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Case Number:23-000467-CI
Filing # 165757041 E-Filed 01/30/2023 04:40:32 PM
IN THE CIRCUIT COURT FOR THE SIXTH JUDICIAL CIRCUIT
IN AND FOR PINELLAS COUNTY, FLORIDA
CIVIL DIVISION
ROBERT KNIGHT,
Plaintiff,
v. CASE NO.:
KATELINE LEWIS,
Defendant.
________________________/
PLAINTIFF’S FIRST REQUEST TO PRODUCE TO DEFENDANT
COMES NOW the Plaintiff, ROBERT KNIGHT, by and through the undersigned counsel,
pursuant to Rule 1.350, Florida Rules of Civil Procedure, and hereby requests that the Defendant,
KATELINE LEWIS, produce for inspection and/or copying by counsel for Plaintiff, the following
documents, said documents to be produced at the offices of Pipas Law Group, 360 Central Avenue,
Suite 1570, St. Petersburg, Florida, 33701, on or before forty-five (45) days from the date of service
hereof.
1. Any and all policies of insurance and indemnity agreements (including declaration
sheets) providing coverage to the Defendant(s) for the subject incident.
2. Any and all written or recorded statements of the Plaintiff.
3. Any and all claims, proof of loss and notices of incidents prepared by investigators,
adjusters, claims personnel or other agents or employees of Defendant(s) from
information obtained directly from the Plaintiff regarding the subject incident.
4. Any and all written or recorded statements taken from parties or witnesses
concerning any issue in this case.
5. Any and all photographs, video recordings, graphs, charts and other documentary
evidence of the scene, parties, or vehicles involved in or pertaining to the subject
incident, occurrence or issues in this case.
***ELECTRONICALLY FILED 01/30/2023 04:40:31 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
Any and all surveillance tapes, videos, movies, photography, and reports of the
Plaintiff, including, but not limited to, surveillance videotapes and photographs.
Documents relating to or discussing repairs or maintenance t0 the Defendant’s
vehicle that were done for the six (6) months prior to and including the date of the
accident, and for the six (6) months following the date of the accident.
Any and all repair bills or estimates concerning the damage to any vehicles involved
in the subject incident.
Any and all laser color copies of all pictures, photographs, Video tapes or
recordings, or slides of any and all vehicles involved in the subject incident.
10. The cellular phone records for the Defendant driver which reflect incoming and
outgoing calls and text messages from 12:00 A.M. on the date of accident to 12:00
A.M. the following day. If unavailable, please provide the cellular telephone
number of the Defendant driving during that time period, the name of his or her
phone carrier, and the name under which the account is listed.
11. Any and all documentation evidencing ownership and leasehold interests in the
vehicle being operated by the Defendant, KATELINE LEWIS, at the time of the
subject incident, including, but not limited to, title,registration, lease agreement,
etc.
12. Any and all records regarding any automobile accidents in which the Defendant,
KATELINE LEWIS, was involved for the three (3) years prior to the subject
incident.
13. Any and all records regarding any automobile accidents in which the Defendant,
KATELINE LEWIS, was involved subsequent to the subject incident.
14. Any and all documentation relating to the download/analysis of Event Data
Recorder and/or “Black Box” technology/equipment on the subject vehicle.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the above was provided via service
of process upon the Defendant, with the Summons and Complaint.
/s/ Christopher W. Waters
Christopher W. Waters, Esq.
Florida Bar No.: 124556
Primary E—Mail: Service@PigasLaw.com
Secondary E-Mail: Chris@PipasLaw.com
PIPAS LAW GROUP
360 Central Avenue, Suite 1570
St. Petersburg, FL 33701
Phone: (727) 888-3925
Fax: (727) 258-0082
Attorney for Plaintiff
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Case Number:23-000467-CI Filing # 165757041 E-Filed 01/30/2023 04:40:32 PM IN THE CIRCUIT COURT FOR THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CIVIL DIVISION ROBERT KNIGHT, Plaintiff, v. CASE NO.: KATELINE LEWIS, Defendant. ________________________/ PLAINTIFF’S FIRST REQUEST TO PRODUCE TO DEFENDANT COMES NOW the Plaintiff, ROBERT KNIGHT, by and through the undersigned counsel, pursuant to Rule 1.350, Florida Rules of Civil Procedure, and hereby requests that the Defendant, KATELINE LEWIS, produce for inspection and/or copying by counsel for Plaintiff, the following documents, said documents to be produced at the offices of Pipas Law Group, 360 Central Avenue, Suite 1570, St. Petersburg, Florida, 33701, on or before forty-five (45) days from the date of service hereof. 1. Any and all policies of insurance and indemnity agreements (including declaration sheets) providing coverage to the Defendant(s) for the subject incident. 2. Any and all written or recorded statements of the Plaintiff. 3. Any and all claims, proof of loss and notices of incidents prepared by investigators, adjusters, claims personnel or other agents or employees of Defendant(s) from information obtained directly from the Plaintiff regarding the subject incident. 4. Any and all written or recorded statements taken from parties or witnesses concerning any issue in this case. 5. Any and all photographs, video recordings, graphs, charts and other documentary evidence of the scene, parties, or vehicles involved in or pertaining to the subject incident, occurrence or issues in this case. ***ELECTRONICALLY FILED 01/30/2023 04:40:31 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** Any and all surveillance tapes, videos, movies, photography, and reports of the Plaintiff, including, but not limited to, surveillance videotapes and photographs. Documents relating to or discussing repairs or maintenance t0 the Defendant’s vehicle that were done for the six (6) months prior to and including the date of the accident, and for the six (6) months following the date of the accident. Any and all repair bills or estimates concerning the damage to any vehicles involved in the subject incident. Any and all laser color copies of all pictures, photographs, Video tapes or recordings, or slides of any and all vehicles involved in the subject incident. 10. The cellular phone records for the Defendant driver which reflect incoming and outgoing calls and text messages from 12:00 A.M. on the date of accident to 12:00 A.M. the following day. If unavailable, please provide the cellular telephone number of the Defendant driving during that time period, the name of his or her phone carrier, and the name under which the account is listed. 11. Any and all documentation evidencing ownership and leasehold interests in the vehicle being operated by the Defendant, KATELINE LEWIS, at the time of the subject incident, including, but not limited to, title,registration, lease agreement, etc. 12. Any and all records regarding any automobile accidents in which the Defendant, KATELINE LEWIS, was involved for the three (3) years prior to the subject incident. 13. Any and all records regarding any automobile accidents in which the Defendant, KATELINE LEWIS, was involved subsequent to the subject incident. 14. Any and all documentation relating to the download/analysis of Event Data Recorder and/or “Black Box” technology/equipment on the subject vehicle. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above was provided via service of process upon the Defendant, with the Summons and Complaint. /s/ Christopher W. Waters Christopher W. Waters, Esq. Florida Bar No.: 124556 Primary E—Mail: Service@PigasLaw.com Secondary E-Mail: Chris@PipasLaw.com PIPAS LAW GROUP 360 Central Avenue, Suite 1570 St. Petersburg, FL 33701 Phone: (727) 888-3925 Fax: (727) 258-0082 Attorney for Plaintiff