Preview
Filing # 196920679 E-Filed 04/24/2024 04:25:41 PM
IN THE CIRCUIT COURT OF THE 11th
JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO.:
JURGEN HANS TEINTZE,
Plaintiff,
vs.
TYLER MAKO MORE and
JORGE LAZARO MORE,
Defendants.
_______________________________________________/
PLAINTIFF’S FIRST REQUEST FOR PRODUCTION
TO DEFENDANT, TYLER MAKO MORE
Plaintiff, Jurgen H. Teintze, through counsel, and pursuant to
Florida Rule of Civil Procedure 1.350, requests that Defendant,
Tyler Mako More, produce and permit the inspection and/or
copying of the following within the time provided by law, at the
offices of the undersigned 1:
1. A copy of each and every personal, business or commercial
insurance policy which protects Defendant, Tyler Mako More,
1 In responding to these requests, please remember to comply with Florida Rule of Civil
Procedure 1.280(i).
I P I 305 371 2692 I F I 305 371 2691 I A I 2665 South Bayshore Drive I Suite 603 I Miami, FL 33133
Page 1 of 7
against the risk of this lawsuit. This request applies to both
“primary” and “excess” insurance policies.
2. For each person, entity, vehicle, or other transportation
equipment involved in the crash described in the complaint,
provide a complete and certified copy of the declaration
pages, policy forms, endorsements, amendments or other
documents for any insurance policies that you or any other
Defendant had in effect at the time of the crash described in
the complaint, whether or not you contend the policy covers
or may provide coverage for the damages sought by the
complaint, including for any automobile, business auto,
commercial general liability, business liability, personal
negligence liability, motor carrier, MCS-90 endorsement,
umbrella, or excess coverage policies.
3. Any and all photographs taken by Defendant, Defendant’s
attorney, or investigators, agents, servants or employees at
any time relative to the collision referred to in the complaint
which are in any manner related to the subject matter of this
litigation. This request includes all videotapes and aerial
photographs.
I P I 305 371 2692 I F I 305 371 2691 I A I 2665 South Bayshore Drive I Suite 603 I Miami, FL 33133
Page 2 of 7
4. Any and all documents showing the individual(s) or entity(s)
that owned the motor vehicle being driven by Defendant,
Tyler Mako More at the time of the subject collision. If the
vehicle is leased, please provide a copy of the lease
agreement.
5. Any and all documents that support your affirmative
defenses.
6. Any and all documents in any way relating to your claims or
defenses.
7. A legible copy of both sides of your current license and any
prior driver’s licenses, including any commercial driver’s
licenses or endorsements.
8. Copies of all reservation of rights letters and/or agreements
regarding any insurance coverage for the crash described in
the complaint.
9. All documents reflecting or regarding any agreement with any
other person or party that would limit that party’s liability to
anyone for any damages sued upon in this case.
10. All documents relating to your point of origin (where you
were coming from) and your destination (where you were
I P I 305 371 2692 I F I 305 371 2691 I A I 2665 South Bayshore Drive I Suite 603 I Miami, FL 33133
Page 3 of 7
going to) at the time of the crash described in the Complaint,
including all stops made that day, any deadlines or route
scheduling sheets for any route planning for the day of the
crash.
11. Any photographs, videos, surveillance footage, security
footage, and/or recordings taken by anyone related to the
crash described in the Complaint, that reflect the scene of
the crash described in the Complaint, the vehicles involved or
of any of the parties to this cause for the day of the crash.
12. A legible color image or copy of any drawings or diagrams
that reflect the scene of the crash described in the
Complaint, the vehicles involved or any of the parties to this
cause.
13. Any documents, photographs, repair estimates, and
payments for property damage suffered by any person or
entity as a result of the crash described in the Complaint.
14. Any statements, either written or recorded, made by the
Plaintiff or any other witness pertaining to the crash
described in the Complaint.
15. All documents assessing preventability of and/or fault for the
I P I 305 371 2692 I F I 305 371 2691 I A I 2665 South Bayshore Drive I Suite 603 I Miami, FL 33133
Page 4 of 7
crash described in the Complaint.
16. All documents relating to any citations charged against you
or prosecuted as a result of the crash described in the
Complaint.
17. All documents reflecting any tests administered to determine
the existence of alcohol, medication, or drugs in your system
after the crash described in the Complaint and the results of
such testing.
18. Any and all social media posts, instant messages, texts,
tweets, snap chats, e-mails or other social media posts by
you or on your behalf that relate to the crash described in
the Complaint.
