Document for Debuhr, Margaret Ruth

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                                11-2024-CA-000324-0001-XX

    Filing # 191920214 E-Filed 02/14/2024 10:01:22 AM


                                  IN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT
                                         IN AND FOR COLLIER COUNTY, FLORIDA

                                                                      GENERAL JURISDICTION DIVISION
             ADRIANA SHERMAN and
             ROBERT SHERMAN, her Husband                              CASE NO.:


             Plaintiffs,


             vs.

            MARGARET RUTH DEBURR and
            UNITED SERVICES AUTOMOBILE ASSOCIATION,

             Defendant.



                                     PLAINTIFF’S REQUEST FOR PRODUCTION TO
                                       DEFENDANT, MARGARET RUTH DEBUHR

                       Plaintiffs, ADRIANA      SHERMAN        and ROBERT       SHERMAN,   by and through     the

            undersigned counsel, requests the Defendant, MARGARET               RUTH   DEBURR,    to produce the

             following documents within forty-five (45) days after service of this request pursuant to the

             applicable Florida Rule of Civil Procedure.

                   1   Any and all damage      appraisals, repair bills and/or estimates of repair to the “2018”

                       Mercedes that was involved in the subject motor vehicle accident.

                       Any and all photographs of any vehicle involved in this accident showing property

                       damages.

                       Any and all photographs of Plaintiff showing injuries.

                       Any and all photographs of the accident scene.

                       Any other photographs of anything or person which is relevant and material to the claim

                       of the Plaintiff or the defenses of the Defendants.




FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 02/14/2024 10:01:22 AM
Any diagram, chart, map or description of the accident scene.

   Any and all written or recorded statements taken of Plaintiff.

   Any and all written or recorded statements taken of any witness.

   Any and all reports of any persons hired by Defendants that is expected to testify at trial

   as an expert.

10 Any and all documents pertaining to the financial responsibility of the Defendant,

   MARGARET           RUTH    DEBUHR      including any and all personal automobile insurance

   policies and excess/umbrella insurance policies.

11 Any   and all documents       pertaining   to driver qualifications   (including   licenses   and

   certifications) of the Defendant, MARGARET RUTH DEBUHR.

12. Any and all documents pertaining to       any maintenance of the “2018” Mercedes that is the

   subject of this lawsuit.

13 Any and all repair invoices for the “2018” Mercedes GLE 350 which is the subject of this

   lawsuit.

14 Any other thing, document or tangible piece of evidence material to this cause which

   Defendants      or defense counsel tentatively plan to introduce into evidence or make

   reference to at the trial of this cause.

15. Any and all activity logs and data from all “Black Box” data recorders, event data

   recorders, and electronic control modules from the “2018” Mercedes which is the subject

   of this lawsuit.

16 Any and all statements previously made by Defendant or Defendant’s agents.

17. Any and all reports from experts whom you intend to call at trial.

18. All documents which relate to or reflect that Defendant, MARGARET           RUTH DEBUHR
was injured in the subject motor vehicle accident.

   19 Any and all documents relied upon in compiling your Answers to Interrogatories.

   20 Any and all documents to relating to or reflecting any Personal Injury Protection or No-

      Fault claim filed on behalf of the Defendant, MARGARET          RUTH DEBURR, as a result

      of the subject motor vehicle accident.

   21 Copies of all records obtained by a records request and/or subpoena concerning the

      subject motor vehicle accident.

   22 Copies of all records obtained by a records request and/or subpoena concerning the

      Plaintiff's injuries sustained in the subject motor vehicle accident.

   23 Any and all video/dash cam footage of the accident including one hour before the

      accident through one hour after the accident.

   24 Any and all documents regarding the “2018” Mercedez “black box” and/or “digital box

      recorder” or GPS    system including any and all testing performed on the “black box”

      and/or “digital box recorder” subsequent to the accident.

                                    CERTIFICATE OF SERVICE


      I HEREBY CERTIFY that a true and correct copy of the foregoing was served upon the

Defendant with the Summons and Complaint.



                                               REIFKIND, THOMPSON & RUDZINSKI, LLP
                                               Attorneys for Plaintiff
                                               3333 W. Commercial Blvd., Suite # 200
                                               Ft. Lauderdale, FL 33309
                                               Phone:         (954) 370-5152
                                               Facsimile:     (954) 370-1992

                                               By:    /s/ Lance C. Rudzinski
                                                      Lance C. Rudzinski, Esq.
Florida Bar No. 0057018
lance@rtrlaw.com
 swift@rtrlaw.com
nhernandez@rtrlaw.com