On January 05, 2018 a
Supplemental Request to Produce - to defendant Geico General Insurance CompanyParty: Plaintiff Ross, Thomas
was filed
involving a dispute between
Ross, Thomas,
and
Geico General Insurance Company,
Liefer, Brian,
for Auto Negligence
in the District Court of Broward County.
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Case Number: CACE-18-000308 Division: 03
Filing # 66138786 E-Filed 01/05/2018 09:20:55 AM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL
CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA
THOMAS ROSS,
Plaintiff, )
)
-VS- )
) CASENO.:
BRIAN LIEFER and GEICO
GENERAL INSURANCE COMPANY, )
Defendants. J
/
SUPPLEMENTAL REQUEST FOR PRODUCTION
TO GEICO GENERAL INSURANCE COMPANY
COMES NOW the Plaintiff, THOMAS ROSS, by and through the undersigned counsel and
pursuant to Fla. R. Civ. P. 1.350, requests that GEICO GENERAL INSURANCE COMPANY,
produce for inspection and copying the following within 45 days after service of the Summons and
Complaint hereof.
1, Any and all correspondence, notes, or memorandums or evidence reflecting
communications either in writing or verbally between the Plaintiff and any of her agents, servants,
or attorneys and the Defendant, GEICO GENERAL INSURANCE COMPANY
2. Any and all correspondence, notes or memorandums or evidence of communications
either verbally or in writing between the Defendant, GEICO GENERAL INSURANCE COMPANY
and any other provider of benefits to the Plaintiff as a result of this incident.
3. Any and all medical reports or records relative to THOMAS ROSS which are in the
possession of the Defendant or any of its agents, servants or attorneys.
4, Any and all records of any benefits which the Plaintiff has received from any source
for expenses or damages incurred as a result to this incident. This includes GEICO GENERAL
INSURANCE COMPANY's own pay-out sheet.
** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 1/5/2018 9:20:53 AM.****5. Any and all reports rendered by experts applicable to any and all issues in the case
intended to be used at trial.
HEREBY CERTIFY that a copy of the foregoing has been served on the above Defendant,
BRIAN LIEFER and GEICO GENERAL INSURANCE COMPANY, with the Complaint.
STEINGER, ISCOE & GREENE, P.A.
Coastal Tower
2400 E. Commercial Blvd Suite 900
Fort Lauderdale, FL 33308
Telephone: (954) 491-7701
Facsimile: (954) 634-8329
Email: mpurow@injurylawyers.com
acox@injurylawyers.com
Attorneys for Plaintiffs
Malcolm A. Purow, Esquire
Florida Bar No.: 282790
Document Filed Date
January 05, 2018
Case Filing Date
January 05, 2018
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Case Number: CACE-18-000308 Division: 03 Filing # 66138786 E-Filed 01/05/2018 09:20:55 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA THOMAS ROSS, Plaintiff, ) ) -VS- ) ) CASENO.: BRIAN LIEFER and GEICO GENERAL INSURANCE COMPANY, ) Defendants. J / SUPPLEMENTAL REQUEST FOR PRODUCTION TO GEICO GENERAL INSURANCE COMPANY COMES NOW the Plaintiff, THOMAS ROSS, by and through the undersigned counsel and pursuant to Fla. R. Civ. P. 1.350, requests that GEICO GENERAL INSURANCE COMPANY, produce for inspection and copying the following within 45 days after service of the Summons and Complaint hereof. 1, Any and all correspondence, notes, or memorandums or evidence reflecting communications either in writing or verbally between the Plaintiff and any of her agents, servants, or attorneys and the Defendant, GEICO GENERAL INSURANCE COMPANY 2. Any and all correspondence, notes or memorandums or evidence of communications either verbally or in writing between the Defendant, GEICO GENERAL INSURANCE COMPANY and any other provider of benefits to the Plaintiff as a result of this incident. 3. Any and all medical reports or records relative to THOMAS ROSS which are in the possession of the Defendant or any of its agents, servants or attorneys. 4, Any and all records of any benefits which the Plaintiff has received from any source for expenses or damages incurred as a result to this incident. This includes GEICO GENERAL INSURANCE COMPANY's own pay-out sheet. ** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 1/5/2018 9:20:53 AM.****5. Any and all reports rendered by experts applicable to any and all issues in the case intended to be used at trial. HEREBY CERTIFY that a copy of the foregoing has been served on the above Defendant, BRIAN LIEFER and GEICO GENERAL INSURANCE COMPANY, with the Complaint. STEINGER, ISCOE & GREENE, P.A. Coastal Tower 2400 E. Commercial Blvd Suite 900 Fort Lauderdale, FL 33308 Telephone: (954) 491-7701 Facsimile: (954) 634-8329 Email: mpurow@injurylawyers.com acox@injurylawyers.com Attorneys for Plaintiffs Malcolm A. Purow, Esquire Florida Bar No.: 282790