[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] SUSAN M. MORALES and JORGE L. MORALES, Individually and as Husband and Wife, Plaintiffs, vs. MORGUARD MANAGEMENT COMPANY INC. and HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC. , Defendants. _____________________________________/ IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. CASE NO: **COMPLAINT** Plaintiffs, SUSAN M. MORALES and JORGE L. MORALES, Individually and as Husband and Wife, by and through the undersigned attorneys, hereby sue the Defendants, MORGUARD MANAGEMENT COMPANY INC. and HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC. , and allege the following: **GENERAL ALLEGATIONS COMMON TO ALL COUNTS** This is an action for damages in excess of the sum of Fifty Thousand ($50, 000. 00) Dollars exclusive of interest, costs and attorneys’ fees. Plaintiffs, SUSAN M. MORALES and JORGE L. MORALES, were and are residents of Lake Worth, Palm Beach County, Florida. At all times material hereto, SUSAN M. MORALES and JORGE L. MORALES were and remain legally married to one another. ----- COMPLAINT Morales vs. Morguard Management Company, Inc. and Home Depot U. S. A. , Inc. d/b/a The Home Depot, Inc. Page 2 At all times material hereto, Defendant, MORGUARD MANAGEMENT COMPANY INC. was and is a Florida Profit Corporation authorized and doing business in Palm Beach County, Florida. At all times material hereto Defendant, MORGUARD MANAGEMENT COMPANY INC. was the management company for The Home Depot, Store #6316 located 5750 S. Jog Road, Lake Worth, Palm Beach County, Florida. At all times material hereto, Defendant, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC. was and is a Foreign Profit Corporation authorized and doing business in Palm Beach County, Florida. At all times material hereto Defendant, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC. owned and operated The Home Depot, Store #6316 located 5750 S. Jog Road, Lake Worth, Palm Beach County, Florida. At all times material hereto, on or about December 13, 2022 at approximately 8:30 a. m. , Plaintiff, SUSAN M. MORALES, an invitee, went to The Home Depot, Store #6316 located at 5750 S. Jog Road, Lake Worth, Palm Beach County, Florida. Plaintiff, SUSAN M. MORALES, parked her car and was walking in the parking lot in order to get into the store. Suddenly and without warning, her feet/foot got caught in a “pallet tie” causing her to violently fall to the ground. As a result, thereof, Plaintiff, SUSAN M. MORALES, suffered significant injuries including a large laceration to her nose, black right eye, contusion to her head, two broken kneecaps, broken left elbow, fractured left wrist and fractured right hand. ----- COMPLAINT Morales vs. Morguard Management Company, Inc. and Home Depot U. S. A. , Inc. d/b/a The Home Depot, Inc. Page 3 Venue is proper in Palm Beach County because the facts giving rise to this action occurred in Palm Beach County. **COUNT I - NEGLIGENCE CLAIM AGAINST** **DEFENDANT, MORGUARD MANAGEMENT COMPANY INC. ** Plaintiffs, SUSAN M. MORALES and JORGE L. MORALES, Individually and as Husband and Wife, reallege and incorporate each and every allegation contained in paragraphs 1 through 11 as if fully set forth herein, and further alleges: At all times material hereto, Defendant, MORGUARD MANAGEMENT COMPANY INC. , was and is the management company for The Home Depot, Store#6316, and had a duty to maintain its premises in a reasonably safe condition and to warn of any hazards about which it knew or should have known. At all times material hereto, Defendant, MORGUARD MANAGEMENT COMPANY INC. , knew or should have known, by and through the exercise of reasonable care in maintaining the parking lot area of The Home Depot, Store #6316, that individuals attempting to access the entrance to the building regularly traversed the parking lot of the premises. Defendant, MORGUARD MANAGEMENT COMPANY INC, knew or should have known that that dangerous conditions existed to individuals attempting to access the entrance to the building, including but not limited to, Plaintiff, SUSAN M. MORALES. Defendant, MORGUARD MANAGEMENT COMPANY INC, had actual or constructive notice of the dangerous condition in the parking lot and had a duty to protect invitees, like SUSAN MORALES, from the dangerous condition in the parking lot. Defendant, MORGUARD MANAGEMENT COMPANY INC, had a duty to warn SUSAN MORALES of ----- COMPLAINT Morales vs. Morguard Management Company, Inc. and Home Depot U. S. A. , Inc. d/b/a The Home Depot, Inc. Page 4 concealed dangers which were or should have been known to Defendant, MORGUARD MANAGEMENT COMPANY INC, and which were unknown to SUSAN MORALES. Defendant, MORGUARD MANAGEMENT COMPANY INC, had a duty to use reasonable care to maintain its premises in a reasonably safe condition. The danger in the parking lot was not known to SUSAN MORALES and even if it had been hypothetically, Defendant, MORGUARD MANAGEMENT COMPANY INC, should have anticipated the harm. Defendant, MORGUARD MANAGEMENT COMPANY INC. , individually, and by and through its employees, agents, servants, and/or apparent agents, was negligent and breached its aforementioned duty to Plaintiff, SUSAN M. MORALES. Defendant, MORGUARD MANAGEMENT COMPANY INC. , breached its duty to Plaintiff, SUSAN M. MORALES, in one or more of the following ways: a. Negligently failing to maintain its premises in a reasonably safe condition; b. Negligently failing to warn SUSAN MORALES of the hidden danger; c. Negligently allowing a known dangerous condition to exist upon its premises for an unreasonable period of time; d. Negligently failing to correct a dangerous condition about which it knew or should have known by the exercise of reasonable care; e. Negligently allowing a dangerous condition, which failed to comply with applicable codes and regulations to exist and thereby exposed business invitees, including Plaintiff, SUSAN M. MORALES, to injury; f. Failing to maintain its parking lots and egress routes in a manner that provided for safe walking conditions for its business invitees, including Plaintiff, SUSAN M. MORALES; and ----- COMPLAINT Morales vs. Morguard Management Company, Inc. and Home Depot U. S. A. , Inc. d/b/a The Home Depot, Inc. Page 5 g. Negligently failing to warn Plaintiff, SUSAN M. MORALES, of a dangerous condition about which Defendant had, or should have had, knowledge greater than that of the Plaintiff. As to Plaintiff, SUSAN M. MORALES’ negligence claim: Plaintiff, SUSAN M. MORALES, suffered bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, inconvenience, loss of the capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, loss of earnings, loss of ability to earn money in the future, and aggravation of a previously existing condition. These losses are either permanent or continuing, and Plaintiff will suffer these losses into the future. As to Plaintiff, JORGE L. MORALES’ consortium claim: As a result of the Defendant, MORGUARD MANAGEMENT COMPANY INC. ’s negligence, Plaintiff, JORGE L. MORALES, has been deprived of the consortium of his wife, Plaintiff, SUSAN M. MORALES, including but not limited to the loss of fellowship, companionship, society, attentions, services, affection, guidance, comfort and household services. These losses are permanent and continuing in nature. WHEREFORE, Plaintiffs, SUSAN M. MORALES and JORGE L. MORALES, Individually and as Husband and Wife, demand judgment for damages against Defendant, MORGUARD MANAGEMENT COMPANY INC. , in excess of $50, 000. 00, demand taxable costs, attorney’s fees, and further demand trial by jury. ----- COMPLAINT Morales vs. Morguard Management Company, Inc. and Home Depot U. S. A. , Inc. d/b/a The Home Depot, Inc. Page 6 **COUNT II - NEGLIGENCE CLAIM AGAINST** **DEFENDANT, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC. ** Plaintiffs, SUSAN M. MORALES and JORGE L. MORALES, Individually and as Husband and Wife, reallege and incorporate each and every allegation contained in paragraphs 1 through 11 as if fully set forth herein, and further alleges: At all times material hereto, Defendant, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC. , owned and operated The Home Depot, Store#6316, and had a duty to maintain its premises in a reasonably safe condition and to warn of any hazards about which it knew or should have known. At all times material hereto, Defendant, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC knew or should have known, by and through the exercise of reasonable care in owning and/or maintaining the parking lot area of The Home Depot, Store #6316, that individuals attempting to access the entrance to the building regularly traversed the parking lot of the premises. Defendant, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC, knew or should have known that that dangerous conditions existed to individuals attempting to access the entrance to the building, including but not limited to, Plaintiff, SUSAN M. MORALES. Defendant, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC, had actual or constructive notice of the dangerous condition in the parking lot and had a duty to protect invitees, like SUSAN MORALES, from the dangerous condition in the parking lot. Defendant, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC, had a duty to warn SUSAN MORALES of concealed dangers which were or should have been known to Defendant, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC, and which were unknown to SUSAN ----- COMPLAINT Morales vs. Morguard Management Company, Inc. and Home Depot U. S. A. , Inc. d/b/a The Home Depot, Inc. Page 7 MORALES. Defendant, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC, had a duty to use reasonable care to maintain its premises in a reasonably safe condition. The danger in the parking lot was not known to SUSAN MORALES and even if it had been hypothetically, Defendant, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC, should have anticipated the harm. Defendant, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC. , individually, and by and through its employees, agents, servants, and/or apparent agents, was negligent and breached its aforementioned duty to Plaintiff, SUSAN M. MORALES. Defendant, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC. , breached its duty to Plaintiff, SUSAN M. MORALES, in, but not limited to, one or more of the following ways: a. Negligently failing to maintain its premises in a reasonably safe condition; b. Negligently failing to warn SUSAN MORALES of the hidden danger; c. Negligently allowing a known dangerous condition to exist upon its premises for an unreasonable period of time; d. Negligently failing to correct a dangerous condition about which it knew or should have known by the exercise of reasonable care; e. Negligently allowing a dangerous condition, which failed to comply with applicable codes and regulations to exist and thereby exposed business invitees, including Plaintiff, SUSAN M. MORALES, to injury; f. Failing to maintain its parking lots and egress routes in a manner that provided for safe walking conditions for its business invitees, including Plaintiff, SUSAN M. MORALES; and g. Negligently failing to warn Plaintiff, SUSAN M. MORALES, of a dangerous condition about which Defendant had, or should have had, knowledge greater than that of the Plaintiff. ----- COMPLAINT Morales vs. Morguard Management Company, Inc. and Home Depot U. S. A. , Inc. d/b/a The Home Depot, Inc. Page 8 As to Plaintiff, SUSAN M. MORALES’ negligence claim: Plaintiff, SUSAN M. MORALES, suffered bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, inconvenience, loss of the capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, loss of earnings, loss of ability to earn money in the future, and aggravation of a previously existing condition. These losses are either permanent or continuing, and Plaintiff will suffer these losses into the future. As to Plaintiff, JORGE L. MORALES’ consortium claim: As a result of the Defendant, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC. ’s negligence, Plaintiff, JORGE L. MORALES, has been deprived of the consortium of his wife, Plaintiff, SUSAN M. MORALES, including but not limited to the loss of fellowship, companionship, society, attentions, services, affection, guidance, comfort and household services. These losses are permanent and continuing in nature. WHEREFORE, Plaintiffs, SUSAN M. MORALES and JORGE L. MORALES, Individually and as Husband and Wife, demand judgment for damages against Defendant, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC. , in excess of $50, 000. 00, demand taxable costs, attorney’s fees, and further demand trial by jury. D this 16[TH] day of March, 2023. ## /S/ KAREN E. TERRY Karen E. Terry Florida Bar No. : 45780 Primary E-Mail: _terryteam@searcylaw. com Searcy Denney Scarola Barnhart & Shipley, P. A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Phone: (561) 686-6300 Work Attorney for Plaintiffs -----

