[System]
You are a lawyer with 10 years of experience. Based on the complaint, create up to 20 questions for the defendant.

The questions should follow the format and style of this example response to a car accident complaint:
1. All photographs, diagrams, or other printed or written material describing or attempting to describe the scene of the accident alleged in the Complaint, or any person described in the Complaint.
2. Documentation substantiating health insurance coverage available to Plaintiff on the date of the accident sued upon.
3. Any cellular phones or other mobile communication system telephone bills, invoices, statements, itemized accounts, or other data compilation for the equipment owned or used by Plaintiffs for the months relevant to the incident.
4. Any and all films, diagnostic tests, MRIs, X-rays, storage devices, digital images, intra-operative photographs, and/or data compilations from which information can be obtained.
5. If a claim is made for lost wages and/or loss of earning capacity in the future, provide specific documentation like Federal Income Tax Returns and W-2 Forms.

Be specific, detailed and relevant to the complaint's allegations. Avoid generic requests for "all documents" or "all evidence". Each question should request specific items, time periods, or information directly related to the complaint's claims.

[User] #### IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEANINE TIERNEY, Plaintiff, v. NEIL MINTZ, Defendant. ### COMPLAI NT #### COMES NOW the Plaintiff, JEANINE TIERNEY, by and through her undersigned counsel and hereby sues the Defendant, NEIL MINTZ, and alleges: **ALLEGATIONS** **COMMON** **TO** **ALL** **COUNTS** This is an action for damages which exceeds the sum of Fifteen #### Thousand Dollars ($15, 000. 00). On or about May 11, 2015, Defendant, NEIL MINTZ, owned and #### operated a motor vehicle at the intersection of NW 13th Street and NW 15th Court in Palm Beach County, Florida. At the time and place aforementioned. Defendant, NEIL MINTZ, so #### negligently operated and maintained his motor vehicle so as to cause it to collide and crash with a motor vehicle owned and operated by Plaintiff, JEANINE TIERNEY. ----- **_Page_** **_2_** #### COUNTI As a direct and proximate result. Plaintiff, JEANINE TIERNEY, was #### injured in and about her body, suffered aggravation of pre-existing condition, pain and suffering, disability, disfigurement, impairment of working ability, mental anguish, loss of enjoyment of life and Plaintiff incurred medical expenses in the care and treatment of said injuries; all of said injuries are permanent within a reasonable degree of medical probability. WHEREFORE, Plaintiff, JEANINE TIERNEY, demands judgment for damages against the Defendant and further demands trial by jury. d this 10th day of February, 2017 ### /s/Todd Fronrath, Esquire #### Todd Fronrath, Esquire Florida Bar No. : 547271 Attorneys for Plaintiff Lytal, Reiter, Smith, Ivey & Fronrath 515 N. Flagler Drive, 10th Floor #### West Palm Beach, FL 33401 Telephone: (561) 655-1990 Facsimile: (561) 832-2932 Email: tfronrath@foryourrights. com Email: kjanis@foryourrights. com -----

