Advantage Plan
card.
19. Copy of the front and back of Plaintiff's Medicaid card.CASE NO. 50 2020-CA-009605
20. Any 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 designated insurer, lien
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 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.CASE NO. 50 2020-CA-009605
I HEREBY CERTIFY that on the __18th __ day of March
; 2021,
pursuant to Administrative Order No. AOSC13-49, a copy of the foregoing Defendant’s Request
for Production has been electronically filed and served using the Florida Courts E-Filing Portal
to:
Law Office of Tracy R. Sharpe
707 North Flagler Drive
West Palm Beach FL 33401-7140
T: 561-659-3433
E: tsharpe@sharpetriallaw.com
E: melissaw@sharpetriallaw.com
E: kreyes@sharpetriallaw.com
TRACY R. SHARPE, ESQUIRE
Florida Bar 323578
LAW OFFICES OF ROBERT J. SMITH
110 SE 6th St Ste 1800
Ft. Lauderdale, FL 33301-5015
Telephone: (954) 334-3050
Toll Free: (877) 250-9958
Attomey Direct: (954) 767-1384
Fax: (877) 838-0840
TAMAR K. SOLARIN
FL Bar No. 102629
Attorney for Defendant
GEORGE BRITTAIN LAND DESIGN, INC.
PRINCIPAL E-MAIL ADDRESS:
FTLAUDERDALELEGAL@ALLSTATE.COM
Personal E-mail Address
(NOT for Service of Pleadings and Documents):
Tamar.Solarin@Allstate.com
Preview
Filing # 123336793 E-Filed 03/18/2021 01:26:47 PM 0575498034.1 Total Pages: 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION SAMUEL DUKE BENNETT AND SONJA CASE NO. BOUCHARD-BENNETT, HIS WIFE, 50 2020-CA-009605 PLAINTIFF, VS. FERNANDO HERNANDEZ JR. AND GEORGE BRITTAIN LAND DESIGN, INC., DEFENDANTS. DEFENDANT, GEORGE BRITTAIN LAND DESIGN INC’S REQUEST FOR PRODUCTION Defendant, GEORGE BRITTAIN LAND DESIGN, INC., by and through the undersigned counsel, requests Plaintiff, SAMUEL DUKE BENNETT, 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 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 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 Plaintiff 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 Plaintiff for any reason since the subject accident. *** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 03/18/2021 01:26:47 PM ***CASE NO. 50 2020-CA-009605 6. Copies 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 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 depicting injuries to Plaintiff sustained as a result of the subject accident. 12. Any releases, "Mary Carter Agreements", and any other type of settlement agreements between Plaintiff and any other party which may have been responsible for the damages claimed by Plaintiff. 13. Any and all photographs, blow-ups, recordings, charts, graphs, sketches and any 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 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 reports filled out by Plaintiff. 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 health insurance card. 18. Copy of the front and back of Plaintiff's Medicare and/or Medicare Advantage Plan card. 19. Copy of the front and back of Plaintiff's Medicaid card.CASE NO. 50 2020-CA-009605 20. Any 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 designated insurer, lien 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 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.CASE NO. 50 2020-CA-009605 I HEREBY CERTIFY that on the __18th __ day of March ; 2021, pursuant to Administrative Order No. AOSC13-49, a copy of the foregoing Defendant’s Request for Production has been electronically filed and served using the Florida Courts E-Filing Portal to: Law Office of Tracy R. Sharpe 707 North Flagler Drive West Palm Beach FL 33401-7140 T: 561-659-3433 E: tsharpe@sharpetriallaw.com E: melissaw@sharpetriallaw.com E: kreyes@sharpetriallaw.com TRACY R. SHARPE, ESQUIRE Florida Bar 323578 LAW OFFICES OF ROBERT J. SMITH 110 SE 6th St Ste 1800 Ft. Lauderdale, FL 33301-5015 Telephone: (954) 334-3050 Toll Free: (877) 250-9958 Attomey Direct: (954) 767-1384 Fax: (877) 838-0840 TAMAR K. SOLARIN FL Bar No. 102629 Attorney for Defendant GEORGE BRITTAIN LAND DESIGN, INC. PRINCIPAL E-MAIL ADDRESS: FTLAUDERDALELEGAL@ALLSTATE.COM Personal E-mail Address (NOT for Service of Pleadings and Documents): Tamar.Solarin@Allstate.com