19. Copies of all responses to public records requests received by
you or any other Defendant regarding this crash or any party
or issue in this lawsuit.
20. All documents regarding traffic or DOT incidents, violations,
citations, or infractions committed by you in the five years
preceding the date of the crash described in the complaint.
21. For each electronic device, if any data is available (whether or
not downloaded or retrieved), color images or copies of any
I P I 305 371 2692 I F I 305 371 2691 I A I 2665 South Bayshore Drive I Suite 603 I Miami, FL 33133
Page 5 of 7
download, report, video, audio or other data that relates to
the operation of the tractor truck for the thirty (30) days
before the date of the subject crash, the date of the subject
crash and seven days after.
22. All records that show or relate to the type, model, make,
serial number, phone number, name of account holder, and
service provider, of any electronic device capable of
communicating with people or entities outside the truck,
owned or possessed by you on the date of the subject crash.
23. Any and all records for each communication device present
in or on the car at the time of the subject crash, for the day
of the subject crash, including, but not limited to, records of
all incoming and outgoing calls, text messages, instant
messaging, internet usage, face time, voice messaging, etc.
24. Color copies or images of all information, data available from
or downloaded from any electronic device or system for the
vehicle being operated by you at the time of the subject
crash.
25. All documents that set forth any facts leading up to the
subject crash.
I P I 305 371 2692 I F I 305 371 2691 I A I 2665 South Bayshore Drive I Suite 603 I Miami, FL 33133
Page 6 of 7
26. All documents that explain what caused the subject crash.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the
foregoing was served with the Summons and Complaint.
DOLAN DOBRINSKY ROSENBLUM
BLUESTEIN, LLP
Counsel for Plaintiff
2665 S. Bayshore Drive, Suite 603
Miami, Florida 33133
Telephone: (305) 371-2692
Facsimile: (305) 371-2691
MDobrinsky@DDRLawyers.Com
EBluestein@DDRLawyers.Com
JCoss@DDRLawyers.Com
BY: /s/ Manuel L. Dobrinsky__________
Manuel L. Dobrinsky, Esq.
FBN: 775525
Eric Bluestein, Esq.
FBN: 58240
I P I 305 371 2692 I F I 305 371 2691 I A I 2665 South Bayshore Drive I Suite 603 I Miami, FL 33133
Page 7 of 7
Preview
Filing # 196920679 E-Filed 04/24/2024 04:25:41 PM IN THE CIRCUIT COURT OF THE 11th JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO.: JURGEN HANS TEINTZE, Plaintiff, vs. TYLER MAKO MORE and JORGE LAZARO MORE, Defendants. _______________________________________________/ PLAINTIFF’S FIRST REQUEST FOR PRODUCTION TO DEFENDANT, TYLER MAKO MORE Plaintiff, Jurgen H. Teintze, through counsel, and pursuant to Florida Rule of Civil Procedure 1.350, requests that Defendant, Tyler Mako More, produce and permit the inspection and/or copying of the following within the time provided by law, at the offices of the undersigned 1: 1. A copy of each and every personal, business or commercial insurance policy which protects Defendant, Tyler Mako More, 1 In responding to these requests, please remember to comply with Florida Rule of Civil Procedure 1.280(i). I P I 305 371 2692 I F I 305 371 2691 I A I 2665 South Bayshore Drive I Suite 603 I Miami, FL 33133 Page 1 of 7 against the risk of this lawsuit. This request applies to both “primary” and “excess” insurance policies. 2. For each person, entity, vehicle, or other transportation equipment involved in the crash described in the complaint, provide a complete and certified copy of the declaration pages, policy forms, endorsements, amendments or other documents for any insurance policies that you or any other Defendant had in effect at the time of the crash described in the complaint, whether or not you contend the policy covers or may provide coverage for the damages sought by the complaint, including for any automobile, business auto, commercial general liability, business liability, personal negligence liability, motor carrier, MCS-90 endorsement, umbrella, or excess coverage policies. 3. Any and all photographs taken by Defendant, Defendant’s attorney, or investigators, agents, servants or employees at any time relative to the collision referred to in the complaint which are in any manner related to the subject matter of this litigation. This request includes all videotapes and aerial photographs. I P I 305 371 2692 I F I 305 371 2691 I A I 2665 South Bayshore Drive I Suite 603 I Miami, FL 33133 Page 2 of 7 4. Any and all documents showing the individual(s) or entity(s) that owned the motor vehicle being driven by Defendant, Tyler Mako More at the time of the subject collision. If the vehicle is leased, please provide a copy of the lease agreement. 5. Any and all documents that support your affirmative defenses. 