[Assistant] IN THE CIRCUIT COURT OF THE `15th` JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEANINE TIERNEY, Judge Meenu Sasser Plaintiff, vs. MILLER’S ALE HOUSE, INC. , a Foreign Profit Corporation, d/b/a EAST BOCA ALE HOUSE and NEIL MINTZ, Defendants. __________________________________ I_ **DEFENDANT, ** **NEIL** **MINTZ’S** **FIRST** **REQUEST** **TO** **PRODUCE** **TO** **PLAINTIFF** COMES NOW, Defendant, NEIL MINTZ, pursuant to Florida Rule of Civil Procedure 350, requests that Plaintiff, JEANINE TIERNEY, produce and permit Defendant to inspect and photograph the following: A photocopy of the card for any and all health insurance you have carried in the past seven (7) years. Cancelled checks and receipts for any expenses incurred by you as a result of this accident. Copies of any documents reflecting any claim you have made in the past for personal injury, wages or other compensation, whether a lawsuit, written demand or for worker's compensation or Social Security benefits. A photocopy of any health insurance policies or insurance records in your possession for the last seven (7) years, or if unavailable, provide the name and address of any company who has custody of such documents. ----- A photocopy of any life insurance applications or other paperwork regarding applications or policies in the last seven (7) years, or if unavailable, the name and address of any company who has custody of such documents. Copies of any disability insurance applications or other paperwork regarding applications or policies in the last seven (7) years, or if unavailable, the name and address of any company who has custody of such documents. A copy of all pages of your passport. Copy or membership number of any frequent flyer program you have been involved in for the last five (5) years. Copies of any statements of any defendant or employee or agent of any defendant with regard to this incident. _(Ifyou_ _are_ _not_ _in_ _possession_ _of_ _any_ _statement, _ _but_ _know_ _who_ _made_ _such_ _written_ _statements, _ _please_ _provide_ _the_ _name, _ _address_ _and_ _telephone_ _number_ _ofthe_ _person_ _whom_ _you_ _believe_ _has_ _possession_ _ofthese_ _written_ _statements. )_ Copies of any statements of any witnesses; or the name, address and identity, includingstatement was taken, of any witnesses. _(Ifyou_ _are_ _not_ _in_ _possession_ ## ofany statement, but know who made such written statements, please provide the _name, _ _address_ _and_ _telephone_ _number_ _of_ _the_ _person_ _whom_ _you_ _believe_ _has_ _possession_ _ofthese_ _written_ _statements. )_ Any and all photographs, films or videotapes in your possession which depict or purport to depict the scene of the subject incident, any aspect of the subject incident scene with regard to this incident. (Defendant will pay reasonable cost for two (2) reprints. ) ----- Any and all photographs, films or videotapes in your possession which depict or purport to depict any aspect of Plaintiffs injuries herein. (Defendant will pay reasonable cost of two (2) reprints. ) Records from any and all non-party health care providers, including, but not limited to hospital records, specialist records, chiropractic records, osteopathic records, psychologist records, psychiatrist records, records from drug and/or alcohol programs, faith healers records, x-ray reports, test results, MRI scan reports, CT scan reports, nurses notes, physical therapy records, including copies ### of any radiographic materials such as x-ray films, CT films, MRI films which relate to or concern the Plaintiffs injuries alleged in the Complaint as a result of the subject incident. Any and all medical bills, receipts or invoices which you contend support or tend to support your damage claims in this case arising from the subject incident. Any and all documents, articles, writings, correspondence, recordings or memoranda which you contend support or tend to support any allegation set forth in the Complaint. Any and all written reports from any expert witness or consultant