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Filing # 195601773 E-Filed 04/05/2024 03:18:39 PM
IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
CIVIL DIVISION
MAXIMINO LEBRON ACEVEDO,
Plaintiff, CASE NO.
DIVISION:
vs.
EARNEST EDWARD GLISSON
and FANICAT LLC,
a Florida Limited Liability Company,
Defendants.
/
PLAINTIFF'S REQUEST FOR PRODUCTION TO DEFENDANTS EARNEST
EDWARD GLISSON AND FANICAT LLC
Plaintiff, MAXIMINO LEBRON ACEVEDO, pursuant to Rule 1.350 of the Florida Rules
of Civil Procedure, hereby requests the Defendants, EARNEST EDWARD GLISSON
(“GLISSON”) and FANICAT LLC, a Florida Limited Liability Company, to produce for
inspection and/or copying by counsel for the Plaintiff, the following documents and/or reports to
be produced at the office of MARK H. WRIGHT, PLLC, 800 West DeLeon Street, Tampa,
Florida, 33606 within forty-five (45) days of the date of service hereof.
1 Any and all surveillance taken of the Plaintiff.
2 Any and all photographs of the vehicle which Defendant, GLISSON, was driving
at the time of the collision at issue in Plaintiff's Complaint, depicting the extent of damage
sustained in the subject collision. Please produce color photographs via Dropbox.
3 Any and all repair estimates, work orders, and/or records indicating the cost of
repair for any damage sustained to the Plaintiff’s vehicle in the subject collision.
4/5/2024 3:18 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
4 Any and all repair estimates, work orders, and/or records indicating the cost of
repair for any damage sustained to the vehicle driven by Plaintiff, MAXIMINO LEBRON
ACEVEDO, in the subject collision.
5 Any and all records with regards to maintenance of vehicle driven by the
Defendant, GLISSON, and owned by Defendant, FANICAT LLC, which was involved in the
subject collision, for the one (1) year prior to the collision.
6 Any and all photographs or diagrams of the collision scene.
7 Any and all 911 calls for the subject collision.
8 A certified copy of any and all insurance policies for the Defendants, GLISSON
and FANICAT LLC, that may provide coverage for the subject accident.
9 Any and all photographs of Plaintiff's vehicle depicting the extent of damage
sustained in the subject collision. Please produce color photographs via Dropbox.
10. Any and all photographs of the vehicle driven by Defendant, GLISSON, depicting
the extent of damage sustained in the subject collision. Please produce color photographs via
Dropbox.
11 Any and all recorded statement(s) given by the Plaintiff.
12 Any recorded statement(s) given by Defendants, GLISSON and FANICAT LLC.
13 The Defendant, GLISSON’S cell phone records for the day of the subject collision,
January 2, 2024.
14. The complete employment/personnel file for Defendant, GLISSON. No objections
to the redaction of the Defendant’s social security number.
15. A copy of Defendant, GLISSON’S driver’s license.
16. The vehicle that Defendant, GLISSON, was driving at the time of the crash.
4/5/2024 3:18 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
17. Any and all text messages sent and/or received by the Defendant, GLISSON, within.
the one (1) hour prior to and one (1) hour after the subject collision.
18. A copy of any and all download / black box data from the Defendant’s vehicle in
connection with the subject collision.
19. Any and all photographs and/or video taken of the collision and/or at the collision
scene, including any other car(s) involved in the collision.
WRIGHT
Fi da Bar No.: 867330
[ARK H. WRIGHT, PLLC
0 West DgLeon Street
mpa, F] rida 33606
Te me: 813-425-2020
Facsimile: 813-374-9333
Attorney for Plaintiff
eservice@markwrightlaw.com
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon
st
the Defendants with the Summons and Complai nt fe amages and Request for Jury Trial and a
copy was filed with the Clerk of the Court on this; day ril, 2024.
fF
ATTORNE
4/5/2024 3:18 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3
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Filing # 195601773 E-Filed 04/05/2024 03:18:39 PM IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA CIVIL DIVISION MAXIMINO LEBRON ACEVEDO, Plaintiff, CASE NO. DIVISION: vs. EARNEST EDWARD GLISSON and FANICAT LLC, a Florida Limited Liability Company, Defendants. / PLAINTIFF'S REQUEST FOR PRODUCTION TO DEFENDANTS EARNEST EDWARD GLISSON AND FANICAT LLC Plaintiff, MAXIMINO LEBRON ACEVEDO, pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, hereby requests the Defendants, EARNEST EDWARD GLISSON (“GLISSON”) and FANICAT LLC, a Florida Limited Liability Company, to produce for inspection and/or copying by counsel for the Plaintiff, the following documents and/or reports to be produced at the office of MARK H. WRIGHT, PLLC, 800 West DeLeon Street, Tampa, Florida, 33606 within forty-five (45) days of the date of service hereof. 1 Any and all surveillance taken of the Plaintiff. 2 Any and all photographs of the vehicle which Defendant, GLISSON, was driving at the time of the collision at issue in Plaintiff's Complaint, depicting the extent of damage sustained in the subject collision. Please produce color photographs via Dropbox. 3 Any and all repair estimates, work orders, and/or records indicating the cost of repair for any damage sustained to the Plaintiff’s vehicle in the subject collision. 4/5/2024 3:18 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 4 Any and all repair estimates, work orders, and/or records indicating the cost of repair for any damage sustained to the vehicle driven by Plaintiff, MAXIMINO LEBRON ACEVEDO, in the subject collision. 5 Any and all records with regards to maintenance of vehicle driven by the Defendant, GLISSON, and owned by Defendant, FANICAT LLC, which was involved in the subject collision, for the one (1) year prior to the collision. 6 Any and all photographs or diagrams of the collision scene. 7 Any and all 911 calls for the subject collision. 8 A certified copy of any and all insurance policies for the Defendants, GLISSON and FANICAT LLC, that may provide coverage for the subject accident. 9 Any and all photographs of Plaintiff's vehicle depicting the extent of damage sustained in the subject collision. Please produce color photographs via Dropbox. 10. Any and all photographs of the vehicle driven by Defendant, GLISSON, depicting the extent of damage sustained in the subject collision. Please produce color photographs via Dropbox. 11 Any and all recorded statement(s) given by the Plaintiff. 12 Any recorded statement(s) given by Defendants, GLISSON and FANICAT LLC. 13 The Defendant, GLISSON’S cell phone records for the day of the subject collision, January 2, 2024. 14. The complete employment/personnel file for Defendant, GLISSON. No objections to the redaction of the Defendant’s social security number. 15. A copy of Defendant, GLISSON’S driver’s license. 16. The vehicle that Defendant, GLISSON, was driving at the time of the crash. 4/5/2024 3:18 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2 17. Any and all text messages sent and/or received by the Defendant, GLISSON, within. the one (1) hour prior to and one (1) hour after the subject collision. 18. A copy of any and all download / black box data from the Defendant’s vehicle in connection with the subject collision. 19. Any and all photographs and/or video taken of the collision and/or at the collision scene, including any other car(s) involved in the collision. WRIGHT Fi da Bar No.: 867330 [ARK H. WRIGHT, PLLC 0 West DgLeon Street mpa, F] rida 33606 Te me: 813-425-2020 Facsimile: 813-374-9333 Attorney for Plaintiff eservice@markwrightlaw.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon st the Defendants with the Summons and Complai nt fe amages and Request for Jury Trial and a copy was filed with the Clerk of the Court on this; day ril, 2024. fF ATTORNE 4/5/2024 3:18 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3