Preview
16-2020-CA-006698-XXXX-MA Div: CV-F
Filing # 117385800 E-Filed 11/30/2020 04:20:04 PM
LEISA JONES; and MIA GRAHAM, IN THE CIRCUIT COURT, FOURTH
JUDICIAL CIRCUIT, IN AND FOR,
Plaintiffs, DUVAL COUNTY, FLORIDA
vs. CASE NO.:
DIVISION:
JOHN MORRISEY; C&K TRUCKING, LLC;
and PROGRESSIVE SELECT INSURANCE
COMPANY,
Defendants.
/
PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION TO
DEFENDANT, JOHN MORRISEY
Plaintiffs, LEISA JONES and MIA GRAHAM, pursuant to Rules 1.280 and 1.350, Florida
Rules of Civil Procedure, hereby request that Defendant, REBECA HERNANDEZ, produce and
permit Plaintiff to inspect and/or copy or photograph, at the offices of Farah & Farah, P.A., 1534
Kingsley Avenue, Orange Park, Florida 32073, within the time provided for in the Rules, each of
the following documents:
DEFINITIONS
As used throughout this Request for Production, the following terms are defined as follows:
A. “Document” is used herein in its customary broad sense to include, by way of
illustration only and not by way of limitation, the following items, whether printed or reproduced
by any process, or written and/or produced by hand, and whether or not claimed to be privileged
or otherwise excludable from discovery, which are in the possession of, subject to the control of,
or within the knowledge of Defendant, its agents, servants, employees or its counsel; namely, all
written or printed matter of any kind including the original and all non-identical copies. Whether
different from the original by reason of any notation made on such copies or otherwise (including
without limitation correspondence, memoranda, notes, speeches, press releases, diaries, calendars,
ACCEPTED: DUVAL COUNTY, RONNIE FUSSELL, CLERK, 12/01/2020 09:20:31 AM
appointment books, statistics, letters, telegrams, minutes, contracts, reports, studies, checks,
statements, receipts, returns, summaries, pamphlets, books, prospectus, interoffice and intraoffice
communications offers, notations or memoranda of any sort of conversation, telephone calls,
meetings or other communications, bulletins, printed matter, computer printouts, teletypes, telefax,
invoices, modifications, changes and amendments of any kind of the foregoing), graphic or aural
records or representations of any kind (including without limitations photographs, charts, graphs,
microfiches, microfilm, videotapes, recordings, motion pictures) and electronics, mechanical or
electrical records or representations of any kind (including without limitations, tapes, cassettes,
discs, punchcards and records).
B The terms “relating to”, “in regard to” and “including” mean constituting,
comprising, containing, setting forth, showing, disclosing, describing, explaining, summarizing,
mentioning, concerning and/or referring to, directly or indirectly.
Cc “Person” shall mean individual, association, trust, public or private institute,
corporation or other legal entity.
CLAIM OF PRIVILEGE
If any document or statement is withheld from this request under a claim of privilege, then
please furnish a list which identifies each document or statement for which privilege is claimed
and include the following information for each such document:
1 The date(s);
2. The subject matter(s);
The sender(s) or author(s);
The recipient(s);
The persons to whom copies were furnished, together with their job titles; and
6 The basis on which privilege is claimed.
GROUPING OR NUMBERING OF ITEMS PRODUCED
It is requested that the documents or other items submitted in response to these Requests
for Production be grouped according to the individual request to which it is responsive and within
each group, arranged in chronological order.
ITEMS TO BE PRODUCED
1 Any and all photographs of the damages to any of the vehicles involved in this
accident.
2. Any and all estimates of repair or invoices for the repair of the damages to any of
the vehicles which resulted from this accident, including, but not limited to, Plaintiffs’ vehicle.
3 Any and all statements, transcripts, tapes etc. of any statement made by Plaintiffs
and in the possession of Defendant.
4 Copies of all insurance policies which may afford coverage to Defendant for
liability for the injuries alleged by Plaintiffs as a result of the accident described in the Complaint.
5 Copies of any and all photographs, slides, movies, video tapes, drawings or other
representations of the Plaintiffs.
6 Any and statements, including but not limited to, recorded telephone interviews,
tapes, written statements, whether signed or unsigned, of all witnesses to the incident relative to
the subject matter of this action and/or any witnesses having knowledge regarding any and all facts
and issues in the instant litigation.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing PLAINTIFFS’ REQUEST FOR
PRODUCTION OF DOCUMENTS TO DEFENDANT, JOHN MORRISEY, has been furnished
to the Defendant by process server along with the Summons and Complaint.
FARAH & FARAH, P.A.