retained by the Plaintiff. Any and all Income Tax returns and W-2 forms for the past seven (7) years. Copy of the Driver's License of the Plaintiff. Copy of the Social Security card of the Plaintiff. Any and all Marriage Licenses of Plaintiff. Copy of the Birth Certificate of the Plaintiff. ----- Any and all accident or incident reports generated from any prior accidents which the Plaintiff was involved in prior to the subject incident, including any automobile accidents or other accidents or incidents. Any and all accident or incident reports generated from any accidents which the Plaintiff was involved in subsequent to the subject incident, including any automobile accidents, or other accidents or incidents. Any and all reports and records of any health care provider for any treatment to the Plaintiff as a result of the subject incident. Any and all reports and records of any health care provider for any treatment to the Plaintiff for seven (7) years prior to the subject incident. Any and all hospital records, nurses' notes, doctors' notes, progress notes, radiology reports, MRI films, x-rays, and MRI reports, and medical bills for any accidents in which the Plaintiffwas involved in prior to the subject incident. Any and all hospital records, nurses' notes, doctors' notes, progress notes, radiology reports, MRI films, x-rays, and MRI reports and medical bills for any accidents in which the Plaintiffs was involved in subsequent to the subject incident. Any and all records supporting a claim for lost wages as a result of the subject incident. Any and all current insurance policies, whether health, disability, life or other. A copy of the PIP payout sheet, and any and all proof of payments made on behalf of the Plaintiff, drafts and any evidence pertaining to paid or payables by the Plaintiffpursuant to their PIP policy of insurance. ----- Copies of any "Mary Carter" agreements, loan receipt agreements, settlement agreements, releases, or covenants not to sue, entered into by you, or on your behalf, with any other Defendant, person, firm or corporation, whom you contend may have some liability exposure to the incident of which you complain. Copies of any documents which relate in any way to prior accidents or claims, including prior demand letters, prior claim letters, prior lawsuits, depositions given or taken, prior injuries, prior settlements, prior medical records or opinions as to permanent impairments, prior PIP applications. Please sign and return the enclosed HIPAA Compliant Authorization for Release ### of Medical Information form. Please sign and return the enclosed Form SSA-7050-F4, Request for Social Security Earnings Information. Please sign and return the enclosed Form 4506, Request for Copy of Tax Return form. It is hereby requested that the aforesaid production be made at the offices of Shendell & Pollock, P. L. Inspection will be made by visual observation, examination and/or copying. (Plaintiffmay furnish copies of all documentation by mail to the Defendants’ counsel’s office). **SEE** **ATTACHED** **CERTIFICATE** **OF** **SERVICE** ----- **CERTIFICATE** **OF** **SERVICE** I HEREBY CERTIFY that the foregoing has been filed with the Clerk of Court via the Florida Courts E-Filing Portal which will serve a notice of electronic filing on this 27th day of April, 2017 on the following: Todd Fronrath, Esq. Attorney for Plaintiff Lytal, Reiter, Smith, Ivey & Fronrath 515 N. Flagler Drive, 10th Floor West Palm Beach, FL 33401 Email: [tffonrath@foryourrights. com](mailto:tffonrath@foryourrights. com) Email: [kianis@foryourrights. com](mailto:kianis@foryourrights. com) Respectfully submitted, LUKS, SANTANIELLO, PETRILLO & JONES 301 NE 51st Street, Suite 4150 Boca Raton, FL 33431 Phone: (561) 893-9088 Fax: (561) 893-9048 Attorney for Defendant By: Zs/ William Peterffiend, Esq. WILLIAM PETERFRIEND, ESQ. Florida Bar No. 544647 [WPeterfriend@insurancedefense. net](mailto:WPeterfriend@insurancedefense. net) [Luksboca-pleadings@ls-law. com](mailto:Luksboca-pleadings@ls-law. com) -----


