[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 KIMBERLY ST. LOUIS, case **2009CPrQO95** **5** **9XXXX** Plaintiff, vs. FLORIDA BAR NO. : 00477$§: IAN ROVNER, Defendant. ``` ----- at 5 GH ``` **VERIFIED** **COMPLAINT** **FOR** **PARTITION** **AND** **FOR** **DAMAGES^** Plaintiff, KIMBERLY ST. LOUIS (“Plaintiff”) by and through undersigned counsel, files this verified complaint for partition and damages against Defendant, IAN ROVNER (“Defendant”), and alleges as follows: **COUNT** **I** **-** **PARTITION** This is an action for partition of real and personal property instituted under Florida Statute Chapter 64. The real property that is the subject of this action is situated in Palm Beach County, Florida, with an address of 9157 Dupont Place, Wellington, Florida 33414 and is more particularly described as follows: Lot 1818, of Olympia - Plat II, Block “F” Replat, according to the Platr thereof, as recorded in Plat Book 101, page 36, of the Public Records of Palm Beach County, Florida. The property is owned by Plaintiff and Defendant as joint tenants with full rights of survivorship with each party owning an undivided fifty per cent (50%) iMgrest in the property. Plaintiff resides at 1335 Olive Tree Circle, Greenacres, Palm Beach County, Florida. Defendant resides at the property. ----- Venue is proper in Palm Beach County, Florida as the causes of action alleged herein accrued in said county and the subject real property is located in Palm Beach County, Florida. Personal property including but not limited to furniture and furnishings acquired by the parties for the real property is also jointly owned with each party owning an undivided fifty per cent (50%) interest in the personal property. Plaintiff has no knowledge of any parties who claim an interest in the property or who will be materially affected by this action other than Plaintiff and Defendant except the recorded mortgage on the property in the amount of $100, 000. 00. Each of the parties is over 18 years of age. The property is not reasonably susceptible of an equitable physical division because of the configuration of certain improvements on it. A private sale of the real and personal property under F. S. 64. 061(4) would not be prejudicial to the interests of the defendant. The prosecution of this partition action is for the common benefit of Plaintiff and Defendant. Defendant has exclusive possession of said property without providing Plaintiff compensation for his use of her share of the property. Due to Defendant’s exclusive possession of the property, Plaintiff is entitled to compensation during the pendency of these proceedings. Plaintiff has retained the law firm of Vincent, Kahn & Shearin, LLC to represent :Plaintiff in this action, and has agreed to pay the firm a reasonable fee for its services. WHEREFORE, Plaintiff respectfully requests the court to order the private sale of the real and personal property jointly owned and distribute the proceeds ofthe sale among the Plaintiff and Defendant as their interests may appear; award Plaintiff compensation for the period ----- that Defendant had exclusive possession of the property; award to Plaintiff reasonable attorney’s fees and costs incurred in this action, and order the payment of those fees and costs from the proceeds of the sale, with each party bearing a proportionate share of the attorney’s fees; and enter any other relief this court deems just and proper. **COUNT** **II** **-UNJUST** **ENRICHMENT** This is an action for damages that exceeds $15, 000. 00. Plaintiff is an individual sui juris residing in Palm Beach County, Florida. Defendant is an individual sui juris residing in Palm Beach County, Florida. Venue is proper in Palm Beach County, Florida as the property at question is located in Palm Beach County, Florida. Plaintiff and Defendant purchased a residential home as joint tenants with rights of survivorship, described in paragraph 2 above and personal property such as furniture and furnishings for said home. Closing on the property was held on September 4, 2007. Plaintiff and Defendant resided in the property until March 5, 2009 when Defendant had Plaintiff forcibly removed from the property and since that time Defendant has maintained exclusive possession of said property. Plaintiff contributed funds and other considerations for said property of which Defendant was aware. Defendant has refused to compensate Plaintiff for the benefits she conferred to Defendant and it would be inequitable for him to retain said property without paying the value thereof. ----- WHEREFORE Plaintiff demands judgment for damages against Defendant and for any other reliefthis court deems just and proper. D this/'$ _day_ of March, 2009. VINCENT, KAHN & SHEARIN, LLC 800 East Broward Boulevard Suite 403 Fort Lauderdale, FL 33301 (954) 524-9494 (954) 653-5027 (fax) Robert L. Shearin, Esquire Attorney for Plaintiff Florida Bar #0047759 STATE OF FLORIDA COUNTY OF PALM BEACH Before me, the undersigned authority, personally appeared KIMBERLY ST. LOUIS, who was swom and says that she has read the Verified Complaint for Partition, and as to the facts stated to be true, they are true, and as to the facts stated upon information and belief, she is informed and believes that they are true. Swom to and subscribed before me on March 211^72009 by KIMBERLY ST. LOUIS. **NOTARY** **PUBLIC-STATE** **OF** **FLORIDA** Notary Public - State of Florida **Robert** **L. ** **Shearin** **Commission** **#** **DD400985** **Expires:** **APR. ** **01, ** **2009** ’ed Thru Atlantic Bonding Co. , Inc. ----- ----- IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA KIMBERLY ST. LOUIS Plaintiff, CASE NO8D **2«l9fPr0095** **59XXXX** **"B** vs. FLORIDA BAR NO. : 0047759 IANROVNER, Defendant. __________________________________ I_ The civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law. This form is required by the Clerk of Court for the purpose of reporting judicial workload data pursuant to Florida Statute §25. 075. TYPE OF CASE (Place an 'x' in one box only) o-- __ Domestic Relations __Torts Other Civil ' ###### c? __ Simplified Dissolution __ Professional Malpractice Contracts - __ Dissolution of Marriage __ Products liability Condominium r“^ - CO - __ Support - FV-D Auto negligence Real property/Mortgage __ Support - Non IV-D Other negligence __ Eminent domain _URESA - IV-D x Other _URESA - NonIV-D __ Domestic Violence Other domestic relations Is Jury Trial Demanded in Complaint? Yes x No: ATTORNEY INITIATING ACTION Robert L. Shearin, Esquire Florida Bar No. : 0047759 -----

[Assistant] IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA **CASE** **NO. ** **50-2009-CA-009559-XXXX-MB** JUDGE THOMAS H. BARKDULL, III KIMBERLY ST. LOUIS, ## * Plaintiff, ### * vs. ### * IAN ROVNER, ### * Defendant. ### * ## REQUEST FOR PRODUCTION OF DOCUMENTS The Defendant requests, in accordance with **Rule** **1. 350, ** **_Florida_** **_Rules_** **_of_** **_Civil_** **_Procedure, _** that the Plaintiff produce the following documents for inspection and copying, at the offices of Christopher N. Link, P. A. , Pine Island Office Centre, 111 North Pine Island Road, Suite 209, Plantation, Florida 33324-1836, within 30 days of theof service: All documents and other items in your possession or #### control which in any way relate to the property located at 9157 Dupont Place, Wellington, Florida 33414, including, but not limited #### to all correspondence, notes, email messages, closing statements, deeds, notes and mortgages. All documents and other items evidencing all sums paid by you towards the acquisition, maintenance and upkeep of the #### property located at 9157 Dupont Place, Wellington, Florida 33414. All documents and other items evidencing all sums paid by you towards any renovations and/or improvements to the #### property located at 9157 Dupont Place, Wellington, Florida 33414. 1 ----- **CASE** **NO. ** **50-2009-CA-009559-XXXX-MB** _Kimberly_ _St. _ _Louis_ _vs. _ _Ian_ _Rovner_ All documents and other items evidencing the existence of all personal property, fumiture and/or furnishings in which the Plaintiff is claiming a 50% interest. **WE** **CERTIFY** that a true copy of the foregoing was served by mail upon counsel for the Plaintiff, Robert L. Shearin, Esquire, Vincent, Kahn & Shearin, LLC, 800 East Broward Boulevard, Suite 403, Fort Lauderdale, Florida 33301, this 24th day of March, 2009. CHRISTOPHER N. LINK, P. A. Attorneys for Defendant Pine Island Office Centre 111 North Pine Island Road, Suite 209 Plantation, Florida 33324-1836 Phone: (954) 915-0400 - Fax: (954) 424-0895 Email: LinkFamilyLaw@earthlink. net By: CHRISTOPHER \NJ N K Florida Bar No. 887821N 2 -----


[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 CASE NO:502022CA005093XXXXMB(AE) NATIONAL BIO-SAFE, INC. , Plaintiff, vs. BLAINE MINTON, and SAMANTHA MINTON, Defendants. __________________________/ **AMENDED COMPLAINT** The plaintiff, NATIONAL BIO-SAFE, INC. , sues the defendants, BLAINE MINTON and SAMANTHA MINTON, and alleges: This is an action for damages in excess of Thirty Thousand Dollars ($30, 000. 