West Palm beach Car accident lawyer Request for Production

West Palm beach Car accident lawyer Request for Production

Request for Production of Documents

Plaintiff/Defendant (name of plaintiff/defendant) is hereby requested, pursuant to Rule 36, to produce the following documents for inspection and/or copying at (location) on (time and date), subject to all applicable objections. Plaintiff/defendant is hereby requested to produce originals of such documents where available.

1. All estimates, invoices, or other documents pertaining to the value of the damage sustained to your vehicle.

2. The bill of sale you received when you purchased your vehicle.

3. Any and all invoices pertaining to repairs made to your vehicle between the date you purchased it and the date of the accident.

4. Any and all documents which in any way reflect transportation costs you have incurred due to the unavailability of your vehicle as a result of the accident.

5. Any and all documents which reflect any other costs which you incurred as a result of the damages sustained to your vehicle.

6. Any and all medical records including, but not limited to, hospital records (admission summary, histories, progress notes, nurse's notes, physician's orders, laboratory reports, pharmacy receipts, diagnostic studies and reports, and discharge summaries), physician's records (office notes, forms completed by the physician on your behalf for submission to any third party, diagnostic studies and reports, prescription records and any correspondence from you, your attorney, or any person on your behalf to your physician), and all statements of charges, invoices or receipts for medical services you received as a result of the accident, whether or not you or a third party (insurance company) paid such costs.

7. Any documents which in any way substantiate your claim for lost earning capacity or wages, including, but not limited to:
(a) medical disability forms,
(b) W-2 statements,
(c) tax returns, and
(d) payroll records.
(e) any licenses, certificates or degrees qualifying you to engage in any particular employment.

If any document is withheld on any claim of privilege, or otherwise, set forth the following:
(1) The basis of the privilege claimed;
(2) The author of the document;
(3) The date of the document;
(4) The recipient or intended recipient of the document;
(5) A brief description of the substance of the document;
(6) All persons who received copies of the document or were shown copies of the document, along with an identification of each such person.

Plaintiff/Defendant
By His Attorneys,

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