On February 19, 2024 a
Party Discovery
was filed
involving a dispute between
Vo, Son Ky,
and
Barlow, Garry V,
for AUTO NEGLIGENCE - CIRCUIT
in the District Court of Pinellas County.
Preview
Case Number:24-000811-CI
Filing # 192249935 E-Filed 02/19/2024 03:23:29 PM
***ELECTRONICALLY FILED 02/19/2024 03:23:27 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
5. Any and all records with regards to maintenance of vehicle driven and owned by
the Defendant, BARLOW, which was involved in the subject collision, for the one (l) year prior
to the collision.
6. Any and all photographs or diagrams of the collision scene.
7. Any and all 911 calls for the subject collision.
8. A certified copy of any and all insurance policies for the Defendant, BARLOW,
that may provide coverage for the subject accident.
9. Any and all photographs of Plaintiff‘s vehicle depicting the extent of damage
sustained in the subject collision. Please produce color photographs via Dropbox.
10. Any and all photographs 0f the vehicle driven by Defendant, BARLOW, depicting
the extent of damage sustained in the subject collision. Please produce color photographs via
Dropbox.
l 1. Any and all recorded statement(s) given by the Plaintiff.
12. Any recorded statement(s) given by Defendant, BARLOW.
l3. The Defendant, BARLOW’S cell phone records for the day 0f the subject collision,
April 27, 2023.
14. The complete employment file for Defendant, BARLOW.
15. A copy of Defendant, BARLOW’S driver’s license.
l6. The vehicle that Defendant, BARLOW, was driving at the time of the crash.
17. Any and all text messages sent and/or received by the Defendant, BARLOW,
within the one (1) hour prior to and one (l) hour after the subject collision.
18. A copy of any and all download / black box data from the Defendant’s vehicle in
connection with the subject collision.
l9. Any and all photographs and/or video taken 0f the collision and/or at the collision
scene, including any other car(s) involved in the collision.
20. The Defendant, BARLOW’S vehicle.
‘
Tampa, FL
Tel: (813) 425-2020 f Fax: (813) 435—2425
Attorneys for Plaintiff
eservice@markwrightlaw.com
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy 0f the foregoing was served with the
Complain. for Damages and Request for Jury Trial to the Defendants and filed with the Court 0n
I
day of February, 2024.
this
L
A TORNEY
Document Filed Date
February 19, 2024
Case Filing Date
February 19, 2024
Category
AUTO NEGLIGENCE - CIRCUIT
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Case Number:24-000811-CI Filing # 192249935 E-Filed 02/19/2024 03:23:29 PM ***ELECTRONICALLY FILED 02/19/2024 03:23:27 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** 5. Any and all records with regards to maintenance of vehicle driven and owned by the Defendant, BARLOW, which was involved in the subject collision, for the one (l) year prior to the collision. 6. Any and all photographs or diagrams of the collision scene. 7. Any and all 911 calls for the subject collision. 8. A certified copy of any and all insurance policies for the Defendant, BARLOW, that may provide coverage for the subject accident. 9. Any and all photographs of Plaintiff‘s vehicle depicting the extent of damage sustained in the subject collision. Please produce color photographs via Dropbox. 10. Any and all photographs 0f the vehicle driven by Defendant, BARLOW, depicting the extent of damage sustained in the subject collision. Please produce color photographs via Dropbox. l 1. Any and all recorded statement(s) given by the Plaintiff. 12. Any recorded statement(s) given by Defendant, BARLOW. l3. The Defendant, BARLOW’S cell phone records for the day 0f the subject collision, April 27, 2023. 14. The complete employment file for Defendant, BARLOW. 15. A copy of Defendant, BARLOW’S driver’s license. l6. The vehicle that Defendant, BARLOW, was driving at the time of the crash. 17. Any and all text messages sent and/or received by the Defendant, BARLOW, within the one (1) hour prior to and one (l) hour after the subject collision. 18. A copy of any and all download / black box data from the Defendant’s vehicle in connection with the subject collision. l9. Any and all photographs and/or video taken 0f the collision and/or at the collision scene, including any other car(s) involved in the collision. 20. The Defendant, BARLOW’S vehicle. ‘ Tampa, FL Tel: (813) 425-2020 f Fax: (813) 435—2425 Attorneys for Plaintiff eservice@markwrightlaw.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy 0f the foregoing was served with the Complain. for Damages and Request for Jury Trial to the Defendants and filed with the Court 0n I day of February, 2024. this L A TORNEY