On December 28, 2022 a
Party Discovery
was filed
involving a dispute between
Tobin Stacy,
and
Kopp Joanne,
Kopp Savior,
for AUTO NEGLIGENCE
in the District Court of Brevard County.
Preview
Filing # 163781790 E-Filed 12/28/2022 05:15:26 PM
IN THE CIRCUIT COURT OF THE
EIGHTEENTH JUDICIAL CIRCUIT,
IN AND FOR BREVARD COUNTY,
FLORIDA
CASE NO:
STACY TOBIN,
Plaintiff,
Vv
SAVIOR KOPP and JOANNE KOPP,
Defendants.
/
PLAINTIFF’S REQUEST TO PRODUCE TO DEFENDANT, JOANNE KOPP
Pursuant to the provisions of Rule 1.350, Florida Rules of Civil Procedure, the
undersigned counsel requests that the Defendant, JOANNE KOPP, produce and permit
the inspection, copying, testing, sampling, measuring, surveying, photographing or
otherwise examining the following:
1) All statements made by any occupants of the vehicles involved in the
subject incident.
2) All statements made by any witnesses to the subject accident.
3) All statements made by the Plaintiff(s) pertaining to or concerning the
subject matter.
4) All photographs of the vehicles involved in the subject accident.
5) All photographs of the Plaintiff(s) depicting injuries received in the subject
accident
6) All photographs of the subject accident scene.
1) All video footage of the subject accident scene.
Filing 163781790 VS 05-2022-CA-058210-XXXX-XX
8) Documents relating to or discussing repairs or maintenance to Defendant's
vehicle that were done for the six (6) months period of time preceding and including the
date of the accident and for the six (6) month period of time following the date of the
accident.
9) The repair bill and estimates for the repairs to any of the vehicles involved
in the accident for damages incurred in the accident.
10) Any and all policies of liability insurance in effect on the date of the subject
accident, providing coverage to the defendant herein.
11) Appraisals of all property damage sustained by Defendant's vehicle in the
subject accident.
12) Appraisals of the property damage sustained by Plaintiffs vehicle in the
subject accident.
13) A copy of any and all surveillance films, photos, or depictions taken of the
Plaintiff as a result of the subject accident.
14) A copy of any and all insurance agreements, insurance policies or
agreements of any kind or nature under which any person or company carrying on an
insurance business may be liable to satisfy part or all of a judgment which may be entered
in this action or to indemnify or reimburse any payments made to satisfy any such
judgment or settlement, including but not limited to a certified copy of the declarations
sheet as to each such policy.
15) Copies of any and all computer generated documents in the possession of
the Defendant(s) or any agent, servant and/or employee of the Defendant(s), which
Filing 163781790 VS 05-2022-CA-058210-XXXX-XX
pertains or relate, in any manner or fashion, to and any past claims history of the Plaintiff
in this lawsuit.
16) Copies of any and all checks issued by the Defendant(s) or any agent,
servant and/or employee of the Defendant(s) to any other person, firm or company
making a claim arising out of the same accident or incident which is the basis of this
lawsuit.
17) All payout records for the insurer of the Defendant(s) for benefits paid to or
on behalf of Plaintiff under the personal injury protection and medical payment coverage
of the policy.
18) A copy of the driver's license of the driver involved in the subject accident
that existed on the date of the accident as well as the current driver’s license.
19) A copy of the Defendant’s mobile phone bill depicting all telephone, text and
data usage for the billing period for the subject date of loss.
It is requested that the above document be furnished or produced on or before
forty-five (45) days from the date of service hereof, to Tyler Swift, Esquire at the offices
of Dan Newlin Injury Attorneys, 7335 Sand Lake Road, Ste 300, Orlando, FL 32819.
In support of this Request To Produce, it is shown that the documents and/or
materials being here requested are believed to be in the possession, custody or control
of the party to whom this request is directed. The information sought by this request is
relevant to the subject matter of this action and cannot otherwise be obtained without
undue hardship. In the event that all or part of the documents, and/or materials herein
requested are not in the possession or control of the above-named Defendant addressee,
then the undersigned counsel further request the identity and location all persons having
Filing 163781790 VS 05-2022-CA-058210-XXXX-XX
such possession and control. This request is made in good faith and for the purposes
herein expressed.
| HEREBY CERTIFY that a copy hereof has been served upon the Defendant,
JOANNE KOPP, together with the Summons and Complaint.
