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Filing #64358071 E-Filed 11/17/2017 02:44:55 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR ORANGE COUNTY, FLORIDA
AURORA ANN PORTER,
Plaintiff,
Vv. CASE NUMBER: 2017-CA-3902-0
ORLANDO UTILITIES COMMISSION,
Defendant.
REQUEST FOR PRODUCTION
COMES NOW the Defendant, ORLANDO UTILITIES COMMISSION, by and through
undersigned counsel, and requests the Plaintiff, AURORA ANN PORTER, produce to said
Defendant at the offices of its counsel O;CONNOR & O’CONNOR, 840 S. Denning Drive, Suite
200, Winter Park, FL, 32789, within thirty (30) days of the date hereof, or at such other reasonable
time and place as might be mutually agreed upon by the attorneys for the parties, for the purpose of
inspection of the matters described below.
Defendant states the need to examine and inspect the attached and described items and are
unable to obtain these items by other means, or alternatively, the Defendant is otherwise entitled to
these items under the applicable Rules of Civil Procedure and case law interpreting such Rules.
1 Copy of the front and back of Plaintiff's driver license.
2 Copies of Plaintiff's complete income tax returns for the years 2012 to the present,
including all Form 1099's and W-2 wage and tax statements received by the Plaintiff.
Copies of all medical bills and reports, dental bills and records, hospital records and bills
and any other medical documentation, reports, opinions or other written memoranda from
physicians, nurses, therapists or other medical practitioners, including x-rays or other
films, that pertain in any way to the damages alleged by Plaintiff in the Complaint;
Copies of all statements obtained by Plaintiff from Defendant, its agents, employees or
representatives whether recorded, transcribed, or handwritten concerning the facts and
events surrounding the accident;
Copies of all statements obtained by Plaintiff from any witnesses, whether recorded,
transcribed, or handwritten concerning the facts and events surrounding the accident;
Copies of all photographs, slides, movies, video tapes, drawings or other representations
or depiction of Plaintiff's alleged injuries;
Copies of all insurance policies, including DEC sheets, which may provide any form of
coverage to Plaintiff for the accident that is the subject of Plaintiff's Complaint, including
but not limited to automobile, disability and health insurance.
Copies of any and all records reflecting payment, by any source, for any and all damages
claimed, to wit:
a. All payments made to you, or on your behalf, by or pursuant to the United States
Social Security Act, as a result of the incident alleged in the Complaint.
All payments made to you or on your behalf by or pursuant to any Federal Income
Disability Act, as a result of the incident described in the Complaint.
Any and all payments made to you or on your behalf by or pursuant to any State
Income Disability Act, as a result of the incident described in the Complaint.
All payments made to you, or on your behalf, by or pursuant to, any local income
disability act, as a result of the incident described in the Complaint.
All payments made to you or on your behalf by or pursuant to any other public
programs providing medical expenses, disability payments, or other similar
benefits, as a result of the incident in the Complaint.
All payments made to you, or on your behalf, by or pursuant to any health,
sickness, or income disability insurance, as a result of the incident described in
the Complaint.
All payments made to you on your behalf as a result of this incident, by or
pursuant to, any other similar insurance benefits, except life insurance benefits
available to you, whether purchased by you, or provided by others.
All payments made to you, or on your behalf, as a result of the incident described
in the Complaint, by or pursuant to any to any contract or agreement of any
group, organization, partnership, or corporation to provide, pay for, or reimburse
the cost of hospital, medical, dental or other health care services incurred by you
or on your behalf as.a result of the subject matter.
All payments made to you, or on your behalf, as a result of the subject incident,
by or pursuant to any contractual or voluntary wage continuation plan provided by
employers or other system intended to provide wages during a period of
disability.
All payments made to you, or on your behalf, as a result of the incident described
in the Complaint, by or pursuant to Workers’ Compensation insurance.
Copies of all records which document or evidence your claim of a wage loss.
10. Copies of any and all releases, settlement agreements covenants not to sue and/or
judgments and all other documents, such as contracts, correspondence, memos, and the
like, pertaining to the settlements reached between the Plaintiff and any other person,
firm or corporation arising out of the incident referred to in the Complaint.
1 All photographs, slides, videotapes, movies, drawings or diagrams, including cell phone
pictures, videos and recordings, of the scene of the motor vehicle accident described in
the Complaint. Please document in a privilege log any items you claim are work product
protected.