00), exclusive of interest and costs. The plaintiff, NATIONAL BIO-SAFE, INC. , is a corporation licensed and authorized to do business in the State of Florida, including Palm Beach County, and is otherwise sui juris. The defendant, BLAINE MINTON, is a a resident of Palm Beach County, Florida, and is otherwise sui juris. The defendant, BLAINE MINTON, was the owner and in possession of real property located at 1420 North Swinton Avenue, Delray Beach, Palm Beach County, Florida, at all times material hereto. The defendant, SAMANTHA MINTON, is a resident of Palm Beach County, Florida, and is otherwise sui juris. The defendant, SAMANTHA MINTON, was the owner and in possession of real property located at 1420 North Swinton Avenue, Delray Beach, Palm Beach County, Florida, at all times material hereto. ----- The plaintiff, NATIONAL BIO-SAFE, INC. , performed services, demolition, moisture and water testing, mold remediation, and provided materials and supplies to the real property located at 1420 North Swinton Avenue, Delray Beach, Palm Beach County, Florida, at all times material hereto. Venue is proper in this jurisdiction as one or more of the acts complained of occurred in Palm Beach County, the defendants, BLAINE MINTON and SAMANTHA MINTON, reside in Palm Beach County and the real property which is the subject matter of this lawsuit is located in Palm Beach County, Florida. **COUNT I** **BREACH OF CONTRACT AS TO BLAINE MINTON** Plaintiff realleges and reaffirms paragraphs 1 through 8 and further alleges: At all times material hereto, defendant, BLAINE MINTON, was the owner, in possession of or had the right of control of the real property located at 1420 North Swinton Avenue, Delray Beach, Palm Beach County, Florida. The above described real property had three separate structures thereon consisting of the main house, pool house and garage house. On August 27, 2020, defendant, BLAINE MINTON, contacted plaintiff, NATIONAL BIO-SAFE, INC. , to meet at the real property located at 1420 North Swinton Avenue, Delray Beach, Palm Beach County, Florida to assess water, moisture and mold damage in the three structures located on the property. Plaintiff, NATIONAL BIO-SAFE, INC. , commenced with moisture evaluation of the mold damage in the three structures. The moisture evaluation in the three structures commenced in the walls, ceilings and floors. On August 28, 2020, plaintiff, NATIONAL BIO-SAFE, INC. , and defendant, BLAINE MINTON, entered into an oral contract. On August 28, 2020, defendant, BLAINE MINTON, requested to plaintiff, NATIONAL BIO-SAFE, INC. , to perform moisture and water testing in the three structures, to assess and ----- conduct moisture evaluation, and to perform mold remediation at the above described real property. On August 28, 2020, plaintiff, NATIONAL BIO-SAFE, INC. , offered to defendant, BLAINE MINTON’s, to perform moisture and water testing in the three structures, to assess and conduct moisture evaluation, and to perform mold remediation for a fee at the above described real property. On August 28, 2020, defendant, BLAINE MINTON, accepted, hired and orally contracted with plaintiff, NATIONAL BIO-SAFE, INC. , to perform moisture and water testing in the three structures, to assess and conduct moisture evaluation, and to perform mold remediation at the above described real property. Defendant, BLAINE MINTON, agreed to pay plaintiff, NATIONAL BIO-SAFE, INC. , a reasonable fee for their services, work and materials. Plaintiff, NATIONAL BIO-SAFE, INC. , performed their work, services, testing, drying out, and mold remediation through November 30, 2020. Plaintiff has performed all conditions precedent to be performed by plaintiff or the conditions have occurred. Plaintiff has demanded payment of the above described services, demolition, mold remediation, moisture and water testing and materials and supplies from defendant, BLAINE MINTON. Defendant, BLAINE MINTON, has not paid plaintiff, NATIONAL BIO-SAFE, INC. , for their work, services, water testing, and remediation performed and materials, supplies, equipment and tools used on the above described real property. Defendant, BLAINE MINTON, owes plaintiff the following: Main house mold remediation $34, 000. 86 Main house EMS dry out $30, 707. 61 Pool house mold remediation $15, 038. 45 Garage house mold remediation $11, 381. 60 ----- TOTAL: $91, 128. 52 Attached as exhibit 1 are copies of the four invoices for work and services performed and materials used by plaintiff, NATIONAL BIO-SAFE, INC. , on the three structures owned by plaintiff. Attached as exhibit 2 are 249 color copies of photographs taken at defendant’s three structures depicting and showing the work and services performed and materials used by plaintiff, NATIONAL BIO-SAFE, INC. , pursuant to the oral contract, at defendant’s property from 8/27/2020 to 11/29/2020. Attached as exhibit 3 in a timeline chronology of the work and services performed by plaintiff, NATIONAL BIO-SAFE, INC. , at defendant’s three structures on defendant’s property from 8/27/2020 to 11/29/2020. WHEREFORE, plaintiff, NATIONAL BIO-SAFE, INC. , demands a judgment for damages against defendant, BLAINE MINTON, together with interest and court costs. **COUNT II** **OPEN ACCOUNT FORM 1. 932, FLORIDA RULES OF CIVIL PROCEDURE** **AS TO BLAINE MINTON** Plaintiff realleges and reaffirms paragraphs 1 through 8 and further alleges: Defendant, BLAINE MINTON, owes plaintiff, NATIONAL BIO-SAFE, INC. , the sum of $91, 128. 52, for their services, demolition, moisture and water testing performed, mold remediation, and materials and supplies used on defendant’s real property located at 1420 North Swinton Avenue, Delray Beach, Palm Beach County, Florida that is due with interest since November 30, Attached as exhibit 1 is a copy of the account/invoicing showing items, time of accrual of each, and amount of each item, for the above described real property. WHEREFORE, plaintiff, NATIONAL BIO-SAFE, INC. , demands a judgment for damages against defendant, BLAINE MINTON, together with interest and court costs. ----- **COUNT III** **FRAUDULENT INDUCEMENT AS TO BLAINE E. MINTON** Plaintiff realleges and reaffirms paragraphs 1 through 8 and further alleges: Defendant, BLAINE MINTON, hired and orally contracted with plaintiff, NATIONAL BIO-SAFE, INC. , to perform services, demolition, moisture and water testing, and mold remediation at the real property located at 1420 North Swinton Avenue, Delray Beach, Palm Beach County, Florida. Defendant, BLAINE MINTON, represented to plaintiff, NATIONAL BIO-SAFE, INC. , that defendant would pay plaintiff for their demolition, moisture and water testing, mold remediation, services performed and materials and supplies utilized at the above described real property. From August 27, 2020, thru November 30, 2020, and for the numerous months thereafter, defendant, BLAINE MINTON, continued to represent to plaintiff, NATIONAL BIO-SAFE, INC. , that defendant would pay plaintiff for their demolition, moisture and water testing performed, mold remediation, services performed and materials and supplies used on the above described real property, and not encumber the property. The representations by defendant, BLAINE MINTON, were knowingly and intentionally false. Defendant, BLAINE MINTON, always intended to use plaintiff’s expertise and efforts in mold remediation to have the three structures on the above described real property remediated without paying plaintiff for their demolition, moisture and water testing performed, mold remediation, services performed and materials and supplies used. The representations by defendant, BLAINE MINTON, were intentionally and falsely made to plaintiff, NATIONAL BIO-SAFE, INC. , so that plaintiff would not file a mechanic’s lien on the real property owned by defendant, BLAINE MINTON. Defendant, BLAINE MINTON, intended for plaintiff, NATIONAL BIO-SAFE, INC. , to rely upon defendant’s representations, and plaintiff did rely on defendant’s representations by expending their time, effort, services, materials, supplies and expertise to water test, demolition and ----- remediate the three structures on the above described real property, and not file a mechanic’s lien on the real property. Plaintiff, NATIONAL BIO-SAFE, INC. , relied upon the representations made by defendant, BLAINE MINTON. Plaintiff, NATIONAL BIO-SAFE, INC. , was damaged by their reliance upon defendant’s misrepresentations that defendant would pay plaintiff for their work, services, water testing, demolition and remediation, and supplies and materials utilized at the above described real property. WHEREFORE, plaintiff, NATIONAL BIO-SAFE, INC. , demands a judgment for damages against defendant, BLAINE MINTON, together with interest and court costs. **COUNT IV** **BREACH OF CONTRACT AS TO SAMANTHA MINTON** Plaintiff realleges and reaffirms paragraphs 1 through 8 and further alleges: At all times material hereto, defendant, SAMANTHA MINTON, was the owner, in possession of or had the right of control of the real property located at 1420 North Swinton Avenue, Delray Beach, Palm Beach County, Florida. The above described real property had three separate structures thereon consisting of the main house, pool house and garage house. On August 27, 2020, defendant, SAMANTHA MINTON, contacted plaintiff, NATIONAL BIO-SAFE, INC. , to meet at the real property located at 1420 North Swinton Avenue, Delray Beach, Palm Beach County, Florida to assess water, moisture and mold damage in the three structures located on the property. Plaintiff, NATIONAL BIO-SAFE, INC. , commenced with moisture evaluation of the mold damage in the three structures. The moisture evaluation in the three structures commenced in the walls, ceilings and floors. On August 28, 2020, plaintiff, NATIONAL BIO-SAFE, INC. , and defendant, SAMANTHA ----- MINTON, entered into an oral contract. On August 28, 2020, defendant, SAMANTHA MINTON, requested to plaintiff, NATIONAL BIO-SAFE, INC. , to perform moisture and water testing in the three structures, to assess and conduct moisture evaluations, and perform mold remediation at the above described real property. On August 28, 2020, plaintiff, NATIONAL BIO-SAFE, INC. , offered to defendant, SAMANTHA MINTON, to perform moisture and water testing in the three structures, to access and conduct moisture evaluation, and to perform mold remediation for a fee at the above described real property. On August 28, 2020, defendant, SAMANTHA MINTON, accepted, hired and orally contracted with plaintiff, NATIONAL BIO-SAFE, INC. , to perform moisture and water testing in the three structures, to assess and conduct moisture evaluation, and to perform mold remediation at the above described real property. Defendant, SAMANTHA MINTON, agreed to pay plaintiff, NATIONAL BIO-SAFE, INC. , a reasonable fee for their services, work and materials. Plaintiff, NATIONAL BIO-SAFE, INC. , performed their work, services, testing, drying out, and mold remediation through November 30, 2020. Plaintiff has performed all conditions precedent to be performed by plaintiff or the conditions have occurred. Plaintiff has demanded payment of the above described services, demolition, mold remediation, moisture and water testing and materials and supplies from defendant, SAMANTHA MINTON. Defendant, SAMANTHA MINTON, has not paid plaintiff, NATIONAL BIO-SAFE, INC. , for their work, services, water testing, and remediation performed and materials, supplies, equipment and tools used on the above described real property. Defendant, SAMANTHA MINTON, ----- owes plaintiff the following: Main house mold remediation $34, 000. 86 Main house EMS dry out $30, 707. 61 Pool house mold remediation $15, 038. 45 Garage house mold remediation $11, 381. 60 TOTAL: $91, 128. 