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Filed: 8/31/2023 3:51 PM
Judge, Circuit Court
Grant County, Indiana
STATE OF INDIANA ) IN THE GRANT CIRCUIT COURT
) SS:
COUNTY OF GRANT ) CAUSE NO: 27C01-2307-CT-000053
STEVEN SMITH
Plaintiff
v.
RICHARD HALT
RITEWAY DELIVERY, INC.
FEDEX GROUND PACKAGE
SYSTEM, INC.
Defendants
PLAINTIFF’S REQUEST FOR PRODUCTION OF
DOCUMENTS TO THE DEFENDANT, RICHARD HALT
TO: Richard Halt
The Plaintiff, Steven Smith, hereby requests pursuant to Trial Rule 34 that the Defendant,
Richard Halt, produce the following:
1. Any liability insurance policy applicable in full force and effect on May 28, 2022,
with respect to the vehicle operated by the Defendant Richard Halt at the time of the accident,
involving Steven Smith, including the Declaration Sheet of said policy.
2. A copy of any statement of the Plaintiff concerning the facts of the accident of
May 28, 2022.
3. Copies of photographs of the vehicle operated by the Defendant on the date of the
accident.
4. Copies of photographs in the possession of the Defendant of the vehicle operated
by the Plaintiff on the date of the accident.
5. Copies of any photographs of the scene of the accident of May 28, 2022.
For purposes of this Request, the terms used herein shall have the following meanings:
A. "Document" and "documents" shall be used in their broadest sense and shall
mean and include all written, printed, typed, recorded or graphic matter of every kind and
description, both originals and copies, and all attachments and appendices thereto. Without
limiting the foregoing, the terms "document" and "documents" shall include all agreements,
contracts, communications, correspondence, letters, telegrams, telexes, messages, memoranda,
records, reports, books, summaries or other records of personal conversations of interviews, sum-
maries or other records of meetings and conferences, summaries or other records of negotiations,
other summaries, diaries, diary entries, calendars, appointment books, time records, instructions,
work assignments, visitor records, forecasts, statistical data, statistical statements, financial
statements, work sheets, work papers, drafts, graphs, maps, charts, tables, accounts, analytical
records, consultants, reports, notices, marginal notations, notebooks, telephone bills or records,
bills, statements, records of obligation and expenditure, invoices, lists, journals, advertising,
recommendations, files, printouts, compilations, tabulations, purchase orders, receipts, sell
orders, confirmations, checks, canceled checks, letters of credit, envelopes or folders or similar
containers, voucher analyses, studies, surveys, transcripts of hearings, transcripts of testimony,
expense reports, microfilm, microfiche, articles, speeches, tape or disc recordings, sound
recordings, video recordings, film, tapes, photographs, punch cards, programs, data compilations
from the information can be obtained (including matter used in data processing), and other
printed, written, handwritten, typewritten, recorded, stenographic, computer-generated,
computer-stored, or electronically-stored matter, however and by whomever produced, prepared,
reproduced, disseminated, or made. The terms "document" and "documents" shall include all
copies of documents by whatever means made, except that where a document is identified or
produced, identical copies thereof which do not contain any markings, additions, or deletions
different from the original need not be separately produced. Without limiting the term "control",
a document is deemed to be within your control if you have ownership, possession or custody of
the document, or the right to secure the document or copy thereof from any person or public or
private entity having physical possession thereof.
B. "You" and "your" shall mean Richard Halt as well as other persons acting or
purporting to act in behalf of Richard Halt including any attorney or other representative.
C. As used herein, the words "and" and "or" shall be construed either conjunctively
or disjunctively as required by the context to bring within the scope of these requests any
document that might be deemed outside its scope by another construction.
D. "Person" shall mean any individual, partnership, association, corporation, joint
venture, firm, proprietorship, agency board, authority, commission, or other legal or business
entity.
E. "Communication" shall mean and include every manner or means of disclosure,
transfer, or exchange, and every disclosure, transfer, or exchange of information, whether orally
or by document or whether face-to-face, by telephone, mail, personal delivery, or otherwise.
F. "Statement" means and includes any written or graphic statement signed or
otherwise adopted or approved by the users in making it, any stenographic, mechanical, electric
or other recording or transcription thereof which is a substantially verbatim recital or an oral
statement made by the person making it and contemporaneously recorded.
You are requested to provide Plaintiff's counsel, Whitney K. Beck, 401 West Walnut,
P.O. Box 868, Kokomo, IN 46903-0868, with true, accurate and legible copies of the requested
documents by mailing the same, by ordinary mail, to Plaintiff's counsel.
You are requested to comply with this Request for Production of Documents on or before
the 30th day of October, 2023.
Respectfully submitted,
/s/ Whitney K. Beck .
WHITNEY K. BECK
WHITNEY K. BECK - #30284-34
Attorney at Law
401 West Walnut Street
P.O. Box 868
Kokomo, IN 46903-0868
Telephone: (765) 456-1318
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a copy of the foregoing document has been served
on Defendant’s counsel this 30th day of August using DoxPop’s Electronic Filing System, which
sends notice to all registered parties via email.
