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Filing # 81967686 E-Filed 12/11/2018 04:32:24 PM
IN THE CIRCUIT COURT OF THE 15™ JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
Case No.: 50-2018-CA-015498-XXXX-MB
Div.: AD
ERROLL INNISS,
Plaintiff,
vs.
THE FLORIDA HIGHWAY PATROL,
A division of FLORIDA DEPARTMENT OF HIGHWAY
SAFETY & MOTOR VEHICLES, an Agency of the
State of Florida, and
TROOPER RICKY LEE MAYO,
Defendants.
/
P TIFF’S REQUEST TO PRODUCE TO DEFENDANT
(SERVED WITH THE COMPLAINT)
TO DEFENDANT:
TROOPER RICKY LEE MAYO
12635 Adventure Drive
Riverview, FL 33579-7792
Plaintiff, ERROLL INNISS, by and through his undersigned attorney, and, pursuant to
Rule 1.350, Florida Rules of Civil Procedure, hereby requests the above-named Defendant to
produce the items and matters hereinafter set forth within forty-five (45) days after receipt
thereof at Steinberg Law, P.A., 10 SE 1° Ave. Ste. C, Delray Beach, Florida 33444.
The items and matters to be produced are as follows:
1. Copies of the declaration sheets of all liability insurance coverages affording coverage for
the accident involved in this lawsuit, specifically including any excess insurance or umbrella
policies.
2. Repair bills and/or estimates on both of the vehicles involved.
3. Photographs or motion pictures taken of the Plaintiff, the Defendant, and the scene of the
*** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 12/11/2018 04:32:24 PM ***accident.
4. Any and all photographs and/or videotapes showing damage to any motor vehicle owned,
driven by the Defendant or occupied by the Defendant, suffered or sustained as a result of the
collision described in the Complaint, before any such damage was repaired or before any vehicle
was sold, disposed or junked.
5. Copies of any and all writings, recordings, memorandums, notes or any other materials
reflecting statements made by any party to this lawsuit.
6. Copies of all bills, medical reports, and checks from any doctor, physician, or other
member of the healing arts, who have examined the Defendant’s physical or mental condition
subsequent to the accident which is the subject matter of this lawsuit.
7. Copies of all reports prepared by the Defendant’s experts expected to testify at trial.
Mims v. Casedemont, 464 So.2d 643 (3d DCA 1985).
8. All written statements obtained by you, your attorneys or investigators conceming this
action or its subject matter, or stenographic, mechanical, electrical, or any other recording or
transcription of a statement that is a substantial verbatim recital of an oral statement.
9. Copies of each and every document, paper, chart, table, document, or writing of any type
indicating the life expectancy or work life expectancy of the Plaintiff.
10. Traffic or other court transcriptions involving the subject matter of the instant litigation.
11. Written summary of any and all oral agreements, including Mary Carter Agreements
between the Defendant and any other party or their insurers as well as any and all oral covenants
or agreements of any sort whatsoever with respect to any issues in this pending litigation.
12. All ordinances, regulations, rules, statutes, customs, practices, publications upon which
your counter defenses and/or claims are made.
13. All documents which record, reflect, refer or relate to all vehicles owned by you, or any
relative with whom you resided on the date of the collision, either individually or jointly.
14. A copy, front and rear, or your driver's license.
15. All correspondence transmitted between you and any other persons or entities, other that
your attomeys or insurers, which record, reflect, refer or relate to the collision.
16. All written or orally recorded statements made by you to any persons, other than your
attomeys, which record, refer, reflect or relate to the collision.
Page 2 of 417. All written or orally recorded statements made by any witness or postoccurrence witness
to the collision.
18. All written or orally recorded statements made by the Plaintiff in this action.
19. All photographs of the scene, vehicles or persons involved in the collision.
20. All reports, correspondence, bills, summaries, exhibits, maps, drawings, models,
diagrams and documents transmitted to or from any expert you intend to call to testify in this
case which refers or relates to the collision, injuries sustained, medical treatment rendered, wage
loss, or any other issue in this case.
21. All reports, records, claims statements and summaries of any treatment rendered to you
within the past five (5) years.
22. All medical records, reports, notes and summaries which relate to any medical treatment
rendered to you from ninety (90) days before to ninety (90) days after the date of the collision.
23. All reports, records, claims and police reports involving any motor vehicle collisions in
which you have been involved within the past five (5) years.
24. All estimates, repair bills, reports, records and other documents which relate or pertain to
the condition, examination or repair of any of the motor vehicles involved in the collision.
25. All documents which record, refer, reflect or relate to any examinations or repairs of any
of the motor vehicles involved in the collision within three (3) months before the collision.
26. All accident reconstruction, engineering or other reports, records, studies and documents
which refer or relate to the collision and events referenced in the Complaint.
27. All automobile insurance policies in which the Defendant is a named insured.
28. A copy of Defendant’s cellular/mobile telephone bills received by the Defendant or on
behalf of the Defendant evidencing incoming/outgoing calls on the date of the accident in
question.
STEINBERG LAW, P.A.