52 Attached exhibit 1 are copies of the four invoices for work and services performed and materials used by plaintiff, NATIONAL BIO-SAFE, INC. , on the three structures owned by plaintiff. Attached exhibit 2 are 249 color copies of photographs taken at defendant’s three structures depicting and showing the work and services performed and materials used by plaintiff, NATIONAL BIO-SAFE, INC. , pursuant to the oral contract, at plaintiff’s property from 8/27/2020 to 11/29/2020. Attached as exhibit 3 is a timeline chronology of the work and services performed by plaintiff, NATIONAL BIO-SAFE, INC. , at defendant’s three structures on defendant’s property from 8/27/2020 to 11/29/2020. WHEREFORE, plaintiff, NATIONAL BIO-SAFE, INC. , demands a judgment for damages against defendant, SAMANTHA MINTON, together with interest and court costs. **COUNT V** **OPEN ACCOUNT FORM 1. 932, FLORIDA RULES OF CIVIL PROCEDURE** **AS TO SAMANTHA MINTON** Plaintiff realleges and reaffirms paragraphs 1 through 8 and further alleges: Defendant, SAMANTHA MINTON, owes plaintiff, NATIONAL BIO-SAFE, INC. , the sum of $91, 128. 52, for their services, demolition, moisture and water testing performed, mold remediation, and materials and supplies used on defendant’s real property located at 1420 North Swinton Avenue, Delray Beach, Palm Beach County, Florida that is due with interest since November 30, 2020. Attached as exhibit 1 is a copy of the account/invoicing showing items, time ----- of accrual of each, and amount of each item, for the above described real property. WHEREFORE, plaintiff, NATIONAL BIO-SAFE, INC. , demands a judgment for damages against defendant, SAMANTHA MINTON, together with interest and court costs. **COUNT VI** **FRAUDULENT INDUCEMENT AS TO SAMANTHA MINTON** Plaintiff realleges and reaffirms paragraphs 1 through 8 and further alleges: Defendant, SAMANTHA MINTON, hired and orally contracted with plaintiff, NATIONAL BIO-SAFE, INC. , to perform services, demolition, moisture and water testing, and mold remediation at the real property located at 1420 North Swinton Avenue, Delray Beach, Palm Beach County, Florida. Defendant, SAMANTHA MINTON, represented to plaintiff, NATIONAL BIO-SAFE, INC. , that defendant would pay plaintiff for their demolition, moisture and water testing, mold remediation, services performed and materials and supplies utilized at the above described real property. From August 27, 2020, thru November 30, 2020, and for the numerous months thereafter, defendant, SAMANTHA MINTON, continued to represent to plaintiff, NATIONAL BIO-SAFE, INC. , that defendant would pay plaintiff for their demolition, moisture and water testing, mold remediation, services performed and materials and supplies used on the above described real property, and not encumber the property. The representations by defendant, SAMANTHA MINTON, were knowingly and intentionally false. Defendant, SAMANTHA MINTON, always intended to use plaintiff’s expertise and efforts in mold remediation to have the three structures on the above described real property remediated without paying plaintiff for their demolition, moisture and water testing performed, mold remediation, services performed and materials and supplies used. The representations by defendant, SAMANTHA MINTON, were intentionally and falsely made to plaintiff, NATIONAL BIO-SAFE, INC. , so that plaintiff would not file a mechanic’s lien on the real property owned by defendant, SAMANTHA MINTON. ----- Defendant, SAMANTHA MINTON, intended for plaintiff, NATIONAL BIO-SAFE, INC. , to rely upon defendant’s representations, and plaintiff did rely on defendant’s representations by expending their time, effort, services, materials, supplies and expertise to water test, demolition and remediate the three structures on the above described real property, and not file a mechanic’s lien on the real property. Plaintiff, NATIONAL BIO-SAFE, INC. , relied upon the representations made by defendant, SAMANTHA MINTON. Plaintiff, NATIONAL BIO-SAFE, INC. , was damaged by their reliance upon defendant’s misrepresentations that defendant would pay plaintiff for their work, services, water testing, demolition and remediation, and supplies and materials. WHEREFORE, plaintiff, NATIONAL BIO-SAFE, INC. , demands a judgment for damages against defendant, SAMANTHA MINTON, together with interest and court costs. **JURY DEMAND** Plaintiff demands a trial by jury of all issues triable as of right. I HEREBY CERTIFY that a true and correct copy of the foregoing was electronically transmitted on the 10th day of January, 2023, to: ADAM P. HANDFINGER, ESQUIRE and BRETT **J. MORITZ, ESQUIRE, at ahandfinger@pecklaw. com**, bmoritz@pecklaw. com, mgil@pecklaw. com, PECKAR & ABRAMSON, P. C. , Attorneys for Defendants, BLAINE E. MINTON, and SAMANTHA C. MINTON, One Southeast Third Avenue, Suite 2000, Miami, Florida 33131. LAW OFFICES OF FRED LAND FULMER, P. A. Attorneys for Plaintiff, NATIONAL BIO-SAFE, INC. Galleria Corporate Centre, Suite 1216 2455 East Sunrise Boulevard Fort Lauderdale, Florida 33304 (954)763-1052 Broward flfulmerlaw@aol. com By /s/ Fred L. Fulmer FRED L. FULMER FLA BAR NO: 347681 ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- -----

[Assistant] IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO:502022CA005093XXXXMB(AE) NATIONAL BIO-SAFE, INC. , Plaintiff, vs. BLAINE MINTON, and SAMANTHA MINTON, Defendants. __________________________/ **PLAINTIFF’S FIRST REQUEST TO PRODUCE TO** **DEFENDANT, SAMANTHA MINTON** In accordance with Rule 1. 350 of the Florida Rules of Civil Procedure, the plaintiff, NATIONAL BIO-SAFE, INC. , requests the defendant, SAMANTHA MINTON, produce at the office of the undersigned attorney within thirty (30) days hereof, the following: **“Subject residence” is defined as the premises located at 1420 North Swinton** **Avenue, Delray Beach, Palm Beach County, Florida. ** Any and all photographs of the work and services performed by plaintiff at the “subject residence”. Any and all photographs of the damages to the “subject residence” you claim as a result of the work performed by the contractors as alleged in the case entitled Blaine E. Minton vs. Boca Development & Construction Corp. , et al, case no. : 502021CA004816. A copy of any insurance policy issued to you in effect at the time of the subject incident which might inure to the benefit of the plaintiff as a result of the incident alleged in the complaint. A copy of any declaration page to the insurance policy in effect at the time of the subject incident which might inure to the benefit of the plaintiff as a result of the incident alleged in the complaint. All policies of insurance, insuring the defendant which might inure to the benefit of the plaintiff as a result of the incident alleged in the complaint. ----- Any and all drawings, graphs, charts, video, photographs, not privileged or work product, pertaining to the subject claims alleged in the complaint. Any and all statements of plaintiff obtained by defendant or any agents or attorneys, recorded or written prior to, at the time of or subsequent to and related to the claims alleged in the complaint. Any and all statements of any witnesses obtained by the defendant or any agents or attorneys, recorded or written, at the time of or subsequent to and related to the claims alleged in the complaint. Any and all text messages, emails, letters or correspondence by and between plaintiff and defendant (plaintiff sent or delivered to defendant, and defendant sent or delivered to plaintiff) from your initial contact with plaintiff to presentregarding the work and services performed by plaintiff at the “subject residence”. Copies of any and all photographs, materials, documents, letters, invoices, bills or statements SAMANTHA MINTON alleges or asserts supports her claim for damages sustained as a result of the contractors who performed services at the “subject residence” in relation to the case entitled Blaine E. Minton vs. Boca Development & Construction Corp. , et al, case no. : 502021CA004816. Copies of any deposition transcript of any individual taken in the case entitle Blaine E. Minton vs. Boca Development & Construction Corp. , et al, case no. : 502021CA004816. Any and all records, reports, letters, emails, text messages, papers, documents, materials and written evidence supporting defendant’s affirmative defense #1. Any and all records, reports, letters, emails, text messages, papers, documents, materials and written evidence supporting defendant’s affirmative defense #2. Any and all records, reports, letters, emails, text messages, papers, documents, materials and written evidence supporting defendant’s affirmative defense #3. Any and all records, reports, letters, emails, text messages, papers, documents, materials and written evidence supporting defendant’s affirmative defense #4. Any and all records, reports, letters, emails, text messages, papers, documents, materials and written evidence supporting defendant’s affirmative defense #5. ----- Any and all records, reports, letters, emails, text messages, papers, documents, materials and written evidence supporting defendant’s affirmative defense #6. Any and all records, reports, letters, emails, text messages, papers, documents, materials and written evidence supporting defendant’s affirmative defense #7. Any and all records, reports, letters, emails, text messages, papers, documents, materials and written evidence supporting defendant’s affirmative defense #8. Any and all records, reports, letters, emails, text messages, papers, documents, materials and written evidence supporting defendant’s affirmative defense #9. Any and all records, reports, letters, emails, text messages, papers, documents, materials and written evidence supporting defendant’s affirmative defense #10. Any and all records, reports, letters, emails, text messages, papers, documents, materials and written evidence supporting defendant’s affirmative defense #11. I HEREBY CERTIFY that a true and correct copy of the foregoing was electronically transmitted on the 3rd day of February, 2023, to: ADAM P. HANDFINGER, ESQUIRE and **BRETT J. MORITZ, ESQUIRE, at ahandfinger@pecklaw. com, bmoritz@pecklaw. com, ** mgil@pecklaw. com, PECKAR & ABRAMSON, P. C. , Attorneys for Defendants, BLAINE E. MINTON, and SAMANTHA C. MINTON, One Southeast Third Avenue, Suite 2000, Miami, Florida 33131. LAW OFFICES OF FRED LAND FULMER, P. A. Attorneys for Plaintiff, NATIONAL BIO-SAFE, INC. Galleria Corporate Centre, Suite 1216 2455 East Sunrise Boulevard Fort Lauderdale, Florida 33304 (954)763-1052 Broward flfulmerlaw@aol. com By /s/ Fred L. Fulmer FRED L. FULMER FLA BAR NO: 347681 -----


[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.

