Party Discovery: CARRANZA TORRES, MARIA vs. REICH, CHARLENE

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                                4.    Any and all document in your possession, custody, and/or control that supports, or might

      tend to support, and of your affirmative defenses.



5.    Any and all photographs and/or movies of the Plaintiff resulting from surveillance and/or

      investigation of the Plaintiff(s).



6.    Any invoices and/or appraisals, estimates, repair invoices, bills, statements,

      supplemental(s), regarding damage to any vehicles involved in the subject collision.



7.    Copy of the Driver’s License of Defendant, CHARLENE REICH.



8.    Copy of Social Security Card of Defendant, CHARLENE REICH.



9.    Copy of the vehicle title driven by you during the accident.



10.   Copy of medical records of Defendant, CHARLENE REICH, for treatment received as a

      result of the subject accident/incident (if any treatment received).



11.   Copy of any and all statements of any witnesses to the subject accident/incident.



12.   Copy of the ticket issued to Defendant, CHARLENE REICH, as a result of this accident.




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13.    Copy of all cell phone records detailing the day of the accident.



14.    Screenshots of all messages in your possession, custody, and/or control which were sent

       and/or received using any messaging application(s) on your mobile device(s) on October

       8, 2023, the date of the subject wreck, including, but not limited to, those on Facebook,

       Tinder, Snapchat, WhatsApp, Instagram, Twitter, and/or YouTube.



15.    Screenshots of any and all posts in your possession, custody, and/or control which were

       made on October 8, 2023, the date of the subject wreck, to any of your social media

       accounts, including Facebook, Tinder, Snapchat, WhatsApp, Instagram, Twitter, and/or

       YouTube.



                               CERTIFICATE OF SERVICE

       I HEREBY CERTIFY that a true and correct copy of the foregoing has been filed with

this Court via the E-Filing Portal and will be served along with the Summons and Complaint.



                                             Respectfully submitted,

                                             /s/ Joseph B. Lancos
                                             Joseph B. Lancos, Esq.
                                             Florida Bar No.: 124769
                                             THE BRUNER LAW FIRM
                                             3201 W-US Highway 98
                                             Panama City, FL 32401
                                             joseph@brunerfirm.com
                                             priddy@brunerfirm.com
                                             Attorney for Plaintiffs




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