[Assistant] ###### 23-423/jat/kpa IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CIVIL DIVISION SUSAN M. MORALES and JORGE L. MORALES, Individually and as Husband and Wife, Plaintiffs, vs. MORGUARD MANAGEMENT COMPANY INC. , and HOME DEPOT U. S. A. , INC. , d/b/a THE HOME DEPOT, INC. , Defendants. / DEFENDANT, MORGUARD MANAGEMENT COMPANY INC. ’s FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO PLAINTIFF, SUSAN M. MORALES Defendant, MORGUARD MANAGEMENT COMPANY INC. , pursuant to Fla. R. Civ. P. 350, requests Plaintiff, SUSAN M. MORALES, to produce for inspection or copying within thirty (30) days the following documents, showing that Plaintiffs has possession, custody, and/or control of each of the documents and that each of them constitutes evidence without which the Defendant cannot safely proceed to trial, all as is seen more fully from an inspection of the pleadings herein: Conformed copies of all income tax returns, with all attached schedules and forms (such as W-2 forms), filed with the Internal Revenue Service for the five (5) years prior to theof the incident described in the Complaint and all years subsequent to theof the incident, together with a record of earnings toin the current year. ----- ###### 2. All bills or statements for medical treatment, medical devices and/or medicines, the cost of which is claimed to have been incurred by you as a result of the injuries sustained in this case. Any and all records and bills of hospitals, including X-rays, in which Plaintiff has been a patient or received treatment allegedly as a result of the injuries sustained in this case by Plaintiff, or written authorization to obtain such records at the cost of the Defendant. Copies of all medical reports received by Plaintiff, her attorneys, investigators, agents, servants, or employees, from any doctor, physician, or anyone else who has treated Plaintiff for injuries alleged to have been incurred as a result of the incident which is the subject matter of this lawsuit. Copies of all medical reports received by Plaintiff, her attorneys, investigators, agents, servants, or employees from any doctor, physician, or anyone else who has examined the Plaintiff’s physical or mental conditions subsequent to the incident which is the subject matter of this lawsuit, and who may be called as a witness on behalf of Plaintiff at the trial of this case. Complete copies of reports prepared by each physician that examined or treated Plaintiff for injuries alleged to have been incurred as a result of the incident which is the subject matter of this lawsuit. Any and all drawings, graphs, charts, laser color copies of all photographs (actual reprints), digital copies (including all original digital files) of all photographs and videos pertaining to any of the issues described in the Complaint. All statements, recorded or written, obtained by you or your attorneys of the Defendant, taken at the time of or subsequent to the subject incident. Any and all business records, pay receipts, or other memoranda indicating gross income from self-employment, salary, commissions, bonuses, or other earnings in the past five (5) years. Copies of any and all insurance policies providing benefits or coverage to you for any claimed injury or damages arising from the subject incident. Copies of any and all documents reflecting whether or not you received any compensation from your own insurance company or from any other insurance company as a result of the subject incident. Any and all written or recorded statements taken from parties or witnesses concerning any issue in this lawsuit. ----- ###### 13. Any and all color photographs (actual reprints or original digital files), graphs, charts, and other documentary evidence in the possession, custody, and control of the Plaintiff, her attorneys, investigators, agents, servants, or employees showing the injury or damage sustained by Plaintiff, which Plaintiff intends to place into evidence or use at trial. Any and all color photographs (actual reprints or original digital files), graphs, charts, and other documentary evidence in the possession, custody, and control of the Plaintiff, her attorneys, investigators, agents, servants, or employees showing the scene of the subject incident or any property damage that allegedly resulted therefrom. All color photographs (actual reprints or original digital files) which depict conditions about the incident scene or other condition present which have changed since the photographs were taken. Copies of any and all documents evidencing the value of all benefits received by Plaintiff on her behalf, by or pursuant to the following sources: (a) United States Social Security Act. (b) Any Federal, State, or Local Income Disability, or any other public program providing medical expenses, disability payments, or other similar benefits. (c) Any health, sickness, or income disability insurance; automobile accident insurance that provides for income disability coverage; and any other similar insurance benefits except life insurance available to Plaintiff, whether purchased by her or provided by others. (d) Any contract or agreement of any group, organization, partnership, or corporation to provide, pay for, or reimburse the costs of hospital, medical, or other health care services. (e) Any contractual or voluntary wage continuation plan provided by Plaintiff’s employers or any other system intended to provide wages during a period of disability. All statements which Plaintiff intends to place into evidence or use at trial. All statements pertaining to issues in this litigation, the substantial equivalent of which cannot be obtained by Defendant without undue hardship. Copies of the front and back of any and all insurance cards for insurance providing medical insurance to the Plaintiff for the past ten (10) years to present. ----- ###### 20. Copies of any and all notices sent to any and all collateral sources notifying those collateral sources of Plaintiff’s intention to claim damages from Defendant and any and all statements received by Plaintiff from each and every such collateral source of that collateral source’s assertion of its right of subrogation or reimbursement pursuant to Fla. Stat. §768. 76. Any and all correspondence, text messages, emails, SMS messages, social media direct messages, etc. sent and/or received by Plaintiff concerning any of the issues in this lawsuit. Copies of any cellular telephone records and bills documenting the Plaintiff’s usage of any cellular telephone on theof the incident described in the Complaint. An original signed, fully executed attached authorization requesting income tax records (IRS 4506 Form & IRS 8821 Form). An original signed, fully executed attached Social Security Administration Consent for Release of Information (SSA-3288 Form). An original signed, fully executed attached Request for Social Security Earnings Information (SSA-7050-F4 Form). An original signed, fully executed attached Medicare authorization form. An original signed, fully executed attached Medicaid authorization form. All statutes, ordinances, standards, or regulations that Plaintiff contends the Defendant violated or that Plaintiff intends to use at trial. (Certificate of Service on following page) ----- ###### CERTIFICATE OF SERVICE I hereby certify that the foregoing document has been furnished to: Boris L. Zhadanovskiy, Esq. , 2139 Palm Beach Lakes Blvd. , West Palm Beach, FL 33409, zhadanovskiyteam@searcylaw. com; [Counsel] for Plaintiff, by delivery [via the][ Court’s] E-Filing Portal on this 19th day of May, 2023. ROBERTS, REYNOLDS, [BEDARD][ &] TUZZIO, [PLLC] 470 Columbia Drive, Bldg. C101 West Palm Beach, FL 33409 Phone: 561/688-6560 Fax: 561/688-2343 Email: shealy@rrbpa. com; lleiva@rrbpa. com, ituchman@rrbpa. com Service Email: service sAH@rrbpa. com Attorneysfor Defendant, Morguard Management /s/ [Jaimie][ A. ][ Tuchman] for SHELLI A. HEALY Florida Bar No. : 180556 Page [5][ of][ 5] ----- Form 4506 Request [for] Copy [of][ Tax][ Return] (Novmeber 2021) - Do not sign this form unless all applicable lines have been completed. OMB No. 1545-0429 - Request may be rejected if the form is incomplete or illegible. Department [of][ the] Treasury Internal Revenue Service - For more irfformation about Form 4506, visit www. irs. gov/form4506. Tip: [Get][ faster][ service:][ Online][ at] www. irs. gov, Get Your Tax Record (Get Transcript) or by calling 1-800-908-9946 for specialized assistance. We have teams available to assist. Note: Taxpayers may register to use Get Transcript to view, print, or download the following transcript types: Tax Return Transcript (shows most line items including Adjusted Gross Income (AGI) from your original Form 1040-series tax return as filed, along with any [forms][ and] schedules), [Tax][ Account] Transcript (shows basic data such as return type, marital status, AGI, taxable income and all payment types), Record of Account Transcript (combines the tax return and tax account transcripts into one complete transcript), Wage and Income Transcript (shows [data][ from][ information][ returns] we receive such as Forms W-2, 1099, 1098 and Form 5498), and Verification of Non-filing Letter (provides proof [that][ the][ IRS][ has][ no][ record][ of][ a][ filed][ Form] 1040-series tax return for the year you request). 1a Name shown on tax return. If a joint return, enter the name shown first. 1b First social security number on tax return, individual taxpayer identification number, or employer [identification][ number] (see instructions) SUSAN M. 2a If a jointMORALES_ return, enter spouse’s name shown on tax return. 2b Second social security number or individual taxpayer [identification][ number][ if] joint tax return 3 Current name, address (including apt. , room, or suite no. ), city, state, and ZIP code (see instructions) 4 Previous address shown on the last return filed if different from line 3 (see instructions) 5 If the tax return is to be mailed to a third party (such as a mortgage company), enter the third party’s name, address, and telephone number. ROBERTS, REYNOLDS, BEDARD & TUZZIO, PLLC, 470 COLUMBIA DRIVE, SUITE C-101, WEST PALM BEACH, FL 33409 PHONE * Caution: If561-688-6560___ the tax return is being sent to the third party, ensure that lines 5 through 7 are completed before signing, (see instructions). 6 Tax return requested. Form 1040, 1120, 941, etc. and all attachments as originally submitted to the IRS, including Form(s) W-2, schedules, [or] amended returns. Copies of Forms 1040, 1040A, and 1040EZ are generally available for 7 years from filing before they are destroyed by [law. ][ Other][ returns] may be available for a longer period of time. Enter only one return number. If you need more than one type [of] return, you [must] complete another Form 4506. - 1040 Note: If the copies must be certified for court or administrative proceedings, check 7 Year or period requested. Enter the endingof the tax year or period using thehere. [J mm/dd/yyyy format (see instructions). 