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**** CASE NUMBER: 502024CA005599XXXAMB Div: Ad ****
Filing # 200670826 E-Filed 06/17/2024 10:40:44 AM
IN THE CIRCUIT COURT OF THE
15TH JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY. >
FLORIDA
CIVIL DIVISION
CASE NO.:
CRYSTAL DERRICK,
Plaintiff,
vs.
SUSAN ANN VAIRO,
Defendant.
/
PLAINTIFF’S FIRST REQUEST TO PRODUCE TO DEFENDANT
COMES NOW Plaintiff, CRYSTAL DERRICK, and requests Defendant, SUSAN ANN
VAIRO, to produce for inspection and/or copying within thirty (30) days of the date herein, in
accordance with Florida Rule of Civil Procedure 1.350, the following:
The items and matters to be produced are as follows.
Photocopies ofthe front and back of your driver’s license.
Any and all titles, rental agreements, lease agreements, registrations, or other papers
regarding any legal or equitable interest in your motor vehicle involved in this accident.
Any and all repair bills, estimates and appraisals pertaining to any of the vehicles involved
in the incident described in the Complaint.
Any and all photographs that were taken in the regular course of business of any of the
vehicles involved in the incident described in the Complaint, both before and after the
incident.
Any and all photographs, graphs, charts, diagrams, sketches and any other documentary
evidence that were taken in the regular course of business which depict the scene and/or
the parties involved in or pertaining to the incident described in Plaintiff's Complaint.
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 06/17/2024 10:40:44 AM
Any and all statements, whether written, taped, audio recorded, stenographically recorded
or videotaped, taken from the Plaintiff.
Any and all statements, whether written, taped, audio recorded, stenographically recorded
or videotaped, taken from the Defendant.
Any and all statements, including, but not limited to, whether written, taped, audio
recorded, stenographically recorded or videotaped that were taken in the regular course
of business from any person or potential witness regarding the facts of this lawsuit.
Any and all incident reports, or other papers describing this incident that were taken or
prepared in the regular course of business.
10. 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.
11 Any and all documentation indicating any and all prior or subsequent claims for personal
injuries made by Plaintiff.
12. Any reports from any IME physician(s) or medical consultant reports used to evaluate
Plaintiff's claim for insurance benefits.
13 Your cellular phone bill for the day of the motor vehicle accident.
14 All surveillance recordings, films, reports and photographs taken of the Plaintiff.
15 All medical records, reports, or bills concerning the Plaintiff.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing will be served on the
Defendant along with the Complaint.
GREEN INJURY LAW FIRM
Attorney for Plaintiff
3487 W Woolbright Rd.
Boynton Beach, FL 33436
Telephone: 561-362-2009
Facsimile: 561-678-3417
Email: Seth@GreenInjuryFirm.com
By:/s/ Seth P. Green
Seth P. Green, Esquire
Florida Bar No.: 105175
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**** CASE NUMBER: 502024CA005599XXXAMB Div: Ad **** Filing # 200670826 E-Filed 06/17/2024 10:40:44 AM IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY. > FLORIDA CIVIL DIVISION CASE NO.: CRYSTAL DERRICK, Plaintiff, vs. SUSAN ANN VAIRO, Defendant. / PLAINTIFF’S FIRST REQUEST TO PRODUCE TO DEFENDANT COMES NOW Plaintiff, CRYSTAL DERRICK, and requests Defendant, SUSAN ANN VAIRO, to produce for inspection and/or copying within thirty (30) days of the date herein, in accordance with Florida Rule of Civil Procedure 1.350, the following: The items and matters to be produced are as follows. Photocopies ofthe front and back of your driver’s license. Any and all titles, rental agreements, lease agreements, registrations, or other papers regarding any legal or equitable interest in your motor vehicle involved in this accident. Any and all repair bills, estimates and appraisals pertaining to any of the vehicles involved in the incident described in the Complaint. Any and all photographs that were taken in the regular course of business of any of the vehicles involved in the incident described in the Complaint, both before and after the incident. Any and all photographs, graphs, charts, diagrams, sketches and any other documentary evidence that were taken in the regular course of business which depict the scene and/or the parties involved in or pertaining to the incident described in Plaintiff's Complaint. FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 06/17/2024 10:40:44 AM Any and all statements, whether written, taped, audio recorded, stenographically recorded or videotaped, taken from the Plaintiff. Any and all statements, whether written, taped, audio recorded, stenographically recorded or videotaped, taken from the Defendant. Any and all statements, including, but not limited to, whether written, taped, audio recorded, stenographically recorded or videotaped that were taken in the regular course of business from any person or potential witness regarding the facts of this lawsuit. Any and all incident reports, or other papers describing this incident that were taken or prepared in the regular course of business. 10. 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. 11 Any and all documentation indicating any and all prior or subsequent claims for personal injuries made by Plaintiff. 12. Any reports from any IME physician(s) or medical consultant reports used to evaluate Plaintiff's claim for insurance benefits. 13 Your cellular phone bill for the day of the motor vehicle accident. 14 All surveillance recordings, films, reports and photographs taken of the Plaintiff. 15 All medical records, reports, or bills concerning the Plaintiff. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing will be served on the Defendant along with the Complaint. GREEN INJURY LAW FIRM Attorney for Plaintiff 3487 W Woolbright Rd. Boynton Beach, FL 33436 Telephone: 561-362-2009 Facsimile: 561-678-3417 Email: Seth@GreenInjuryFirm.com By:/s/ Seth P. Green Seth P. Green, Esquire Florida Bar No.: 105175