Requests to Produce to Defendant

CIRCUIT COURT OF THE STATE OF FLORIDA

COUNTY OF MARION, FIFTH CIRCUIT

REDACTED, an individual

 

Plaintiff,

vs.

 

REDACTED, INC.

 

Defendant.

CASE NO.: 

 

 

 

 

 

REQUESTS TO PRODUCE TO DEFENDANT

COME NOW, REDACTED (“BAKER”), plaintiff in the above-styled matter, and serves the following requests to produce to REDACTED, INC. (“you”, “your” or “Defendant”) pursuant to Rule 1.350.  Plaintiff requests that the following documents be produced at the law offices of the undersigned within 30 days.

 

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 is addressed and all other persons acting or purporting to act on said person’s behalf.

(b) “Document”

Includes, without limitation, writings, emails (whether printed or not), agreements, contracts, and printed matter of every kind and description; data stored on a computer hard disk or other memory card, photographs and drawings; notes and records of any oral communications; e-mails 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 incident which is described in Plaintiff’s 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 Answer to Plaintiff’s Complaint or response to the Complaint.

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 incident 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 incident described in Plaintiff’s Complaint or any of Plaintiff’s 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 incident or any person or physical object which relate in any way to the circumstances of the incident.

6.

Please produce any and all documents prepared by anyone as a result of tests, inspections or measurements made or taken with respect to the scene of the incident.

7.

Please produce any and all documents which contain or are related to any surveillance or investigation concerning Plaintiff’s claims or allegations in this action.

8.

Please produce any and all documents which evince, contain or relate to any statements made by Plaintiff or any other person or any communication by any person at the scene of the store 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 correspondence or similar communication between any parties to this action.

11.

Please produce a copy of all transcripts containing the testimony of any party or witness pertaining to the incident.

12.

Please produce any and all reports from any accident investigators or reconstruction experts or engineers.

13.

Please produce any and all documents or other written material which you contend evidence, support or refute any fact or circumstance relating to your defenses or claims in this action.

14.

Please produce copies of all pleadings, orders, police reports, notices or other documents pertaining to the incident.

15.

            Please produce any medical or employment records you have obtained relating to the Plaintiff.  Your response to this request should be periodically supplemented.

16.

            Please produce any and all of your insurance policies in effect at the time of the accident as described in Plaintiff’s Complaint.

17.

            Please produce any and all insurance policies that relate in any way to the allegations in Plaintiff’s Complaint or incidents referred to in Plaintiff’s Complaint.

18.

            Any and all land records, contracts, documents or the like reflecting the persons or

 

entities owning the property where the plaintiff was injured, as described in the Complaint.