12 / 31 / 2015 12 / 31 / 2016 12 / 31 / 2017 12 / 31 / 2018 12 / 31 / 2019 12 / 31 / 2020 12 / 31 / 2021 12 / 31 / 2022 8 Fee. There is a $43 fee for each return requested. Full payment must be included with your request or it will be rejected. Make your check or money order payable to “United States Treasury. ” Enter your SSN, ITIN, or EIN and “Form 4506 request” on your check or money order. a Cost for each $ 43. 00 b Number of returns requested on line 8 c Total cost. Multiplyreturn. line 8a by line $ 344. 00 we i, [we] refund should go to the third party listed on line 5, check here. . Caution: Do not sign this form unless all applicable lines have been completed. [of] taxpayers). [I] declare that[ I] am either the taxpayer whose name is shown on line 1a or 2a, or a person authorized to obtain the tax return requested. [If][ the] request applies [to][ a] joint return, 8b. at least one spouse must sign. If signed by a corporate officer, 1 percent or more shareholder, partner, managing member, guardian, [tax][ matters] partner, executor, receiver, administrator, trustee, or party other than the taxpayer, I certify that I have the authority to execute Form 4506 on behalf of the taxpayer. Note:7. This form must be received by IRS within 120 days of the. ###### □ Signatory [attests][ that] he/she has read the attestation clause and upon so reading declares that he/she has the authority to sign the Form 4506. See instructions. Phone number of taxpayer on line 1a or 2a k ###### r(see instructions)Sign Here T►-_L. Print/1 ype name Title (if line 1 a above is a corporation, partnership, estate, or trust) I r Spouse’sPrint/Type [name] For and #### k_ ----- Form 4506 (Rev. 11-2021) Page [2] Sectionunless otherwise references noted. are to the Internal Revenue Code Chart for all other returns beIndividuals. furnished to Copies either spouse. of jointly Only filed one taxreturns may is required. Sign [Form][ 4506] exactly [as] your [name] ###### Future Developments ForForm returns 1040 series, not in Mail to: appearedname, also[on]sign[ the] youroriginal current[return. ] name. [ If] you changed your For the latest information about Form 4506 and its if the address on Corporations. Generally, [Form][ 4506] can be instructions, go to www. irs. gov/form4506. the return was in: signed by: (1) [an][ officer] having legal authority [to][ bind] the corporation, (2) any person designated by the ###### General Instructions Connecticut, Delaware, board of directors or other governing body, or (3) Caution: Do not sign this form unless all applicable District of Columbia, any [officer][ or] employee [on][ written] request by any completed. lines, including [lines][ 5] through 7, have been Georgia, Kentucky, Illinois, Maine, Indiana, otherprincipal officer. [officer] A bona[ and][ attested] fide shareholder[ to] by [the] ofsecretary record [or] Maryland, owning [1] percent [or][ more][ of][ the] outstanding [stock] Designated Recipient [Notification. ][ Internal] Massachusetts, Internal Revenue Service of the corporation may submit a Form 4506 but must Revenue Code, Section 6103(c), limits disclosure Michigan, [New] RAIVSTeam provide [documentation][ to] support [the] requester's and use of return information received pursuant to Hampshire, [New] Jersey, Stop [6705][ S-2] right [to][ receive][ the][ information. ] thesubjectotherexpress taxpayer’s use, permission[to] orpenalties redisclosure consent[or][for] andrequest. any without holds[unauthorized] the the recipient taxpayer'saccess, Carolina, NewPennsylvania, Island, York, South Ohio, NorthCarolina, [Rhode] 64999Kansas City, MO signedrequestedpartnershipPartnerships. by any[on] during[ line] person Generally, [ 7. ] any[who] part[ was][of][Form][ the][ a][ member][ 4506][ tax] period[ can][ of][ be][ the] Taxpayer [Notification. ][ Internal] Revenue Code, Tennessee, Vermont, Section 6103(c), limits disclosure and use of return Virginia, [West] Virginia, All others. See section 6103(e) if the taxpayer has Information provided pursuant to your consent and Wisconsin died, [Is] Insolvent, [is][ a][ dissolved] corporation, or[ if] a holdsprivate the right recipient[of] action, subject[for] any to penalties, [unauthorized] broughtaccess, by Alabama, Alaska, trustee, administrator guardian, Is acting executor, for the receiver, taxpayer. or other use, or redisclosure without your express Arizona, Arkansas, Note: If you are Heir at law, Next of kin, or permission [or] request. California, Colorado, Beneficiary you [must][ be][ able][ to][ establish][ a][ material] Purpose [of][ form. ][ Use][ Form][ 4506] to request a copy Florida, Hawaii, Idaho, interest In the estate or trust. of your tax return. You can also designate (on line 5) Iowa, Kansas, Louisiana, Documentation. For entities other than individuals, a third party to receive the tax return. Minnesota, Mississippi, you [must][ attach][ the][ authorization][ document. ][ For] calendarHow long days will for it take? us to It process may take your up request. to 75 Missouri, Nebraska, Mexico, [North] Montana, Nevada, Dakota, [New] Internal Revenue Service theexample, officer letters authorizing[this] testamentary[ could] an[ be] employee[ the] authorizing[ letter] of[ from] the an[ the] corporation individualprincipal to or Where to file. Attach payment and mail Form 4506 Oklahoma, Oregon, RAIVSTeam act for an estate. to the address below for the state you lived in, or the South Dakota, Texas, P. O. Box 9941 filed. state There your business are two address was in, when charts: that one return for was Wyoming, Utah, Washington, [a] foreign Ogden, Mail Stop[UT] 6734[ 84409]can sign Form by [a] 4506representative. for a taxpayer[A] onlyrepresentative if this individual returns (Form 1040 series) and one for all country, [American] authority [has][ been] specifically delegated [to][ the] other returns. Samoa, Puerto Rico, representative [on][ Form] 2848, [line][ 5a. ][ Form][ 2848] If you are requesting a return for more than one Guam, the showing4506. [the] delegation [must][ be][ attached][ to][ Form] year [or] period [and][ the][ chart][ below][ shows][ two] Commonwealth of the differentaddress of addresses, your most send recent your return. request based on the NorthernIslands, Islands, [the][or] Mariana[ A. P. O. ][ U. S. ] Virginor PrivacyNotice. We[Act] ask[ and] forPaperwork the Information[Reduction] on thisAct form to ###### Chart for individual returns F. P. O. address establish your right to gain access to the requested return(s) [under][ the][ Internal][ Revenue][ Code. ][ We][ need] (Form [1040] series) this information to properly identify the return(s) and If you filed an Specific [Instructions] taxrespond return, [to] sectionsyour request. 6103 and[If] you 6109 request require[a] copy you to[of][ a] individual return Mail to: Line 1b. Enter the social security number (SSN) or provide [this] information, including your [SSN] or EIN, and lived in: individual taxpayer identification number (ITIN) for to process your request. If you do not provide this the individual listed on line 1 a, or enter the employer information, we may not be able to process your Florida, Louisiana, identification number (EIN) for the business listed on request. Providing [false][ or][ fraudulent][ information] Mississippi, [Texas, ][ a] line 1 a. For example, if you are requesting Form may subject you [to] penalties. foreign country, [American] Internal Revenue Service 1040 that includes Schedule C (Form 1040), enter Routine uses of this information include giving it to Samoa, Puerto Rico, RAIVSTeam your [SSN. ] the Department of Justice for civil and criminal theA. P. O. Guam, CommonwealthNorthern U. S. or the Virgin Mariana F. P. O. Islands, of address Islands, the or Austin, Stop [6716AUSC][TX][ 73301] filedLinebox, Line if please 4. 3. different Enter Enter[include] the your from address current[ it] the on address this shown address. line entered on 3. If the you last on use return line a P. O. 3. anddiscloselitigation, in administering U. S. this commonwealths[and] informationcities, their states, tax to laws. and other[the] possessions We[ District] countries may[ of] alsoColumbia, under for use a Note. If the addresses on lines 3 and 4 are different taxfederal treaty, nontax to federal criminal and laws, state or agencies to federal to law enforce Alabama, Arkansas, andIRS, you[file] haveForm not 8822, changed Change your of Address, address or with Form the terrorism. enforcement and intelligence agencies to combat Delaware, Georgia, 8822-B, Change [of][ Address][ or] Responsible Party [-] Illinois, Indiana, Iowa, Business, [with][ Form] 4506. You are not required to provide the information Massachusetts, Kentucky, Maine, Internal Revenue Service Line 7. Enter the endof the tax year or period requestedReduction Act[on][ a] unless[ form][ that] the[ is] formsubject displays[to][ the] a validPaperwork OMB Minnesota, Missouri, RAIVS Team requested [in] mm/dd/yyyy [format. ][ This] may be[ a] control number. Books or records relating to a form New Hampshire, New Stop [6705][ S-2] calendar year, fiscal year or quarter. Enter each or its instructions must be retained as long as their Jersey, [New] York, [North] Kansas City, MO 64999 quarter requested [for] quarterly [returns. ] Example: contents may become material in the administration Carolina, Oklahoma, Enter 12/31/2018 for a calendar year 2018 Form of any Internal Revenue law. Generally, tax returns Tennessee, South Carolina, Vermont, 9411040 return. return, or 03/31/2017 for a first quarter Form andby [section] return[ 6103. ] information are confidential, as required Virginia, Alaska, Arizona, [Wisconsin]dIRS must by the receive[and] taxpayer. ] Form[ Form] listed 4506[ 4506] on within linemust 120 1 a be or days 2a. signed The of the and willestimatedThe vary time depending average needed time to on complete individual is: Learning and circumstances. file about Form the 4506 law The California, Connecticut, Colorado, [District][ of]Ensure signed that all by applicable the taxpayer lines, or it including will be rejected. lines 5 orand the Copying, form, 10 assembling, min. ; Preparing and sending the form, the 16 form min. ; Columbia, Hawaii, Idaho, through 7, [are] completed [before] signing. to the IRS, 20 min. Kansas, Michigan, Nebraska, Mexico, Maryland, [North] Montana, Nevada, Dakota, [New] RAIVSP. O. MailInternal Stop Box Team Revenue 9941 6734 ServicehaveYou must the authority check[area][ to] theacknowledge to box sign in and request the you theseFormIf you 4506 time have estimates simpler, comments we or would suggestions concerning be happy for the to making accuracy hear from of Ohio, Oregon, Ogden, [UT][ 84409] CAUTION the information. The form will not be you. [You][ can][ write][ to:] Island, Pennsylvania, South Dakota, [Rhode] processedunchecked. [and] returned[ to] you [if] the box is TaxInternal Forms Revenue and Publications Service Division Utah, Washington, West 1111 Constitution Ave. NW, IR-6526 Virginia, Wyoming Washington, [DC][ 20224. ] ----- Form Tax Information Authorization ForOMB IRS No. Use 1545-1165 Only ###### 8821 ► Go to for instructions and the latest information. Received by: (Rev. DepartmentInternal January Revenue[of] 2021)[ the] ServiceTreasury - Don’t►or signDon’t to authorize this use form Form someone unless 8821 to all to request applicable represent copies you. lines of See have your instructions. tax been returns completed. Telephone_Name_Function_1 Taxpayer [information. ] Taxpayer [must] sign [and][ this][ form][ on] line Taxpayer [name][ and][ address] Taxpayer [identification] number(s) ###### 6. _ Daytime telephone [number][ Plan][ number] (if applicable) SUSAN M. MORALES 2 Designee(s). If you wish to name more than two designees, attach a list to this form. Check here if a list of additional ###### designees [is][ attached][ ►] □ Name and. address CAF No. PTIN ROBERTS, REYNOLDS, BEDARD, [&] TUZZIO, PLLC 470 COLUMBIA DR, BLDG C-101 Telephone [No. ] 561-688-6560 WEST PALM BEACH, FL 33409 Fax No. 561-688-2343 Check if to be sent copies of notices and communications 0 Check if new: Address □ Telephone [No. ] - Fax No. □ Name and address CAF No. TelephonePTIN____[No. ] Fax No. Check if to be sent copies of notices and communications 0 Check if new: Address □ Telephone [No. ] - Fax No. □ 3 Tax information. Each designee is authorized to inspect and/or receive confidential tax information for the type of tax, forms, periods, [and] specific [matters] you [list][ below. ][ See][ the][ line][ 3][ instructions. ] ###### 0 By checking here, I authorize access to my IRS records via an Intermediate Service Provider. (a) (b) (c) (d) Type [of][ Tax][ Information] (Income, Tax Form Number Year(s) [or] Period(s) Specific [Tax][ Matters] Employment, Payroll, Excise, Estate, Gift, (1040, 941, 720, etc. ) Civil Penalty, Sec. 4980H Payments, etc. ) Income 1040 2015-2022 4 Specific use not recorded on the Centralized Authorization File (CAF). If the tax information authorization is for a specific [use][ not][ recorded][ on] CAF, check[ this] box. See the instructions. If you check this box, skip line - ###### 5. ► 5 of prior tax information authorizations. If the line 4 box is checked, skip this line. If the line 4 box isn’t checked, the IRS will automatically revoke all prior tax information authorizations on file unless you check the line 5 box and attach a copy of the tax information authorization® that you want to 0 To revoke a prior tax information authorization(s) without submitting a new authorization, r e t a i see the line 5 Instructions. 