On January 17, 2018 a
Request for Production - Party: Plaintiff Myrie, Markeemo K
was filed
involving a dispute between
Myrie, Markeemo K,
and
State Farm Mutual Automobile Insurance Company,
St Warmington, Christopher K,
for Auto Negligence
in the District Court of Broward County.
Preview
Filing # 67197742 E-Filed 01/29/2018 03:36:45 PM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL
CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA
" CASE NO: CACE-18-001261 Div: 02
MARKEEMO K. MYRIE,
Plaintiff,
vs.
CHRISTOPHER K. ST WARMINGTON,
and STATE FARM MUTUAL
AUTOMOBILE INSURANCE
COMPANY, an Insurance Company
Defendants.
/
REQUEST FOR PRODUCTION TO THE DEFENDANT,
Cc ‘OPHER K. ST INGTON
COMES NOW the Plaintiff, MARKEEMO K. MYRIE, by and through his undersigned
counsel, pursuant to Rule 1.350, of the Florida Rules of Civil Procedure, and requests the Defendant,
CHRISTOPHER K. ST WARMINGTON, to produce for copying and/or inspection, the following
documents or items:
1. A copy of the front and back of the Defendant’s Driver’s License.
2. Any and all repair bills, repair estimates, receipts, invoices, canceled checks, and/or
credit card receipts or statements, obtained for the Defendant's vehicle after the accident, which is the
subject matter of the Complaint.
3. Any and all photographs taken by the Defendant, his attorney, investigators, agents,
servants, or employees, after the accident referred to in the Complaint, which are in any manner
related to the subject matter of this lawsuit.
4, Copy of the title to the Defendant's motor vehicle which was involved in the subject
accident.
5. Copies of all transcripts of any and all hearings, trials, or other adjudications held by
any state, county or municipality with respect to the incident upon which this cause of action is
alleged to be based.
*** FILED: BROWARD COUNTY. FL BRENDA D. FORMAN. CLERK 1/29/2018 3:36:44 PM.****6. Copies of all writings, recordings, memorandums, notes or other materials reflecting
statements made by the Plaintiff regarding the issues in this case.
fe Copies of all insurance polices inuring to the benefit of Plaintiff in this case.
As good cause for this request, Plaintiff would show unto the Court that the documents
requested are in the care, custody and control of the Defendant, his agents, servants and/or employees,
insurance companies or attorneys, and the Plaintiff cannot secure the equivalent of same. Said
material is relevant and material to the issues in this lawsuit and the Plaintiff cannot secure them
without this request.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Request for Production
was served upon the Defendant together with Summons and Complaint.
The Law Offices of
NEUFELD, KLEINBERG & PINKIERT, P.A.
2641 N.E. 207th Street
Aventura, Florida 33180
Telephone No: (305) 931-6666 - Dade
(954) 523-8292 - Broward
Da
FLORIDA BAR NO: 765260
Primary: Dkleinberg/@inkplaw.com
Secondary: Sara‘@nkplaw.com
Document Filed Date
January 29, 2018
Case Filing Date
January 17, 2018
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing # 67197742 E-Filed 01/29/2018 03:36:45 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA " CASE NO: CACE-18-001261 Div: 02 MARKEEMO K. MYRIE, Plaintiff, vs. CHRISTOPHER K. ST WARMINGTON, and STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, an Insurance Company Defendants. / REQUEST FOR PRODUCTION TO THE DEFENDANT, Cc ‘OPHER K. ST INGTON COMES NOW the Plaintiff, MARKEEMO K. MYRIE, by and through his undersigned counsel, pursuant to Rule 1.350, of the Florida Rules of Civil Procedure, and requests the Defendant, CHRISTOPHER K. ST WARMINGTON, to produce for copying and/or inspection, the following documents or items: 1. A copy of the front and back of the Defendant’s Driver’s License. 2. Any and all repair bills, repair estimates, receipts, invoices, canceled checks, and/or credit card receipts or statements, obtained for the Defendant's vehicle after the accident, which is the subject matter of the Complaint. 3. Any and all photographs taken by the Defendant, his attorney, investigators, agents, servants, or employees, after the accident referred to in the Complaint, which are in any manner related to the subject matter of this lawsuit. 4, Copy of the title to the Defendant's motor vehicle which was involved in the subject accident. 5. Copies of all transcripts of any and all hearings, trials, or other adjudications held by any state, county or municipality with respect to the incident upon which this cause of action is alleged to be based. *** FILED: BROWARD COUNTY. FL BRENDA D. FORMAN. CLERK 1/29/2018 3:36:44 PM.****6. Copies of all writings, recordings, memorandums, notes or other materials reflecting statements made by the Plaintiff regarding the issues in this case. fe Copies of all insurance polices inuring to the benefit of Plaintiff in this case. As good cause for this request, Plaintiff would show unto the Court that the documents requested are in the care, custody and control of the Defendant, his agents, servants and/or employees, insurance companies or attorneys, and the Plaintiff cannot secure the equivalent of same. Said material is relevant and material to the issues in this lawsuit and the Plaintiff cannot secure them without this request. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Request for Production was served upon the Defendant together with Summons and Complaint. The Law Offices of NEUFELD, KLEINBERG & PINKIERT, P.A. 2641 N.E. 207th Street Aventura, Florida 33180 Telephone No: (305) 931-6666 - Dade (954) 523-8292 - Broward Da FLORIDA BAR NO: 765260 Primary: Dkleinberg/@inkplaw.com Secondary: Sara‘@nkplaw.com