/s/ Whitney K. Beck .
WHITNEY K. BECK
Preview
Filed: 8/31/2023 3:51 PM Judge, Circuit Court Grant County, Indiana STATE OF INDIANA ) IN THE GRANT CIRCUIT COURT ) SS: COUNTY OF GRANT ) CAUSE NO: 27C01-2307-CT-000053 STEVEN SMITH Plaintiff v. RICHARD HALT RITEWAY DELIVERY, INC. FEDEX GROUND PACKAGE SYSTEM, INC. Defendants PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS TO THE DEFENDANT, RICHARD HALT TO: Richard Halt The Plaintiff, Steven Smith, hereby requests pursuant to Trial Rule 34 that the Defendant, Richard Halt, produce the following: 1. Any liability insurance policy applicable in full force and effect on May 28, 2022, with respect to the vehicle operated by the Defendant Richard Halt at the time of the accident, involving Steven Smith, including the Declaration Sheet of said policy. 2. A copy of any statement of the Plaintiff concerning the facts of the accident of May 28, 2022. 3. Copies of photographs of the vehicle operated by the Defendant on the date of the accident. 4. Copies of photographs in the possession of the Defendant of the vehicle operated by the Plaintiff on the date of the accident. 5. Copies of any photographs of the scene of the accident of May 28, 2022. For purposes of this Request, the terms used herein shall have the following meanings: A. "Document" and "documents" shall be used in their broadest sense and shall mean and include all written, printed, typed, recorded or graphic matter of every kind and description, both originals and copies, and all attachments and appendices thereto. Without limiting the foregoing, the terms "document" and "documents" shall include all agreements, contracts, communications, correspondence, letters, telegrams, telexes, messages, memoranda, records, reports, books, summaries or other records of personal conversations of interviews, sum- maries or other records of meetings and conferences, summaries or other records of negotiations, other summaries, diaries, diary entries, calendars, appointment books, time records, instructions, work assignments, visitor records, forecasts, statistical data, statistical statements, financial statements, work sheets, work papers, drafts, graphs, maps, charts, tables, accounts, analytical records, consultants, reports, notices, marginal notations, notebooks, telephone bills or records, bills, statements, records of obligation and expenditure, invoices, lists, journals, advertising, recommendations, files, printouts, compilations, tabulations, purchase orders, receipts, sell orders, confirmations, checks, canceled checks, letters of credit, envelopes or folders or similar containers, voucher analyses, studies, surveys, transcripts of hearings, transcripts of testimony, expense reports, microfilm, microfiche, articles, speeches, tape or disc recordings, sound recordings, video recordings, film, tapes, photographs, punch cards, programs, data compilations from the information can be obtained (including matter used in data processing), and other printed, written, handwritten, typewritten, recorded, stenographic, computer-generated, computer-stored, or electronically-stored matter, however and by whomever produced, prepared, reproduced, disseminated, or made. The terms "document" and "documents" shall include all copies of documents by whatever means made, except that where a document is identified or produced, identical copies thereof which do not contain any markings, additions, or deletions different from the original need not be separately produced. Without limiting the term "control", a document is deemed to be within your control if you have ownership, possession or custody of the document, or the right to secure the document or copy thereof from any person or public or private entity having physical possession thereof. B. "You" and "your" shall mean Richard Halt as well as other persons acting or purporting to act in behalf of Richard Halt including any attorney or other representative. C. As used herein, the words "and" and "or" shall be construed either conjunctively or disjunctively as required by the context to bring within the scope of these requests any document that might be deemed outside its scope by another construction. D. "Person" shall mean any individual, partnership, association, corporation, joint venture, firm, proprietorship, agency board, authority, commission, or other legal or business entity. E. "Communication" shall mean and include every manner or means of disclosure, transfer, or exchange, and every disclosure, transfer, or exchange of information, whether orally or by document or whether face-to-face, by telephone, mail, personal delivery, or otherwise. F. "Statement" means and includes any written or graphic statement signed or otherwise adopted or approved by the users in making it, any stenographic, mechanical, electric or other recording or transcription thereof which is a substantially verbatim recital or an oral statement made by the person making it and contemporaneously recorded. You are requested to provide Plaintiff's counsel, Whitney K. Beck, 401 West Walnut, P.O. Box 868, Kokomo, IN 46903-0868, with true, accurate and legible copies of the requested documents by mailing the same, by ordinary mail, to Plaintiff's counsel. You are requested to comply with this Request for Production of Documents on or before the 30th day of October, 2023. Respectfully submitted, /s/ Whitney K. Beck . WHITNEY K. BECK WHITNEY K. BECK - #30284-34 Attorney at Law 401 West Walnut Street P.O. Box 868 Kokomo, IN 46903-0868 Telephone: (765) 456-1318 CERTIFICATE OF SERVICE The undersigned hereby certifies that a copy of the foregoing document has been served on Defendant’s counsel this 30th day of August using DoxPop’s Electronic Filing System, which sends notice to all registered parties via email. /s/ Whitney K. Beck . WHITNEY K. BECK