6 Taxpayer. If signed by a corporate officer, partner, guardian, partnership representative (or designated individual, [if] applicable), executor, receiver, administrator, trustee, or individual other than the taxpayer, I certify that I have the legal authority to execute this form with respect to the tax matters and tax periods shown on line 3 above. - IF NOT COMPLETED, SIGNED, ANDD, THIS TAX INFORMATION AUTHORIZATION WILL BE RETURNED. - DON’T SIGN THIS FORM IF IT IS BLANK OR INCOMPLETE. Print Name Title (If applicable) For Privacy Act and Paperwork Reduction Act Notice, see the instructions. Cat. No. 11596P Form 8821 (Rev. 01-2021) ----- Discontinue Prior Editions Page [1][ of][ 3] Social Security Administration OMB No. 0960-0566 ###### Consent for Release of Information Instructions for Using this Form Complete [this][ form] only [if] you [want][ us][ to] give [information][ or][ records][ about] you, [a] minor, [or][ a] legally incompetent adult, [to][ an] individual or group (for example, a doctor or an insurance company). You may complete this form to release only the minor's non¬ medical records, if you are the natural or adoptive parent or legal guardian, acting on behalf of a minor child. We require proof of relationship, [if] you [are][ not][ the] subject [of][ the][ record. ][ We] may charge [a][ fee][ for] providing [the] information, [if] you [are] requesting [the] information for a purpose unrelated to the administration of a program under the Social Security Act. If you are requesting information, [such][ as][ a][ Social] Security [Statement][ or][ benefit][ verification] letter, you [can][ also][ access][ this][ information] by creating [an] ###### account at https://www. ssa. gov/myaccount/. NOTE: Do NOT use this form to request: - The release of a minor child's medical records. Instead, visit your local Social Security office or call our toll-free ###### number, [1-800-772-1213] (TTY-1-800-325-0778), [or] - Detailed information about your earnings or employment history. Instead, complete and mail form SSA-7050-F4. You can obtain form SSA-7050-F4 from your local Social Security office or online at ###### www. ssa. gov/online/ssa-7050. Ddf. How to Complete this Form We will not honor this form unless all required fields are completed. An asterisk (*) indicates a required field. Also, we will not honor blanket requests for "any and all records" or the "entire file. " You must specify the information you are requesting and you must sign andthis form. - Fill in the name, of birth, and social security number of the subject of the record. - Fill in the name and address of the person or organization of where you want us to send the requested information. - Specify [the][ reason] you [want][ us][ to][ release][ the][ information] (e. g. , litigation, investigation, determining eligibility [for] benefits). If you are the natural or adoptive parent or legal guardian, acting on behalf of a minor child or legally incompetent adult, you [must][ state][ how][ the][ release][ of][ information][ is][ in][ the][ best][ interest][ of][ the][ minor][ child][ or] legally incompetent [adult. ] - Check the box next to the type(s) of information you want us to release including specificranges, where applicable. NOTE: Unless otherwise specified, the consent form is valid for one-time use only. Also, it is valid for one year from theof, [unless] you [are] requesting [medical][ records. ][ A][ consent][ form][ that][ includes][ a] request [for][ medical][ records][ is][ valid][ for][ 90] ###### days [from][ the][ of]. Send or bring the completed form to the subject of the record's local servicing office. To locate the appropriate servicing office, visit https://secure. ssa. gov/ICON/main. jsp. and input the subject of the record's ZIP code. ----- ( ) ###### Consent for Release of You must complete all requiredUF_PageInformation_. fields. We will not honor your request unless all required fields are completed. (*Signifies a ###### required [field. ][ **These][ are][ not] mandatory [fields][ for] the consent form[ to] be acceptable. Please complete these fields in case we need to contact you about the consent form). TO: Social Security Administration ###### Consent for Release of You must complete all requiredInformation_. fields. We will not honor your request unless all required fields are completed. (*Signifies a ###### required [field. ][ **These][ are][ not] mandatory [fields][ for] the consent form[ to] be acceptable. Please complete these fields in case we need to contact you about the consent form). TO: Social Security Administration SUSAN M. MORALES ###### Tull Name *of Birth Tull Social Security Number (MM/DD/YYYY) I authorize the Social Security Administration to release information or records about me to: ‘NAME OF PERSON OR ORGANIZATION: ‘ADDRESS OF PERSON OR ORGANIZATION: ###### “ PHONE NUMBER OF PERSON OR ORGANIZATION: Roberts, Reynolds, Bedard, & Tuzzio, PLLC 470 Columbia Drive, Bldg C-101 West Palm Beach, FL 33409 *1 want this information released because: We may charge a fee to release information for non-program purposes. ###### Litigation ‘Please release the following information selected from the list below: Check at least one box. If requesting medical records, do not check both boxes 7 and 8. We will not disclose records unless you include specificranges where applicable. 0 Verification of Social Security Number 0 Current monthly Social Security benefit amount 0 Current monthly Supplemental Security Income payment amount 0 Social Security benefit amounts from2011 to[2023] 0 Supplemental Security Income payment amounts from2011 to[2023] 0 Medicare entitlement from2011 to[2023] [3 Medical records from2011' to2023 |3 Complete medical records 9- S Other Social Security record(s) (We will not honor a request for "any and all records" or "the entire file. " You must specify which records you are seeking. For example, award/denial notices, benefit applications, appeals) ###### All reports, medical records, billing records, liens, applications, evaluations, questionnaires, award notices, denial notices, appeals I am the individual, to whom the requested information or record applies, or the parent or legal guardian of a minor, or ###### the legal guardian of a legally incompetent adult. I declare under penalty of perjury (28 CFR § 1746) that I have examined all the information on this form and it is true and correct to the best of my knowledge. I understand that anyone who ###### knowingly [or] willfully [seeks][ or][ obtains] access to records about another person under false pretenses is punishable by a fine of up to $5, 000. ‘: ‘: “Address: “Daytime [Phone:] “Relationship (if [not][ the] subject [of][ the] record): “Daytime [Phone:] Witnesses must sign this form ONLY if the aboveis by mark (X). If signed by mark (X), two witnesses to the signing who know the signee must sign below and provide their full addresses. Please print the signee's name next to the mark (X) on the ######[line][ above. ] ~~[of][ witness] 2. [of][ witness] ###### Address (Number and street, City, State, and ZIP Code) Address (Number and street, City, State, and ZIP Code) ----- ###### Privacy [Act][ Statement] Collection and Use of Personal Information The Privacy Act (5 U. S. C. 552a) and Section 205(a) of the Social Security Act, as amended, allow us to collect this information. Furnishing [us][ this][ information][ is] voluntary. However, failing [to] provide [all][ or] part [of][ the][ information] may prevent [us][ from] honoring ###### the request to release information or records about you. We will use the information you provide to respond to the request for Social Security Administration (SSA) records. We may share the information for the following purposes, called routine uses: - To contractors and other Federal agencies, as necessary, for the purpose of assisting SSA in the efficient administration of its programs. In addition, we may share this information in accordance with the Privacy Act and other Federal laws. For example, where authorized, [we] may [use][ and][ disclose][ this][ information][ in] computer matching programs, [in] which our records are compared with ###### other records to establish or verify a person's eligibility for Federal benefit programs and for repayment of incorrect or delinquent debts under these programs. A list of additional routine uses is available in our Privacy Act System of Records Notices (SORN) 60-0089, entitled Claims Folders System, as published in the Federal Register (FR) on April 1, 2003, at 68 FR 15784; 60-0320, entitled Electronic Disability [Claim] File, [as] published [in][ the][ FR][ on][ December] 22, 2003, [at][ 68][ FR] 71210; [and] 60-0340, [entitled][ FOIA][ and] Privacy [Act] Record Request and Appeal System, as published in the FR on July 13, 2016, at 81 FR 45352. Additional information, and a full listing [of][ all][ our] SORNs, [is][ available][ on][ our][ website][ at] ###### Paperwork [Reduction][ Act][ Statement] This information collection meets the requirements of 44 U. S. C. § 3507, as amended by section 2 of the Paperwork Reduction Act of 1995. You do not need to answer these questions unless we display a valid Office of Management and Budget control number. We estimate that it will take about 5 minutes to read the instructions, gather the facts, and answer the questions. You may [send][ comments][ on][ our][ time][ estimate][ above][ to:] SSA, [6401] Security Blvd. , Baltimore, [MD][ 21235-6401. ][ Send] only ###### comments relating to our time estimate to this address, not the completed form. ----- Discontinue Prior Editions Page [1][ of][ 4] Social Security Administration OMB No. 0960-0525 ###### REQUEST FOR SOCIAL SECURITY EARNING INFORMATION "Use This Form If You Need DO NOT USE THIS FORM TO REQUEST Certified/Non-Certified Detailed Earnings Information YEARLY EARNINGS TOTALS Includes periods of employment or self-employment ###### and the names and addresses of employers. Yearly earnings [totals][ are][ free][ to][ the] public if you do not require certification. Certified Yearly Totals of Earnings Includes total earnings for each year but does not To obtain FREE yearly totals of earnings, include the names and addresses of