/s/ Tyler Swift
Tyler Swift, Esquire
Florida Bar No.: 124260
Dan Newlin Injury Attorneys
7335 W. Sand Lake Road, Suite 300
Orlando, FL 32819
Direct: (407) 203-6560
Fax: (863) 877-2504
Tyler.Swift@newlinlaw.com
SwiftPleadings@newlinlaw.com
Filing 163781790 VS 05-2022-CA-058210-XXXX-XX
Document Filed Date
December 28, 2022
Case Filing Date
December 28, 2022
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing # 163781790 E-Filed 12/28/2022 05:15:26 PM IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT, IN AND FOR BREVARD COUNTY, FLORIDA CASE NO: STACY TOBIN, Plaintiff, Vv SAVIOR KOPP and JOANNE KOPP, Defendants. / PLAINTIFF’S REQUEST TO PRODUCE TO DEFENDANT, JOANNE KOPP Pursuant to the provisions of Rule 1.350, Florida Rules of Civil Procedure, the undersigned counsel requests that the Defendant, JOANNE KOPP, produce and permit the inspection, copying, testing, sampling, measuring, surveying, photographing or otherwise examining the following: 1) All statements made by any occupants of the vehicles involved in the subject incident. 2) All statements made by any witnesses to the subject accident. 3) All statements made by the Plaintiff(s) pertaining to or concerning the subject matter. 4) All photographs of the vehicles involved in the subject accident. 5) All photographs of the Plaintiff(s) depicting injuries received in the subject accident 6) All photographs of the subject accident scene. 1) All video footage of the subject accident scene. Filing 163781790 VS 05-2022-CA-058210-XXXX-XX 8) Documents relating to or discussing repairs or maintenance to Defendant's vehicle that were done for the six (6) months period of time preceding and including the date of the accident and for the six (6) month period of time following the date of the accident. 9) The repair bill and estimates for the repairs to any of the vehicles involved in the accident for damages incurred in the accident. 10) Any and all policies of liability insurance in effect on the date of the subject accident, providing coverage to the defendant herein. 11) Appraisals of all property damage sustained by Defendant's vehicle in the subject accident. 12) Appraisals of the property damage sustained by Plaintiffs vehicle in the subject accident. 13) A copy of any and all surveillance films, photos, or depictions taken of the Plaintiff as a result of the subject accident. 14) A copy of any and all insurance agreements, insurance policies or agreements of any kind or nature under which any person or company carrying on an insurance business may be liable to satisfy part or all of a judgment which may be entered in this action or to indemnify or reimburse any payments made to satisfy any such judgment or settlement, including but not limited to a certified copy of the declarations sheet as to each such policy. 15) Copies of any and all computer generated documents in the possession of the Defendant(s) or any agent, servant and/or employee of the Defendant(s), which Filing 163781790 VS 05-2022-CA-058210-XXXX-XX pertains or relate, in any manner or fashion, to and any past claims history of the Plaintiff in this lawsuit. 16) Copies of any and all checks issued by the Defendant(s) or any agent, servant and/or employee of the Defendant(s) to any other person, firm or company making a claim arising out of the same accident or incident which is the basis of this lawsuit. 17) All payout records for the insurer of the Defendant(s) for benefits paid to or on behalf of Plaintiff under the personal injury protection and medical payment coverage of the policy. 18) A copy of the driver's license of the driver involved in the subject accident that existed on the date of the accident as well as the current driver’s license. 19) A copy of the Defendant’s mobile phone bill depicting all telephone, text and data usage for the billing period for the subject date of loss. It is requested that the above document be furnished or produced on or before forty-five (45) days from the date of service hereof, to Tyler Swift, Esquire at the offices of Dan Newlin Injury Attorneys, 7335 Sand Lake Road, Ste 300, Orlando, FL 32819. In support of this Request To Produce, it is shown that the documents and/or materials being here requested are believed to be in the possession, custody or control of the party to whom this request is directed. The information sought by this request is relevant to the subject matter of this action and cannot otherwise be obtained without undue hardship. In the event that all or part of the documents, and/or materials herein requested are not in the possession or control of the above-named Defendant addressee, then the undersigned counsel further request the identity and location all persons having Filing 163781790 VS 05-2022-CA-058210-XXXX-XX such possession and control. This request is made in good faith and for the purposes herein expressed. | HEREBY CERTIFY that a copy hereof has been served upon the Defendant, JOANNE KOPP, together with the Summons and Complaint. /s/ Tyler Swift Tyler Swift, Esquire Florida Bar No.: 124260 Dan Newlin Injury Attorneys 7335 W. Sand Lake Road, Suite 300 Orlando, FL 32819 Direct: (407) 203-6560 Fax: (863) 877-2504 Tyler.Swift@newlinlaw.com SwiftPleadings@newlinlaw.com Filing 163781790 VS 05-2022-CA-058210-XXXX-XX