Attorney for Plaintiff
10 S.E. 1 Avenue, Ste. C.
Delray Beach, FL 33444
Telephone: (561) 630-0053
Facsimile: (561) 594-1838
E-Mail:_brett@brettsteinberglaw.com
steinberglawservice@gmail.com
Page 3 of 4By: /s/ Brett. Steinberg
Brett M. Steinberg, Esquire
Florida Bar No.: 11677
Page 4 of 4
Preview
Filing # 81967686 E-Filed 12/11/2018 04:32:24 PM IN THE CIRCUIT COURT OF THE 15™ JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No.: 50-2018-CA-015498-XXXX-MB Div.: AD ERROLL INNISS, Plaintiff, vs. THE FLORIDA HIGHWAY PATROL, A division of FLORIDA DEPARTMENT OF HIGHWAY SAFETY & MOTOR VEHICLES, an Agency of the State of Florida, and TROOPER RICKY LEE MAYO, Defendants. / P TIFF’S REQUEST TO PRODUCE TO DEFENDANT (SERVED WITH THE COMPLAINT) TO DEFENDANT: TROOPER RICKY LEE MAYO 12635 Adventure Drive Riverview, FL 33579-7792 Plaintiff, ERROLL INNISS, by and through his undersigned attorney, and, pursuant to Rule 1.350, Florida Rules of Civil Procedure, hereby requests the above-named Defendant to produce the items and matters hereinafter set forth within forty-five (45) days after receipt thereof at Steinberg Law, P.A., 10 SE 1° Ave. Ste. C, Delray Beach, Florida 33444. The items and matters to be produced are as follows: 1. Copies of the declaration sheets of all liability insurance coverages affording coverage for the accident involved in this lawsuit, specifically including any excess insurance or umbrella policies. 2. Repair bills and/or estimates on both of the vehicles involved. 3. Photographs or motion pictures taken of the Plaintiff, the Defendant, and the scene of the *** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 12/11/2018 04:32:24 PM ***accident. 4. Any and all photographs and/or videotapes showing damage to any motor vehicle owned, driven by the Defendant or occupied by the Defendant, suffered or sustained as a result of the collision described in the Complaint, before any such damage was repaired or before any vehicle was sold, disposed or junked. 5. Copies of any and all writings, recordings, memorandums, notes or any other materials reflecting statements made by any party to this lawsuit. 6. Copies of all bills, medical reports, and checks from any doctor, physician, or other member of the healing arts, who have examined the Defendant’s physical or mental condition subsequent to the accident which is the subject matter of this lawsuit. 7. Copies of all reports prepared by the Defendant’s experts expected to testify at trial. Mims v. Casedemont, 464 So.2d 643 (3d DCA 1985). 8. All written statements obtained by you, your attorneys or investigators conceming this action or its subject matter, or stenographic, mechanical, electrical, or any other recording or transcription of a statement that is a substantial verbatim recital of an oral statement. 9. Copies of each and every document, paper, chart, table, document, or writing of any type indicating the life expectancy or work life expectancy of the Plaintiff. 10. Traffic or other court transcriptions involving the subject matter of the instant litigation. 11. Written summary of any and all oral agreements, including Mary Carter Agreements between the Defendant and any other party or their insurers as well as any and all oral covenants or agreements of any sort whatsoever with respect to any issues in this pending litigation. 12. All ordinances, regulations, rules, statutes, customs, practices, publications upon which your counter defenses and/or claims are made. 13. All documents which record, reflect, refer or relate to all vehicles owned by you, or any relative with whom you resided on the date of the collision, either individually or jointly. 14. A copy, front and rear, or your driver's license. 15. All correspondence transmitted between you and any other persons or entities, other that your attomeys or insurers, which record, reflect, refer or relate to the collision. 16. All written or orally recorded statements made by you to any persons, other than your attomeys, which record, refer, reflect or relate to the collision. Page 2 of 417. All written or orally recorded statements made by any witness or postoccurrence witness to the collision. 18. All written or orally recorded statements made by the Plaintiff in this action. 19. All photographs of the scene, vehicles or persons involved in the collision. 20. All reports, correspondence, bills, summaries, exhibits, maps, drawings, models, diagrams and documents transmitted to or from any expert you intend to call to testify in this case which refers or relates to the collision, injuries sustained, medical treatment rendered, wage loss, or any other issue in this case. 21. All reports, records, claims statements and summaries of any treatment rendered to you within the past five (5) years. 22. All medical records, reports, notes and summaries which relate to any medical treatment rendered to you from ninety (90) days before to ninety (90) days after the date of the collision. 23. All reports, records, claims and police reports involving any motor vehicle collisions in which you have been involved within the past five (5) years. 24. All estimates, repair bills, reports, records and other documents which relate or pertain to the condition, examination or repair of any of the motor vehicles involved in the collision. 25. All documents which record, refer, reflect or relate to any examinations or repairs of any of the motor vehicles involved in the collision within three (3) months before the collision. 26. All accident reconstruction, engineering or other reports, records, studies and documents which refer or relate to the collision and events referenced in the Complaint. 27. All automobile insurance policies in which the Defendant is a named insured. 28. A copy of Defendant’s cellular/mobile telephone bills received by the Defendant or on behalf of the Defendant evidencing incoming/outgoing calls on the date of the accident in question. STEINBERG LAW, P.A. Attorney for Plaintiff 10 S.E. 1 Avenue, Ste. C. Delray Beach, FL 33444 Telephone: (561) 630-0053 Facsimile: (561) 594-1838 E-Mail:_brett@brettsteinberglaw.com steinberglawservice@gmail.com Page 3 of 4By: /s/ Brett. Steinberg Brett M. Steinberg, Esquire Florida Bar No.: 11677 Page 4 of 4