On March 20, 2024 a
Party Discovery
was filed
involving a dispute between
Morales, David Rodriguez,
and
Blanco, Mateo,
for CIRCUIT CIVIL
in the District Court of Osceola County.
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Filing # 194470392 E-Filed 03/20/2024 05:09:36 PM
IN THE CIRCUIT COURT
OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY,
FLORIDA
CASE NO:
DAVID RODRIGUEZ MORALES,
Plaintiff,
v.
MATEO BLANCO,
Defendants.
____________________________________/
PLAINTIFF, DAVID RODRIGUEZ MORALES’S REQUEST TO PRODUCE
TO DEFENDANT MATEO BLANCO
Pursuant to the provisions of Rule 1.350, Florida Rules of Civil Procedure, the
undersigned counsel requests that the Defendant, MATEO BLANCO, produce and permit the
inspection, copying, testing, sampling, measuring, surveying, photographing or otherwise
examining the following:
1) All statements made by any occupants of the vehicles involved in the subject
incident.
2) All statements made by any witnesses to the subject accident.
3) All statements made by the Plaintiffs pertaining to or concerning the subject
matter.
4) All photographs of the vehicles involved in the subject accident.
5) All photographs of the Plaintiffs depicting injuries received in the subject
accident.
6) All photographs of the subject accident scene.
7) Documents relating to or discussing repairs or maintenance to Defendants’
vehicle that were done for the six (6) months period of time preceding and including the date of
the accident and for the six (6) month period of time following the date of the accident.
8) The repair bill and estimates for the repairs to any of the vehicles involved in the
accident for damages incurred in the accident.
9) Any and all policies of liability insurance in effect on the date of the subject
accident, providing coverage to the defendant herein.
10) Appraisals of all property damage sustained by Defendants’ vehicle in the subject
accident.
11) Appraisals of the property damage sustained by Plaintiff's vehicle in the subject
accident.
12) A copy of any and all surveillance films, photos, or depictions taken of the
Plaintiffs as a result of the subject accident.
13) 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 or 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.
14) Copies of any and all computer generated documents in the possession of the
Defendants or any agent, servant and/or employee of the Defendants, which pertains or relate, in
any manner or fashion, to and any past claims history of the Plaintiffs in this lawsuit.
15) Copies of any and all checks issued by the Defendants or any agent, servant
and/or employee of the Defendants to any other person, firm or company making a claim arising
out of the same accident or incident which is the basis of this lawsuit.
16) All payout records for the insurer of the Defendants for benefits paid to or on
behalf of Plaintiffs under the personal injury protection and medical payment coverage of the
policy.
17) A copy of Defendant, MATEO BLANCO’s driver’s license that existed on the
date of the accident as well as the current driver’s license.
18) A copy of the Defendant, MATEO BLANCO’s, mobile phone bill depicting all
telephone, text and data usage for the billing period for the subject date of loss.
It is requested that the above document be furnished or produced on or before forty-five
(45) days from the date of service hereof, to S. Maxwell Karrick, Esquire, at the offices of Dan
Newlin & Partners, 7335 Sand Lake Road, Ste. 300, Orlando, FL 32819.
In support of this Request To Produce, it is shown that the documents and/or materials
being here requested are believed to be in the possession, custody or control of the party to
whom this request is directed. The information sought by this request is relevant to the subject
matter of this action and cannot otherwise be obtained without undue hardship. In the event that
all or part of the documents, and/or materials herein requested are not in the possession or
control of the above-named Defendant addressee, then the undersigned counsel further request
the identity and location all persons having such possession and control. This request is made in
good faith and for the purposes herein expressed.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy hereof has been furnished the Defendant along with
the Summons and Complaint.
/s/ S. Maxwell Karrick, Esq.