employers. visit our website at www. ssa. gov/myaccount. ###### Privacy [Act][ Statement] Collection and Use of Personal Information Section 205 of the Social Security Act, as amended, allows us to collect this information. In addition, the Budget and Accounting [Act][ of][ 1950][ and][ Debt][ Collection][ Act][ of] 1982 authorize us to collect credit card information, if you choose to pay [for][ the] earnings [information] you [have] requested with a credit card. Furnishing us this information is voluntary. However, failing [to] provide [all] or part of the information may prevent us from processing your request. We will use the information to identify your records, process your request, and send the earnings information you request. We may also share the information for the following purposes, called routine uses: To the Internal Revenue Service (IRS) for auditing SSA's compliance with the safeguard provisions of the Internal ###### Revenue Code of 1986, as amended. To contractors and other Federal agencies, as necessary, for the purpose of, assisting the Social Security Administration (SSA) in the efficient administration of its programs. To banks enrolled in the Treasury credit card network to collect a payment or debt when the individual has given his/her credit card number for this purpose. In addition, we may share this information in accordance with the Privacy Act and other Federal laws. For example, ###### where authorized, we may use and disclose this information in computer matching programs, in which our records are compared [with][ other][ records][ to][ establish][ or] verify a person’s eligibility for Federal benefit programs and for repayment of incorrect or delinquent debts under these programs. A list of additional routine uses is available in our Privacy Act System of Records Notices (SORNs) 60-0059, entitled Earnings Recording [and] Self-Employment Income System, 60-0090, entitled Master Beneficiary Record, 60-0224, entitled SSA-lnitiated Personal Earnings and Benefit Estimate Statement, and 60-0231, entitled Financial Transactions of SSA Accounting and Finance Offices. Additional information and a full listing of all our SORNs are available on our ###### website at www. socialsecurity. gov/foia/bluebook. Paperwork [Reduction][ Act] Statement -This information collection meets the requirements of 44 U. S. C. § 3507, as amended by section 2 of the Paperwork Reduction Act of 1995. You do not need to answer these questions unless we display [a][ valid][ Office][ of] Management [and] Budget control number. We estimate that it will take about 11 minutes to read ###### the instructions, gather the facts, and answer the questions. Send only comments relating to our time estimate above to: SSA, 6401 Security Blvd, Baltimore, MD 21235-6401. ----- ###### REQUEST FOR SOCIAL SECURITY EARNING INFORMATION Provide your name as it appears on your most recent Social Security card or the name of the individual whose ###### earnings you [are] requesting. First Name: s U S A N Middle Initial: M Last Name: M O R A L E S Social Security Number (SSN) One SSN per requestof Birth:of Death: Other Name(s) Used Maiden Name What kind of earnings information do you need? (Choose ONE of the following types of earnings or SSA must return this request. ) [X] [Itemized][ Statement][ of] Earnings [$100. 00] Year(s) Requested: 2 0 1 1 to 2 0 2 3 (Includes [the][ names][ and][ addresses][ of] employers) If you check this box, tell us why you need this Year(s) Requested: to information below. ###### Litigation Check this box if you want the earnings □ [information][ CERTIFIED][ for][ an][ additional] $44. 00 fee. ###### Q [Certified] Yearly [Totals][ of] Earnings [$44. 00] Year(s) Requested: (Does [not][ include][ the][ names][ and][ addresses][ of] employers)Yearly earnings [totals][ are][ FREE][ to][ the] public [if] you do not require certification. To obtain FREE yearly totals of Year(s) Requested: earnings, [visit][ our][ website][ at] www. ssa. gov/myaccount. If you would like this information sent to someone else, please fill in the information below. I authorize the Social Security Administration to release the earnings information to: Name Roberts, Reynolds, Bedard, & Tuzzio, PLLC ###### Address 470 Columbia Drive, Bldg C-101 State FL City West Palm Beach ZIP Code [33409] I am the individual to whom the record pertains (or a person authorized to sign on behalf of that individual). I declare under penalty of perjury that I have examined all the information on this form, and on any accompanying ###### statements or forms, and it is true and correct to the best of my knowledge. SSA must receive this form within 120 days ######[AND][ Printed][ Name][ of][ Individual][ or] Legal [Guardian] from thesignedRelationship (if applicable, you [must][ attach] proof) Daytime [Phone:] ###### Address State City ZIP Code ###### Witnesses must sign this form ONLY if the aboveis by marked (X). If signed by mark (X), two witnesses to the signing [who][ know][ the] signee [must] sign [below][ and] provide [their][ full][ addresses. ][ Please] print [the] signee's [name][ next][ to][ the] mark (X) on theline above. of Witness 2. of Witness ###### Address (Number and Street, City, State and ZIP Code) Address (Number and Street, City, State and ZIP Code) ----- Form SSA-7050-F4 (11-2022) Page [3][ of][ 4] ###### REQUEST FOR SOCIAL SECURITY EARNING INFORMATION INFORMATION ABOUT YOUR REQUEST You may use this form to request earnings information for one ONE Social Security Number (SSN) How do I get my earnings statement? Is There A Fee For Earnings Information? You must complete the attached form. Tell us the Yes. We charge a $100. 00 fee for providing information specific years [of] earnings you want, type [of] earnings for purposes unrelated to the administration of our record, [and] provide your mailing address. The itemized programs. ###### statement of earnings will be mailed to ONE address, therefore, [if] you [want][ the] statement sent to someone 1. Certified or Non-Certified Itemized Statement of ###### other than yourself, provide their address in section 3. Earnings Mail the completed form to SSA within 120 days of In most instances, individuals request Itemized. [If] you sign [with][ an] "X", your [mark][ must][ be] Statements of Earnings for purposes unrelated to ###### witnessed by two impartial persons who must provide our programs such as a private pension plan or their name and address in the spaces provided. personal injury [suit. ][ Bulk][ submitters] may [email] ###### Select ONE type of earnings statement and include the OCO. Pension. Fund@ssa. gov [for][ an][ alternate] appropriate [fee. ] method of obtaining itemized earnings information. Certified/Non-Certified Itemized Statement of We will certify the itemized earnings information for ###### Earnings an additional $44. 00 fee. Certification is usually not This statement includes years of self-employment or necessary [unless] you [are] specifically requested [to] employment [and][ the][ names][ and][ addresses][ of] obtain a certified earnings record. employers. Sometimes, [there][ is][ no] charge for itemized earnings Certified Yearly Totals of Earnings information. If you have reason to believe your This statement includes the total earnings for each earnings [are][ not][ correct] (for example, you [have] ###### year requested [but][ does][ not][ include][ the][ names][ and] previously [received] earnings [information][ from][ us] addresses of employers. and it does not agree with your records), we will supply you [with][ more][ detail][ for][ the] year(s) [in] If you require one of each type of earnings statement, question. [Be][ sure][ to][ show][ the] year(s) involved[ on] you [must] complete [two] separate [forms. ][ Mail] each form the request form and explain why you need the to SSA with one form of payment attached to each information. If you do not tell us why you need the request. information, [we][ will] charge [a] fee. How do I get someonestatement? else's earnings 2. Certified Yearly Totals of Earnings We charge $44. 00 to certify yearly totals of You may get someone else's earnings information if you earnings. However, [if] you [do][ not][ want][ or][ need] ###### meet one of the following criteria, attach the necessary certification, you may [obtain] yearly totals FREE of documents to show your entitlement to the earnings charge [at] www. ssa. gov/myaccount. [Certification][ is] information and include the appropriate fee. usually [not] necessary [unless] you [are][ advised] specifically [to][ obtain][ a][ certified] earnings [record. ] Someone Else's Earnings The natural or adoptive parent or legal guardian of a Method of Payment minor child, or the legal guardian of a legally This Fee Is Not Refundable. DO NOT SEND CASH. ###### declared incompetent individual, may obtain earnings [information][ if] acting [in][ the][ best] interest of You may pay by credit card, check or money order. the minor child or incompetent individual. You must • Credit Card Instructions include proof of your relationship to the individual Complete [the][ credit][ card][ section][ on] page [4][ and] with your request. The proof may include a birth return it with your request form. certificate, [court] order, adoption decree, or other legally binding [document. ] - Check or Money Order Instructions Enclose one check or money order per request A Deceased Person's Earnings form payable to the Social Security You can request earnings information from the Administration and write the Social Security record of a deceased person if you are: number in the memo. - The legal representative of the estate; - A survivor (that is, the spouse, parent, child, How long will it take SSA to process my request? divorced spouse of divorced parent); or - An individual with a material interest (e. g. , Please allow SSA 120 days to process this request. financial) [who][ is][ an][ heir][ at] law, [next][ of] kin, After 120 days, you may contact 1-800-772-1213 to beneficiary [under][ the][ will][ or][ donee][ of] property [of] leave an inquiry regarding your request. the decedent. You must include proof of death and proof of your relationship [to][ the][ deceased][ with] your request. ----- Form SSA-7050-F4 (11 -2022) Page [4][ of][ 4] ###### REQUEST FOR SOCIAL SECURITY EARNING INFORMATION - Where do I send my complete request? Mail the completed form, supporting documentation, If using private contractor such as FedEx mail form, and applicable fee to: supporting documentation, [and] application [fee][ to:] ###### Social Security Administration Social Security Administration P. O. Box 33011 P. O. Box 33011 Baltimore, Maryland [21290-33011] Baltimore, Maryland [21290-33011] - How much do I have to pay for an Itemized Statement of Earnings? ###### Non-Certified Itemized Statement of Earnings Certified Itemized Statement of Earnings $100. 00 $144. 00 - How much do I have to pay for Certified Yearly Totals of Earnings? Certified yearly totals of earnings cost $44. 00. You may obtain non-certified yearly totals FREE of charge at www. ssa. gov/myaccount. [Certification][ is] usually [not] necessary [unless] you [are] specifically asked to obtain a certified earnings record. YOU CAN MAKE YOUR PAYMENT BY CREDIT CARD As a convenience, we offer you the option to make your payment by credit card. However, regular credit card rules will apply. [You][ also] pay by [check][ or] money [order. ][ Make][ check] payable [to][ Social] Security Administration. ###### □ [Visa] Q [American][ Express] CHECK ONE ###### □ [MasterCard] [J [Discover] Credit Card Holder's Name (Enter [the][ name][ from][ the][ credit] card) First Name, Middle Initial, Last Name Credit Card Holder's Address Number & Street City, State, [&][ ZIP][ Code] Daytime Telephone [Number] Area Code Credit Card Number Credit Card Expiration(MM/YY) Amount Charged ###### See above to select the correct fee for your request. Applicable [fees][ are] $44. 