Requests For Production

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Documents & Evidence Related to Your Injuries:

Any and all medical records, reports, physicians' notes, nurses' notes, hospital charts, admission summaries, discharge summaries, and all other medical memoranda relating to examination, treatment or care received by Plaintiff as a result of the injuries alleged in Plaintiff's Complaint.

Any and all bills, whether paid or unpaid, relating to medical expenses incurred by Plaintiff as a result of the injuries alleged in their complaint.

Copies of all pictures, drawings, or photographs of Plaintiff's injuries taken after the accident alleged in Plaintiffs Complaint.

Copies of all documents relating to compensation received by the Plaintiff as a result of the incident which is the subject of his Complaint, including but not limited to, worker's compensation, insurance coverage, and compensation by employers.

All documents which contain, relate to or include the assignment of a permanent partial impairment (APPI) rating to Plaintiff, or which contain, relate to or include any facts, considerations, measurements, calculations or other information utilized to derive and assign a PPI rating to Plaintiff.

Documents & Evidence Related to Your Other Damages:

Any and all bills or memoranda of expenses for which Plaintiff claims compensation as an alleged result of the injuries alleged in his Complaint.

All documents which contain, relate to or include any information upon which you base your allegation that your earning capacity has been permanently impaired.

Copies of all tax returns, state and federal, filed by Plaintiff or on his behalf in the last five (5) years (if claiming lost wages).

Copies of all reports, records or other documents verifying any losses claimed as a result of the alleged accident.

Documents & Evidence Relating to the Incident

Copies of all photographs, pictures, drawings or diagrams of the scene of the alleged accident.

Documents & Evidence Related to Witnesses

A copy of any statement taken from any witness to the alleged accident.

Copies of all statements, whether written, recorded, or memoranda of oral statements, taken from the Defendant or any of its agents, employees or servants.

Any statements, memoranda of statements, or other evidence of any kind whatsoever relating to any statement, written or oral, given by defendant to anyone, which is in the possession of or available to Plaintiff, any statements, diagrams, or other materials relating to the incident.

Documents and Things Related to Motor Vehicle Collision

Any and all estimates, bills, invoices, receipts, or other documentation evidencing any repair, replacement or installation of any parts on the vehicle which is the subject of Plaintiff's complaint.

Any and all bills, contracts, checks agreements, receipts or other documents of any nature, relating to the purchase or sale of the vehicle which is the subject of Plaintiff's complaint.

Any and all maintenance invoices, logs, or forms which were kept for the vehicle which is the subject of Plaintiff=s complaint including but not limited to all service, repair and maintenance records.

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