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Filing # 200986028 E-Filed 06/20/2024 01:20:53 PM
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT IN AND
FOR ORANGE COUNTY, FLORIDA
CASE NO.
BRANDON BARBER,
Plaintiff,
vs.
ROBERT COPE AND ATHALIA COPE,
Defendants.
________________________________________/
PLAINTIFF’S FIRST REQUEST FOR PRODUCTION TO
DEFENDANT, ATHALIA COPE
COMES NOW, Plaintiff, BRANDON BARBER, by and through undersigned counsel
and pursuant to Rule 1.350, Fla. R. Civ. P., hereby requests that Defendant, ATHALIA COPE,
produce and permit said Plaintiffs to inspect and/or copy each of the following documents in its
possession, custody or subject to its control It is requested that the production be made at the
offices of Trial Pro, P.A., 250 N. Orange Avenue, 14th Floor, Orlando, Florida 32801, within
forty-five (45) days from the date listed on the Affidavit of service, or at such other time or place
as may be agreed upon by counsel, or in default thereof, as specified by order of the court.
Inspection of the documents and things will be made by the undersigned attorneys, who may
make copies of documents and things at their own expense.
DEFINITIONS
A. The term, "plaintiff," or "plaintiffs," as used herein shall mean Plaintiff, his
agents, officers, directors, servants, employees, attorneys, expert witnesses, accountants, auditors
and all other persons over whom Plaintiffs have control or authority or who have been hired or
retained or employed for any purpose by Plaintiffs, or any of them severally.
B. The term, "defendant," or "defendants," shall mean Defendant, their agents,
officers, directors, servants, employees, attorneys, expert witnesses, accountants, auditors and all
other persons over whom Plaintiffs have control or authority or who have been hired or retained
or employed for any purpose by Defendant, or any of them severally.
C. The term, "person," as used herein shall mean an individual, corporation,
partnership, joint venture, group, association, body politic, governmental agency, unit or other
organization.
D. The term, "document," as used herein shall refer to correspondence, memoranda,
listings, accounts, records of account, ledger sheets, audits, questionnaires, recordings,
transcriptions, floppy discs, computer printouts, writings, drawings, graphs, charts, photographs,
phonographs, or any other data, compilation or written material of any kind or character.
DOCUMENTS AND THINGS TO BE PRODUCED
1. Copies of any photographs in Defendant's possession including photographs of
the automobiles of both Plaintiff and Defendant, scene of the accident, or any other photographs
relating to this claim.
2. A copy of the automobile insurance policy of Defendant which relates to this
claim.
3. A copy of the so-called declaration page of Defendant's insurance policy, which
was in effect on the date subject to this claim, with the indication of policy limits on such
declaration page.
4. Copies of statements obtained by any witness which are not privileged, and which
have been reduced to writing in some fashion.
5. Copies of the driving record of Defendant, if obtained by any office or official
agency of this state.
6. Copies of the repair estimates of Defendant's vehicle, which resulted from the
claim which is the subject of this matter.
7. Copies of any medical reports or records relating to Plaintiff in the possession of
Defendant whether or not such records or reports are for injuries sustained in this incident or at
any other time unless previously obtained by Defendant from the undersigned counsel.
8. Copies of any police reports or records obtained which in any way relate to the
incident, which is the subject of this claim.
9. Copies of any employment records relating to Plaintiff, which have been obtained
by Defendant unless such records were actually produced by the undersigned counsel.
10. If Defendant was not the owner of the subject vehicle, a copy of the registration
form or certificate of title of such vehicle.
11. Copies of any traffic citations or complaints relating to this incident, which may
have been issued to Defendant, or any other party.
12. All documents, tape recordings, or other writings memorializing or in any way
recording or reflecting any words, statements, declarations, conversations, or other
communications by Defendant that relate in any manner to the allegations contained in Plaintiff’s
Complaint or any of the issues in this lawsuit.
13. All written and/or recorded statements, reports and/or notes taken from interviews
of any witnesses to the claims made the basis of this lawsuit.
14. Any documents which refer to or relate to, or evidence, any communication
between Plaintiff and any agent of Defendant, concerning the subject matter of this action.
15. Any documents that refer or relate to, or evidence, any communication between
Defendant and any non-parties concerning the subject matter of this action.
16. Copies of any drawings, maps, charts, diagrams, or other representation of the
scene of the accident or of any other aspect of the accident which is the subject of this claim.
17. Copies of any photographs of Plaintiff taken subsequent to the incident, which is
the subject of this claim including any surveillance photos.
18. Copies of any motion pictures or videotapes taken of Plaintiff subsequent to the
incident which is the subject of this claim.
19. A copy of Defendant’s driver's license.
20. All documents referred to, or relied upon, by Defendants in answering or in
preparing answers to the interrogatories that were propounded to Defendant.
21. Please produce any and all information and/or data, including, without limitation,
any photograph or video, recorded, compiled, saved or preserved by any device or system on any
vehicle(s) involved in the subject collision, or of the subject collision, or any other aspect of the
crash which is the subject matter of this lawsuit.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been
electronically filed with the Florida Courts E-Filing Portal System and copies furnished by initial
Process of Service.
/s/ Brian M. Davis
Brian M. Davis, Esq.
Trial Pro, P.A.
