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Filing # 195991977 E-Filed 04/11/2024 01:08:52 PM
IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT
IN AND FOR MANATEE COUNTY, FLORIDA
CIVIL DIVISION
JANTZEN ADAMS,
Plaintiff,
vs. CASE NO.:
TONIA LYNN WHITTEN and
ALLSTATE FIRE & CASUALTY INSURANCE COMPANY,
Defendants.
/
REQUEST TO PRODUCE
Plaintiff, JANTZEN ADAMS, in the above-styled and numbered cause, serves this
Request for Production of documents Pursuant to Rule 1.350, Florida Rules of Civil Procedure,
directed to ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY, Defendant. These
Requests are being served on Defendant, who is given forty-five (45) days from the date of service
of these Requests for Production to produce the requested documents for inspection and copying
at the office of Christopher T. Borzell, Morgan & Morgan Tampa, P.A., 101 Riverfront Blvd.,
Suite 600, Bradenton, FL 34205. Demand is made for supplementation of the defendant’s
responses to these Requests for Production as may be required by the Florida Rules of Civil
Procedure.
DEFINITIONS
For purposes of the following definitions apply:
“You” and “your” means and refers to ALLSTATE FIRE AND CASUALTY INSURANCE
COMPANY, its employees, and /or representatives.
"2024CA000579AX" 195991977 Filed at Manatee County Clerk 04/11/2024 01:08:51 PM EDT
“Accident in question, me 1 incident in question, 24, ‘collision in question,” mean and refer to the
September 25, 2023 collision referred to in the plaintiff's Original Complaint and any
supplementations to such pleading.
"2024CA000579AX" 195991977 Filed at Manatee County Clerk 04/11/2024 01:08:51 PM EDT
REQUEST FOR PRODUCTION
All photographs, slides, movie film, video tape and/or any other documents depicting the
conditions, or damage to, the uninsured/underinsured motorist’s vehicle as a result of the
motor vehicle incident which is the subject matter of this action.
All photographs, slides, movie film, video tape and/or any other documents depicting the
condition, or damage to, the Plaintiff's vehicle as a result of the motor vehicle incident which
is the subject matter of this action.
Repair estimates and repair bills, including paid and unpaid bills and/or any other document
reflecting damage to alleged uninsured motorist’s vehicle sustained as a result ofthis incident
which is the subject matter of this action.
All photographs, slides, movie film, video tape and/or any other document depicting the
scene of the motor vehicle incident which is the subject matter of this action.
A copy of any and all statements by any party and/or witness as defined in the Florida Rules
of Civil Procedures concerning this action or the subject matter of this action previously
made by the Plaintiff.
Copies of all documentation supporting defendant’s refusal to pay damages to Plaintiff,
JANTZEN ADAMS under JANTZEN ADAMS uninsured/underinsured coverage, which has
been made the basis of the action.
Any and all surveillance films, photographs or digital media taken by you or anyone on your
behalf, of the Plaintiff.
Any and all statements taken by the defendant or its representatives of any witnesses with
regard to any fact relevant to any fact in this action.
A copy of the declaration pages providing liability coverage to the alleged
uninsured/underinsured motorist for the incident which is the subject matter of this action.
10. Any and all insurance agreements or policies inuring to JANTZEN ADAMS which may be
liable to satisfy part or all of a judgment that may be rendered in this action or to indemnify
or reimburse for payments made to satisfy the judgment, including, but not limited to, any
liability insurance policy covering defendant.
11 Repair estimates and repair bills including paid and unpaid bills and/or any other documents
reflecting damages to the Plaintiff's vehicle allegedly sustained as a result of this incident
which is the subject of this action.
12 Documents that refer or relate to any prior personal injury claims or incidents involving
Plaintiff.
"2024CA000579AX" 195991977 Filed at Manatee County Clerk 04/11/2024 01:08:51 PM EDT
13 Any documents that refer to, or reflect any injury to the same area of the body for which
Plaintiff is seeking damages in this action which was sustained prior or subsequent to the
incident that is the subject of this action.
14. Please provide a copy of all prior claim forms, accident or incident reports, lawsuit papers,
health care records, Autotrax reports, ISOs, claim history detail reports or any other
documents that evidence any personal injury sustained by Plaintiff prior or subsequent to the
incident that is the subject of this action.
15 A copy of the declaration pages providing uninsured motorist coverage to the Plaintiff for
the incident described in the Complaint.
16. Any and all documents in your possession or control which establish, suggest, or otherwise
support your position that Plaintiff did not sustain a permanent injury as a result of the
incident which gives rise to this lawsuit.
17 A ledger itemizing all premiums paid by the Plaintiff to ALLSTATE FIRE AND
CASUALTY INSURANCE COMPANY to secure all insurance benefits sought herein,
including PIP, Med Pay and UM coverages.
18 If the subject claim involves non-stacked UM coverage, please provide the statutory revised
premium rates applicable to this coverage.
19. Any and all forms signed by the Plaintiff (or Plaintiffs family members) as to the rejection
of the uninsured/underinsured motorist coverage, or as to the rejection of stacking
uninsured/underinsured motorist coverage.
I HEREBY CERTIFY that a true copy of the foregoing has been furnished to the
Defendant, ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY together with the
Summons and Complaint.
"2024CA000579AX" 195991977 Filed at Manatee County Clerk 04/11/2024 01:08:51 PM EDT
/s/ Christopher Borzell
Christopher Borzell, Attorney
Morgan & Morgan Tampa, P.A.