[Assistant] IN THE CIRCUIT COURT OF THE 15[TH ]JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, STATE OF FLORIDA CIVIL DIVISION KIMBERLY ANN TCHIVIDJIAN, Plaintiff, CASE NO: 2023-CA-002312 vs. WOW VENTURES LLC D/B/A HIJINKS SPORTS GRILL, a Florida Limited Liability Company, SYDNEY SMITH, individually, and AMMY SMITH, individually, Defendants. __________ / **REQUEST FOR PRODUCTION TO PLAINTIFF, KIMBERLY ANN** **TCHIVIDJIAN** Defendant, WOW VENTURES LLC. D/B/A HIJINKS SPORTS GRILL, a Florida Limited Liability Company, (“Hijinks”), by and through its undersigned counsel and pursuant to Rule 1. 350 of The Florida Rules of Civil Procedure, hereby instructs Plaintiff, KIMBERLY ANN TCHIVIDJIAN (“Plaintiff”) to produce for inspection and/or copying within thirty (30) days, copies of the following documents relating to the subject litigation that are in Plaintiff’s possession, custody or control, or are in the possession, custody or control of any agent, servant, employee, attorney or representative of Plaintiff. **INSTRUCTIONS FOR ANSWERING** You are required in responding to this Request for Production to obtain and furnish all information available to you and any of your representatives, employees, agents, brokers, servants, or attorneys and to obtain and furnish all information that is in your possession or under your control, or in the possession or under the control of any of your representatives, employees, agents, servants or attorneys. Each Request which seeks information relating in any way to communications, to, from, or within a business and/or corporate entity, is hereby designated to demand, and should be construed to include, all communications by and between representatives, employees, agents, brokers and/or servants of the business and/or corporate entity. ----- Each Request should be responded to separately. However, a document which is the response to more than one request may, if the relevant portion is marked or indexed, be produced and referred to in a later response. All documents produced shall be segregated and identified by the paragraphs to which they are primarily responsive. Where required by a particular paragraph of this Request, documents produced shall be further segregated and identifies as indicated in this paragraph. For any documents that are stored or maintained in files in the normal course of business, such documents shall be produces in such files, or in such a manner as to preserve and identify the file from which such documents were taken. If you object to part of any Request, please furnish documents responsive to the remainder of the request. Each Request refers to all documents that are either known by the defendant to exist or that can be located or discovered by reasonably diligent efforts of the defendant. The documents produced in response to this request shall include all attachments and enclosures. The documents requested for production include those in the possession, custody, or control of defendant, its agents, representatives, or attorneys. References to the singular include the plural. The use of any tense of any verb shall be considered also to include within its meaning all other tenses of the verb so used. [If under Federal Rules of Civil Procedure:] Please note that the defendant, pursuant to Federal Rules of Civil Procedure 26(e), is under a continuing duty to seasonably supplement the production with documents obtained subsequent to the preparation and filing of a response to each request. All documents called for by this Request (or related to this Request) for which the defendant claims a privilege or statutory authority as a ground for non-production shall be listed chronologically as follows: a. The place, and manner of recording or otherwise preparing the document; b. The name and title of the sender; c. The identity of each person or persons (other than stenographic or clerical assistants) participating in the preparation of the document; d. The identity and title, if any, or the person or persons supplying the attorney with the information requested above; ----- e. The identity of each person to whom the contents of the document have heretofore been communicated by copy, exhibition, sketch, reading or substantial summarization, thes of said communication, and the employer and title of said person at the time of said communication; f. Type of document; g. Subject matter (without revealing the relevant information for which privilege or statutory authority is claimed); and h. Factual and legal basis for claim, privilege or specific statutory or regulatory authority which provides the claimed ground for non-production. Each Request for a document or documents shall be deemed to call for the production of the original document or documents to the extent that they are in, or subject to, directly or in directly, the control of the party to whom this Request is addressed. In addition, each Request, should be considered as including a Request for separate production of all copies and, to the extent applicable, preliminary drafts of documents that differ in any respect from the original or final draft or from each other (e. g. , by reason of differences in form or content or by reason of handwritten notes or comments having been added to one copy of a document but not on the original or other copies thereof). All documents produced in response to this Request shall be complete, notwithstanding the fact that portions thereof may contain information not requested. If any documents requested herein have been lost or destroyed, the documents so lost or destroyed shall be identified by author, and subject matter. Where exact information cannot be furnished, estimated information is to be supplied to the extent possible. Where estimation is used, it should be so indicated, and an explanation should be given as to the basis on which the estimate was made and the reason exact information cannot be furnished. With respect to any document requested which was once in possession, custody or control, but no longer is, please indicate thethe document ceased to be in possession, custody or control, the manner in which it is ceased, and the name and address of its present custodian. Unless otherwise indicated, each Request is to be construed as encompassing all documents which pertain to the stated subject matter and to events which transpired between 2019, up to the present. Production can be accomplished by mailing the documents within the rule time to the Law Offices of Lydecker Diaz. , 4350 W. Cypress Street, Suite 910, Tampa, FL 33607. **Definitions** You, "your" and "yourself refer to the party to whom the following requests are addressed. , and its agents, representatives, officers, directors, affiliates, predecessors and successors in ----- interest, parents, divisions, subsidiaries, area and regional offices, and employees including persons or entities outside of the United States. "Person" means natural persons, firms, proprietorships, associations, partnerships, corporations and every other type of organization or entity. "Identify" means when used in reference to: a. A document, to state separately: (1) Its description (e. g. letter, report, memorandum, etc. ), (2) Its, (3) Its subject matter, (4) The identity of each author or signer. (5) Its present location and the identity of its custodian b. An oral statement, communication, conference or conversation, to state separately: (1) Itsand the place where it occurred, (2) Its substance, (3) The identity of each person participating in the communication or conversation, and (4) The identity of all notes, memoranda or other documents memorializing, referring to or relating to the subject matter of the statement; c. A natural person or persons to state separately: (1) The full name of each such person, (2) His or her present, or last known business address and his or her present or last known residential address, and (3) The employer of the person at the time to which the interrogatory answer is directed and the person's title or position at that time; d. An organization or entity other than a natural person (e. g. , a company, corporation, firm, association, or partnership), to state separately: (1) The full name and type of organization or entity, (2) Theand state of organization or incorporation, (3) The address of each of its principal places of business, and (4) The nature of the business conducted. "Communication" shall mean any transmission of information, the information transmitted, and any process by which information is transmitted, and shall include written communications and oral communications. ----- "Document" or "documents" includes without limitation any written, typed, printed, recorded or graphic matter, however preserved, produced, or reproduced, of any type or description, regardless of origin or location, including without limitation any binder, cover note, certificate, letter, correspondence, record, table, chart, analysis, graph, schedule, report, test, study memorandum, note, list, diary, log, calendar, telex, message (including, but not limited to, inter-office and intra-office communications), questionnaire, bill, purchase order, shipping order, contract, memorandum of contract, agreement, assignment, license, certificate, permit, ledger, ledger entry, book of account, check, order, invoice, receipt, statement, financial data, acknowledgment, computer or data processing card, computer or data processing disk, computer-generated matter, photograph, photographic negative, phonograph recording, transcript or log of an such recording, projection, videotape, film, microfiche, and all other data compilations from which information can be obtained or translated, reports and/or summaries of investigations, drafts and revisions of drafts of any documents and original preliminary notes or sketches, no matter how produced or maintained, in you actual or constructive possession, custody or control, or the existence of which you have knowledge, and whether prepared, published or released by you or by any other person. If a document has been prepared in several copies, or additional copies have been made, or copies are not identical (or which by reason of subsequent modification of a copy by the addition of notations or other modifications, are no longer identical), each non-identical copy as a separate document. "Relating to" means consisting of, referring to, describing, discussing, constituting, evidencing, containing, reflecting, mentioning, concerning, pertaining to, citing, summarizing, analyzing or bearing any logical or factual connection with the matter discussed. "Claim" means a demand or assertion, whether oral or written, formal or informal, by any person for monetary payment, the undertaking of action, or the cessation of action. "Consulted" or "contracted" means any form of communication, e. g. , oral statements, telephonic conversations or other mechanical communications or any other type of