REQUEST TO PRODUCE TO DEFENDANTS July 30, 2024 (2024)

On July 30, 2024 aREQUEST TO PRODUCE TO DEFENDANTSwas filedinvolving a dispute betweenKarina Lopez,andEthan J Cushing,Lucila Rodriguez Cushing,for Circuit Civilin the District Court of Manatee County.

 
Preview
 Filing # 203692455 E-Filed 07/30/2024 04:40:28 PM IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR MANATEE COUNTY, FLORIDA KARINA LOPEZ, Plaintiff, VS Case No: ETHAN J. CUSHING and LUCILA RODRIGUEZ CUSHING Defendants. REQUEST TO PRODUCE TO DEFENDANTS Plaintiff, KARINA LOPEZ, by and through her undersigned attorney and pursuant to F.R.C.P. 1.350, requests that the Defendants produce copies of the following items within forty- five (45) days of the date of service. 1 All statements concerning this action or the subject matter of this action previously made by Plaintiff. Duplicate color photographs or color reproductions of all photographs depicting the accident scene or the damage to either Plaintiff's, Defendant’s, or any other vehicle, which was sustained in the subject accident. Actual color photographs are requested. All documents, maps, plats, photographic diagrams, items of physical evidence, or other items of evidence relating to the subject matter of this action. Certified copies of any and all policies of insurance available to Defendant(s) that afforded or might afford coverage for Plaintiff's claimed damages in this action. Copies of any and all repair cstimates to any and all vehicles involved in the subject accident. Reproductions of any and all photographs, videotapes, surveillance films or the like taken of the Plaintiff by the Defendant or anyone on Defendant’s behalf. "2024CA00 1252AX" 203692455 Filed at Manatee County Clerk 08/01/2024 09:20:09 AM EDTCopics of all transcripts of any and all hearings, trials, or other adjudications held by any state, county or municipality involving the instant matter. Copies of the Defendants’ driver's licenses front and back. A copy of the title to Defendant's motor vehicle which was involved in the subject accident. 10 A copy of any traffic citation issued to the Defendant driver relating to the occurrence alleged in the Complaint. 11 Copies of Defendant, ETHAN J. CUSHING, cellular telephone billing statements and/or records from the date of loss, including the twenty-four (24) hour period before and twenty-four (24) hour period after the date of loss. This request includes any records which may be provided to Defendant via internet, electronic mail and/or “paperless billing.” 12 If the above requested documents are not within Defendant’s possession, please produce copies of any and all cellular telephone billing statements and/or records which are in the Defendant’s possession and are for the service provider and telephone number which Defendant had in operation at the time of the subject motor vehicle crash. This request includes any records which may be provided to Defendant via internet, electronic mail and/or “paperless billing.” *** Jf you intend to claim that any of the requested items are privileged in any way, or,subject to protection as trial preparation material, please comply with F.R.C.P. 1.280(b)(5). *** I HEREBY CERTIFY that a true copy of the foregoing was furnished to the Defendantalong with the Summons and Complaint.Dated: July 30, 2024 (/ C.3, CLA C.J, Czaia, Esq. Attorney for the Plaintiff CZAIA LAW 862 62nd Street Circle East Suite 101 Bradenton, FL 34208 "2024CA00 1252AX" 203692455 Filed at Manatee County Clerk 08/01/2024 09:20:09 AM EDT833-255-6697 Phone 844-642-6672 Fax cje@ezaialaw.com Florida Bar Number: 0934429"2024CA00 1252AX" 203692455 Filed at Manatee County Clerk 08/01/2024 09:20:09 AM EDT 

Related Contentin Manatee County