[System]
You are a lawyer with 10 years of experience. Based on the complaint, create up to 20 questions for the defendant.

The questions should follow the format and style of this example response to a car accident complaint:
1. All photographs, diagrams, or other printed or written material describing or attempting to describe the scene of the accident alleged in the Complaint, or any person described in the Complaint.
2. Documentation substantiating health insurance coverage available to Plaintiff on the date of the accident sued upon.
3. Any cellular phones or other mobile communication system telephone bills, invoices, statements, itemized accounts, or other data compilation for the equipment owned or used by Plaintiffs for the months relevant to the incident.
4. Any and all films, diagnostic tests, MRIs, X-rays, storage devices, digital images, intra-operative photographs, and/or data compilations from which information can be obtained.
5. If a claim is made for lost wages and/or loss of earning capacity in the future, provide specific documentation like Federal Income Tax Returns and W-2 Forms.

Be specific, detailed and relevant to the complaint's allegations. Avoid generic requests for "all documents" or "all evidence". Each question should request specific items, time periods, or information directly related to the complaint's claims.

[User] #### IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEANINE TIERNEY, Plaintiff, v. NEIL MINTZ, Defendant. ### COMPLAI NT #### COMES NOW the Plaintiff, JEANINE TIERNEY, by and through her undersigned counsel and hereby sues the Defendant, NEIL MINTZ, and alleges: **ALLEGATIONS** **COMMON** **TO** **ALL** **COUNTS** This is an action for damages which exceeds the sum of Fifteen #### Thousand Dollars ($15, 000. 00). On or about May 11, 2015, Defendant, NEIL MINTZ, owned and #### operated a motor vehicle at the intersection of NW 13th Street and NW 15th Court in Palm Beach County, Florida. At the time and place aforementioned. Defendant, NEIL MINTZ, so #### negligently operated and maintained his motor vehicle so as to cause it to collide and crash with a motor vehicle owned and operated by Plaintiff, JEANINE TIERNEY. ----- **_Page_** **_2_** #### COUNTI As a direct and proximate result. Plaintiff, JEANINE TIERNEY, was #### injured in and about her body, suffered aggravation of pre-existing condition, pain and suffering, disability, disfigurement, impairment of working ability, mental anguish, loss of enjoyment of life and Plaintiff incurred medical expenses in the care and treatment of said injuries; all of said injuries are permanent within a reasonable degree of medical probability. WHEREFORE, Plaintiff, JEANINE TIERNEY, demands judgment for damages against the Defendant and further demands trial by jury. d this 10th day of February, 2017 ### /s/Todd Fronrath, Esquire #### Todd Fronrath, Esquire Florida Bar No. : 547271 Attorneys for Plaintiff Lytal, Reiter, Smith, Ivey & Fronrath 515 N. Flagler Drive, 10th Floor #### West Palm Beach, FL 33401 Telephone: (561) 655-1990 Facsimile: (561) 832-2932 Email: tfronrath@foryourrights. com Email: kjanis@foryourrights. com -----

[Assistant] #### IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEANINE TIERNEY, Plaintiff, v. NEIL MINTZ, Defendant. **PLAINTIFF'S** **REQUEST** **FOR** **PRODUCTION** **TO** **DEFENDANT** #### Plaintiff, JEANINE TIERNEY, by and through her undersigned counsel, and in accordance with Rule 1. 350, Fla. R. Civ. P. , hereby requests Defendant, NEIL MINTZ, to produce the following documents, or copies thereof, within the time limits provided by said Rule, at the office of the undersigned: Color laser copies or duplicates from the negatives of all photographs taken by #### the defendant, attorneys, investigators, agents, servants or employees of the accident vehicles referred to in the complaint which are in any manner related to the subject matter of this lawsuit. All estimates and repair bills for the damage sustained in the subject accident to #### the vehicle operated by the Defendant. Copy of any and all liability insurance policies which were in effect on the#### of the subject accident. Copy of the Florida title for the vehicle operated by the defendant at the time of #### the subject accident. Bill of sale for the purchase of the vehicle operated by the defendant at the time #### of the subject accident. ----- **_Page_** **_2_** Copy of the Florida registration for the vehicle operated by the defendant at the #### time of the subject accident. Copy and any all statements of the Plaintiff, JEANINE TIERNEY. Copy of Defendant's driver's license. Surveillance photographs and movies, surveillance reports, surveillance #### contracts, and invoices, charges, notes, and other documents from parties for any surveillance you reasonably expect to be used at trial in the subject case. It is hereby requested that the aforesaid production be made forty-five (45) days from theof service of process at the offices of the undersigned. d this 10th day of February, 2017. ### /s/Todd Fronrath, Esquire #### Todd Fronrath, Esquire Florida Bar No. : 547271 Attorneys for Plaintiff Lytal, Reiter, Smith, Ivey & Fronrath 515 N. Flagler Drive, 10th Floor #### West Palm Beach, FL 33401 Telephone: (561) 655-1990 Facsimile: (561) 832-2932 Email: tfronrath@foryourrights. com Email: kjanis@foryourrights. com -----


[System]
You are a lawyer with 10 years of experience. Based on the complaint, create up to 20 questions for the defendant.

The questions should follow the format and style of this example response to a car accident complaint:
1. All photographs, diagrams, or other printed or written material describing or attempting to describe the scene of the accident alleged in the Complaint, or any person described in the Complaint.
2. Documentation substantiating health insurance coverage available to Plaintiff on the date of the accident sued upon.
3. Any cellular phones or other mobile communication system telephone bills, invoices, statements, itemized accounts, or other data compilation for the equipment owned or used by Plaintiffs for the months relevant to the incident.
4. Any and all films, diagnostic tests, MRIs, X-rays, storage devices, digital images, intra-operative photographs, and/or data compilations from which information can be obtained.
5. If a claim is made for lost wages and/or loss of earning capacity in the future, provide specific documentation like Federal Income Tax Returns and W-2 Forms.

Be specific, detailed and relevant to the complaint's allegations. Avoid generic requests for "all documents" or "all evidence". Each question should request specific items, time periods, or information directly related to the complaint's claims.