/s/ Jeffrey L. Gadd
Jeffrey L. Gadd, Esquire
Florida Bar No.: 0027786
1534 Kingsley Avenue
Orange Park, Florida 32073
(904) 396-5555 (Telephone)
(904) 420-7746 (Facsimile)
Attorney for Plaintiff
jgadd@farahandfarah.com
myanko@farahandfarah.com
Preview
16-2020-CA-006698-XXXX-MA Div: CV-F Filing # 117385800 E-Filed 11/30/2020 04:20:04 PM LEISA JONES; and MIA GRAHAM, IN THE CIRCUIT COURT, FOURTH JUDICIAL CIRCUIT, IN AND FOR, Plaintiffs, DUVAL COUNTY, FLORIDA vs. CASE NO.: DIVISION: JOHN MORRISEY; C&K TRUCKING, LLC; and PROGRESSIVE SELECT INSURANCE COMPANY, Defendants. / PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION TO DEFENDANT, JOHN MORRISEY Plaintiffs, LEISA JONES and MIA GRAHAM, pursuant to Rules 1.280 and 1.350, Florida Rules of Civil Procedure, hereby request that Defendant, REBECA HERNANDEZ, produce and permit Plaintiff to inspect and/or copy or photograph, at the offices of Farah & Farah, P.A., 1534 Kingsley Avenue, Orange Park, Florida 32073, within the time provided for in the Rules, each of the following documents: DEFINITIONS As used throughout this Request for Production, the following terms are defined as follows: A. “Document” is used herein in its customary broad sense to include, by way of illustration only and not by way of limitation, the following items, whether printed or reproduced by any process, or written and/or produced by hand, and whether or not claimed to be privileged or otherwise excludable from discovery, which are in the possession of, subject to the control of, or within the knowledge of Defendant, its agents, servants, employees or its counsel; namely, all written or printed matter of any kind including the original and all non-identical copies. Whether different from the original by reason of any notation made on such copies or otherwise (including without limitation correspondence, memoranda, notes, speeches, press releases, diaries, calendars, ACCEPTED: DUVAL COUNTY, RONNIE FUSSELL, CLERK, 12/01/2020 09:20:31 AM appointment books, statistics, letters, telegrams, minutes, contracts, reports, studies, checks, statements, receipts, returns, summaries, pamphlets, books, prospectus, interoffice and intraoffice communications offers, notations or memoranda of any sort of conversation, telephone calls, meetings or other communications, bulletins, printed matter, computer printouts, teletypes, telefax, invoices, modifications, changes and amendments of any kind of the foregoing), graphic or aural records or representations of any kind (including without limitations photographs, charts, graphs, microfiches, microfilm, videotapes, recordings, motion pictures) and electronics, mechanical or electrical records or representations of any kind (including without limitations, tapes, cassettes, discs, punchcards and records). B The terms “relating to”, “in regard to” and “including” mean constituting, comprising, containing, setting forth, showing, disclosing, describing, explaining, summarizing, mentioning, concerning and/or referring to, directly or indirectly. Cc “Person” shall mean individual, association, trust, public or private institute, corporation or other legal entity. CLAIM OF PRIVILEGE If any document or statement is withheld from this request under a claim of privilege, then please furnish a list which identifies each document or statement for which privilege is claimed and include the following information for each such document: 1 The date(s); 2. The subject matter(s); The sender(s) or author(s); The recipient(s); The persons to whom copies were furnished, together with their job titles; and 6 The basis on which privilege is claimed. GROUPING OR NUMBERING OF ITEMS PRODUCED It is requested that the documents or other items submitted in response to these Requests for Production be grouped according to the individual request to which it is responsive and within each group, arranged in chronological order. ITEMS TO BE PRODUCED 1 Any and all photographs of the damages to any of the vehicles involved in this accident. 2. Any and all estimates of repair or invoices for the repair of the damages to any of the vehicles which resulted from this accident, including, but not limited to, Plaintiffs’ vehicle. 3 Any and all statements, transcripts, tapes etc. of any statement made by Plaintiffs and in the possession of Defendant. 4 Copies of all insurance policies which may afford coverage to Defendant for liability for the injuries alleged by Plaintiffs as a result of the accident described in the Complaint. 5 Copies of any and all photographs, slides, movies, video tapes, drawings or other representations of the Plaintiffs. 6 Any and statements, including but not limited to, recorded telephone interviews, tapes, written statements, whether signed or unsigned, of all witnesses to the incident relative to the subject matter of this action and/or any witnesses having knowledge regarding any and all facts and issues in the instant litigation. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing PLAINTIFFS’ REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT, JOHN MORRISEY, has been furnished to the Defendant by process server along with the Summons and Complaint. FARAH & FARAH, P.A. /s/ Jeffrey L. Gadd Jeffrey L. Gadd, Esquire Florida Bar No.: 0027786 1534 Kingsley Avenue Orange Park, Florida 32073 (904) 396-5555 (Telephone) (904) 420-7746 (Facsimile) Attorney for Plaintiff jgadd@farahandfarah.com myanko@farahandfarah.com