communication including written letters or documents. "Plaintiff ' means and any other individuals who have acted on the plaintiff s behalf. "Management" or "manage" includes any act of directing, conducting, administering, controlling or handling an identified function or duty. "During the relevant time period" shall mean a period of five years before and up to theof occurrence alleged. "Any" shall also mean "all" and vice versa. "And" shall mean "or" and "or" shall mean "and" as necessary to call for the broadest possible answer. ----- **REQUESTS FOR PRODUCTION TO PLAINTIFF, KIMBERLY ANN TCHIVIDJIAN** Copies of Federal Income Tax Returns, W-2 withholding tax statements, any and all other business records and/or income records, payroll withholding tax statements, commission statements, personal records of income and any other documents of income for six (6) years prior to the current year, together with a record of earnings toin the current year. Any and all medical or related bills, paid or owing, allegedly resulting from the subject incident or occurrence. All clinical records pertaining to medical examinations or treatments administered to Plaintiff because of the incident involved in this lawsuit, which are in the Plaintiff’s possession or control or in the possession or control of Plaintiff’s attorneys, agents, representatives or employees. All medical records, reports, hospital records, chiropractic records, osteopathic records, faith healers’ records, x-ray reports, MRI scan reports, lab results, CT scan reports, nurses notes, physical therapy records, and any other medical information in your possession, including copies of any radiographic materials such as x-ray films, CT films, MRI films, for treatment rendered to Plaintiff for injuries allegedly incurred as a result of the incident or occurrences described in the Complaint which are in the Plaintiff’s possession or control or in the possession or control of Plaintiff’s attorneys, agents, representatives or employees. All documents reflecting expenses, other than medical expenses, paid or owing allegedly resulting from the incident or occurrence as alleged in the Complaint, including but not limited to repair bills and estimates for property damage. All reports, evaluations, recommendations and/or analysis submitted by any expert expected to testify at trial, including vocational specialist and rehabilitative consultant, which relate to the incident which is the subject matter of this lawsuit and/or injuries, damages or losses allegedly caused by the incident, pursuant to Mims v. Casademont, 464 So. 2d 643 (Fla. 3d DCA 1985). All police reports, accident reports, incident reports, or any other reports made as a result of the alleged incident or occurrence alleged in the Complaint. All written or recorded statements of any witnesses to this action other than Plaintiff(s) relating to facts or issues involved in this lawsuit or a stenographic, mechanical, electrical, or other recording or transcription of a statement that is a substantial verbatim recital of an oral statement. All written or recorded statements taken of Hijinks(s), their agents or employees, relating to facts or issues involved in this lawsuit or a stenographic, mechanical, electrical, or other recording or transcription of a statement that is a substantial verbatim recital of an oral statement. ----- All photographs, graphs, charts, and other documentary evidence of the scene, parties or vehicles involved in or pertaining to the subject incident, occurrence or issues in this cause. All photographs and/or films depicting injuries Plaintiff allegedly sustained as a result of the subject incident. All photographs, graphs, charts, diagrams, documents, and/or other documentary or physical evidence of the incident scene, the subject product, or any objects present at the incident scene that depict things or conditions that have changed since the photographs were taken. Pierson v. Seale, 128 So. 2d 887 (Fla. 3d DCA 1961). All insurance policies in full force and effect on theof the incident described in the Complaint providing any type of insurance under which Plaintiff received or is eligible to receive in connection with medical, health, hospital, accident, Medicare, Medicaid, disability, sickness, Social Security, worker’s compensation, income disability, wage continuation, lost wages, umbrella liability, and other expenses occasioned as a result of the subject incident and as to all insurance available to Plaintiff the following: a. All contracts of insurance and/or other similar benefits applied for, together with the identification card and declaration sheet of all insurance in effect on theof the occurrence described in the Complaint; b. All applications for benefits available under the above-referenced insurance policies; c. All records of payments, duplicate checks, check stubs, memos and correspondence relating to payment made under the above-referred to policies; and d. All applications for insurance as above-referenced applied for by Plaintiff. All documents relating to any settlement by Plaintiff with any other person or entity who may have been liable for damages claimed by Plaintiff. All documents relating to payment by any source, and any resulting lien, for medical bills, doctor bills, hospital bills, prescription bills, ambulance bills, or bills for any similar expenses incurred by Plaintiff(s) as a result of the alleged incident described in the Complaint. All documents relating to any efforts by Plaintiff to seek employment (or to seek compensation for the performance of services) with any employer, person or entity at any time from theof the subject incident through theof your response to this request. All documents relating to any Medicare, Medicaid, Social Security, unemployment, other governmental benefits or other benefits of any kind whatsoever which you have applied to and/or received since theof the subject incident. ----- All medical reports, clinical records and documents relating to the care, examination, and treatment of Plaintiff by any and all physicians, hospitals, or other practitioners of any kind, whatsoever, for any medical or other health-related conditions, of any kind, for any illnesses, conditions or injuries of the Plaintiff for the past ten (10) years. Each and every document, including employment or payroll record, time sheet, attendance log or writing of any type documenting each and every day or partial day you claim to have missed from work as a result of the incident which is the subject matter of this lawsuit. Any and all curriculum vitae for experts expected to testify at trial of this cause. Any and all bills or statements for services submitted by experts expected to testify at trial of this cause and documentation reflecting the amount for such services paid to. All documents provided by any expert witnesses retained or consulted by Plaintiff in connection with this matter, whether or not Plaintiff intends to call the expert as a witness. Legible copy of the front and back of the Plaintiff’s current driver’s license. Legible copy of the front and back of all cards reflecting Plaintiff’s medical or health insurance providers. All documents relating to any meetings, discussions, encounters and/or conversations, whether public or private, that Plaintiff had with any present and/or former agent or employee of Hijinks. A copy of the Application and/or Claim for Benefit and/or Claim for Payment submitted by Plaintiff to Plaintiff's insurance company for either personal injuries and/or property damage sustained by Plaintiff, in the subject accident and/or incident. Any and all medical reports which reflect any injury, disability, infirmity or illness suffered by the Plaintiff which pre-existed the incident which forms the subject matter of this litigation. Any and all accidents and/or incident reports which reflect accidents or incidents involving the Plaintiff which occurred prior to the incident which forms the subject matter of this litigation. Any and all accident and/or incident reports which reflect accidents or incidents involving the Plaintiff which occurred subsequent to the incident which forms the subject matter of this litigation. In support of this Request for Production, Hijinks would show that it is unable to obtain the materials without due expense and hardship. The articles are in the sole or exclusive possession ----- #### of the Plaintiff, her agents, or attorneys; and such items are necessary for Hijinks to properly prepare [its][ case. ] #### CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 25th day of October 2023, a true and correct copy of the foregoing has been furnished by Eservice to: Glen B. Levine, Esq. , Elie Anidjar, Esq. , LAW OFFICES OF ANIDJAR & LEVINE, P. A. , Attorneysfor Plaintiff [ pleadings@anl-law. com ] and the original [has][ been][ filed][ with][ the][ Court. ] #### LYDECKER LLP 4350 W. Cypress St Suite 910 Tampa, [FL][ 33607] Counselfor Defendant Telephone [No. :] (813) [443-8424] Facsimile No. : (305) 416-3190 BY: /s/ Dawn ## George_ DAWN E. GEORGE, ESQ. Florida Bar No. : 1006408 deg@lydecker. com ANA REYES, ESQ. Florida Bar No. : 1036548 apr@lydecker. 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.

[Assistant] IN THE CIRCUIT COURT OF THE 15™ JUDICIAL COURT IN AND FOR PALM BEACH COUNTY, FLORIDA KIMBERLY ANN TCHIVIDJIAN, Plaintiff, vs. WOW VENTURES LLC, d/b/a HIJINKS SPORTS GRILL, a Florida Limited Liability Company, Defendant. ##### FIRST REQUEST FOR PRODUCTION TO DEFENDANT, WOW VENTURES LLC, d/b/a HIJINKS SPORTS GRILL. # _/ ##### COMES NOW, the Plaintiff, by and through undersigned counsel, and pursuant to Florida Rules of Civil Procedure, Rule 1. 350, and files this First Request for Production to Defendant, ##### WOW VENTURES LLC, d/b/a HIJINKS SPORTS GRILL. , and requests the Defendant produce [the][ items][ listed][ below][ in][ accordance][ with][ Rule][ 1. 350:] Any [and][ all][ Policies][ of][ Insurance][ that ]you [contend][ cover][ or] may [cover] any Defendant[ for] the allegations contained in Plaintiffs' Complaint. Any [and][ all][ documents][ which] support [the][ affirmative][ defenses][ in] your [answer. ] Any [and][ all] reports [of] expert [witnesses][ who][ will] testify [at][ time][ of][ trial] pertaining [to] any issue involved in this lawsuit. Any [statements][ of][ the][ Plaintiff][ taken][ in][ connection][ with][ the][ above][ lawsuit. ] Any model, plat, map, drawing, [motion] picture, [video] tape, [or] photograph pertaining to any [fact][ or][ issue][ involved][ in][ this] controversy. A copy of the title and registration for the subject bar/restaurant. 1 ----- A copy of your driver’s license. Any [materials] you [intend][ to][ use][ at][ trial][ to] impeach [the] parties, [their][ witnesses][ or] experts, including impeachment [material][ set][ forth][ in][ and] Northup[ v. ][ Acken][ 865][ So. 2d][ 1267] (Fla. 2004). Any [and][ all][ invoices][ and/or] repair [estimates][ of][ Defendant’s][ bar/restaurant] pertaining [to] the accident. ##### CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been furnished via the Florida court E-Filing Portal to: Dawn E. George, Esq. and Ana Reyes, Esq. , Lydecker LLP, [4350][ W] Cypress St, [Suite] 910, Tampa, [Florida] 33607, [Counsel]for Defendant, at: deafh lvdecker. com and aiir. t71vdecker. com, on this 0 day [of] December, [2023. ] LAW OFFICES OF ANIDJAR & LEVINE, P. A. 300 SE 17th Street Fort Lauderdale, Florida 33316 Phone (954) 525-0050/Fax (954) 525-0020 E-Service: pleadings# anl, -, law. com By: GLEN B. LEVINE, ESQ. FBN 0144355 ANTHONY K. GOODMAN, ESQ. FBN 019641 2 -----