12. All photographs, slides, videotapes, movies, drawings or diagrams of the motor vehicles
involved in the motor vehicle accident described in the Complaint. Please document in a
privilege log any items you claim are work product protected.
13 All photographs, slides, videotapes, movies, drawings or diagrams of the site of the motor
vehicle accident described in the Complaint. Please document in a privilege log any
items you claim are work product protected.
14, All rental bills, vehicle appraisals and repair bills for the vehicles involved in the accident
described in the Complaint.
15 A copy of all accident reports for the accident described in the Complaint. Please
document in a privilege log any items you claim are work product protected.
16. All documentary evidence that Plaintiff intends to introduce at the trial of this cause of
action.
17. All reports, opinions, correspondence or other memoranda from experts whom you intend
to call as witnesses at trial.
18 A copy of the title and registration for the vehicle in which Plaintiff was in at the time of
the accident which is the subject of Plaintiff's Complaint.
CERTIFICATE OF SERVICE
I] HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by U.S.
Mail to MATTHEW A. RABIN, ESQ., REIFKIND, THOMPSON & RUDZINSKI, P.L., 12545
Orange Drive, Ste 503, Davie, FL 33330, (e-service: mrabin@rtrlaw.com;LSepot-
Green@rtrlaw.com) counsel for Plaintiff and CARLOS L. WOODY, ESQ. and TERRIE L
TRESSLER, ESQ. 100 W. Anderson Street, P.O. Box 3193, Orlando, FL 32801 (e-service
cwoody@ouc.com, ttessler@ouc.com, kplajstek@ouc.com) co-counsel for Defendant on this
_L Pay of November, 2017 kz L.
DENNIS\R. O'C
Florida Bar Number: neh
DOConno oconl: col
RONALD k. HARROP, ESQ
Florida Bar mber: 260584
rharrop@oconlaw.com
O'CONNOR & O'CONNOR , LLC
840 S. Denning Drive, Suite 200
Winter Park, FL 32789
(407) 843-2100 PH: (407) 843-2061 Facsimile
CARLOS L. WOODY, ESQ
Florida Bar No.: 0014077
TERRIEL. TRESSLER, ESQ
Florida Bar No.: 0015809
ORLANDO UTILITIES COMMISSION
100 W. Anderson Street
P.O. Box 3193
Orlando, FL 32801
Attorneys for Defendant Orlando Utilities
Commission
Preview
Filing #64358071 E-Filed 11/17/2017 02:44:55 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA AURORA ANN PORTER, Plaintiff, Vv. CASE NUMBER: 2017-CA-3902-0 ORLANDO UTILITIES COMMISSION, Defendant. REQUEST FOR PRODUCTION COMES NOW the Defendant, ORLANDO UTILITIES COMMISSION, by and through undersigned counsel, and requests the Plaintiff, AURORA ANN PORTER, produce to said Defendant at the offices of its counsel O;CONNOR & O’CONNOR, 840 S. Denning Drive, Suite 200, Winter Park, FL, 32789, within thirty (30) days of the date hereof, or at such other reasonable time and place as might be mutually agreed upon by the attorneys for the parties, for the purpose of inspection of the matters described below. Defendant states the need to examine and inspect the attached and described items and are unable to obtain these items by other means, or alternatively, the Defendant is otherwise entitled to these items under the applicable Rules of Civil Procedure and case law interpreting such Rules. 1 Copy of the front and back of Plaintiff's driver license. 2 Copies of Plaintiff's complete income tax returns for the years 2012 to the present, including all Form 1099's and W-2 wage and tax statements received by the Plaintiff. Copies of all medical bills and reports, dental bills and records, hospital records and bills and any other medical documentation, reports, opinions or other written memoranda from physicians, nurses, therapists or other medical practitioners, including x-rays or other films, that pertain in any way to the damages alleged by Plaintiff in the Complaint; Copies of all statements obtained by Plaintiff from Defendant, its agents, employees or representatives whether recorded, transcribed, or handwritten concerning the facts and events surrounding the accident; Copies of all statements obtained by Plaintiff from any witnesses, whether recorded, transcribed, or handwritten concerning the facts and events surrounding the accident; Copies of all photographs, slides, movies, video tapes, drawings or other representations or depiction of Plaintiff's alleged injuries; Copies of all insurance policies, including DEC sheets, which may provide any form of coverage to Plaintiff for the accident that is the subject of Plaintiff's Complaint, including but not limited to automobile, disability and health insurance. Copies of any and all records reflecting payment, by any source, for any and all damages claimed, to wit: a. All payments made to you, or on your behalf, by or pursuant to the United States Social Security Act, as a result