00, $100. 00, or $144. 00. $ SSA will return forms without the appropriate fee. Credit Card Holder'sAuthorization ###### DO NOT WRITE IN THIS SPACE NameOFFICE USE ONLY Remittance Control # ----- ###### MEDICARE AUTHORIZATION FORM **ALL SECTIONS REQUIRED** ###### SECTION A: BENEFICIARY INFORMATION Enter beneficiary name as it appears on Medicare card. First Name: Middle Name: Last Name: ###### SUSAN M. MORALESof Birth Medicare Identification Number: ###### (mmlddlyyyy)_ Address: City: Staff*: Zip [code:] ###### SECTION B: RECORD DETAILS DEFINITION Medicare will only disclose the claim information identified below for the individual in Section A. cSelect�. one option:. . - Release all records toQ2/16/2012 to end: [02/16/2024] ###### ° lnclude a" records NY residents only: LJ Exclude information about alcohol and drug abuse, mental health treatment, and HIV Indicate whether authorization release is for a one-time disclosure, or Identify a futureor event when the authorization will expire. ###### □ One-time disclosure Select one option: ® Expiration upon specified02/16/2024_ El Expiration upon specified event ###### SECTION C: RELEASE INFORMATION TO Identify [the] name, [address][ and][ contact][ information][ of][ the] person and/or organization to whom you want[ Medicare] to disclose ###### the claim records. Medicare will only release claim records to those listed. Release claim records to beneficiary at mailing address above. Organization/lndividual 1 Name Recipient [1][ Email][ Address] ###### Roberts Reynolds Bedard Tuzzio PLLC service BLB@rrbpa. com Recipient [1] Mailing [Address:] ###### 470 Columbia Drive, Suite C-101, West Palm_ Beach, Florida 33409 SECTION D: PURPOSE FOR REQUEST This section helps Medicare understand the reason or intent for use for this record request. At the request of the individual - Litigation ###### SECTION E: AUTHORIZATION AGREEMENT I authorize Medicare to disclose claim records to the person(s) or organization(s) documented in Section C. I understand that ###### these claim records may be re-disclosed by the recipient and may no longer be protected by law. I understand I have the right to revoke this authorization at any time, in writing, except to the extent that Medicare has already [acted][ based][ on] my permission. I understand that signing this authorization is voluntary. Treatment, payment, enrollment in a health plan or eligibility for benefits will not be conditioned on my authorization of this disclosure. [of] Beneficiary [or] Representative Authorized by Law:Signed: Legal [Role][ of] Representative (Requires [Additional] Documentation): ----- MEDICARE AUTHORIZATION FORM - AU SECTIONS REQUIRED4* SECTION A; BENEFICIARY INFORMATION Lr’» [’] hi ><•r ifv/, time ant p •>d«c’, M<? du im'd First Wam. K? . MkidteN. AW'-; 1 Wst haw*:. baf? af girth Ms«j'raf<Hdcrp|fi«(|on Niimis^ tip SECTION B: RECORD DETAILS DEFINITION Mrih Jie a’IjI unty h i m! . - » » ■11k Halm lr formation Idrfit'be-u L~iov< tu> ’hr -nd - ‘ Sc^ct <w<! option: RrIsakRelease wordsintiwehwifi ait rewreis to data frOftiswH dat? )n «rxt NY rwdervta <s*ty; fo-lutfe [Hifarmat«aBM>^^] and drug abuMb mental health Heatmenl, and HIV itidirjt iMtflu* jlUlKtkvtnl'feHO hfv (I t hr J 111 ur I fitK, i 'arm (M" t r - � ht Itio <9J5hCifiwiC^ Opp time d|Kle»ure one wimp: ^pkatippuprinp - tit4 tfoli Ex? ) [at][ (] l/( [th] spe* [tb][ (] n SECTION C RELEASE INFORMATION TO l-to< i ’i H * 'unH - us d ri-ritei/ mt sHnjtijn - ” e Md vr i. yon n» %»l [i<~] Whufil yesf! «5r>i M*tJlvat«r Sa liiKlui^ KP<|| mr >H‘ M< fi i ite wji| < ruy r*1>»i<w m [»-. rra•»>] (p -'»>», * Jt03t* Rditose o»hrt twiidi to wnefrow *t fcddnm «ww. Orq^ftfrahiwiWhildaal 1 Na«i» RiK'p? «f>s. [I] email Address Redp^nt [l] eading Addms- SECTION D: PURPOSE FOR REQUEST Tt i. (. MHcn bt- ps undmVnd’ht tftwn wr nts’r. r t. n t <«' thuirrofrj rpr|wr Al-tha. teguoiKut [ton][ irtdiVidUat] | Utejaticft SECTION E: AUTHORIZATION AGREEMENT I auihadzi Mcilkafe to disclose, claim records to the petsards? or oryahizatitoi^ documented hi Section Ciunderstand that tiwe sWto fecpjdj may be re-dl. «iu«ed by W't« recipient. and may nn longer be protected by law, I under^Utid I havr the right to revoke th s nutomuMfc-n at aa> time in utItlrg, rM'“pl te the extent that Meditate has already [acted][ b«ted][ on] my permission. - I understand that signing this authorization is Treatment payment; ewellmenl, in a health pinrs or eligibility for beneflu will not be conditioned bn my authorization at this disclosure. 5|goatufe [of] Bertehbary &( ReurtseriUtive Aucbuto'^d by iiyp5i^ned. Legal [Sols][ of] kepHiHinv, iWs (Requires Adddiito^bciriitoem^ ###### 1. BENEFICIARY INFORMATION 5. SPECIFY ORGANIZATION TO RELEASE TO Add beneficiary name and ID number as printed Specify individual(s) [to][ whom][ records][ should][ be] on Medicare identification card, of birth, and released. First name, last name, and address are ###### address. required. [Additional][ contact][ information] provided 2. RECORD TIMEFRAME will be used only to follow up on questions related Indicaterange of records to release, or select to your application submission. "release all records. " 6. SELECT REASON FOR REQUEST 3. NY RESIDENTS: EXCLUSIONS OPT-IN Select purpose for record release request to help (NY residents only) Specify whether to exclude Medicare understand how records will be used. ###### records related to alcohol and drug abuse, mental 7. BENEFICIARYhealth treatment, and HIV. [and] by beneficiary [or][ authorized] 4. SELECT EXPIRATIONOR EVENT representative [in] acceptance [of][ HIPAA][ clauses] Indicateor event information release required [to][ release][ information. ][ If][ form][ not] signed authorization will expire, if you are not requesting by beneficiary, [attach][ notarized][ Power][ of] Attorney a one-time disclosure. (living individual), [or][ Letters] Testamentary [and/][ or] ###### Letters of Administration from the court (deceased individual). ----- ###### Consent to Release Liability [Insurance] (Including Self-Insurance), [No-Fault] Insurance, or Workers’ Compensation Where to find Information on “Consent to Release” vs. “Proof of Representation” Please refer to the PowerPoint document on this website titled: “Rules and Model Language for ‘Proof of Representation’ [vs. ][ ‘Consent][ to][ Release’][ for][ Medicare] Secondary Payer Liability [Insurance] (Including Self- Insurance), [No-Fault] Insurance, [or][ Workers’] Compensation” [for][ detailed][ information][ on] • When to use a “consent to release” document vs. a “proof of representation” document, • Appropriate [content][ for][ both] documents, • The need for appropriate documentation when there are two layers of representatives involved (examples: attorney [1][ refers][ a][ case][ to] attorney 2; [the] beneficiary’s guardian [hires][ an] attorney [to] pursue [a] liability insurance claim) or when a beneficiary’s representative signs a “consent to release” document on the beneficiary’s behalf, • What liability insurers (including self-insurers), no-fault insurers, and workers’ compensation entities must have in order to obtain conditional payment information, and • Use of agents by insurers’ or workers’ compensation. General A “consent to release” document is used by an individual or entity who does not represent the Medicare beneficiary [but][ is] requesting [information] regarding [the] beneficiary’s [conditional] payment information. A “consent to release” does not authorize the individual or entity to act on behalf of the beneficiary or make decisions on behalf of the beneficiary. Model Language See attached. Use of the model language is not required, but any documentation submitted as a “Consent to Release” must include the information the model language requests. Where to Submit a [“] Consent to Release” document: Liability Insurance, [No-Fault] Insurance, [Workers’] Compensation: NGHP PO Box 138832 Oklahoma City, OK 73113 Fax: (405) 869-3309 ----- ###### MODEL LANGUAGE CONSENT TO RELEASE The language below should be used when you, a Medicare beneficiary, want to authorize someone other than your attorney [or][ other] representative [to][ receive] information, including [identifiable] health information, from the Centers for Medicare & Medicaid Services (CMS) related to your liability insurance (including self-insurance), no-fault insurance or workers’ compensation claim. I, (print your [name] exactly [as][ shown][ on] your [Medicare] card) ###### hereby [authorize][ the] CMS, [its] agents [and/or][ contractors][ to] release, upon request, [information] related to my injury/illness [and/or][ settlement][ for][ the] specified [ of] injury/illness [to][ the][ individual][ and/or] entity listed below: CHECK ONLY ONE OF THE FOLLOWING TO INDICATE WHO MAY RECEIVE INFORMATION AND THEN PRINT THE REQUESTED INFORMATION: (If you [intend][ to][ have] your [information][ released][ to][ more][ than][ one] individual or entity, you must complete a separate [release][ for][ each] one. ) Insurance Company Workers’ Compensation Carrier [Other] Firm J (Explain) Name of entity: Roberts, Reynolds, Bedard, [&] Tuzzio, PLLC Contact for above entity: Benjamin [L. ] Bedard, Esquire Address: 470 Columbia Drive, Suite C101 Address Line 2: City/State/ZIP: West Palm Beach, FL 33409 561-688-6560 Telephone: CHECK ONE OF THE FOLLOWING TO INDICATE HOW LONG CMS MAY RELEASE YOUR INFORMATION (The period you [check][ will][ run][ from][ when] you sign [and] below. ): One Year Two Years Other (Provide [a] specific period [of] time) I understand that I may revoke this “consent to release information” at any time, in writing. ###### MEDICARE BENEFICIARY INFORMATION AND: Beneficiary:_ signed:_ Note: If the beneficiary is incapacitated, the submitter of this document will need to include documentation establishing [the] authority [of] [the][ individual] signing [on][ the] beneficiary’s [behalf. ][ Please][ visit] https://go. cms. gov/cobro [for][ further][ instructions. ] Medicare ID (The number on your Medicare card. ): ----- ###### Authorization for the Use and Disclosure of Protected Health Information Information Identifying the Individual Whose Records Are Being Requested SUSAN M- MORALES Name of Individual: SSN: Disclosure of your Social Security Number is not mandatory. The Agency for Health Care Administration (AHCA or Agency) may request your [Social] Security [Number] pursuant [to][ Section] 119. 