[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 IN AND FOR PALM BEACH COUNTY, FLORIDA Probate Division: File No: FRIENDS OF THE ISRAEL DEFENSE FORCES Plaintiff, V. LAINIE BETH ROLDAN Defendant. / COMPLAINT Plaintiff, FRIENDS OF THE ISRAEL DEFENSE FORCES ("FIDF"), by and through its undersigned counsel, sues Defendant, LAINIE BETH ROLDAN ("ROLDAN"), as follows: FACTS COMMON TO ALL COUNTS This is an action concerning the Barry Rubin Legacy Trust under the Last Will and Testament of Barry E. Rubin dtd. December 3, 2019 ("Trust") [Exhibit "A"]. The principle place of administration of the Trust is Palm Beach County, Florida. FIDF is a 501(c)(3) not-for-profit organization and the residuary beneficiary under both the Will and Trust. Refer to ARTICLE IX of the Trust. ROLDAN is a resident of Palm Beach County, Florida. This Court has jurisdiction over the parties and the subject matter of this action. On December 3, 2019, Barry E. Rubin executed the Trust. Barry E. Rubin ("decedent") died on October 27, 2021 in Palm Beach County, Florida at which time the Trust because irrevocable. Prior to his death, the decedent owned the following assets: Asset DOD Value Owner/Benefieiary/Joint Owner 2014 Merces Benz E350 $13, 189. 00 Barry E. Rubin Misc. tangible personal property 10, 000. 00 Barry E. Rubin Charles Schwab Acct#REDACTED 9, 099, 788. 61 Barry E. Rubin ----- REDACTE REDACTE REDACTE ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- ----- REDACTE ----- ----- REDACTED R -----

[Assistant] IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA FRIENDS OF THE ISRAEL CASE NO: 502022CP003828XXXXSB DEFENSE FORCES, PROBATE DIVISION: IZ Plaintiff, v. LAINIE BETH ROLDAN, et. al, Defendants. ###### LAINIE BETH ROLDAN’S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS # _I ###### TO FRIENDS OF THE ISRAEL DEFENSE FORCES Defendant Lanue Beth Roldan, by and through undersigned counsel, pursuant to Florida Rule ###### of Civil Procedure 1. 350, hereby requests Plaintiff Friends of the Israel Defense Forces to produce and permit the inspection of the documents identified below in its possession, custody, or control. The documents requested should be produced for inspection and copying within 30 days at Pankauski Lazarus PLLC, 415 South Olive Avenue, West Palm Beach, Florida 33401. Alternatively, you may [send] copies [of][ the][ documents][ via][ e-mail][ to] iason@phflonda. com; ##### If arrangement needs to be made to facilitate or accommothe production, please contact the undersigned [counsel. ] #### Definitions The following definitions shall apply: A. The terms "you" and "your" shall mean the person or entity to whom this request is propounded, and any and all agents, employees, attorneys, attorneys-in-fact, accountants, representatives, investigators, auditors, predecessors [and][ successors][ in] interest, [and] any [other] persons acting [or] purporting [to][ act][ on][ behalf][ of] you [or][ under][ the] control, [instruction][ or] guidance [of] your attorneys, [and] any entity [in][ which] you [have][ an] ownership [interest. ] B. The term "Plaintiff' refers to Friends of die Israel Defense Forces. 1 ----- C. The term “Defendant” refers to Lainie Beth Roldan. D. The term “Decedent” refers to Barry E. Rubin. E. The term “Will” refers to the Last Will and Testament of Barry E. Rubind December 3, 2019. F. The term “Beneficiary Designation” refers to the Designated Beneficiary Plan Agreementd October 19, 2021 with Charles Schwab. G. The "Amended Complaint” means the Amended Complaint that you filed in this action on September 19, 2022. H. The term "document" shall mean the originals and all non-identical copies of any written, recorded, or graphic matter, however produced, reproduced, or fixed in a tangible medium of expression, of every kind, and regardless of where located, and all tangible and intangible things from which information can be processed or transcribed, including the originals and all non-identical copies, including but not limited to any summary, schedule, memorandum, note, message, electronic mail, statement, computer record, letter, telegram, facsimile, telefax, bulletin, inter- or intra-office communication, report, diary, desk or pocket calendar, electronic calendar, notebook, day book, chronological data compilation, appointment book, message slip, message book, pamphlet, periodical, magazine, newspaper article, advertisement, list, graph, motion picture, photograph, x-ray or other machine-produced diagnostic picture or depiction, chart, index, tape, record, drawing, compilation, tabulation, computer print-out, computer-stored memory component or device, e-mail, study, analysis, transcript, minutes, books, data sheet, data processing card or tape, phone records, correspondence, ledgers, invoices, worksheets, receipts, returns, prospectuses, financial statements, schedules, affidavits, contracts, agreements, subcontracts, bonds and similar documents, cancelled checks, checkbooks, check stubs, promissory notes, complaints and all other pleadings, judgments, transcripts, statistics, surveys, releases, microfiche, microfilm, metadata, electronic and digital and mechanical recordings of every kind (including but not limited to tapes, videotapes, cassettes, disks, cd's, dvd's, and all other manner of electronic, mechanical and digital recordings, including recordings using any new technology not specifically mentioned herein), notes or documents memorializing conversations or meetings or conferences, cards, notations, and all writings of any other kind, in the possession, custody or control of you or your attorney(s), and any and all drafts, amendments, revisions, alternations, modifications, changes, and amendments of all of the foregoing. The term "document" shall also include the files in which any such documents are maintained, including file folders and file jackets, and any indices thereof. I. The term "all documents" shall mean every document, group of documents, partial document, non-identical reproduction of a document, attachments, exhibits, transmittal correspondence, responses and replies. J. The term "communication" shall mean any oral or written statement, remark, conversation, dialogue, discussion, agreement, argument, exchange, note, contract, or transmission, between any two or more persons, including but not limited to communications in person, over the telephone, via electronic mail or instant messaging or text messaging video conferencing and all other electronic means, meetings, conferences, and other communications involving any number of persons. 2 ----- K. The term "person" shall mean any individual, natural person, proprietorship, partnership, firm, corporation, association, organization, joint venture, business trust, business enterprise, governmental agency or body, public entity, legal or business entity, revocable or irrevocable trust, or any other group of natural persons. L. The term "entity" shall mean any legal or business entity, proprietorship, business enterprise, partnership, firm, company, corporation, association, organization, joint venture, governmental agency, public entity, foundation, revocable or irrevocable trust, or any other group of natural persons working for profit or not for profit. M. The terms "evidence”, “support” or "relate” shall mean concerning, reflecting, relating to, respecting, referring to, summarizing, digesting, embodying, establishing, tending to establish, tending not to establish, evidencing, supporting, comprising, connected with, commenting on, referencing, responding to, disagreeing with, showing, describing, analyzing, representing, constituting and including. N. The term "identify", when used in reference to a document or record, shall mean and include the name and address of the custodian of the document or record, the location of the document or record, a general description of the document or record, including (1) the title of the document or record if it has one, (2) the general subject matter of the document or record, (3) theof the document or record, and (4) the name and address of the author of the document or record. If you don't know the location of each document or record, then please state the name(s) and address(es) of anyone whom you know to have possession or control of the original or copy of such document or record. **DOCUMENTS REQUESTED** All emails, text messages, and other documents by and between you and the Decedent. All documents reflecting any donation made by Decedent to you during his lifetime. All documents reflecting any planned giving or bequest that Decedent intended to make to you, such as donor pledges and donor contact records. All documents reflecting any of your donor events that Decedent attended. All internal emails, text messages, memoranda, and other communications that you created prior to Decedent’s death that in any way relate to Decedent. All documents and communications by and between you and Marc Rubin relating to Lainie Roldan, the Will, the Beneficiary Designation, the substance of the Amended Complaint or the subject matter of this litigation. 3 ----- All documents and communications by and between you and Eileen Gould relating to Lainie Roldan, the Will, the Beneficiary Designation, the substance of the Amended Complaint or the subject matter of this litigation. All documents and communications by and between you and Barbara Stubbs relating to Lainie Roldan, the Will, the Beneficiary Designation, the substance of the Amended Complaint or the subject matter of this litigation. All documents and communications by and between you and Loretta Friedman relating to Lainie Roldan, the Will, the Beneficiary Designation, the substance of the Amended Complaint or the subject matter of this litigation. All documents and communications by and between you and any other person relating to Lainie Roldan, the Will, the Beneficiary Designation, the substance of the Amended Complaint or the subject matter of this litigation. All documents which evidence, support or relate to your allegations in Paragraphs 6 and 7 of the Amended Complaint regarding the medical conditions suffered by the Decedent. All documents which evidence, support or relate to your allegation in Paragraph 9 of the Amended Complaint that the Decedent was incapable of making his own medical decisions as of October 19, 2021. All documents which evidence, support or relate to your allegations in Paragraphs 14 and 17 of the Amended Complaint that the Beneficiary Designation is void on the basis of incapacity. All documents which evidence, support or relate to your allegations in Paragraphs 14 and 23 of the Amended Complaint that the Beneficiary Designation is void on the basis of undue influence. All documents which evidence, support or relate to your allegations in Paragraphs 14 and 28 of the Amended Complaint that the Beneficiary Designation is void on the basis of fraud. 