6. Any and all documents in any way relating to your claims or defenses. 7. A legible copy of both sides of your current license and any prior driver’s licenses, including any commercial driver’s licenses or endorsements. 8. Copies of all reservation of rights letters and/or agreements regarding any insurance coverage for the crash described in the complaint. 9. All documents reflecting or regarding any agreement with any other person or party that would limit that party’s liability to anyone for any damages sued upon in this case. 10. All documents relating to your point of origin (where you were coming from) and your destination (where you were I P I 305 371 2692 I F I 305 371 2691 I A I 2665 South Bayshore Drive I Suite 603 I Miami, FL 33133 Page 3 of 7 going to) at the time of the crash described in the Complaint, including all stops made that day, any deadlines or route scheduling sheets for any route planning for the day of the crash. 11. Any photographs, videos, surveillance footage, security footage, and/or recordings taken by anyone related to the crash described in the Complaint, that reflect the scene of the crash described in the Complaint, the vehicles involved or of any of the parties to this cause for the day of the crash. 12. A legible color image or copy of any drawings or diagrams that reflect the scene of the crash described in the Complaint, the vehicles involved or any of the parties to this cause. 13. Any documents, photographs, repair estimates, and payments for property damage suffered by any person or entity as a result of the crash described in the Complaint. 14. Any statements, either written or recorded, made by the Plaintiff or any other witness pertaining to the crash described in the Complaint. 15. All documents assessing preventability of and/or fault for the I P I 305 371 2692 I F I 305 371 2691 I A I 2665 South Bayshore Drive I Suite 603 I Miami, FL 33133 Page 4 of 7 crash described in the Complaint. 16. All documents relating to any citations charged against you or prosecuted as a result of the crash described in the Complaint. 17. All documents reflecting any tests administered to determine the existence of alcohol, medication, or drugs in your system after the crash described in the Complaint and the results of such testing. 18. Any and all social media posts, instant messages, texts, tweets, snap chats, e-mails or other social media posts by you or on your behalf that relate to the crash described in the Complaint. 19. Copies of all responses to public records requests received by you or any other Defendant regarding this crash or any party or issue in this lawsuit. 20. All documents regarding traffic or DOT incidents, violations, citations, or infractions committed by you in the five years preceding the date of the crash described in the complaint. 21. For each electronic device, if any data is available (whether or not downloaded or retrieved), color images or copies of any I P I 305 371 2692 I F I 305 371 2691 I A I 2665 South Bayshore Drive I Suite 603 I Miami, FL 33133 Page 5 of 7 download, report, video, audio or other data that relates to the operation of the tractor truck for the thirty (30) days before the date of the subject crash, the date of the subject crash and seven days after. 22. All records that show or relate to the type, model, make, serial number, phone number, name of account holder, and service provider, of any electronic device capable of communicating with people or entities outside the truck, owned or possessed by you on the date of the subject crash. 23. Any and all records for each communication device present in or on the car at the time of the subject crash, for the day of the subject crash, including, but not limited to, records of all incoming and outgoing calls, text messages, instant messaging, internet usage, face time, voice messaging, etc. 24. Color copies or images of all information, data available from or downloaded from any electronic device or system for the vehicle being operated by you at the time of the subject crash. 25. All documents that set forth any facts leading up to the subject crash. I P I 305 371 2692 I F I 305 371 2691 I A I 2665 South Bayshore Drive I Suite 603 I Miami, FL 33133 Page 6 of 7 26. All documents that explain what caused the subject crash. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was served with the Summons and Complaint. DOLAN DOBRINSKY ROSENBLUM BLUESTEIN, LLP Counsel for Plaintiff 2665 S. Bayshore Drive, Suite 603 Miami, Florida 33133 Telephone: (305) 371-2692 Facsimile: (305) 371-2691 MDobrinsky@DDRLawyers.Com EBluestein@DDRLawyers.Com JCoss@DDRLawyers.Com BY: /s/ Manuel L. Dobrinsky__________ Manuel L. Dobrinsky, Esq. FBN: 775525 Eric Bluestein, Esq. FBN: 58240 I P I 305 371 2692 I F I 305 371 2691 I A I 2665 South Bayshore Drive I Suite 603 I Miami, FL 33133 Page 7 of 7