No Value: TEGUE, GREGORY vs. HORNBUCKLE, CINDY

• 
• 
• 
• 
• 
• 
• 
• 

						
                                
Preview
                                IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
                    CHARLOTTE COUNTY, FLORIDA

                                       CASE NO: 23-         -559

 GREGORY TEGUE,

        Plaintiff,

 vs.

 CINDY HORNBUCKLE and THE
 STANDARD FIRE INSURANCE
 COMPANY, a Florida Profit
 Corporation,

        Defendants.
                                               /

                                   REQUEST TO PRODUCE

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

counsel requests that the Defendant, CINDY HORNBUCKLE, 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.

       All statements made by any witnesses to the subject accident or from individuals who have

       knowledge of alleged injuries and prior subsequent accidents.

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

       All photographs of the vehicles involved in the subject accident.

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

       All photographs of the subject accident scene.

       Copy of any dashboard camera videos from the vehicles involved in the subject accident that

       recorded the accident and events prior and after the accident.
Copy of any videos that document the subject accident and events prior to and after the

accident.

Copy of any photographs or videos of the Plaintiff posted on social media/YouTube/internet.

Copy of downloaded data of the subject accident from any electronic control module

(ECM)/event recorder (“black box”) from the subject vehicles operated on the date of the

accident.

Copy of any recorded data on the date of accident from a GPS system/Fleet Tracker and or

other monitoring system/On-Star       or other emergency call system for the subject vehicles

involved in the acciden

Copy of 911 emergency calls reporting the subject accident.

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.

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.

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

Appraisals of the property damage sustained by Plaintiff's vehicle in the subject accident.

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

of the subject accident.

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




                                            2
       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.

       Copies of any and all computer generated documents in the possession of the Defendant or

       any agent, servant and/or employee of the Defendant, which pertains or relate, in any manner

       or fashion, to and any past claims history of the Plaintiff in this lawsuit.

       Copies of any and all checks issued by the Defendant or any agent, servant and/or employee

       of the Defendant 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.

       All payout records for the insurer of the Defendant for benefits paid to or on behalf of Plaintiff

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

       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.

       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 Angela Agostino, Attorney at the offices of Morgan, &

Morgan, 12800 University Dr, Suite 600, Fort Myers FL 33907.

       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 tha

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




                                                   3
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, along with the summons and complaint.

                                                    /s/ Angela C. Agostino, Esq.
                                                    ANGELA C. AGOSTINO, Esq.
                                                    Florida Bar No.: 91290
                                                    Morgan & Morgan, P.A.
                                                    12800 University Drive, Suite 600
                                                    Fort Myers, FL 33907
                                                    Telephone: (239) 243-0427
                                                    Facsimile: (239) 210-5362
                                                    Primary Email:aagostino@forthepeople.com
                                                    Counsel for Plaintiff




                                                4