Document for JAHNEE HOLMES VS J HOWARD

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                                Filing # 112659268 E-Filed 08/3 1/2020 04:41:07 PM




                                       IN THE CIRCUIT COURT OF THE EIGHTEENTH
                                           JUDICIAL CIRCUIT IN AND FOR BREVARD
                                                     COUNTY FLORIDA

                                                                CASE NO:

            JAHNEE HOLMES,

                               Plaintiff,

            vs.


            JOSHUA HOWARD,

                               Defendant.




                                                       REQUEST TO PRODUCE

                       Pursuant to the provisions of Rule 1.350, Florida Rules of Civil Procedure, the undersigned

            counsel requests that the Defendant(s), JOSHUA HOWARD, 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.

                       All statements made by the Plaintiff(s) pertaining to or concerning the subject matter.

                       All photographs of the vehicles involved in the subject accident.

                       All photographs of the Plaintiff(s) depicting injuries received in the subject accident.

                       All photographs of the subject accident scene.

                       Documents relating to or discussing repairs or maintenance to Defendant’s(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.




 Filing 112659268                            VS                                                         05-2020-CA-040792-XXXX-XX
The repair bill and estimates for the repairs to any of the vehicles involved in the accident for

                   damages incurred in the accident.

                   Any and all policies of liability insurance in effect on the date of the subject accident, providing

                   coverage to the defendant herein.

            10.    Appraisals of all property damage sustained by Defendant's(s’) vehicle in the subject accident.

            11     Appraisals of the property damage sustained by Plaintiff's(s’) vehicle in the subject accident.

            12.    A copy of any and all surveillance films, photos, or depictions taken of the Plaintiff as a result of the

                   subject accident.

            13     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.

            14.    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 pertains or relate, in any manner or

                   fashion, to and any past claims history of the Plaintiff(s) in this lawsuit.

            15     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.

            16.    All payout records for the insurer of the Defendant(s) for benefits paid to or on behalf of Plaintifi(s)

                   under the personal injury protection and medical payment coverage of the policy.

            17.    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.




Filing 112659268                          VS                                                          05-2020-CA-040792-XXXX-XX
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 Ryan McCarville,     at the offices of Morgan & Morgan, P.A., 940

           South Harbor City Boulevard, Melbourne, FL 32901.

                   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 such possession and control.        This request is made in good faith and for the

           purposes herein expressed.

                                              CERTIFICATE OF SERVICE

                   I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon

           said Defendant(s), along with the summons and complaint.




                                                                    Zs/ Ryan McCarville
                                                                    Ryan McCarville, Esq.
                                                                    FBN: 0117831
                                                                    Morgan & Morgan, P.A.
                                                                    940 S Harbor City Blvd
                                                                    Melbourne, FL 32901
                                                                    Telephone: (321) 327-6263
                                                                    Facsimile: (321) 327-6897
                                                                    Primary email: rmecarville@forthepeople.com
                                                                    Secondary email:
                                                                    mhutchinsonwilkins@forthepeople.com
                                                                    Attorney for Plaintiff




Filing 112659268                        VS                                                       05-2020-CA-040792-XXXX-XX