Maxwell Karrick, Esquire
Dan Newlin Injury Attorneys
Florida Bar No.: 119762
7335 W. Sand Lake Road
Suite 300
Orlando, FL 32819
Phone: (407) 888-8000
Attorney for Plaintiffs
Maxwell.Karrick@newlinlaw.com
Fabiola.Nazario@newlinlaw.com
Nathaly.Hernandezrosario@newlinlaw.com
Maxwell Karrick
Dan Newlin Injury Attorneys
Florida Bar No.:
7335 W. Sand Lake Road
Suite 300
Orlando, FL 32819
Phone: (407) 888-8000
Attorney for DAVID RODRIGUEZ
MORALES
Document Filed Date
March 20, 2024
Case Filing Date
March 20, 2024
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Filing # 194470392 E-Filed 03/20/2024 05:09:36 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO: DAVID RODRIGUEZ MORALES, Plaintiff, v. MATEO BLANCO, Defendants. ____________________________________/ PLAINTIFF, DAVID RODRIGUEZ MORALES’S REQUEST TO PRODUCE TO DEFENDANT MATEO BLANCO Pursuant to the provisions of Rule 1.350, Florida Rules of Civil Procedure, the undersigned counsel requests that the Defendant, MATEO BLANCO, produce and permit the inspection, copying, testing, sampling, measuring, surveying, photographing or otherwise examining the following: 1) All statements made by any occupants of the vehicles involved in the subject incident. 2) All statements made by any witnesses to the subject accident. 3) All statements made by the Plaintiffs pertaining to or concerning the subject matter. 4) All photographs of the vehicles involved in the subject accident. 5) All photographs of the Plaintiffs depicting injuries received in the subject accident. 6) All photographs of the subject accident scene. 7) Documents relating to or discussing repairs or maintenance to Defendants’ vehicle that were done for the six (6) months period of time preceding and including the date of the accident and for the six (6) month period of time following the date of the accident. 8) The repair bill and estimates for the repairs to any of the vehicles involved in the accident for damages incurred in the accident. 9) Any and all policies of liability insurance in effect on the date of the subject accident, providing coverage to the defendant herein. 10) Appraisals of all property damage sustained by Defendants’ vehicle in the subject accident. 11) Appraisals of the property damage sustained by Plaintiff's vehicle in the subject accident. 12) A copy of any and all surveillance films, photos, or depictions taken of the Plaintiffs as a result of the subject accident. 13) 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 or 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. 14) Copies of any and all computer generated documents in the possession of the Defendants or any agent, servant and/or employee of the Defendants, which pertains or relate, in any manner or fashion, to and any past claims history of the Plaintiffs in this lawsuit. 15) Copies of any and all checks issued by the Defendants or any agent, servant and/or employee of the Defendants to any other person, firm or company making a claim arising out of the same accident or incident which is the basis of this lawsuit. 16) All payout records for the insurer of the Defendants for benefits paid to or on behalf of Plaintiffs under the personal injury protection and medical payment coverage of the policy. 17) A copy of Defendant, MATEO BLANCO’s driver’s license that existed on the date of the accident as well as the current driver’s license. 18) A copy of the Defendant, MATEO BLANCO’s, mobile phone bill depicting all telephone, text and data usage for the billing period for the subject date of loss. It is requested that the above document be furnished or produced on or before forty-five (45) days from the date of service hereof, to S. Maxwell Karrick, Esquire, at the offices of Dan Newlin & Partners, 7335 Sand Lake Road, Ste. 300, Orlando, FL 32819. In support of this Request To Produce, it is shown that the documents and/or materials being here requested are believed to be in the possession, custody or control of the party to whom this request is directed. The information sought by this request is relevant to the subject matter of this action and cannot otherwise be obtained without undue hardship. In the event that all or part of the documents, and/or materials herein requested are not in the possession or control of the above-named Defendant addressee, then the undersigned counsel further request the identity and location all persons having such possession and control. This request is made in good faith and for the purposes herein expressed. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy hereof has been furnished the Defendant along with the Summons and Complaint. /s/ S. Maxwell Karrick, Esq. Maxwell Karrick, Esquire Dan Newlin Injury Attorneys Florida Bar No.: 119762 7335 W. Sand Lake Road Suite 300 Orlando, FL 32819 Phone: (407) 888-8000 Attorney for Plaintiffs Maxwell.Karrick@newlinlaw.com Fabiola.Nazario@newlinlaw.com Nathaly.Hernandezrosario@newlinlaw.com Maxwell Karrick Dan Newlin Injury Attorneys Florida Bar No.: 7335 W. Sand Lake Road Suite 300 Orlando, FL 32819 Phone: (407) 888-8000 Attorney for DAVID RODRIGUEZ MORALES