071, [Florida] Statutes. [ If] provided, the Agency will use your information for purposes of finding the requested information. Individual's Street City: Address:_State: Zip [Code:] Medicaid ID or Gold Card Phone Number:_of Birth: ###### Number:; Provide the specifics of service included. From: To: Purpose [for][ this][ disclosure:]I wish this authorization Litigation_ to expire (expires in one year if nois provided): I direct AHCA to mail the requested hard copy records to the below person(s), group or entity: ###### 0 Documents Requested: LZlPaid Claims Records I IDenied Claims Records I IAll Claims Records I. I Name: Roberts, Reynolds, Bedard, [&] Tuzzio, ###### Other:_ Street Address: [470][ Columbia] Drive, Bldg PLLC_ qty: [West][ Palm][ Beach] state:C-101_FL zip Code: 33409 | | I authorize the below person(s), group or entity to verbally discuss specific topics with AHCA: The specific topics to be discussed Name: I understand the following: I have theare:_ right to revoke this authorization at any time by writing to the Agency's Privacy Officer or completing [the][ revocation][ section][ on][ the][ second] page [of][ this][ form][ and] sending it to the address listed for the Agency’s Privacy Officer. I understand that any information previously disclosed would not be subject to my revocation request. The information described above may be re-disclosed by the person or group that I am giving the Agency permission to disclose to and therefore my information may no longer be protected by [Federal] privacy regulations. I may inspect or request copies of any information disclosed by this authorization if the Agency initiated this request for disclosure. I may refuse to sign this authorization and my refusal to sign will not affect my ability to obtain treatment, payment [for][ health][ care] services or eligibility for benefits. This form specifically includes authorization to provide documents related to sensitive health conditions including: drug, alcohol or substance abuse, psychological or psychiatric treatment, sickle cell anemia, birth control or family planning, genetic diseases or tests, tuberculosis, [and] HIV/AIDS [or][ STDs. ] To restrict sensitive information, see Page 2. I DECLARE UNDER PENALTY OF LAW THAT THE INFORMATION ON THIS FORM IS TRUE AND CORRECT. :: Printed Name: Legal Authority (If [Other][ Than] ###### Individual):_ If you are a legal representative of the person whose information you are requesting disclosure of, you must provide documentation__ proving your legal authority to request this information (for example, power of attorney, guardianship papers, health care surrogate form, Custody Order, Order Appointing Personal Representative, Letters of Administration). AHCA Form 1000-3003, Revised (AUG 2018) Page [1][ of][ 2] ----- ###### Authorization for the Use and Disclosure of Protected Health Information Instructions for Completing this Form Complete [the][ first] page [of][ this][ form][ and][ return][ it][ to:][ HIPAA] Privacy Officer, Agency for Health Care Administration, 2727 Mahan Dr. , MS #4, Tallahassee, FL 32308, Phone: 850-412-3960, Fax 850-414-6837 Email: HIPAAComplianceOffice@AHCA. MyFlorida. com. Special types [of][ health][ information][ have] specific [laws] and rules that must be followed before that information may be disclosed: HIV/AIDS and Sexually Transmitted Diseases (STD): All information about HIV/AIDS and sexually transmitted diseases is protected [under][ Federal][ and][ State][ laws][ and][ cannot] be disclosed without your written authorization unless otherwise provided in the regulations. To release HIV/AIDS or STD information, this authorization must include a statement of the specific HIV/AIDS or STD information you are giving the Agency permission to disclose. Re-disclosure of HIV/AIDS information is not allowed except in compliance [with][ law][ or][ with] your [written] permission. [To][ NOT][ INCLUDE] this information, initial here_ Alcohol or Drug Treatment: Alcohol and/or drug treatment records are protected under Federal and State laws and regulations and cannot be disclosed without your written authorization, unless otherwise provided for in Federal and State laws or regulations. To release alcohol and/or drug treatment information, this authorization must include a statement of the specific Information that you are giving the Agency permission to disclose (for example, "For the purposes of my assessment, treatment plan, attendance, [or] discharge plan. ") Re-disclo$ure of your alcohol and/or drug treatment records is not allowed except in compliance with law or with your written permission (see 45 CFRPart 2). To NOT INCLUDE this information, initial here_ Mental Health Treatment: Mental health treatment records are protected under Federal and State laws and regulations and cannot be disclosed without your written authorization unless otherwise allowed in Federal or State laws or regulations. To release mental health treatment information, this authorization must include a statement of the specific Information that you are giving the Agency permission [to][ disclose] (for example, ["For] the purposes of my assessment, treatment plan, attendance, or discharge plan. ") [Disclosure][ of] your psychotherapist's [notes] needs separate written permission. Re-disclosure of your mental health treatment records is not allowed except in compliance with law or with your writtenpermission. To NOT INCLUDE this information, initial ###### here_ Revocation of Authorization DO NOT COMPLETE FOR A NEW AUTHORIZATION. THIS SECTION IS ONLY FOR REVOKING A PREVIOUS AUTHORIZATION. Disclosure of your Social Security Number is not mandatory. The Agency for Health Care Administration may request your Social Security Number pursuant to Section 119. 071, Florida Statutes. Nameof Birth Phone Social Security Number Medicaid ID Number or Gold Card Number Street Address City State Zip [Code] 1 hereby revoke my authorization for the Agency for Health Care Administration to disclose my protected health information to the following person(s), group [or] entity:Printed Name Legal Relationship to Individual If you are the subject's legal representative, you must provide documentation proving your legal authority to revoke this authorization. (For example, an authorization, power of attorney, guardianship papers, health care surrogate form, Order Appointing [Personal] Representative, [Letters][ of] Administration). AHCA Form 1000-3003, Revised (AUG 2018) Page [2][ of][ 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] SUSAN M. MORALES and JORGE L. MORALES, Individually and as Husband and Wife, Plaintiffs, vs. MORGUARD MANAGEMENT COMPANY INC. and HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC. , Defendants. _____________________________________/ IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. CASE NO: **COMPLAINT** Plaintiffs, SUSAN M. MORALES and JORGE L. MORALES, Individually and as Husband and Wife, by and through the undersigned attorneys, hereby sue the Defendants, MORGUARD MANAGEMENT COMPANY INC. and HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC. , and allege the following: **GENERAL ALLEGATIONS COMMON TO ALL COUNTS** This is an action for damages in excess of the sum of Fifty Thousand ($50, 000. 00) Dollars exclusive of interest, costs and attorneys’ fees. Plaintiffs, SUSAN M. MORALES and JORGE L. MORALES, were and are residents of Lake Worth, Palm Beach County, Florida. At all times material hereto, SUSAN M. MORALES and JORGE L. MORALES were and remain legally married to one another. ----- COMPLAINT Morales vs. Morguard Management Company, Inc. and Home Depot U. S. A. , Inc. d/b/a The Home Depot, Inc. Page 2 At all times material hereto, Defendant, MORGUARD MANAGEMENT COMPANY INC. was and is a Florida Profit Corporation authorized and doing business in Palm Beach County, Florida. At all times material hereto Defendant, MORGUARD MANAGEMENT COMPANY INC. was the management company for The Home Depot, Store #6316 located 5750 S. Jog Road, Lake Worth, Palm Beach County, Florida. At all times material hereto, Defendant, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC. was and is a Foreign Profit Corporation authorized and doing business in Palm Beach County, Florida. At all times material hereto Defendant, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC. owned and operated The Home Depot, Store #6316 located 5750 S. Jog Road, Lake Worth, Palm Beach County, Florida. At all times material hereto, on or about December 13, 2022 at approximately 8:30 a. m. , Plaintiff, SUSAN M. MORALES, an invitee, went to The Home Depot, Store #6316 located at 5750 S. Jog Road, Lake Worth, Palm Beach County, Florida. Plaintiff, SUSAN M. MORALES, parked her car and was walking in the parking lot in order to get into the store. Suddenly and without warning, her feet/foot got caught in a “pallet tie” causing her to violently fall to the ground. As a result, thereof, Plaintiff, SUSAN M. MORALES, suffered significant injuries including a large laceration to her nose, black right eye, contusion to her head, two broken kneecaps, broken left elbow, fractured left wrist and fractured right hand. ----- COMPLAINT Morales vs. Morguard Management Company, Inc. and Home Depot U. S. A. , Inc. d/b/a The Home Depot, Inc. Page 3 Venue is proper in Palm Beach County because the facts giving rise to this action occurred in Palm Beach County. **COUNT I - NEGLIGENCE CLAIM AGAINST** **DEFENDANT, MORGUARD MANAGEMENT COMPANY INC. ** Plaintiffs, SUSAN M. MORALES and JORGE L. MORALES, Individually and as Husband and Wife, reallege and incorporate each and every allegation contained in paragraphs 1 through 11 as if fully set forth herein, and further alleges: At all times material hereto, Defendant, MORGUARD MANAGEMENT COMPANY INC. , was and is the management company for The Home Depot, Store#6316, and had a duty to maintain its premises in a reasonably safe condition and to warn of any hazards about which it knew or should have known. At all times material hereto, Defendant, MORGUARD MANAGEMENT COMPANY INC. , knew or should have known, by and through the exercise of reasonable care in maintaining the parking lot area of The Home Depot, Store #6316, that individuals attempting to access the entrance to the building regularly traversed the parking lot of the premises. Defendant, MORGUARD MANAGEMENT COMPANY INC, knew or should have known that that dangerous conditions existed to individuals attempting to access the entrance to the building, including but not limited to, Plaintiff, SUSAN M. MORALES. Defendant, MORGUARD MANAGEMENT COMPANY INC, had actual or constructive notice of the dangerous condition in the parking lot and had a duty to protect invitees, like SUSAN MORALES, from the dangerous condition in the parking lot. Defendant, MORGUARD MANAGEMENT COMPANY INC, had a duty to warn SUSAN MORALES of ----- COMPLAINT Morales vs. Morguard Management Company, Inc. and Home Depot U. S. A. , Inc. d/b/a The Home Depot, Inc. Page 4 concealed dangers which were or should have been known to Defendant, MORGUARD MANAGEMENT COMPANY INC, and which were unknown to SUSAN MORALES. Defendant, MORGUARD MANAGEMENT COMPANY INC, had a duty to use reasonable care to maintain its premises in a reasonably safe condition. The danger in the parking lot was not known to SUSAN MORALES and even if it had been hypothetically, Defendant, MORGUARD MANAGEMENT COMPANY INC, should have anticipated the harm. Defendant, MORGUARD MANAGEMENT COMPANY INC. , individually, and by and through its employees, agents, servants, and/or apparent agents, was negligent and breached its aforementioned duty to Plaintiff, SUSAN M. MORALES. Defendant, MORGUARD MANAGEMENT COMPANY INC. , breached its duty to Plaintiff, SUSAN M. MORALES, in one or more of the following ways: a. Negligently failing to maintain its premises in a reasonably safe condition; b. Negligently failing to warn SUSAN MORALES of the hidden danger; c. Negligently allowing a known dangerous condition to exist upon its premises for an unreasonable period of time; d. Negligently failing to correct a dangerous condition about which it knew or should have known by the exercise of reasonable care; e. Negligently allowing a dangerous condition, which failed to comply with applicable codes and regulations to exist and thereby exposed business invitees, including Plaintiff, SUSAN M. MORALES, to injury; f. Failing to maintain its parking lots and egress routes in a manner that provided for safe walking conditions for its business invitees, including Plaintiff, SUSAN M. MORALES; and ----- COMPLAINT Morales vs. Morguard Management Company, Inc. and Home Depot U. S. A. , Inc. d/b/a The Home Depot, Inc. Page 5 g. Negligently failing to warn Plaintiff, SUSAN M. MORALES, of a dangerous condition about which Defendant had, or should have had, knowledge greater than that of the Plaintiff. As to Plaintiff, SUSAN M. MORALES’ negligence claim: Plaintiff, SUSAN M. MORALES, suffered bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, inconvenience, loss of the capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, loss of earnings, loss of ability to earn money in the future, and aggravation of a previously existing condition. These losses are either permanent or continuing, and Plaintiff will suffer these losses into the future. As to Plaintiff, JORGE L. MORALES’ consortium claim: As a result of the Defendant, MORGUARD MANAGEMENT COMPANY INC. ’s negligence, Plaintiff, JORGE L. MORALES, has been deprived of the consortium of his wife, Plaintiff, SUSAN M. MORALES, including but not limited to the loss of fellowship, companionship, society, attentions, services, affection, guidance, comfort and household services. These losses are permanent and continuing in nature. WHEREFORE, Plaintiffs, SUSAN M. MORALES and JORGE L. MORALES, Individually and as Husband and Wife, demand judgment for damages against Defendant, MORGUARD MANAGEMENT COMPANY INC. , in excess of $50, 000. 