On April 23, 2024 a
Party Discovery
was filed
involving a dispute between
Shaun Moodie,
and
Stephanie Masse,
for AUTO NEGLIGENCE
in the District Court of Palm Beach County.
Preview
**** CASE NUMBER: 502024CA003763XXXAMB Div: AE ****
Filing # 196790388 E-Filed 04/23/2024 12:36:18 PM
IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH
COUNTY, FLORIDA
SHAUN MOODIE,
Case No.
Plaintiff,
v.
STEPHANIE MASSE,
Defendant.
REQUEST TO PRODUCE
The Plaintiff, by and through the undersigned attorney, and pursuant to Florida Rules of Civil
Procedure, requests the following from Defendant:
1. The motor vehicle insurance policy for the motor vehicle you were operating on May 03,
2023 and all other motor vehicles in which you were a named insured on said date.
2. If you were not the owner of said motor vehicle, please attach the complete policy for:
1. all motor vehicles you owned or were a named insured on May 03, 2023, and
2. all motor vehicles owned by a resident relative on said date.
3. Please attach the complete policy for all excess, business and/or umbrella policies, which
may provide coverage for this accident.
4. Please attach a copy of any statements, written or recorded, regarding the collision
described in the plaintiff's Complaint or any injuries or property damage arising out of this
collision. This request includes any statements made by Plaintiff or Defendant.
5. Please produce all photographs, drawings or measurements of anything or anyone at the
scene of this collision or of any vehicle involved. Plaintiff will pay the cost of reproducing the
photographs in color.
6. Please attach a copy of any reports, including factual observations and opinions, which
have been prepared by your expert. If you or your attorney believes any such documents are
privileged, please identify the document (name the author and describe the document, i.e.
medical report) and the privilege relied upon.
7. Please produce a copy of all estimates and appraisals of damage to each vehicle involved
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 04/23/2024 12:36:18 PM
in the collision, which are in your possession, custody or control.
8. Please attach a copy of each and every driver license issued to Defendant on the date of
the incident, and any licenses issued thereafter through the present time.
9. Please attach a copy of the registration for the motor vehicle involved in the collision.
10. Please attach a copy of any videotape or other recording of the Plaintiff.
11. Please attach a copy of any document reflecting prepayment of a fine, or a plea of guilty
or nolo contendere to any traffic charge arising out of the collision with Plaintiff.
12. Please attach a copy of any document in your possession, which tends to establish that
you were not at fault for this collision.
13. Please attach a copy of your cellular phone statement from the month of the collision.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing was served along with a copy of the
Complaint.
IAN BRESSLER LAW P.A.
8461 Lake Worth Rd., #469
Lake Worth, FL 33467
P- 561-305-8257
F- 561-210-8925
Service: ian@ianbresslerlaw.com
By: /s/ Ian Bressler
Ian Bressler, Esq.
Florida Bar No.: 104905
Document Filed Date
April 23, 2024
Case Filing Date
April 23, 2024
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**** CASE NUMBER: 502024CA003763XXXAMB Div: AE **** Filing # 196790388 E-Filed 04/23/2024 12:36:18 PM IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA SHAUN MOODIE, Case No. Plaintiff, v. STEPHANIE MASSE, Defendant. REQUEST TO PRODUCE The Plaintiff, by and through the undersigned attorney, and pursuant to Florida Rules of Civil Procedure, requests the following from Defendant: 1. The motor vehicle insurance policy for the motor vehicle you were operating on May 03, 2023 and all other motor vehicles in which you were a named insured on said date. 2. If you were not the owner of said motor vehicle, please attach the complete policy for: 1. all motor vehicles you owned or were a named insured on May 03, 2023, and 2. all motor vehicles owned by a resident relative on said date. 3. Please attach the complete policy for all excess, business and/or umbrella policies, which may provide coverage for this accident. 4. Please attach a copy of any statements, written or recorded, regarding the collision described in the plaintiff's Complaint or any injuries or property damage arising out of this collision. This request includes any statements made by Plaintiff or Defendant. 5. Please produce all photographs, drawings or measurements of anything or anyone at the scene of this collision or of any vehicle involved. Plaintiff will pay the cost of reproducing the photographs in color. 6. Please attach a copy of any reports, including factual observations and opinions, which have been prepared by your expert. If you or your attorney believes any such documents are privileged, please identify the document (name the author and describe the document, i.e. medical report) and the privilege relied upon. 7. Please produce a copy of all estimates and appraisals of damage to each vehicle involved FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 04/23/2024 12:36:18 PM in the collision, which are in your possession, custody or control. 8. Please attach a copy of each and every driver license issued to Defendant on the date of the incident, and any licenses issued thereafter through the present time. 9. Please attach a copy of the registration for the motor vehicle involved in the collision. 10. Please attach a copy of any videotape or other recording of the Plaintiff. 11. Please attach a copy of any document reflecting prepayment of a fine, or a plea of guilty or nolo contendere to any traffic charge arising out of the collision with Plaintiff. 12. Please attach a copy of any document in your possession, which tends to establish that you were not at fault for this collision. 13. Please attach a copy of your cellular phone statement from the month of the collision. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing was served along with a copy of the Complaint. IAN BRESSLER LAW P.A. 8461 Lake Worth Rd., #469 Lake Worth, FL 33467 P- 561-305-8257 F- 561-210-8925 Service: ian@ianbresslerlaw.com By: /s/ Ian Bressler Ian Bressler, Esq. Florida Bar No.: 104905