On March 20, 2023 a
was filed
involving a dispute between
Owens, Marvin Jr,
and
Rhodes, Zofia Zak,
for Auto Negligence
in the District Court of Charlotte County.
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Filing # 182662038 E-Filed 09/26/2023 09:56:35 PM
IN THE CIRCUIT COURT OF THE 20™ JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
MARVIN OWENS, JR., CIVIL DIVISION
Plaintiff, CASE NO.: 23-000608 CA
Vv.
ZOFIA ZAK RHODES,
Defendant.
/
PLAINTIFF’S REQUEST FOR PRODUCTION TO
DEFENDANT, ZOFIA ZAK RHODES
The Plaintiff, MARVIN OWENS, JR., by and through the undersigned attorneys, hereby
requests the Defendant, ZOFIA ZAK RHODES, produce for inspection and/or photocopying
within thirty (30) days from the date of service of this request, pursuant to Fla.R.Civ.P., at
RUBENSTEIN LAW, P.A., 9130 S Dadeland Blvd, PH Suite, Miami, FL 33156, the following:
1 Any photographs (in color) taken by or on behalf of the Defendant that relate to the parties
and/or scene of the alleged occurrence.
Any and all statements of the Plaintiff, Plaintiffs agents or employees, revealing
knowledge of facts relevant and material to the claims and defenses in the instant litigation.
Any and all insurance policies providing benefits or coverage to the Defendant for any
claims injury or damage and the claim forms and records related to same for the subject
accident or occurrence.
Any and all records reflecting the ownership, call logs, data usage, and/or text usage of any
cellular telephone that you had in your possession or at your disposal at the time of this
accident.
Any and all photographs (in color) of vehicle damage that was sustained by the Plaintiff or
the Defendant on July 25, 2022.
Any and all data collected by any electronic data recording device that was operational in
your vehicle at the time of the accident which occurred on July 25, 2022.
23000608CA
Any and all video tapes of the area where the car accident occurred.
Any and all bills and/or estimates (including supplemental estimates) for repair to your
vehicle or to the Plaintiff's vehicle as a result of the subject incident.
Any and all contracts including any indemnity agreements between Zofia Zak Rhodes and
any third parties responsible for the operation of the vehicle that you were operating on
July 25, 2022.
10. Any and all bills and/or estimates of repairs of vehicle and/or damage to property arising
from the accident which occurred on or about July 25, 2022.
11 Any and all photographs, diagrams, charts or drawings pertaining to and acquired by the
Defendant as an alleged result of the accident giving rise to this suit.
12 Any and all photographs (in color) and/or video recording of the Plaintiff, resulting from
surveillance and/or investigation of the Plaintiff.
13 Any transcript from traffic Court or any other Court involving the subject matter of the
instant litigation and/or present name, address and telephone number of the court reporter
present at said court.
14 Clear and legible copy of the Defendant’s driver’s license.
15 Clear and legible copy of motor vehicle registration of the motor vehicle operated by the
Defendant at the time of the accident which is the subject matter of this lawsuit.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was electronically
submitted on this 26" day of September, 2023, to: Jesse Gubernat, Esq., Banker Lopez Gassler
P.A, 4415 Metro Parkway, Suite 208, Fort Myers, FL 33916, service-
jgubernat@bankerlopez.com.
RUBENSTEIN LAW, P.A.
Attorneys for Plaintiff
9130 S Dadeland Blvd, PH Suite
Miami, Florida 33156
Tel: (305) 661-6000
Fax: (305) 670-7555
Email: tim@rubensteinlaw.com
jmolano@rubensteinlaw.com
23000608CA
service@rubensteinlaw.com
By: _/s/ R. Timothy Vannatta
R. TIMOTHY VANNATTA
Florida Bar No.: 0055890
Document Filed Date
November 03, 2023
Case Filing Date
March 20, 2023
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Filing # 182662038 E-Filed 09/26/2023 09:56:35 PM IN THE CIRCUIT COURT OF THE 20™ JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA MARVIN OWENS, JR., CIVIL DIVISION Plaintiff, CASE NO.: 23-000608 CA Vv. ZOFIA ZAK RHODES, Defendant. / PLAINTIFF’S REQUEST FOR PRODUCTION TO DEFENDANT, ZOFIA ZAK RHODES The Plaintiff, MARVIN OWENS, JR., by and through the undersigned attorneys, hereby requests the Defendant, ZOFIA ZAK RHODES, produce for inspection and/or photocopying within thirty (30) days from the date of service of this request, pursuant to Fla.R.Civ.P., at RUBENSTEIN LAW, P.A., 9130 S Dadeland Blvd, PH Suite, Miami, FL 33156, the following: 1 Any photographs (in color) taken by or on behalf of the Defendant that relate to the parties and/or scene of the alleged occurrence. Any and all statements of the Plaintiff, Plaintiffs agents or employees, revealing knowledge of facts relevant and material to the claims and defenses in the instant litigation. Any and all insurance policies providing benefits or coverage to the Defendant for any claims injury or damage and the claim forms and records related to same for the subject accident or occurrence. Any and all records reflecting the ownership, call logs, data usage, and/or text usage of any cellular telephone that you had in your possession or at your disposal at the time of this accident. Any and all photographs (in color) of vehicle damage that was sustained by the Plaintiff or the Defendant on July 25, 2022. Any and all data collected by any electronic data recording device that was operational in your vehicle at the time of the accident which occurred on July 25, 2022. 23000608CA Any and all video tapes of the area where the car accident occurred. Any and all bills and/or estimates (including supplemental estimates) for repair to your vehicle or to the Plaintiff's vehicle as a result of the subject incident. Any and all contracts including any indemnity agreements between Zofia Zak Rhodes and any third parties responsible for the operation of the vehicle that you were operating on July 25, 2022. 10. Any and all bills and/or estimates of repairs of vehicle and/or damage to property arising from the accident which occurred on or about July 25, 2022. 11 Any and all photographs, diagrams, charts or drawings pertaining to and acquired by the Defendant as an alleged result of the accident giving rise to this suit. 12 Any and all photographs (in color) and/or video recording of the Plaintiff, resulting from surveillance and/or investigation of the Plaintiff. 13 Any transcript from traffic Court or any other Court involving the subject matter of the instant litigation and/or present name, address and telephone number of the court reporter present at said court. 14 Clear and legible copy of the Defendant’s driver’s license. 15 Clear and legible copy of motor vehicle registration of the motor vehicle operated by the Defendant at the time of the accident which is the subject matter of this lawsuit. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was electronically submitted on this 26" day of September, 2023, to: Jesse Gubernat, Esq., Banker Lopez Gassler P.A, 4415 Metro Parkway, Suite 208, Fort Myers, FL 33916, service- jgubernat@bankerlopez.com. RUBENSTEIN LAW, P.A. Attorneys for Plaintiff 9130 S Dadeland Blvd, PH Suite Miami, Florida 33156 Tel: (305) 661-6000 Fax: (305) 670-7555 Email: tim@rubensteinlaw.com jmolano@rubensteinlaw.com 23000608CA service@rubensteinlaw.com By: _/s/ R. Timothy Vannatta R. TIMOTHY VANNATTA Florida Bar No.: 0055890