4 ----- All documents winch evidence, support or relate to your allegations in Paragraphs 14 and 33 of the Amended Complaint that the Beneficiary Designation is void on the basis of insane delusion. All documents which evidence, support or relate to your allegations in Paragraph 40 ###### of the Amended Complaint that Lanne abused her confidential relationship with Decedent and improperly acquired [and][ retained][ his] personal property. All documents which evidence, support or relate to any other allegations of the Amended Complaint. All reports or tests of any neurologist or any other medical professional relating to the Decedent’s mental capacity. All documents identified in your response to Defendant’s First Set of Interrogatories. All documents relied upon in preparing your response to answers to Defendant’s First Set of Interrogatories. ###### CERTIFICATE OF SERVICE I HEREBY CERTIFY diat a true and correct copy of the foregoing was filed electronically [and][ served][ on] January 4, 2023, [to][ the] following persons [in][ die][ method][ noted:] David M. Garten, Esq. , Law Office of David M. Garten, 400 Columbia Drive Ste. 100, West Palm Beach, [FL][ 33409][ via] e-portal [to:] dgarten@gartenlaw. com; chancock@gartenlaw. com; ###### Jordan [R. ] Hammer, Esq. , [Ellis][ Law] Group, P. L. , [4755] Technology Way, [Suite] 205, [Boca] Raton, [FL] 33431 via email to e-portal to: iordan@ellis-law. com; service@ellis-law. com; Marc H. Rubin, 10 Woodlake Drive, Croton on the Hudson, NY 10520 via US Mail; ###### Samantha Rubin, 10 Woodlake Drive, Croton on the Hudson, NY 10520 via US Mail; Matthew Rubin, 10 Woodlake Drive, Croton on the Hudson, NY 10520 via US Mail; Claire Rubin, 10 Woodlake Drive, Croton on die Hudson, NY 10520 via US Mail; ###### Eileen Gould, 300 First Avenue, Apt. 1A, New York, NY 10019 via US Mail Loretta Friedman, 34 Locust Grove Road, Saratoga Springs, NY 12866 via US Mail 5 ----- ##### Pankauski Lazarus PLLC 415 South Olive Avenue West Palm Beach, Florida 33401 Telephone: [561-514-0900] courtfilnigs@phflorida. com By: [/s/] Jason [D. ] ### L/i^ams_ Jason [D. ] Lazarus, Esq. Florida Bar No. 139040 Andrew S. Kwan, Esq. Florida Bar No. 76539 6 -----


[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 DJINNEE O. GUNNING, Case No: Judge: Plaintiff(s), vs. UNITED SERVICES AUTOMOBILE ASSOCIATION and SARAH B. SMITH Defendant(s). _____ ________ _______ _______ / **COMPLAINT** Plaintiff, DJINNEE O. GUNNING, by and through undersigned counsel, sues the Defendants, SARAH B. SMITH and UNITED SERVICES AUTOMOBILE ASSOCIATION, and alleges: **GENERAL** **ALLEGATIONS** This Is a claim for damages that exceeds fifteen thousand dollars ($15, 000. 00). Plaintiff, DJINNEE O. GUNNING, at all times relevant herein, is over the age of eighteen years, sui juris, and a resident of Palm Beach County, Florida. Defendant, SARAH B. SMITH, at all times relevant herein, is over the age of eighteen years, sui juris and a resident of Palm Beach County, Florida. Defendant, UNITED SERVICES AUTOMOBILE ASSOCIATION, is a foreign corporation with offices located in Palm Beach County, Florida, where it maintains sales agents, adjusters, insurance policy writers and insures risks of loss that result to policy holders who entered into a policy of automobile insurance and who resided within Palm Beach County, Florida at the time the policies were issued. At all ----- times relevant and material herein, Defendant, UNITED SERVICES AUTOMOBILE ASSOCIATION, issued and provided a policy of automobile insurance to Plaintiff, DJINNEE O. GUNNING, where such policy offered underinsured/uninsured motorist benefits. The cause of actions complained of herein occurred in Palm Beach County, Florida. **COUNT** **I** **NEGLIGENCE** The Plaintiff, DJINNEE O. GUNNING, reavers and realleges each and every allegation contained in paragraphs one (1) through three (3) and five (5) above as ## if fully set forth herein. On or about May 13, 2013, Defendant, SARAH B. SMITH, was operating a vehicle owned by her on Military Trail at or near its intersection with Burns Road, City ## of Palm Beach Gardens, Palm Beach County, Florida. At said time, Defendant, SARAH B. SMITH, carelessly and negligently operated and/or maintained said vehicle and collided into the vehicle Plaintiff, DJINNEE O. GUNNING, was operating. As a result of the negligence of Defendant, SARAH B. SMITH, the Plaintiff, DJINNEE O. GUNNING, suffered bodily injury that is permanent within a reasonable degree of medical probability, resulting pain and suffering, disability, disfigurement, mental anguish, lost wages, loss of capacity for the enjoyment of life, inconvenience, expense of hospitalization, medical and nursing care and treatment, loss of earnings, and loss of ability to earn money and aggravation of a preexisting condition. These losses are either permanent or continuing and the Plaintiff will suffer these losses ----- in the future. Plaintiffs vehicle was damaged and he/she lost the use of it during the period required for its repair or replacement WHEREFORE, Plaintiff, DJINNEE O. GUNNING, demands judgment against the Defendant, SARAH B. SMITH, for damages in excess of Fifteen Thousand Dollars ($15, 000. 00), plus costs incurred herein and any other relief this court deems fit and proper. **COUNT** **TWO** **CLAIM** **FOR** **UNDERINSURED/UNINSURED** **MOTORIST** **AS** **TO** **UNITED** **SERVICES** **AUTOMOBILE** **ASSOCIATION** Plaintiff re-alleges, re-adopts and incorporates paragraphs one (1) through five (5) above as if fully set forth herein. This is an action for underinsured/uninsured motorist benefits pursuant to Section 627. 727, Florida Statutes. At all times relevant and material herein, Defendant, UNITED SERVICES AUTOMOBILE ASSOCIATION, maintained and provided a policy of automobile insurance containing an endorsement for underinsured/uninsured motorist benefits issued to the Plaintiff, DJINNEE O. GUNNING, Policy Number 00064 72 82U 7104 3 Notice of a claim arising out of and directly related to the motor vehicle crash of May 13, 2013 was presented to the Defendant, UNITED SERVICES AUTOMOBILE ASSOCIATION. Plaintiff is not in possession of the contract/policy of insurance, but it is readily available to and in the possession of the Defendant, UNITED SERVICES AUTOMOBILE ASSOCIATION. Pursuant to the provisions of the contract/policy of insurance, Defendant, UNITED SERVICES AUTOMOBILE ASSOCIATION, is obligated to pay the Plaintiff, ----- DJINNEE O. GUNNING, for the damages recoverable to her as a direct and proximate result of the negligence of Defendant, SARAH B. SMITH. As a result, Plaintiff, DJINNEE O. GUNNING, suffered bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, expense of hospitalization, medical, nursing, and professional health care treatment, loss of earnings, loss of ability to earn money, and aggravation of a previously existing condition. The losses are either permanent or continuing, and plaintiff will suffer the losses in the future. Plaintiff’s motor vehicle was damaged and she lost the use of it during the time required for its repair or replacement. WHEREFORE, Plaintiff, DJINNEE 0. GUNNING, demands judgment against Defendant, UNITED SERVICES AUTOMOBILE ASSOCIATION, for damages in excess of Fifteen Thousand Dollars ($15, 000. 00), plus costs incurred herein and any other relief this court deems fit and proper. **DEMAND** **FOR** **TRIAL** **BY** **JURY** The Plaintiff, DJINNEE O. GUNNING, hereby demands a trial by jury of all issues so triable. LITTKY, SMITH, PHIPPS & CASAS, P. A. Suite 800, Citizens Building 105 South Narcissus Avenue West Palm Beach, Florida 33401 (561) 655-8444/ office / (561) 655-5028 fax (800) 519-1965 toll free Discovery e-m? II: [lspc. discovery@lspcinjury. com](mailto:lspc. discovery@lspcinjury. com) BY:_______ ALEJAN G. CASAS, Esq. Florida Bhrllo. : 0914398 -----

[Assistant] **IN** **THE** **CIRCUIT** **COURT** **OF** **THE** **15TH** **JUDICIAL** **CIRCUIT** **IN** **AND** **FOR** **PALM** **BEACH** **COUNTY, ** **FLORIDA** **DJNNEE** **O. ** **GUNNING, ** **CASE** **NO. :** **502013CA010239XXXXMB** **DIVISION:** **GENERAL** **JURISDICTION** **Plaintiff, ** **vs. ** **UNITED** **SERVICES** **AUTOMOBILE** **ASSOCIATION, ** **Defendant. ** ``` ___________________________ I ``` **REQUEST** **TO** **PRODUCE** Defendant, UNITED SERVICES AUTOMOBILE ASSOCIATION, by and through the undersigned counsel, requests **Plaintiff, ** **DJINNEE** **GUNNING, ** to produce the following items within thirty (30) days in accordance with the applicable Rules of Civil Procedure: 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. All medical, hospital and/or other related bills regarding the accident alleged in the Complaint. All medical reports and/or hospital records in your possession regarding the accident alleged in the Complaint. Documentation substantiating health insurance coverage available to Plaintiff on theof the accident sued upon. Any statements, either recorded or written, and in the custody of Plaintiff or ### Plaintiffs attorney made by Defendant in regard to the above matter. ----- Any statements, either recorded or written, and in the custody of Plaintiff or ### Plaintiffs attorney made by persons who have knowledge concerning the subject incident. Any cellular phones or other mobile communication system telephone bills, invoices, statements, itemized accounts, or any other data compilation for the equipment owned or used by plaintiffs for the months of May 2013 and June 2013. Any and all films, diagnostic tests, MRI’s, x-rays, storage devices, digital images, intra-operative photographs, and/or data compilations from which information can be obtained, or translated if necessary which are in possession of Plaintiff and/or counsel for Plaintiff. If a claim is made for lost wages and/or loss of earning capacity in the future, all Federal Income Tax Returns and W-2 Forms of the Plaintiffs herein from five (5) years prior to the accident sued upon to the present. If a claim is made for lost wages and/or loss of earning capacity in the future, all withholding statements, pay envelopes, deposit slips, or any other evidence of income earned by Plaintiff for the current calendar year. Any and all medical records, hospital records, emergency room records and records from any health care provider pertaining to the treatment of Plaintiff for any reason in the five (5) years