of the incident alleged in the Complaint. All payments made to you or on your behalf by or pursuant to any Federal Income Disability Act, as a result of the incident described in the Complaint. Any and all payments made to you or on your behalf by or pursuant to any State Income Disability Act, as a result of the incident described in the Complaint. All payments made to you, or on your behalf, by or pursuant to, any local income disability act, as a result of the incident described in the Complaint. All payments made to you or on your behalf by or pursuant to any other public programs providing medical expenses, disability payments, or other similar benefits, as a result of the incident in the Complaint. All payments made to you, or on your behalf, by or pursuant to any health, sickness, or income disability insurance, as a result of the incident described in the Complaint. All payments made to you on your behalf as a result of this incident, by or pursuant to, any other similar insurance benefits, except life insurance benefits available to you, whether purchased by you, or provided by others. All payments made to you, or on your behalf, as a result of the incident described in the Complaint, by or pursuant to any to any contract or agreement of any group, organization, partnership, or corporation to provide, pay for, or reimburse the cost of hospital, medical, dental or other health care services incurred by you or on your behalf as.a result of the subject matter. All payments made to you, or on your behalf, as a result of the subject incident, by or pursuant to any contractual or voluntary wage continuation plan provided by employers or other system intended to provide wages during a period of disability. All payments made to you, or on your behalf, as a result of the incident described in the Complaint, by or pursuant to Workers’ Compensation insurance. Copies of all records which document or evidence your claim of a wage loss. 10. Copies of any and all releases, settlement agreements covenants not to sue and/or judgments and all other documents, such as contracts, correspondence, memos, and the like, pertaining to the settlements reached between the Plaintiff and any other person, firm or corporation arising out of the incident referred to in the Complaint. 1 All photographs, slides, videotapes, movies, drawings or diagrams, including cell phone pictures, videos and recordings, of the scene of the motor vehicle accident described in the Complaint. Please document in a privilege log any items you claim are work product protected. 12. All photographs, slides, videotapes, movies, drawings or diagrams of the motor vehicles involved in the motor vehicle accident described in the Complaint. Please document in a privilege log any items you claim are work product protected. 13 All photographs, slides, videotapes, movies, drawings or diagrams of the site of the motor vehicle accident described in the Complaint. Please document in a privilege log any items you claim are work product protected. 14, All rental bills, vehicle appraisals and repair bills for the vehicles involved in the accident described in the Complaint. 15 A copy of all accident reports for the accident described in the Complaint. Please document in a privilege log any items you claim are work product protected. 16. All documentary evidence that Plaintiff intends to introduce at the trial of this cause of action. 17. All reports, opinions, correspondence or other memoranda from experts whom you intend to call as witnesses at trial. 18 A copy of the title and registration for the vehicle in which Plaintiff was in at the time of the accident which is the subject of Plaintiff's Complaint. CERTIFICATE OF SERVICE I] HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by U.S. Mail to MATTHEW A. RABIN, ESQ., REIFKIND, THOMPSON & RUDZINSKI, P.L., 12545 Orange Drive, Ste 503, Davie, FL 33330, (e-service: mrabin@rtrlaw.com;LSepot- Green@rtrlaw.com) counsel for Plaintiff and CARLOS L. WOODY, ESQ. and TERRIE L TRESSLER, ESQ. 100 W. Anderson Street, P.O. Box 3193, Orlando, FL 32801 (e-service cwoody@ouc.com, ttessler@ouc.com, kplajstek@ouc.com) co-counsel for Defendant on this _L Pay of November, 2017 kz L. DENNIS\R. O'C Florida Bar Number: neh DOConno oconl: col RONALD k. HARROP, ESQ Florida Bar mber: 260584 rharrop@oconlaw.com O'CONNOR & O'CONNOR , LLC 840 S. Denning Drive, Suite 200 Winter Park, FL 32789 (407) 843-2100 PH: (407) 843-2061 Facsimile CARLOS L. WOODY, ESQ Florida Bar No.: 0014077 TERRIEL. TRESSLER, ESQ Florida Bar No.: 0015809 ORLANDO UTILITIES COMMISSION 100 W. Anderson Street P.O. Box 3193 Orlando, FL 32801 Attorneys for Defendant Orlando Utilities Commission