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Filing # 93089861 E-Filed 07/24/2019 02:57:25 PM
92411-8
IN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT
IN AND FOR LEE COUNTY, FLORIDA
WILLIAM ANTHONY and CIRCUIT - CIVIL DIVISION
PATRICIA ANTHONY,
CASE NO. 19-CA-3237
Plaintiffs,
vs.
WILLIAM BINDER,
Defendant.
/
DEFENDANT’S, WILLIAM BINDER, FIRST REQUEST TO PRODUCE TO
PLAINTIFFS
PURSUANT to Fla. R. Civ. P., 1.350, the Plaintiffs, WILLIAM ANTHONY and
PATRICIA ANTHONY, are requested to produce to the Defendant, WILLIAM BINDER, in the
time required by Fla. R. Civ. P., 1.350, at the offices of the undersigned counsel, the following:
1.
All repair bills, and repair estimates or documents evidencing property damage incurred
or being claimed as a result of the incidents which are the subject matter of the
Complaint.
Laser color copies of any and all photographs in the possession of the Plaintiff(s),
Plaintiff(s)’ attorneys, investigators, agents, servants, or employees which are in any
manner related to the subject matter of this lawsuit, specifically including but not limited
to all photographs of the parties, or the scene of the subject accident or incident. If none
in your possession, but the item(s) exist, please so state, including the name and address
of the party who maintains possession.
All statements made by this Defendant, or any Defendant, its agents or employees, that
are in the possession or control of Plaintiff(s) or Plaintiff(s)’ attorneys, servants,
employees or agents regarding the incidents complained of or in any way relating to the
issues raised by the Complaint.
All reports received from any experts the Plaintiff(s) intend to call at the time of trial and
copies of all documents the experts have reviewed in preparation for rendering any
opinions in this case.
All documents that the experts have reviewed in arriving at their opinions in this case.
(This request only relates to experts Plaintiff(s) intend to call at trial to testify.)
eFiled Lee County Clerk of Courts Page 1CASE NO. 19-CA-3237
6. All other documents in the possession or control of the Plaintiff(s) that support the
Plaintiff(s)’ claims that the Defendant is liable for the damages being claimed in this
case.
7. Any correspondence sent to or received by the Plaintiff(s) from Defendant. This request
does not include any correspondence with any attorneys and is strictly limited to any
correspondence between the named parties in this litigation.
8. Each and every appraisal, estimate, bill, invoice, cancelled check and receipt or document
which supports the damages claimed by the Plaintiffs in this action.
9. The proof of loss statement, and all supporting documentation, filed by Plaintiffs with
any insurance company or agency.
10. Each and every other file or document not described in the requests set forth above which
concern this incident.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a copy hereof has been electronically served via Florida
ePortal to: CHARLES PT PHOENIX, ESQUIRE, cptp@RhodesTucker.com, JOSHUA M.
BIALEK, ESQUIRE, jbialek@porterwright.com, rhuffman@porterwright.com, SARA K.
WHITE, ESQUIRE, swhite@porterwright.com, brosado@porterwright.com on this 24" day of
July, 2019.
48/_ BRANDON M. NICHOLS, ESQUIRE
Kevin W. Crews, Esquire — FB #: 31887
Brandon M. Nichols, Esquire — FB #: 51307
Brittany A. Perez, Esquire — FB #: 124467
WICKER SMITH O'HARA McCOY & FORD, P.A.
Attorneys for William Binder
9132 Strada Place, Suite 400
Naples, FL 34108
Telephone: (239) 552-5300
Facsimile: (239) 552-5399
Email: NAPcrtpleadings@wickersmith.com
eFiled Lee County Clerk of Courts Page 2
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Filing # 93089861 E-Filed 07/24/2019 02:57:25 PM 92411-8 IN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR LEE COUNTY, FLORIDA WILLIAM ANTHONY and CIRCUIT - CIVIL DIVISION PATRICIA ANTHONY, CASE NO. 19-CA-3237 Plaintiffs, vs. WILLIAM BINDER, Defendant. / DEFENDANT’S, WILLIAM BINDER, FIRST REQUEST TO PRODUCE TO PLAINTIFFS PURSUANT to Fla. R. Civ. P., 1.350, the Plaintiffs, WILLIAM ANTHONY and PATRICIA ANTHONY, are requested to produce to the Defendant, WILLIAM BINDER, in the time required by Fla. R. Civ. P., 1.350, at the offices of the undersigned counsel, the following: 1. All repair bills, and repair estimates or documents evidencing property damage incurred or being claimed as a result of the incidents which are the subject matter of the Complaint. Laser color copies of any and all photographs in the possession of the Plaintiff(s), Plaintiff(s)’ attorneys, investigators, agents, servants, or employees which are in any manner related to the subject matter of this lawsuit, specifically including but not limited to all photographs of the parties, or the scene of the subject accident or incident. If none in your possession, but the item(s) exist, please so state, including the name and address of the party who maintains possession. All statements made by this Defendant, or any Defendant, its agents or employees, that are in the possession or control of Plaintiff(s) or Plaintiff(s)’ attorneys, servants, employees or agents regarding the incidents complained of or in any way relating to the issues raised by the Complaint. All reports received from any experts the Plaintiff(s) intend to call at the time of trial and copies of all documents the experts have reviewed in preparation for rendering any opinions in this case. All documents that the experts have reviewed in arriving at their opinions in this case. (This request only relates to experts Plaintiff(s) intend to call at trial to testify.) eFiled Lee County Clerk of Courts Page 1CASE NO. 19-CA-3237 6. All other documents in the possession or control of the Plaintiff(s) that support the Plaintiff(s)’ claims that the Defendant is liable for the damages being claimed in this case. 7. Any correspondence sent to or received by the Plaintiff(s) from Defendant. This request does not include any correspondence with any attorneys and is strictly limited to any correspondence between the named parties in this litigation. 8. Each and every appraisal, estimate, bill, invoice, cancelled check and receipt or document which supports the damages claimed by the Plaintiffs in this action. 9. The proof of loss statement, and all supporting documentation, filed by Plaintiffs with any insurance company or agency. 10. Each and every other file or document not described in the requests set forth above which concern this incident. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a copy hereof has been electronically served via Florida ePortal to: CHARLES PT PHOENIX, ESQUIRE, cptp@RhodesTucker.com, JOSHUA M. BIALEK, ESQUIRE, jbialek@porterwright.com, rhuffman@porterwright.com, SARA K. WHITE, ESQUIRE, swhite@porterwright.com, brosado@porterwright.com on this 24" day of July, 2019. 48/_ BRANDON M. NICHOLS, ESQUIRE Kevin W. Crews, Esquire — FB #: 31887 Brandon M. Nichols, Esquire — FB #: 51307 Brittany A. Perez, Esquire — FB #: 124467 WICKER SMITH O'HARA McCOY & FORD, P.A. Attorneys for William Binder 9132 Strada Place, Suite 400 Naples, FL 34108 Telephone: (239) 552-5300 Facsimile: (239) 552-5399 Email: NAPcrtpleadings@wickersmith.com eFiled Lee County Clerk of Courts Page 2