Party Discovery: MILLER, WARREN vs DELGATTO, JOAN et al

• 
• 
• 
• 

						
                                
Preview
                                Filing # 193499182 E-Filed 03/07/2024 09:16:52 AM
                          IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT
                        IN AND FOR THE COUNTY OF SUMTER, STATE OF FLORIDA
                                                  CIVIL DIVISION

          WARREN     MILLER,

                    Plaintiff,

          vs.                                                     CASE NO.:
                                                                  DIVISION:
          LISA KESSLER; JOAN DELGATTO; and
          GEICO GENERAL INSURANCE
          COMPANY,

                    Defendants.
                                                              /

                PLAINTIFF’S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS                               TO
                       DEFENDANT, GEICO GENERAL INSURANCE COMPANY

                  COMES     NOW     the Plaintiff, WARREN         MILLER,     by and through his undersigned

          attorney, pursuant to Florida Rules of Civil Procedure, Rule 1.350, requests the Defendant,

          GEICO    GENERAL        INSURANCE     COMPANY,          produce at the office of Catania & Catania,

          P.A., Bank of America Plaza, Suite 2400, 101 E. Kennedy Blvd., Tampa, Florida 33602, within

          forty-five (45) days the following documents requested in Schedule A.

                                           CERTIFICATE OF SERVICE

                  1 HEREBY CERTIFY that a true and correct copy of the foregoing was furnished to the

          Defendant via service of process.

                                                        CATANIA & CATANIA, P.A.

                                                         VT eR                Y   \?         LL
                                                        MARC B. PARISH, ESQUIRE
                                                        FBN: 0056714
                                                        efiling@cataniaandcatania.com
                                                        Bank of America Plaza, Suite 2400
                                                        101 E. Kennedy Boulevard
                                                        Tampa, FL 33602
                                                        813/222-8545
                                                        Attorney for Plaintiff




        Electronically Filed Sumter Case # 2024CA000129AXMX 03/07/2024 09:16:52 AM
SCHEDULE      A

         1  Any photographs of the vehicles involved in the accident, any photographs at the
scene of the accident, and any photographs of the Plaintiff in his injured condition, including
photographs illustrating any personal injuries alleged by the Plaintiff.

         2.    Any and all written or recorded statements taken from the Plaintiff concerning any
issues in this cause.

         3. Any and all photographs, graphs, charts, and other documentary evidence of the scene,
parties, or vehicles involved in or pertaining to the subject accident or occurrence or the issues in
this cause.

         4.    All written statements, including opinion, memoranda and reports of defendant and
defendant's agents and employees which defendant expects to introduced into evidence at the
trial of this case.

        5. All written statements, including opinions, memoranda and reports of any and all
witnesses and especially experts which defendant expects to introduce into evidence or utilize at
the trial of this cause.

         6. A complete copy of the policy of insurance issued to Plaintiff which is the subject of
this action.

         7. Any surveillance movies or photographs which have been made of the Plaintiff.

        8. A complete copy of certified declaration and coverage pages any and all policies of
insurance in your possession which provide or which may provide coverage to the Defendant.