On February 26, 2019 a
to Discount Tire Co etc by Tammy Bradford etc
was filed
involving a dispute between
Tammy Bradford,
and
Discount Tire Co,
for PRODUCTS LIABILITY
in the District Court of Volusia County.
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Filing # E-Filed 11/19/2020 02:05:56 PM
IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT IN AND FOR
VOLUSIA COUNTY, FLORIDA
TAMMY BRADFORD,
as Personal Representative of the Estate
of MICHAEL BLAZE BRADFORD, deceased; CASE NO.: 2019 10377 CIDL
and as Personal Representative of the
Estate of WARREN MICHAEL BRADFORD,
Deceased
Plaintiff,
vs.
MICHELIN NORTH AMERICA, INC.,
a foreign corporation; and DISCOUNT
TIRE CO., a Florida corporation
Defendants.
/
PLAINTIFF'S SECOND REQUEST FOR PRODUCTION TO DEFENDANT,
DISCOUNT TIRE CO.
The Plaintiff, by and through her undersigned counsel, propounds the following Requests
for Production to Defendant, Discount Tire Co., to be answered in accordance with the Florida
Rules of Civil Procedure. Your answers must be in writing and under oath. Each answer should
state fully such of the information requested as is known to you, reasonably believed by you, or
available to you or your agents or attorneys and you are to serve your answers upon the
undersigned within thirty (30) days after service of these discovery requests upon you.
REQUESTS FOR PRODUCTION
1. If you deny Request for Admission No. 2, please produce all documents which support
DT-FL' s inference that DT-FL did warn Michael Blaze Bradford about aged tires remaining on
his vehicle when he purchased two new tires from DT-FL on February 11, 2017 and February
13, 2017.
RESPONSE:
2. If you deny Request for Admission No. 4, please produce all documents which support
DT-FL' s inference that Michael Blaze Bradford would not have purchased four new tires rather
than two new tires from DT-FL on February 11, 2017 and February 13, 2017 if he had been
warned about aged tires remaining on his vehicle.
RESPONSE:
3. If you deny Request for Admission No. 6, please produce all documents which support
DT-FL' s inference that Michael Blaze Bradford would not have replaced aged tires remaining on
his vehicle before the accident if DT-FL had warned Michael Blaze Bradford about aged tires on
February 11, 2017 and February 13, 2017.
RESPONSE:
4. If you deny Request for Admission No. 7, please produce all documents which prove or
disprove any discussions between Michael Blaze Bradford and DT-FL.
RESPONSE:
5. If you deny Request for Admission No. 12, please produce all documents which support
DT-FL' s allegation that the subject tire (as described in the complaint) was not on the subject
vehicle on February 13, 2017.
RESPONSE:
6. If you deny Request for Admission No. 14, please produce all documents which support
DT-FL' s allegation that the subject tire was not the tire that DT-FL rotated on February 13, 2017.
RESPONSE:
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on 11/19/20, the foregoing was electronically filed with the Clerk
of Court by using the Florida Courts e-Filing Portal and served on all parties by the e-portal.
Respectfully submitted,
KASTER, LYNCH, FARRAR & BALL, LLP
BY: /s/Skip Edward Lynch
Skip Edward Lynch
Florida Bar No. 0021085
Skip @thetirelawyers.com
josh@thetirelawyers.com
Jessica@thetirelawyers.com
Bruce R. Kaster
Florida Bar No. 200271
brk@thetirelawyers.com
daneen@thetirelawyers.com
125 N.E. 1st Avenue, Suite 3
Ocala, FL 34470
Phone: 352-622-1600
Fax: 352-622-1611
ATTORNEYS FOR PLAINTIFF
Document Filed Date
November 19, 2020
Case Filing Date
February 26, 2019
Category
PRODUCTS LIABILITY
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Filing # E-Filed 11/19/2020 02:05:56 PM IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT IN AND FOR VOLUSIA COUNTY, FLORIDA TAMMY BRADFORD, as Personal Representative of the Estate of MICHAEL BLAZE BRADFORD, deceased; CASE NO.: 2019 10377 CIDL and as Personal Representative of the Estate of WARREN MICHAEL BRADFORD, Deceased Plaintiff, vs. MICHELIN NORTH AMERICA, INC., a foreign corporation; and DISCOUNT TIRE CO., a Florida corporation Defendants. / PLAINTIFF'S SECOND REQUEST FOR PRODUCTION TO DEFENDANT, DISCOUNT TIRE CO. The Plaintiff, by and through her undersigned counsel, propounds the following Requests for Production to Defendant, Discount Tire Co., to be answered in accordance with the Florida Rules of Civil Procedure. Your answers must be in writing and under oath. Each answer should state fully such of the information requested as is known to you, reasonably believed by you, or available to you or your agents or attorneys and you are to serve your answers upon the undersigned within thirty (30) days after service of these discovery requests upon you. REQUESTS FOR PRODUCTION 1. If you deny Request for Admission No. 2, please produce all documents which support DT-FL' s inference that DT-FL did warn Michael Blaze Bradford about aged tires remaining on his vehicle when he purchased two new tires from DT-FL on February 11, 2017 and February 13, 2017. RESPONSE: 2. If you deny Request for Admission No. 4, please produce all documents which support DT-FL' s inference that Michael Blaze Bradford would not have purchased four new tires rather than two new tires from DT-FL on February 11, 2017 and February 13, 2017 if he had been warned about aged tires remaining on his vehicle. RESPONSE: 3. If you deny Request for Admission No. 6, please produce all documents which support DT-FL' s inference that Michael Blaze Bradford would not have replaced aged tires remaining on his vehicle before the accident if DT-FL had warned Michael Blaze Bradford about aged tires on February 11, 2017 and February 13, 2017. RESPONSE: 4. If you deny Request for Admission No. 7, please produce all documents which prove or disprove any discussions between Michael Blaze Bradford and DT-FL. RESPONSE: 5. If you deny Request for Admission No. 12, please produce all documents which support DT-FL' s allegation that the subject tire (as described in the complaint) was not on the subject vehicle on February 13, 2017. RESPONSE: 6. If you deny Request for Admission No. 14, please produce all documents which support DT-FL' s allegation that the subject tire was not the tire that DT-FL rotated on February 13, 2017. RESPONSE: CERTIFICATE OF SERVICE I HEREBY CERTIFY that on 11/19/20, the foregoing was electronically filed with the Clerk of Court by using the Florida Courts e-Filing Portal and served on all parties by the e-portal. Respectfully submitted, KASTER, LYNCH, FARRAR & BALL, LLP BY: /s/Skip Edward Lynch Skip Edward Lynch Florida Bar No. 0021085 Skip @thetirelawyers.com josh@thetirelawyers.com Jessica@thetirelawyers.com Bruce R. Kaster Florida Bar No. 200271 brk@thetirelawyers.com daneen@thetirelawyers.com 125 N.E. 1st Avenue, Suite 3 Ocala, FL 34470 Phone: 352-622-1600 Fax: 352-622-1611 ATTORNEYS FOR PLAINTIFF