IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
CASE NUMBER: 00-xxxx
M.B.,
Plaintiff,
vs.
C.B.,
Defendant.
__________________________________/
PLAINTIFF’S REQUEST FOR PRODUCTION TO DEFENDANT
The Plaintiff, M.B., through his undersigned attorney, requests the Defendant, C.B., to produce, pursuant to Fla.R.Civ.P. 1.350, the following:
1. Photographs of the vehicle Defendant’s was operating at the time of the subject incident depicting the damage the vehicle sustained as a result of the subject collision.
2. Repair bill for the damage referred to in #1, above.
3. Any statements of the Plaintiff taken by or on behalf of the Defendant or her insurer or reproductions of any recorded statements of the Plaintiff.
4. Statements of any witnesses taken by or on behalf of the Defendant or her insurer.
5. Declaration sheet of each liability policy insuring the Defendant for her potential liability to the Plaintiff.
6. Copy of any and all Defendant’s cell-phone records and bills of Defendant for the day of subject incident.
7. Medical records of Defendant for injuries sustained in the subject incident.
8. Photographs or surveillance of Plaintiff taken by or on behalf of Defendant or his insurer.
IT IS HEREBY CERTIFIED that a true and correct copy of the foregoing has been served with the complaint.
LAW OFFICE OF ALAN D. SACKRIN
Attorney for Plaintiff(s)
2100 East Hallandale Beach Blvd.
Suite 200
Hallandale Beach, FL 33009
Telephone: (954) 455-0800
Facsimile: (954) 455-9649
By______________________________
ALAN D. SACKRIN
Florida Bar No. 349070
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The pleading above is a sample document related to a specific set of facts and circumstances and should not be used or relied upon for any personal injury matter. We recommend and urge you to consult with an experienced lawyer for professional advice as each case is unique.