The Plaintiff, J.B., through his undersigned attorney, requests the Defendant, C.M., to produce, pursuant to Fla.R.Civ.P. 1.350, the following:
1. Photographs of the vehicle C.M. was operating at the time of the subject incident depicting the damage the vehicle sustained as a result of the subject collision.
2. Any statements of the Plaintiff taken by or on behalf of any of the defendant or her insurer or reproductions of any recorded statements of the Plaintiff.
3. Statements of any witnesses taken by or on behalf of the Defendant or her insurer.
4. Declaration sheet of each liability policy insuring any of the Defendant for their potential liability for the Plaintiff.
5. Copy of any and all cell-phone records/bill of Defendant from the day of subject incident.
6. Medical records of Defendant for injuries sustained in the subject incident.
7. Photographs or surveillance of Plaintiff by or on behalf of Defendant or her 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.
Hallandale Beach, FL 33009
Telephone: (954) 455-0800
Facsimile: (954) 455-9649
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.