prior to the referenced incident. Any and all bills, statements or receipts relating to any non-medical expenses claimed as damages in this lawsuit that have not been produced in response to any of the preceding paragraphs. Any bills and/or estimates for the repair of plaintiffs vehicle any other damaged property. If the vehicle was not repairable, in addition, attach estimates of the value of the ----- vehicle on theof the alleged incident and estimates and/or receipts concerning salvage value. Any and all photographs of the vehicles involved in the incident before and after the accident. Any and all photographs of Plaintiff depicting injuries sustained as a result of the within incident. Any releases, “Mary Carter Agreements, ” and any other type of settlement agreements between Plaintiff and any other party which may have been responsible for the damages claimed by Plaintiff. Any and all policies of insurance providing collateral source payments to Plaintiff, including, but not limited to, PIP insurance, medical payment insurance, disability insurance, and/or employment related insurance. Any and all claim forms submitted by Plaintiff pursuant to the policies of insurance referred to in Paragraph 17 above. All incident reports filed by Plaintiff for any purpose, including, but not limited to, reports to employer and/or insurance company regarding the incident, if applicable, and/or any other reports filled out by Plaintiff. All documents, papers or evidence to be introduced at trial. All expert reports from any experts who will testify at trial. All reports, statements, written opinions and affidavits prepared by any experts retained by, or on behalf of, Plaintiff and who may called by Plaintiff to testify at the trial of this cause. **_See, _** **_Mims_** **_v. _** **_Casademont, _** **_N. D. ,_** 464 So. 2nd 643 (Fla. 3dDCA 1985). ----- **CERTIFICATE** **OF** **SERVICE** **I** **HEREBY** **CERTIFY** that a true and correct copy of the foregoing was served via e-mail to: Alejandro G. Casas, Esq. , LITTKY, SMITH, PHIPPS & CASAS, P. A. , 105 South Narcissus Avenue, Suite 800, West Palm Beach, FL 33401, [lspc. discovery@lspcinjury. com, ](mailto:lspc. discovery@lspcinjury. com) this 18th day of August, 2013. LAW OFFICES OF KEVIN M. McGOWEN Attorneys for Defendant USAA 1000 South Pine Island Road, Suite 420 Plantation, Florida 33324 Primary e-mail: [hmg. pld. sfl@USAA. com](mailto:hmg. pld. sfl@USAA. com) ### Phone(954)370-3129 Fax (954) 474-0689 Florida Bai-No. : 602248 -----


[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 DJINNEE O. GUNNING, Case No: Judge: Plaintiff(s), vs. UNITED SERVICES AUTOMOBILE ASSOCIATION and SARAH B. SMITH Defendant(s). _____ ________ _______ _______ / **COMPLAINT** Plaintiff, DJINNEE O. GUNNING, by and through undersigned counsel, sues the Defendants, SARAH B. SMITH and UNITED SERVICES AUTOMOBILE ASSOCIATION, and alleges: **GENERAL** **ALLEGATIONS** This Is a claim for damages that exceeds fifteen thousand dollars ($15, 000. 00). Plaintiff, DJINNEE O. GUNNING, at all times relevant herein, is over the age of eighteen years, sui juris, and a resident of Palm Beach County, Florida. Defendant, SARAH B. SMITH, at all times relevant herein, is over the age of eighteen years, sui juris and a resident of Palm Beach County, Florida. Defendant, UNITED SERVICES AUTOMOBILE ASSOCIATION, is a foreign corporation with offices located in Palm Beach County, Florida, where it maintains sales agents, adjusters, insurance policy writers and insures risks of loss that result to policy holders who entered into a policy of automobile insurance and who resided within Palm Beach County, Florida at the time the policies were issued. At all ----- times relevant and material herein, Defendant, UNITED SERVICES AUTOMOBILE ASSOCIATION, issued and provided a policy of automobile insurance to Plaintiff, DJINNEE O. GUNNING, where such policy offered underinsured/uninsured motorist benefits. The cause of actions complained of herein occurred in Palm Beach County, Florida. **COUNT** **I** **NEGLIGENCE** The Plaintiff, DJINNEE O. GUNNING, reavers and realleges each and every allegation contained in paragraphs one (1) through three (3) and five (5) above as ## if fully set forth herein. On or about May 13, 2013, Defendant, SARAH B. SMITH, was operating a vehicle owned by her on Military Trail at or near its intersection with Burns Road, City ## of Palm Beach Gardens, Palm Beach County, Florida. At said time, Defendant, SARAH B. SMITH, carelessly and negligently operated and/or maintained said vehicle and collided into the vehicle Plaintiff, DJINNEE O. GUNNING, was operating. As a result of the negligence of Defendant, SARAH B. SMITH, the Plaintiff, DJINNEE O. GUNNING, suffered bodily injury that is permanent within a reasonable degree of medical probability, resulting pain and suffering, disability, disfigurement, mental anguish, lost wages, loss of capacity for the enjoyment of life, inconvenience, expense of hospitalization, medical and nursing care and treatment, loss of earnings, and loss of ability to earn money and aggravation of a preexisting condition. These losses are either permanent or continuing and the Plaintiff will suffer these losses ----- in the future. Plaintiffs vehicle was damaged and he/she lost the use of it during the period required for its repair or replacement WHEREFORE, Plaintiff, DJINNEE O. GUNNING, demands judgment against the Defendant, SARAH B. SMITH, for damages in excess of Fifteen Thousand Dollars ($15, 000. 00), plus costs incurred herein and any other relief this court deems fit and proper. **COUNT** **TWO** **CLAIM** **FOR** **UNDERINSURED/UNINSURED** **MOTORIST** **AS** **TO** **UNITED** **SERVICES** **AUTOMOBILE** **ASSOCIATION** Plaintiff re-alleges, re-adopts and incorporates paragraphs one (1) through five (5) above as if fully set forth herein. This is an action for underinsured/uninsured motorist benefits pursuant to Section 627. 727, Florida Statutes. At all times relevant and material herein, Defendant, UNITED SERVICES AUTOMOBILE ASSOCIATION, maintained and provided a policy of automobile insurance containing an endorsement for underinsured/uninsured motorist benefits issued to the Plaintiff, DJINNEE O. GUNNING, Policy Number 00064 72 82U 7104 3 Notice of a claim arising out of and directly related to the motor vehicle crash of May 13, 2013 was presented to the Defendant, UNITED SERVICES AUTOMOBILE ASSOCIATION. Plaintiff is not in possession of the contract/policy of insurance, but it is readily available to and in the possession of the Defendant, UNITED SERVICES AUTOMOBILE ASSOCIATION. Pursuant to the provisions of the contract/policy of insurance, Defendant, UNITED SERVICES AUTOMOBILE ASSOCIATION, is obligated to pay the Plaintiff, ----- DJINNEE O. GUNNING, for the damages recoverable to her as a direct and proximate result of the negligence of Defendant, SARAH B. SMITH. As a result, Plaintiff, DJINNEE O. GUNNING, suffered bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, expense of hospitalization, medical, nursing, and professional health care treatment, loss of earnings, loss of ability to earn money, and aggravation of a previously existing condition. The losses are either permanent or continuing, and plaintiff will suffer the losses in the future. Plaintiff’s motor vehicle was damaged and she lost the use of it during the time required for its repair or replacement. WHEREFORE, Plaintiff, DJINNEE 0. GUNNING, demands judgment against Defendant, UNITED SERVICES AUTOMOBILE ASSOCIATION, for damages in excess of Fifteen Thousand Dollars ($15, 000. 00), plus costs incurred herein and any other relief this court deems fit and proper. **DEMAND** **FOR** **TRIAL** **BY** **JURY** The Plaintiff, DJINNEE O. GUNNING, hereby demands a trial by jury of all issues so triable. LITTKY, SMITH, PHIPPS & CASAS, P. A. Suite 800, Citizens Building 105 South Narcissus Avenue West Palm Beach, Florida 33401 (561) 655-8444/ office / (561) 655-5028 fax (800) 519-1965 toll free Discovery e-m? II: [lspc. discovery@lspcinjury. com](mailto:lspc. discovery@lspcinjury. com) BY:_______ ALEJAN G. CASAS, Esq. Florida Bhrllo. : 0914398 -----

[Assistant] IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA DJINNEE O. GUNNING, Case No: Plaintiff(s), vs. UNITED SERVICES AUTOMOBILE ASSOCIATION and SARAH B, SMITH Defendant(s). ________________________/ **PLAINTIFF’S** **FIRST** **REQUEST** **TO** **PRODUCE** **TO** **DEFENDANT, ** **UNITED** **SERVICES** **AUTOMOBILE** **ASSOCIATION** Plaintiff, by and through undersigned counsel, and pursuant to Rule 1. 350, Florida Rules of Civil Procedure, request the Defendant, UNITED SERVICES AUTOMOBILE ASSOCIATION, to produce and permit the Plaintiff to inspect and/or copy the following documents and items hereinafter enumerated within forty-five (45) days from theof service, at the offices of undersigned counsel. Inspection will be made by visual observation, examination and/or copying. Copies of any and all communications, writings, recordings, memorandums, notes, depositions, written statements, transcripts, recorded statements (audio and/or video) and all other materials reflecting statements made by the Plaintiff relative to the subject incident. Copies of any and all communications, writings, recordings, memorandums, notes, depositions, written statements, transcripts, recorded statements (audio and/or video) and all other materials reflecting statements made by any Defendant relative to the subject incident. Copies of any and all communications, writings, recordings, memorandums, notes, depositions, written statements, transcripts, recorded statements (audio and/or video) and all other materials reflecting statements made by any witnesses relative to the subject incident. ----- Color copies of any and all photographs and/or video of the scene of the incident, the vehicles involved and the parties involved. Certified copy of any applicable liability insurance contracts and/or policies including any excess coverage and all declaration sheets relative thereto. Copies of any and all documents which evidence property damage to the defendant’s vehicle involved in the incident which is the subject matter of this lawsuit. Copies of any and all documents which evidence property damage to the vehicle operated by the Plaintiff involved in the incident which is the subject matter of this lawsuit. Copy of the complete claim file relative to the subject uninsured/underinsured motorists claim. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished with the complaint via service of process on the above named defendant. LITTKY, SMITH, PHIPPS & CASAS P. A. Suite 800, Citizens Building 105 South Narcissus Avenue West Palm Beach Florida 33401 (561) 655-8444 trffice / (561) 655-5028 fax (800) 519-1965 toll free Discovery E-Maill [lspc. discoverv@lspciniurv. com](mailto:lspc. discoverv@lspciniurv. com) BY:__________/ - Alejandro G/Qasas, Esq. Florida Bar ho. : 0914398 -----