On February 28, 2024 a
Party Discovery
was filed
involving a dispute between
Kowalski, Jessica,
and
Knight Transportation, Llc,
Lucas, Jeremy Michael,
for Civil
in the District Court of Hillsborough County.
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Filing # 192915215 E-Filed 02/28/2024 12:00:27 PM
IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH COUNTY FLORIDA,
CIVIL DIVISION
JESSICA KOWALSKI,
Plaintiff,
CASE NO:
-vs-
JEREMY MICHAEL LUCAS and KNIGHT
TRANSPORTATION, LLC,
Defendant(s).
/
REQUEST TO PRODUCE
PURSUANT TO Rule 1.350, Florida Rules of Civil Procedure, Plaintiff, JESSICA
KOWALSKI, by and through his undersigned attorney, requests Defendant, JEREMY MICHAEL
LUCAS, to produce for inspection or copying the documents set forth below. Defendant shall
produce these documents to Amy Ferrera, Esquire, c/o Morgan & Morgan Tampa P.A., 201 N.
Franklin Street 7th Floor, Tampa, FL 33602, within 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.
2. All statements made by any witnesses to the subject accident.
3. All statements made by the Plaintiff pertaining to or concerning the subject matter.
4. All color photographs of the vehicles involved in the subject accident.
5. All color photographs of the Defendant depicting injuries received in the subject
accident.
2/28/2024 12:00 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
6. 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.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true copy of the foregoing has been furnished to the
Defendant, together with the Summons and Complaint.
/s/ Amy Ferrera
Amy Ferrera, Esquire
Florida Bar #: 15313
Morgan & Morgan Tampa P.A.
201 N Franklin St, 7th Floor
Tampa, FL 33602
Tele: (813) 577-4738
Fax: (813) 559-4846
Primary email: AMFpleadings@Forthepeople.com
Secondary email: sneal@forthepeople.com
Attorney for Plaintiff
2/28/2024 12:00 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
Document Filed Date
February 28, 2024
Case Filing Date
February 28, 2024
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Filing # 192915215 E-Filed 02/28/2024 12:00:27 PM IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY FLORIDA, CIVIL DIVISION JESSICA KOWALSKI, Plaintiff, CASE NO: -vs- JEREMY MICHAEL LUCAS and KNIGHT TRANSPORTATION, LLC, Defendant(s). / REQUEST TO PRODUCE PURSUANT TO Rule 1.350, Florida Rules of Civil Procedure, Plaintiff, JESSICA KOWALSKI, by and through his undersigned attorney, requests Defendant, JEREMY MICHAEL LUCAS, to produce for inspection or copying the documents set forth below. Defendant shall produce these documents to Amy Ferrera, Esquire, c/o Morgan & Morgan Tampa P.A., 201 N. Franklin Street 7th Floor, Tampa, FL 33602, within 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. 2. All statements made by any witnesses to the subject accident. 3. All statements made by the Plaintiff pertaining to or concerning the subject matter. 4. All color photographs of the vehicles involved in the subject accident. 5. All color photographs of the Defendant depicting injuries received in the subject accident. 2/28/2024 12:00 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 6. 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. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing has been furnished to the Defendant, together with the Summons and Complaint. /s/ Amy Ferrera Amy Ferrera, Esquire Florida Bar #: 15313 Morgan & Morgan Tampa P.A. 201 N Franklin St, 7th Floor Tampa, FL 33602 Tele: (813) 577-4738 Fax: (813) 559-4846 Primary email: AMFpleadings@Forthepeople.com Secondary email: sneal@forthepeople.com Attorney for Plaintiff 2/28/2024 12:00 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2