On March 20, 2023 a
Party Discovery
was filed
involving a dispute between
Davila, Luis Antonio,
and
Home Depot Usa Inc,
Jacques, Ralph,
for CIRCUIT CIVIL
in the District Court of Osceola County.
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Filing # 169108452 E-Filed 03/20/2023 01:09:16 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY, FLORIDA
CASE NO:
LUIS ANTONIO DAVILA,
Plaintiff,
vs.
RALPH JACQUES AND
HOME DEPOT USA INC,
Defendants. /
PLAINTIFF'S FIRST REQUEST TO PRODUCE TO DEFENDANT, RALPH JACQUES
Pursuant to the provisions of Rule 1.350, Florida Rules of Civil Procedure, the undersigned
counsel requests that the Defendant, RALPH JACQUES, 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 Plaintiff pertaining to or concerning the subject matter.
4. All photographs of the vehicles involved in the subject accident.
5. All photographs of the Plaintiff depicting injuries received in the subject accident.
6. All photographs of the subject accident scene.
7. Any and all videos in your possession depicting the scene of the incident described in the
complaint.
8. Any and all videos in your possession depicting any of the parties involved in the incident
describe dint he complaint; whether before, during or after the incident.
9. Documents relating to or discussing repairs or maintenance to Defendant’s 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.
10. The repair bill and estimates for the repairs to any of the vehicles involved in the accident for
damages incurred in the accident.
11. — Any and all policies of liability insurance in effect on the date of the subject accident,
providing coverage to the defendant herein.
12. Appraisals of all property damage sustained by Defendant's vehicle in the subject accident.
13. Appraisals of the property damage sustained by Plaintiff's vehicle in the subject accident.
14... Acopy of any and all surveillance films, photos, or depictions taken of the Plaintiff as a result
of the subject accident.
15. 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.
16. Copies of any and all computer generated documents in the possession of the Defendant or
any agent, servant and/or employee of the Defendant, which pertains or relate, in any manner
or fashion, to and any past claims history of the Plaintiff in this lawsuit.
17. Copies of any and all checks issued by the Defendant or any agent, servant and/or employee
of the Defendant to any other person, firm or company makinga claim arising out of the same
accident or incident which is the basis of this lawsuit.
18. All payout records for the insurer of the Defendant for benefits paid to or on behalf of Plaintiff
under the personal injury protection and medical payment coverage of the policy.
19. Acopy of the driver’s license of the driver involved in the subject accident that existed on the
date of the accident as well as the current driver’s license.
20. All invoices for cell phone service providers for cell phones owned by or used by Defendant
driver on the date of the incident alleged.
21. Video of the incident described in the Complaint.
It is requested that the above documents be furnished or produced on or before fifty-five (45)
days from the date of service hereof, to Manuel F. Stefan, Esquire at the offices of Morgan & Morgan,
P.A., 4495 South Semoran Blvd., Orlando, Florida 32822.
In support of this Request To Produce, it is shown that the documents and/or materials being
herein 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 requests 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 true and correct copy of the foregoing has been served upon
said Defendant, along with the summons and complaint.
/s/ Manuel Stefan, Esq.
Manuel “Manny” Stefan, Esq.
Florida Bar No.: 0103389
MORGAN & MORGAN, P.A.
4495 South Semoran Blvd.
Orlando, FL 32822
Telephone No.: (407) 452-6982
Facsimile No.: (407) 572-0124
Primary email: MStefan@forthepeople.com
Secondary email: cvictor@forthepeople.com
Attorneyfor Plaintiff
Document Filed Date
March 20, 2023
Case Filing Date
March 20, 2023
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Filing # 169108452 E-Filed 03/20/2023 01:09:16 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO: LUIS ANTONIO DAVILA, Plaintiff, vs. RALPH JACQUES AND HOME DEPOT USA INC, Defendants. / PLAINTIFF'S FIRST REQUEST TO PRODUCE TO DEFENDANT, RALPH JACQUES Pursuant to the provisions of Rule 1.350, Florida Rules of Civil Procedure, the undersigned counsel requests that the Defendant, RALPH JACQUES, 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 Plaintiff pertaining to or concerning the subject matter. 4. All photographs of the vehicles involved in the subject accident. 5. All photographs of the Plaintiff depicting injuries received in the subject accident. 6. All photographs of the subject accident scene. 7. Any and all videos in your possession depicting the scene of the incident described in the complaint. 8. Any and all videos in your possession depicting any of the parties involved in the incident describe dint he complaint; whether before, during or after the incident. 9. Documents relating to or discussing repairs or maintenance to Defendant’s 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. 10. The repair bill and estimates for the repairs to any of the vehicles involved in the accident for damages incurred in the accident. 11. — Any and all policies of liability insurance in effect on the date of the subject accident, providing coverage to the defendant herein. 12. Appraisals of all property damage sustained by Defendant's vehicle in the subject accident. 13. Appraisals of the property damage sustained by Plaintiff's vehicle in the subject accident. 14... Acopy of any and all surveillance films, photos, or depictions taken of the Plaintiff as a result of the subject accident. 15. 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. 16. Copies of any and all computer generated documents in the possession of the Defendant or any agent, servant and/or employee of the Defendant, which pertains or relate, in any manner or fashion, to and any past claims history of the Plaintiff in this lawsuit. 17. Copies of any and all checks issued by the Defendant or any agent, servant and/or employee of the Defendant to any other person, firm or company makinga claim arising out of the same accident or incident which is the basis of this lawsuit. 18. All payout records for the insurer of the Defendant for benefits paid to or on behalf of Plaintiff under the personal injury protection and medical payment coverage of the policy. 19. Acopy of the driver’s license of the driver involved in the subject accident that existed on the date of the accident as well as the current driver’s license. 20. All invoices for cell phone service providers for cell phones owned by or used by Defendant driver on the date of the incident alleged. 21. Video of the incident described in the Complaint. It is requested that the above documents be furnished or produced on or before fifty-five (45) days from the date of service hereof, to Manuel F. Stefan, Esquire at the offices of Morgan & Morgan, P.A., 4495 South Semoran Blvd., Orlando, Florida 32822. In support of this Request To Produce, it is shown that the documents and/or materials being herein 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 requests 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 true and correct copy of the foregoing has been served upon said Defendant, along with the summons and complaint. /s/ Manuel Stefan, Esq. Manuel “Manny” Stefan, Esq. Florida Bar No.: 0103389 MORGAN & MORGAN, P.A. 4495 South Semoran Blvd. Orlando, FL 32822 Telephone No.: (407) 452-6982 Facsimile No.: (407) 572-0124 Primary email: MStefan@forthepeople.com Secondary email: cvictor@forthepeople.com Attorneyfor Plaintiff