On December 19, 2019 a
Request for Production
was filed
involving a dispute between
Jean Baptiste, Chandler,
and
City Of Sunrise,
Otello, Frank Anthony,
for Auto Negligence
in the District Court of Broward County.
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Filing # 102472974 E-Filed 01/30/2020 10:16:48 AM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE-19-026009
CHANDLER JEAN BAPTISTE,
Plaintiff,
VS.
CITY OF SUNRISE,
Defendant.
/
PLAINTIFF’S REQUEST FOR PRODUCTION TO DEFENDANT
The Plaintiff, CHANDLER JEAN BAPTISTE, by and through his/her undersigned
attorney, pursuant to the Rules of Civil Procedure, requests the Defendant, CITY OF SUNRISE,
to produce within thirty (30) days from the date of this Request the following items:
1. A copy of any and all insurance policies that were in force and effect on
8/22/2018 which would inure to the benefits of CITY OF SUNRISE.
2. Any and all photographs taken by the Defendant, showing the extent of damage to
any of the vehicles involved in the accident.
3. Any and all photographs taken by the Defendant of the scene of the accident.
4, Any all estimates of repair or statements concerning the nature and extent of
damage to any of the vehicles involved in the accident.
5. Any and all writings, memorandums, notes, or other materials reflecting
examination by the Defendant of any of the vehicles involved in the accident.
6. Any and all records reflecting the towing of any vehicles involved in the accident
from the scene of the accident.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/30/2020 10:16:49 AM.****7. Any and all statements, oral and/or written taken by Defendant of the Plaintiff.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was forwarded by
Electronic Mail to: E. BRUCE JOHNSON, ESQ., JOHNSON, ANSELMO, MURDOCH,
BURKE, PIPER, & HOCHMAN, P.A., Attorneys for Defendant, johnson@jambg.com, this
Bet day of (Janu 2029.
MILLER LAW GROUP, P.A.
1937 East Atlantic Boulevard, Suite 204
Pompano Beach, Florida 33060
Telephone: (954)972-8011
Telefax: (954)782-3636
Primary E-Mail: litigation@millerlaw.legal
/s/ MOHAMMED HAIDER
By:
MOHAMMED HAIDER
Florida Bar No. 1003274
Document Filed Date
January 30, 2020
Case Filing Date
December 19, 2019
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Filing # 102472974 E-Filed 01/30/2020 10:16:48 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-19-026009 CHANDLER JEAN BAPTISTE, Plaintiff, VS. CITY OF SUNRISE, Defendant. / PLAINTIFF’S REQUEST FOR PRODUCTION TO DEFENDANT The Plaintiff, CHANDLER JEAN BAPTISTE, by and through his/her undersigned attorney, pursuant to the Rules of Civil Procedure, requests the Defendant, CITY OF SUNRISE, to produce within thirty (30) days from the date of this Request the following items: 1. A copy of any and all insurance policies that were in force and effect on 8/22/2018 which would inure to the benefits of CITY OF SUNRISE. 2. Any and all photographs taken by the Defendant, showing the extent of damage to any of the vehicles involved in the accident. 3. Any and all photographs taken by the Defendant of the scene of the accident. 4, Any all estimates of repair or statements concerning the nature and extent of damage to any of the vehicles involved in the accident. 5. Any and all writings, memorandums, notes, or other materials reflecting examination by the Defendant of any of the vehicles involved in the accident. 6. Any and all records reflecting the towing of any vehicles involved in the accident from the scene of the accident. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/30/2020 10:16:49 AM.****7. Any and all statements, oral and/or written taken by Defendant of the Plaintiff. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was forwarded by Electronic Mail to: E. BRUCE JOHNSON, ESQ., JOHNSON, ANSELMO, MURDOCH, BURKE, PIPER, & HOCHMAN, P.A., Attorneys for Defendant, johnson@jambg.com, this Bet day of (Janu 2029. MILLER LAW GROUP, P.A. 1937 East Atlantic Boulevard, Suite 204 Pompano Beach, Florida 33060 Telephone: (954)972-8011 Telefax: (954)782-3636 Primary E-Mail: litigation@millerlaw.legal /s/ MOHAMMED HAIDER By: MOHAMMED HAIDER Florida Bar No. 1003274