[User] #### IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEANINE TIERNEY, Plaintiff, v. NEIL MINTZ, Defendant. ### COMPLAI NT #### COMES NOW the Plaintiff, JEANINE TIERNEY, by and through her undersigned counsel and hereby sues the Defendant, NEIL MINTZ, and alleges: **ALLEGATIONS** **COMMON** **TO** **ALL** **COUNTS** This is an action for damages which exceeds the sum of Fifteen #### Thousand Dollars ($15, 000. 00). On or about May 11, 2015, Defendant, NEIL MINTZ, owned and #### operated a motor vehicle at the intersection of NW 13th Street and NW 15th Court in Palm Beach County, Florida. At the time and place aforementioned. Defendant, NEIL MINTZ, so #### negligently operated and maintained his motor vehicle so as to cause it to collide and crash with a motor vehicle owned and operated by Plaintiff, JEANINE TIERNEY. ----- **_Page_** **_2_** #### COUNTI As a direct and proximate result. Plaintiff, JEANINE TIERNEY, was #### injured in and about her body, suffered aggravation of pre-existing condition, pain and suffering, disability, disfigurement, impairment of working ability, mental anguish, loss of enjoyment of life and Plaintiff incurred medical expenses in the care and treatment of said injuries; all of said injuries are permanent within a reasonable degree of medical probability. WHEREFORE, Plaintiff, JEANINE TIERNEY, demands judgment for damages against the Defendant and further demands trial by jury. d this 10th day of February, 2017 ### /s/Todd Fronrath, Esquire #### Todd Fronrath, Esquire Florida Bar No. : 547271 Attorneys for Plaintiff Lytal, Reiter, Smith, Ivey & Fronrath 515 N. Flagler Drive, 10th Floor #### West Palm Beach, FL 33401 Telephone: (561) 655-1990 Facsimile: (561) 832-2932 Email: tfronrath@foryourrights. com Email: kjanis@foryourrights. com -----

[Assistant] ### IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEANINE TIERNEY, Plaintiff(s), MILLER'S ALE HOUSE, INC. , a Foreign ### Profit Corporation, d/b/a EAST BOCA ALE HOUSE and NEIL MINTZ, ### Defendant(s). **PLAINTIFF'S** **REQUEST** **FOR** **PRODUCTION** **TO** **MILLER'S** **ALE** **HOUSE, ** **INC. ,** **d/b/a** **EAST** **BOCA** **ALE** **HOUSE** Plaintiff, JEANINE TIERNEY, by and through her undersigned counsel, and in ### accordance with Rule 1. 350, Fla. R. Civ. P. , hereby requests Defendant, MILLER'S ALE HOUSE, INC. , d/b/a EAST BOCA ALE HOUSE, to produce the following documents, ### or copies thereof, within the time limits provided by said Rule, at the office of the undersigned: A copy of the videotape of the area where JEANINE TIERNEY fell for the one- ### half hour period before and after her respective fall on July 1, 2014, including the videotape of her fall. A copy of your policies and procedures manual concerning the maintenance of ### the respective floors of the MILLER'S ALE HOUSE, which would include all safety procedures in existence as of July 1, 2014. A copy of the incident report pertaining to JEANINE TIERNEY'S fall on July 1, ----- **_Page_** **_2_** A copy of all policies and procedures that were in effect as of July _1, _ 2014, ### concerning cautions to be taken for water and/or any foreign substances that may be on the floor of the MILLER'S ALE HOUSE being used by the respective customers. It is hereby requested that the aforesaid production be made forty-five (45) days from theof service of process at the offices of the undersigned. d this 28th day of February, 2017 ## /s/Todd Fronrath, Esquire ### Todd Fronrath, Esquire Florida Bar No. : 547271 Attorneys for Plaintiff Lytal, Reiter, Smith, Ivey & Fronrath 515 N. Flagler Drive, 10th Floor ### West Palm Beach, FL 33401 Telephone: (561) 655-1990 Facsimile: (561) 832-2932 Email: [tfronrath@foryourrights. com](mailto:tfronrath@foryourrights. com) Email: [kjanis@foryourrights. com](mailto:kjanis@foryourrights. com) -----