West Palm Beach, Florida SAMPLE REQUEST FOR PRODUCTION OF DOCUMENTS FROM DEFENSE COUNSEL IN AN AUTOMOBILE CASE
REQUEST #1:
A certified, legible copy of any memoranda, notes, correspondence, reports including pharmacology reports, or other documents of any kind, of any hospital, laboratory, clinic or other medical or health facility, by or at which the Plaintiff has been examined, treated, or tested within the last ten years.
REQUEST #2:
Legible copies of any and all reports, correspondence, memoranda, notes including office notes or other documents of any kind whatsoever reflecting the examination, testing, or treatment provided by any physician, technician, physical therapist, or other practitioner of the healing arts, or psychologist, psychiatrist, marriage and/or sex counselor, or other treating individual, relative to the Plaintiff within ten years prior to this request.
REQUEST #3:
Legible copies of any report, list, memoranda, graph, correspondence or other documents of any kind, reflecting in any way test or treatment or examination performed on or with the Plaintiff, within the ten years prior to the date of this request.
REQUEST #4:
Each and every statement, bill, check or other document of any kind reflecting any medical expenses on the part of the Plaintiff, related to the occurrence of which the Plaintiff complained in this action.
REQUEST #5:
Each and every document of any kind which relates in any way to the damages which are not of a medical nature which the Plaintiff claims to have suffered or incurred in relation to the subject matter of this action.
REQUEST #6:
All statements, recorded or written, by any witness or party.
REQUEST #7:
Every report or description of the occurrence which is the subject of your Complaint, including reports to the State Division of Motor Vehicles, any policy agency, and your insurer.
REQUEST #8:
Any and all notes, memoranda, correspondence, reports, or other documents of any kind, reflecting treatment, examination, testing, or consultation for each and every psychologist, psychiatrist, psychotherapist, or similar health professional, relating to injuries allegedly sustained by the Plaintiff relative to the occurrence which forms the subject matter of this suit.
REQUEST #9:
Any and all tax returns filed in any state, local or federal taxing authority filed by or on behalf of the Plaintiff for the past five years, together with any and all W2 forms or similar statements of earnings of the Plaintiff for the past 5 years.
REQUEST #10:
Plaintiff’s employment records, including but not limited to the personnel file, application to, evidence of wages or income paid by, resignation, notice of termination, correspondence to and from and all other records kept by each of the Plaintiff and Plaintiff’s employers in the five years immediately preceding the date of the incident.
REQUEST #11:
All records verifying Plaintiff’s claim for lost income.
REQUEST #12:
A copy of each and every photograph, sketch, videotape, chart or diagram which relates in any way to the claim which is the subject matter of this action.
REQUEST #13:
Each and every document in the nature of a report or otherwise reflecting any of the Plaintiff’s experts’ opinions concerning the subject matter of this action.
REQUEST #14:
Copies of all workers compensation pleadings, transcripts or other documents relating to the injury which is the subject of this lawsuit.
REQUEST #15:
Copies of all employment records including but not limited to personnel files, time cards, and medical records for the past ten years prior to the date of this request.
REQUEST #16:
Copies of all pleadings from any civil lawsuit in which you were a plaintiff in the past ten years.
REQUEST #17:
All repair bills, estimates of repair and photographs of the physical damage you claim was caused to any motor vehicle in the occurrence which is the subject of your Complaint.
REQUEST #18:
Copies of your cellular phone bill for the month in which the incident that is the subject of your complaint occurred.