Florida Request to Produce

4 Aug 2016

Florida Request to Produce

Posted By :
Comments : 0

IN THE CIRCUIT COURT OF
THE EIGHTH JUDICIAL CIRCUIT IN AND FOR
ALACHUA COUNTY, FLORIDA

Ronique T. Myers, Case No.: 01-2016-CA-0001422

Plaintiff, Circuit Civil Division J

vs.

Kyle BJarkman
and JJ’S OF FLORIDA, LLC
d/b/a JIMMY JOHN’S GOURMET
SANDWICHES,

Defendants.
——————————————–/

PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION OF
DOCUMENTS AND NOTICE TO PRODUCE TO DEFENDANTS

COME NOW, Plaintiff in the above-styled action, and hereby requests both Defendants KYLE BJARKMAN and JJ’S OF FLORIDA, LLC d/b/a JIMMY JOHN’S GOURMET SANDWICHES produce and permit Plaintiff, or someone acting on their behalf, to inspect and copy the following designated documents.  Copy costs will not be paid without prior written approval. 
INTRODUCTORY NOTES

I. Definitions
As used in this Request for Production of Documents, the following terms mean:
(a) “You” or “your”
The person(s) to whom this Request for Documents are addressed and all other persons acting or purporting to act on said person’s behalf.
(b) “Document”
Includes, without limitation, writings, agreements, contracts, and printed matter of every kind and description; photographs and drawings; notes and records of any oral communications; and recordings (tape, disc or other) of oral communications.
(c) “Person” or “persons”
Any individual, corporation, partnership, joint venture, firm, association, proprietorship, agency, board, authority, commission or any other entity.
(d) “Communicate” or “communication”
Includes every manner or means of disclosure, transfer, or exchange and every disclosure, transfer or exchange of information, whether orally or by documents or whether face-to-face or by telephone, mail, personal delivery or otherwise.
(e) “Or”
Shall be construed either conjunctively or disjunctively to bring within the scope of this Request for Documents any information which might otherwise be construed to be outside their scope.

II. Instructions
(a) Unless otherwise indicated, this Request for Documents concerns and relates to the automobile collision which is described in Plaintiffs’ Complaint.
(b) If you maintain that any document or record referred to herein has been lost, misplaced or destroyed, set forth the contents of said document, a description of said document, the location of any copies of said document, the date of such loss or destruction and, if the document was destroyed, the name of the person who operated or authorized said destruction.
(c) If you maintain that any of the documents requested cannot be produced by virtue of any claimed privilege or immunity, set forth precisely the grounds for your objection to producing the documents in question.

REQUESTS FOR PRODUCTION
1.
Please produce any and all documents identified, referred to or used by any person in connection with the compilation of your Responses to Plaintiffs’ First Interrogatories.
2.
Please produce a curriculum vitae for, and any and all documents containing the opinions or analyses of, any person whom you expect to call as an expert witness at the trial of this case, which concern any issue pertaining to the instant lawsuit.

3.
Please produce any and all correspondence, memoranda, reports, written notes, diagrams, charts or other similar documents which relate to the collision described in Plaintiffs’ Complaint or any of Plaintiffs’ claims or your defenses in this action.
4.
Please produce any and all books, documents or other tangible items relating to the collision described in Plaintiffs’ Complaint or any of Plaintiffs’ claims or your defenses in this action.
5.
Please produce any and all photographs, videotapes, motion pictures, drawings, sketches, diagrams, plats or the like taken at or made of the scene of the collision or any person or physical object which relate in any way to the circumstances of the collision, including, without limitation, photographs of the damaged bicycle.
6.
Please produce any and all documents prepared by anyone as the result of tests, inspections or measurements made or taken with respect to the scene of the collision.
7.
Please produce any and all documents which contain or are related to any surveillance or investigation concerning Plaintiffs’ claims or allegations in this action.
8.
Please produce any and all documents which evidence, contain or relate to any statements made by either Plaintiff or any other person or any communication by any person at the scene of the collision in question.
9.
Please produce any and all insurance policies which may provide coverage to you for part or all of any judgment for which they may be adjudged liable in this action or under which you may be indemnified or reimbursed for payments made to satisfy such judgment.
10.
Please produce any and all documents which evidence, refer to or relate to repairs made to any vehicle damaged in connection with the collision described in Plaintiffs’ Complaint.
11.
Please produce any and all correspondence or similar communication between any parties to this action not produced in response to any previous Request for Production of Documents.
12.
Please produce a copy of all transcripts containing the testimony of any party or witness pertaining to the instant collision.
13.
Please produce any and all reports from any accident investigators or reconstruction experts or engineers not produced in response to any previous Request for Production of Documents.
14.
Please produce any and all documents or other written material not produced in response to any previous Request for Production of Documents, which you contend evidence, support or refute any fact or circumstance relating to your defenses or claims in this action.
15.
Please produce copies of all pleadings, orders, notices or other documents pertaining to any criminal or traffic court proceeding related to this collision.
16.
Please produce all documents which relate to or evidence your authority/permission, or lack thereof, to operate the vehicle which you were driving at the time of the collision.
17.
Please produce at least one document, such as title or registration, evidencing ownership of the vehicle you were driving which was involved in the collision described in Plaintiffs’ Complaint.
18.
Please produce copies of your current driver’s license and the registration for the vehicle involved in the collision described in Plaintiffs’ Complaint.
19.
Please produce all documents relating to alco-sensor, breathalyzer or blood-alcohol tests you
performed on the date of the collision.
20.
Please produce any medical or employment records you have obtained relating to either
Plaintiff. Your response to this request should be periodically supplemented.
21.
Please produce a copy of any and all contracts or agreements between any of the Defendants in this matter.
Dated: June 20, 2016
/s/ Michael Massey
Counsel for Plaintiff
Designated Email: Massey@352law.com
Fla. Bar No. 153680
Massey & Duffy, P LLC
855 E. Univ. Ave.
Gainesville, FL 32601
352-505-8900

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been provided by Email to counsel for Plaintiff this June 20, 2016 by efiling the same with the Court’s efiling system.
/s/ Michael Massey
Michael Massey
Fla. Bar No. 153680
855 E. Univ. Ave.
Gainesville, FL 32601
Phone: 325-505-8900
Massey@352law.com

About the Author:

Massey & Duffy has existed since October, 2003. We focus exclusively on civil litigation, including wrongful death, overtime cases, car and trucking accidents, insurance claims, breach of contract, general employment law, and serious personal injury lawsuits.