Discovery in Florida Personal Injury Cases: Requests for Production

After a personal injury lawsuit is filed in the state of Florida, both the Plaintiff and the Defendant engage in what is known as the “Discovery” process. Requests for Production of documents are one of the major discovery tools and are often one of the first used after a personal injury suit is commenced. Requests for Production can be a fast and relatively inexpensive way to for each side to begin obtaining information about the other side’s case. requests to the attorney for the insurance company and/or responsible driver.

A Request for Production is simply a request for documents in the possession, custody, or control of a party. Most of the time, the documents that a Defendant will request will involve the following subjects: medical records, medical bills, health insurance payment information, copies of tax returns (if you are claiming lost wages), and copies of past medical treatment records. You have 30 days to provide the requested documents to the other side.

What Are Some Typical Requests Found in Requests for Production in Personal Injury Cases?

  • Copies of all tax returns, W2’s Forms, or any other evidence of income for all years to date, beginning with the five (5) years preceding the within incident.
  • Copies of any and all medical records, hospital records, emergency room records, and records from any health care provider pertaining to the treatment of Plaintiff(s) for any injuries sustained in the within incident.
  • Copies of bills and/or estimates for the repair of Plaintiff’s vehicle and any other damaged property. If the vehicle was not repairable, in addition, attach estimates of the value of the vehicle on the date of the alleged incident and estimates and/or receipts concerning salvage value.
  • Any and all statements, including, but not limited to, recorded telephone interviews, tapes, written statements, whether signed or unsigned, of all witnesses to the incident relative to the subject matter of this action and/or witnesses having knowledge regarding any and all facts and issues in the instant litigation.
  • Any and all photographs, diagrams or sketches of the scene of the accident.
  • Any and all photographs of the vehicles involved in the incident before and after the accident.
  • Copies of all reports, evaluations, recommendations and/or analysis submitted by any disclosed Plaintiff’s expert witnesses regarding the subject accident and/or the Plaintiff’s injuries and/or damages allegedly caused by the subject accident.
  • All policies of insurance providing collateral source payments to Plaintiff(s), including, but not limited to, PIP insurance, medical payment insurance, disability insurance, and/or employment-related insurance.

Our attorneys have years of experience in guiding our clients through the Discovery process. Our attorneys meet with each of our clients in person to make sure that they have a full understanding of the questions being asked of them. Let the personal injury attorneys at Suarez & Montero review the circumstances of your case and discuss your legal options. Our attorneys are ready to provide proven legal representation in pursuing your claim and stand ready to protect your rights.

Contact us today at 786 Lawyers for a FREE consultation!

Jaime Suarez

An experienced legal personal injury defense professional in Miami, who is dedicated to helping accident victims with personal injury cases involving automobile accidents, brain and spinal cord injuries, slip and fall accidents, prescription errors, wrongful death, and accidents at work.