Party Discovery: Heather Grant, et al Plaintiff vs. David Vadillo, et al Defendant

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                                Filing #   129136528 E-Filed 06/21/2021 11:18:39 AM




                                                                                                                   ,th
                                                                     IN THE CIRCUIT COURT OF THE 17
                                                                     JUDICIAL CIRCUIT IN AND FOR
                                                                     BROWARD        COUNTY, FLORIDA

                                                                     CASE NO.: CACE-21-009583            (21)


              HEATHER         GRANT,

                       Plaintiff.
              VS.



              FRANCISCO GABRIEL
              VADILLO, DAVID VADILLO and
              LYFT, INC.,

                       Defendants.
                                                      i


                      REQUEST TO PRODUCE TO DEFENDANT, FRANCISCO VADILLO

                       Plaintiff,   HEATHER      GRANT, by and through her undersigned counsel, requests

              the   Defendant,      FRANCISCO GABRIEL VADILLO to                    produce   at the offices of the



              undersigned,within forty-five (45) days of service, the following              for   inspection, copying

              and/or photocopying:


                       1.        Certified   copies   of any and all   policies of insurance, including excess and

              umbrella      insurance, which cover you     for the   allegations contained   in the   Complaint.

                       2.        Any    and all declaration sheets in effect for all automobile insurance


              policies including excess and umbrella policies in effect on May 3, 2019.

                       3.        Any   and all statements in the possession of the Defendant from any and all


              witnesses to the      subject incident, which is the subject matter of this proceeding.

                       4.        Any and all      statements    of the     Plaintiff,   HEATHER GRANT taken


              regarding this incident.




             ***
                   FILED: BROWARD COUNTY, FL BRENDA D.               FORMAN, CLERK 06/21/2021 11:18:39 AM.****
         5.        Any    and all    surveillance, photographs, DVDs, videotapes or                  any   pictorial

images ofthe Plaintiff, HEATHER GRANT on May 3, 2019.

         6.        Any    and all    repair bills   or   estimates for    repair     for the motor vehicle you


were    operating    on    May 3,     2019 that      was    involved in the          subject   incident with the


Plaintiff,    HEATHER GRANT.


         7.        Any    and all computer data           or   reports generated from computers             on   the


motor vehicle you were         driving from    15 minutes before the            subject incident to   15 minutes


after the    subject incident.

         8.        Any    and all   photographs, DVDs, videotapes               or   any   pictorial images   of the


scene   ofthe subject incident on        May 3, 2019.

         9-        The results of any       drug testing       or    alcohol   testing done    on   you   following

the   subject incident of May 3,       2019.


          10.      Any    and all    photographs taken         of both vehicles involved in the             subject

incident.


          12.      The    registration for the motor vehicle involved in the subject incident.

          13.      A copy of your driver's license, front and back.


          14.      Any     and all   photographs, DVDs, videotapes or                  any   pictorial images    of


your vehicle and Plaintiff's vehicle at         or   after the incident of May 3, 2019.


          15.      The title for the motor vehicle involved in the                subject incident    in effect on


May 3,   2019.


          16.      Your cell   phone billing records           for   May 3,    2019 from 3 hours before until


3 hours after the    subject incident.
       17.    Any     and all written agreements and/or contracts between you and the


Defendant, LYFT FLORIDA, INC.         d/b/a LYFT, INC. in effect       on   May 3,   2019.


       18.    Your entire    trip history through    the   Lyft   app for   May 3,   2019 from 4:00


p.m to 6:00 p.m.   including but not limited to   destination records and     receipts.

                         CERTIFICATE OF SERVICE


   I HEREBY CERTIFY that the           foregoing    has been served     along with the    Summons


and Amended Complaint.




                                                           is/Jon A.Zmck.      Esq.
                                                           Jon A.   Zepnick, Esq.
                                                           Florida Bar No.. 586951
                                                           ANSEL & MILLER, LLC
                                                           Counsel for the Plaintiff
                                                           1939  Tyler Street
                                                           Hollywood, Florida 33020
                                                           Phone: (954) 922-9100
                                                           Fax: (954) 922-9176




                                                           eansel@anselmiller. com