On December 27, 2023 a
Party Discovery
was filed
involving a dispute between
Lasala, Kathleen,
and
Ride With Class Wheelchair Tra,
Rodriguez, Erika,
Safeco Insurance Company Of Il,
for Circuit Civil 3-C
in the District Court of Hernando County.
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Filing # 188696746 E-Filed 12/27/2023 12:22:28 PM
IN THE CIRCUIT COURT OF THE FIFTH CIRCUIT
IN AND FOR HERNANDO COUNTY, STATE OF FLORIDA
CIVIL DIVISION
KATHLEEN LASALA,
Plaintiff,
-Vs- CASE NO. :
ERIKA RODRIGUEZ, an individual, and
RIDE WITH CLASS WHEELCHAIR TRANSP(
A limited liability company, and
SAFECO INSURANCE COMPANY OF
ILLINOIS, a foreign profit corporation,
Defendants.
REQUEST TO PRODUCE
PURSUANT TO Rule 1.350, Florida Rules of Civil Procedure, Plaintiff, KATHLEEN
LASALA, by and through her undersigned counsel, requests that Defendant, RIDE WITH CLASS
MEDICAL TRANSPORTATION, produce for inspection or copying the documents set forth below.
Defendant shall produce these documents at 35686 U.S. Highway 19 North, Palm Harbor, Florida
34683within forty-five (45) days after service of this Request to Produce.
DEFENDANT SHALL PRODUCE THE FOLLOWING ITEMS AND MATTERS:
1 All statements made by any occupants of the vehicles involved in the subject
accident.
All statements made by any witnesses to the subject accident.
All statements made by the Plaintiff pertaining to or concerning the subject matter.
All color photographs of the vehicles involved in the subject accident.
All photographs of the Defendants or the Plaintiff depicting injuries received in the
subject accident.
Electronically Filed Hernando Case # 23001834CAAXMX 12/27/2023 12:22:28 PM
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 of 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.
Documents relating to or discussing repairs or maintenance to the Defendant's
vehicle that were done for the six (6) month 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 the Defendant's vehicle for damages
incurred in the accident.
Documents relating to or discussing any statements made by Defendants.
10. All photographs of the accident scene and surrounding areas.
11 Any and all documentation relating to the download/analysis of Event Data
Recorder and/or “Black Box” technology/equipment on the subject vehicle.
I HEREBY CERTIFY that a true copy of the foregoing has been furnished to the
Defendants, together with the Summons and Complaint.
/s/ MichaelJ. Vitoria, Esquire
Michael J. Vitoria, Esquire
Morgan & Morgan, P.A. — Palm Harbor
35686 U.S. Highway 19 North
Palm Harbor, Florida 34683
Tele: (727) 275-6090
Fax: (727) 275-6130
SERVICE EMAIL:
MvVPleadings@forthepeople.com
EMAIL:
MVitoria@ForThePeople.com
JVaughn@ForThePeople.com
SFor m@ForThePeople.com
KG: (@ForThePeople.com
Florida Bar #: 0135534
Attorney for Plaintiff
Document Filed Date
December 28, 2023
Case Filing Date
December 27, 2023
Category
Circuit Civil 3-C
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Filing # 188696746 E-Filed 12/27/2023 12:22:28 PM IN THE CIRCUIT COURT OF THE FIFTH CIRCUIT IN AND FOR HERNANDO COUNTY, STATE OF FLORIDA CIVIL DIVISION KATHLEEN LASALA, Plaintiff, -Vs- CASE NO. : ERIKA RODRIGUEZ, an individual, and RIDE WITH CLASS WHEELCHAIR TRANSP( A limited liability company, and SAFECO INSURANCE COMPANY OF ILLINOIS, a foreign profit corporation, Defendants. REQUEST TO PRODUCE PURSUANT TO Rule 1.350, Florida Rules of Civil Procedure, Plaintiff, KATHLEEN LASALA, by and through her undersigned counsel, requests that Defendant, RIDE WITH CLASS MEDICAL TRANSPORTATION, produce for inspection or copying the documents set forth below. Defendant shall produce these documents at 35686 U.S. Highway 19 North, Palm Harbor, Florida 34683within forty-five (45) days after service of this Request to Produce. DEFENDANT SHALL PRODUCE THE FOLLOWING ITEMS AND MATTERS: 1 All statements made by any occupants of the vehicles involved in the subject accident. All statements made by any witnesses to the subject accident. All statements made by the Plaintiff pertaining to or concerning the subject matter. All color photographs of the vehicles involved in the subject accident. All photographs of the Defendants or the Plaintiff depicting injuries received in the subject accident. Electronically Filed Hernando Case # 23001834CAAXMX 12/27/2023 12:22:28 PM 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 of 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. Documents relating to or discussing repairs or maintenance to the Defendant's vehicle that were done for the six (6) month 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 the Defendant's vehicle for damages incurred in the accident. Documents relating to or discussing any statements made by Defendants. 10. All photographs of the accident scene and surrounding areas. 11 Any and all documentation relating to the download/analysis of Event Data Recorder and/or “Black Box” technology/equipment on the subject vehicle. I HEREBY CERTIFY that a true copy of the foregoing has been furnished to the Defendants, together with the Summons and Complaint. /s/ MichaelJ. Vitoria, Esquire Michael J. Vitoria, Esquire Morgan & Morgan, P.A. — Palm Harbor 35686 U.S. Highway 19 North Palm Harbor, Florida 34683 Tele: (727) 275-6090 Fax: (727) 275-6130 SERVICE EMAIL: MvVPleadings@forthepeople.com EMAIL: MVitoria@ForThePeople.com JVaughn@ForThePeople.com SFor m@ForThePeople.com KG: (@ForThePeople.com Florida Bar #: 0135534 Attorney for Plaintiff