FBN: 884650
250 N. Orange Avenue, 14th Floor
Orlando, Florida 32801
Tel: 407-300-0000
Fax: 407-246-5022
Brian@TrialPro.com
Eliana@TrialPro.com
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Filing # 200986028 E-Filed 06/20/2024 01:20:53 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CASE NO. BRANDON BARBER, Plaintiff, vs. ROBERT COPE AND ATHALIA COPE, Defendants. ________________________________________/ PLAINTIFF’S FIRST REQUEST FOR PRODUCTION TO DEFENDANT, ATHALIA COPE COMES NOW, Plaintiff, BRANDON BARBER, by and through undersigned counsel and pursuant to Rule 1.350, Fla. R. Civ. P., hereby requests that Defendant, ATHALIA COPE, produce and permit said Plaintiffs to inspect and/or copy each of the following documents in its possession, custody or subject to its control It is requested that the production be made at the offices of Trial Pro, P.A., 250 N. Orange Avenue, 14th Floor, Orlando, Florida 32801, within forty-five (45) days from the date listed on the Affidavit of service, or at such other time or place as may be agreed upon by counsel, or in default thereof, as specified by order of the court. Inspection of the documents and things will be made by the undersigned attorneys, who may make copies of documents and things at their own expense. DEFINITIONS A. The term, "plaintiff," or "plaintiffs," as used herein shall mean Plaintiff, his agents, officers, directors, servants, employees, attorneys, expert witnesses, accountants, auditors and all other persons over whom Plaintiffs have control or authority or who have been hired or retained or employed for any purpose by Plaintiffs, or any of them severally. B. The term, "defendant," or "defendants," shall mean Defendant, their agents, officers, directors, servants, employees, attorneys, expert witnesses, accountants, auditors and all other persons over whom Plaintiffs have control or authority or who have been hired or retained or employed for any purpose by Defendant, or any of them severally. C. The term, "person," as used herein shall mean an individual, corporation, partnership, joint venture, group, association, body politic, governmental agency, unit or other organization. D. The term, "document," as used herein shall refer to correspondence, memoranda, listings, accounts, records of account, ledger sheets, audits, questionnaires, recordings, transcriptions, floppy discs, computer printouts, writings, drawings, graphs, charts, photographs, phonographs, or any other data, compilation or written material of any kind or character. DOCUMENTS AND THINGS TO BE PRODUCED 1. Copies of any photographs in Defendant's possession including photographs of the automobiles of both Plaintiff and Defendant, scene of the accident, or any other photographs relating to this claim. 2. A copy of the automobile insurance policy of Defendant which relates to this claim. 3. A copy of the so-called declaration page of Defendant's insurance policy, which was in effect on the date subject to this claim, with the indication of policy limits on such declaration page. 4. Copies of statements obtained by any witness which are not privileged, and which have been reduced to writing in some fashion. 5. Copies of the driving record of Defendant, if obtained by any office or official agency of this state. 6. Copies of the repair estimates of Defendant's vehicle, which resulted from the claim which is the subject of this matter. 7. Copies of any medical reports or records relating to Plaintiff in the possession of Defendant whether or not such records or reports are for injuries sustained in this incident or at any other time unless previously obtained by Defendant from the undersigned counsel. 8. Copies of any police reports or records obtained which in any way relate to the incident, which is the subject of this claim. 9. Copies of any employment records relating to Plaintiff, which have been obtained by Defendant unless such records were actually produced by the undersigned counsel. 10. If Defendant was not the owner of the subject vehicle, a copy of the registration form or certificate of title of such vehicle. 11. Copies of any traffic citations or complaints relating to this incident, which may have been issued to Defendant, or any other party. 12. All documents, tape recordings, or other writings memorializing or in any way recording or reflecting any words, statements, declarations, conversations, or other communications by Defendant that relate in any manner to the allegations contained in Plaintiff’s Complaint or any of the issues in this lawsuit. 13. All written and/or recorded statements, reports and/or notes taken from interviews of any witnesses to the claims made the basis of this lawsuit. 14. Any documents which refer to or relate to, or evidence, any communication between Plaintiff and any agent of Defendant, concerning the subject matter of this action. 15. Any documents that refer or relate to, or evidence, any communication between Defendant and any non-parties concerning the subject matter of this action. 16. Copies of any drawings, maps, charts, diagrams, or other representation of the scene of the accident or of any other aspect of the accident which is the subject of this claim. 17. Copies of any photographs of Plaintiff taken subsequent to the incident, which is the subject of this claim including any surveillance photos. 18. Copies of any motion pictures or videotapes taken of Plaintiff subsequent to the incident which is the subject of this claim. 19. A copy of Defendant’s driver's license. 20. All documents referred to, or relied upon, by Defendants in answering or in preparing answers to the interrogatories that were propounded to Defendant. 21. Please produce any and all information and/or data, including, without limitation, any photograph or video, recorded, compiled, saved or preserved by any device or system on any vehicle(s) involved in the subject collision, or of the subject collision, or any other aspect of the crash which is the subject matter of this lawsuit. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been electronically filed with the Florida Courts E-Filing Portal System and copies furnished by initial Process of Service. /s/ Brian M. Davis Brian M. Davis, Esq. Trial Pro, P.A. FBN: 884650 250 N. Orange Avenue, 14th Floor Orlando, Florida 32801 Tel: 407-300-0000 Fax: 407-246-5022 Brian@TrialPro.com Eliana@TrialPro.com