00, demand taxable costs, attorney’s fees, and further demand trial by jury. ----- COMPLAINT Morales vs. Morguard Management Company, Inc. and Home Depot U. S. A. , Inc. d/b/a The Home Depot, Inc. Page 6 **COUNT II - NEGLIGENCE CLAIM AGAINST** **DEFENDANT, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC. ** Plaintiffs, SUSAN M. MORALES and JORGE L. MORALES, Individually and as Husband and Wife, reallege and incorporate each and every allegation contained in paragraphs 1 through 11 as if fully set forth herein, and further alleges: At all times material hereto, Defendant, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC. , owned and operated The Home Depot, Store#6316, and had a duty to maintain its premises in a reasonably safe condition and to warn of any hazards about which it knew or should have known. At all times material hereto, Defendant, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC knew or should have known, by and through the exercise of reasonable care in owning and/or maintaining the parking lot area of The Home Depot, Store #6316, that individuals attempting to access the entrance to the building regularly traversed the parking lot of the premises. Defendant, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC, knew or should have known that that dangerous conditions existed to individuals attempting to access the entrance to the building, including but not limited to, Plaintiff, SUSAN M. MORALES. Defendant, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC, had actual or constructive notice of the dangerous condition in the parking lot and had a duty to protect invitees, like SUSAN MORALES, from the dangerous condition in the parking lot. Defendant, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC, had a duty to warn SUSAN MORALES of concealed dangers which were or should have been known to Defendant, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC, and which were unknown to SUSAN ----- COMPLAINT Morales vs. Morguard Management Company, Inc. and Home Depot U. S. A. , Inc. d/b/a The Home Depot, Inc. Page 7 MORALES. Defendant, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC, had a duty to use reasonable care to maintain its premises in a reasonably safe condition. The danger in the parking lot was not known to SUSAN MORALES and even if it had been hypothetically, Defendant, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC, should have anticipated the harm. Defendant, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC. , individually, and by and through its employees, agents, servants, and/or apparent agents, was negligent and breached its aforementioned duty to Plaintiff, SUSAN M. MORALES. Defendant, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC. , breached its duty to Plaintiff, SUSAN M. MORALES, in, but not limited to, one or more of the following ways: a. Negligently failing to maintain its premises in a reasonably safe condition; b. Negligently failing to warn SUSAN MORALES of the hidden danger; c. Negligently allowing a known dangerous condition to exist upon its premises for an unreasonable period of time; d. Negligently failing to correct a dangerous condition about which it knew or should have known by the exercise of reasonable care; e. Negligently allowing a dangerous condition, which failed to comply with applicable codes and regulations to exist and thereby exposed business invitees, including Plaintiff, SUSAN M. MORALES, to injury; f. Failing to maintain its parking lots and egress routes in a manner that provided for safe walking conditions for its business invitees, including Plaintiff, SUSAN M. MORALES; and g. Negligently failing to warn Plaintiff, SUSAN M. MORALES, of a dangerous condition about which Defendant had, or should have had, knowledge greater than that of the Plaintiff. ----- COMPLAINT Morales vs. Morguard Management Company, Inc. and Home Depot U. S. A. , Inc. d/b/a The Home Depot, Inc. Page 8 As to Plaintiff, SUSAN M. MORALES’ negligence claim: Plaintiff, SUSAN M. MORALES, suffered bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, inconvenience, loss of the capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, loss of earnings, loss of ability to earn money in the future, and aggravation of a previously existing condition. These losses are either permanent or continuing, and Plaintiff will suffer these losses into the future. As to Plaintiff, JORGE L. MORALES’ consortium claim: As a result of the Defendant, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC. ’s negligence, Plaintiff, JORGE L. MORALES, has been deprived of the consortium of his wife, Plaintiff, SUSAN M. MORALES, including but not limited to the loss of fellowship, companionship, society, attentions, services, affection, guidance, comfort and household services. These losses are permanent and continuing in nature. WHEREFORE, Plaintiffs, SUSAN M. MORALES and JORGE L. MORALES, Individually and as Husband and Wife, demand judgment for damages against Defendant, HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC. , in excess of $50, 000. 00, demand taxable costs, attorney’s fees, and further demand trial by jury. D this 16[TH] day of March, 2023. ## /S/ KAREN E. TERRY Karen E. Terry Florida Bar No. : 45780 Primary E-Mail: _terryteam@searcylaw. com Searcy Denney Scarola Barnhart & Shipley, P. A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Phone: (561) 686-6300 Work Attorney for Plaintiffs -----

[Assistant] IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. SUSAN M. MORALES and JORGE L. Wife, Plaintiffs, vs. MORGUARD MANAGEMENT COMPANY INC. and HOME DEPOT U. S. A, INC. d/b/a THE HOME DEPOT, INC. , Defendants. _____________________________________/ **PLAINTIFFS’ FIRST REQUEST TO PRODUCE AND REQUEST FOR INSPECTION** **TO DEFENDANT, HOME DEPOT U. S. A. , INC. D/B/A THE HOME DEPOT, INC. ** Plaintiffs, SUSAN M. MORALES and JORGE L. MORALES, Individually and as Husband and Wife, by and through the undersigned counsel, request, pursuant to Rule 1. 350 of the Florida Rules of Civil Procedure, that Defendant, HOME DEPOT U. S. A. , INC. d/b/a THE HOME DEPOT, INC. , produce and permit SUSAN M. MORALES and JORGE L. MORALES, Individually and as Husband and Wife to inspect and copy each of the following documents*: Ê Any and all policies of insurance, including excess insurance, that may provide coverage to Plaintiffs for the injuries sustained in the above-styled action. Ê Any and all recordings, including video recordings, that depict the fall occurring on December 13, 2022, which is the subject of the Complaint. Ê Copies of any and all surveillance video of any part of The Home Depot, Store #6316 located at 5750 S. Jog Road, Lake Worth, Palm Beach County, Florida or surrounding area, ----- Plaintiff’s First Request to Produce and Request for Inspection to Defendant, Home Depot U. S. A. , Inc. d/b/a The Home Depot, Inc. Morales v. Morguard Management Company, et. al. including but not limited to, the parking lot, for the two hours prior to the fall which is the subject of the Complaint. Ê Any and all documents showing changes, additions, or improvements made to The Home Depot, Store #6316, the parking lot located at 5750 S. Jog Road, Lake Worth, Palm Beach County, Florida for six months preceding theof the subject incident. Ê Copies of all repair and maintenance records including but not limited to invoices for The Home Depot, Store #6316 or surrounding area, including but not limited to, the parking lot, located at 5750 S. Jog Road, Lake Worth, Palm Beach County, Florida where the incident took place as set forth in Plaintiffs’ Complaint for six months preceding theof the subject incident. Ê Copies of all incident reports for any falls occurring at The Home Depot, Store #6316 in the parking lot, located at 5750 S. Jog Road, Lake Worth, Palm Beach County, Florida for three years preceding theof the subject incident. Ê A complete copy of the incident report for the incident which is the subject of the Complaint. Ê A copy of any witness statements pertaining to the incident which is the subject of the Complaint. Ê Any indemnification agreements between you and/or your insurer and/or Morguard Management Company Inc. in effect in 2022. Ê All documentation including but not limited to a copy of the contract or agreement between you and Morguard Management Company Inc. in effect in 2022 which set forth duties and obligations. 2 ----- Plaintiff’s First Request to Produce and Request for Inspection to Defendant, Home Depot U. S. A. , Inc. d/b/a The Home Depot, Inc. Morales v. Morguard Management Company, et. al. Ê Inspection logs demonstrating what inspections were performed by Defendant from November 13, 2022, to December 13, 2022 prior to the incident alleged in the Complaint. Ê Inspection logs demonstrating the results of the inspection, if any, performed by Defendant after Plaintiff’s fall on December 13, 2022. Ê The index to all policies and procedures and/or rules and regulations in effect in *"Documents" shall include, but not be limited to all non-identical copies of writings, drawings, graphs, charts, photographs, phono-records, recordings, and/or any other data compilations from which information can be obtained, translated, if necessary, by the party to whom the request is directed through detection devices into reasonably usable form. “Documents” also include all electronic data as well as application metadata and system metadata. All inventories and rosters of your information technology (IT) systems-e. g. , hardware, software and data, including but not limited to network drawings, lists of computing devices (servers, PCs, laptops, PDAs, cell phones, with data storage and/or transmission features), programs, data maps and security tools and protocols. It is requested that the aforesaid production be made within forty-five days of service of this request at the offices of Searcy Denney Scarola Barnhart & Shipley, P. A. , 2139 Palm Beach Lakes Boulevard, West Palm Beach, FL 33409Inspection will be made by visual observation, examination and/or copying. If any document responsive to a request has been lost or destroyed, produce all documents describing or referencing: 3 ----- Plaintiff’s First Request to Produce and Request for Inspection to Defendant, Home Depot U. S. A. , Inc. d/b/a The Home Depot, Inc. Morales v. Morguard Management Company, et. al. Ê The identity of each document sufficient to describe each; including theof the document, the author of the document; the intended recipient of each document; and the title of each document. Ê The content of the lost or destroyed document. Ê All locations in which any copy of the lost or destroyed document had been maintained. Ê Theof the loss or destruction of each document. Ê The name of each person who ordered, authorized, and carried out the destruction of any responsive document. Ê All document retention and destruction policies in effect at the time any requested document was destroyed. Ê All efforts made to locate any responsive document alleged to have been lost. I HEREBY CERTIFY that a true and correct copy of the foregoing was served via Service of Process with the Summons and Complaint. ## /s/ KAREN E. TERRY Karen E. Terry Florida Bar No. : 45780 Primary E-Mail: _terryteam@searcylaw. com Searcy Denney Scarola Barnhart & Shipley, P. A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Phone: (561) 686-6300 Fax: (561) 383-9441 Attorney for Plaintiffs 4 -----