One Tampa City Center
201 /N. Franklin Street, 7th Floor
Tampa, FL 33602
Tele: (941) 271-6384
Fax: (941) 271-6484
Florida Bar #: 68277
Attorney for Plaintiff
Primary Email: CBorzell@ForThePeople.cor
Sccondary: CT BPicadings@ForfhePcople.com
Paralegal: RHoward@ForlhePcople.com
"2024CA000579AX" 195991977 Filed at Manatee County Clerk 04/11/2024 01:08:51 PM EDT
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Filing # 195991977 E-Filed 04/11/2024 01:08:52 PM IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR MANATEE COUNTY, FLORIDA CIVIL DIVISION JANTZEN ADAMS, Plaintiff, vs. CASE NO.: TONIA LYNN WHITTEN and ALLSTATE FIRE & CASUALTY INSURANCE COMPANY, Defendants. / REQUEST TO PRODUCE Plaintiff, JANTZEN ADAMS, in the above-styled and numbered cause, serves this Request for Production of documents Pursuant to Rule 1.350, Florida Rules of Civil Procedure, directed to ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY, Defendant. These Requests are being served on Defendant, who is given forty-five (45) days from the date of service of these Requests for Production to produce the requested documents for inspection and copying at the office of Christopher T. Borzell, Morgan & Morgan Tampa, P.A., 101 Riverfront Blvd., Suite 600, Bradenton, FL 34205. Demand is made for supplementation of the defendant’s responses to these Requests for Production as may be required by the Florida Rules of Civil Procedure. DEFINITIONS For purposes of the following definitions apply: “You” and “your” means and refers to ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY, its employees, and /or representatives. "2024CA000579AX" 195991977 Filed at Manatee County Clerk 04/11/2024 01:08:51 PM EDT “Accident in question, me 1 incident in question, 24, ‘collision in question,” mean and refer to the September 25, 2023 collision referred to in the plaintiff's Original Complaint and any supplementations to such pleading. "2024CA000579AX" 195991977 Filed at Manatee County Clerk 04/11/2024 01:08:51 PM EDT REQUEST FOR PRODUCTION All photographs, slides, movie film, video tape and/or any other documents depicting the conditions, or damage to, the uninsured/underinsured motorist’s vehicle as a result of the motor vehicle incident which is the subject matter of this action. All photographs, slides, movie film, video tape and/or any other documents depicting the condition, or damage to, the Plaintiff's vehicle as a result of the motor vehicle incident which is the subject matter of this action. Repair estimates and repair bills, including paid and unpaid bills and/or any other document reflecting damage to alleged uninsured motorist’s vehicle sustained as a result ofthis incident which is the subject matter of this action. All photographs, slides, movie film, video tape and/or any other document depicting the scene of the motor vehicle incident which is the subject matter of this action. A copy of any and all statements by any party and/or witness as defined in the Florida Rules of Civil Procedures concerning this action or the subject matter of this action previously made by the Plaintiff. Copies of all documentation supporting defendant’s refusal to pay damages to Plaintiff, JANTZEN ADAMS under JANTZEN ADAMS uninsured/underinsured coverage, which has been made the basis of the action. Any and all surveillance films, photographs or digital media taken by you or anyone on your behalf, of the Plaintiff. Any and all statements taken by the defendant or its representatives of any witnesses with regard to any fact relevant to any fact in this action. A copy of the declaration pages providing liability coverage to the alleged uninsured/underinsured motorist for the incident which is the subject matter of this action. 10. Any and all insurance agreements or policies inuring to JANTZEN ADAMS which may be liable to satisfy part or all of a judgment that may be rendered in this action or to indemnify or reimburse for payments made to satisfy the judgment, including, but not limited to, any liability insurance policy covering defendant. 11 Repair estimates and repair bills including paid and unpaid bills and/or any other documents reflecting damages to the Plaintiff's vehicle allegedly sustained as a result of this incident which is the subject of this action. 12 Documents that refer or relate to any prior personal injury claims or incidents involving Plaintiff. "2024CA000579AX" 195991977 Filed at Manatee County Clerk 04/11/2024 01:08:51 PM EDT 13 Any documents that refer to, or reflect any injury to the same area of the body for which Plaintiff is seeking damages in this action which was sustained prior or subsequent to the incident that is the subject of this action. 14. Please provide a copy of all prior claim forms, accident or incident reports, lawsuit papers, health care records, Autotrax reports, ISOs, claim history detail reports or any other documents that evidence any personal injury sustained by Plaintiff prior or subsequent to the incident that is the subject of this action. 15 A copy of the declaration pages providing uninsured motorist coverage to the Plaintiff for the incident described in the Complaint. 16. Any and all documents in your possession or control which establish, suggest, or otherwise support your position that Plaintiff did not sustain a permanent injury as a result of the incident which gives rise to this lawsuit. 17 A ledger itemizing all premiums paid by the Plaintiff to ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY to secure all insurance benefits sought herein, including PIP, Med Pay and UM coverages. 18 If the subject claim involves non-stacked UM coverage, please provide the statutory revised premium rates applicable to this coverage. 19. Any and all forms signed by the Plaintiff (or Plaintiffs family members) as to the rejection of the uninsured/underinsured motorist coverage, or as to the rejection of stacking uninsured/underinsured motorist coverage. I HEREBY CERTIFY that a true copy of the foregoing has been furnished to the Defendant, ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY together with the Summons and Complaint. "2024CA000579AX" 195991977 Filed at Manatee County Clerk 04/11/2024 01:08:51 PM EDT /s/ Christopher Borzell Christopher Borzell, Attorney Morgan & Morgan Tampa, P.A. One Tampa City Center 201 /N. Franklin Street, 7th Floor Tampa, FL 33602 Tele: (941) 271-6384 Fax: (941) 271-6484 Florida Bar #: 68277 Attorney for Plaintiff Primary Email: CBorzell@ForThePeople.cor Sccondary: CT BPicadings@ForfhePcople.com Paralegal: RHoward@ForlhePcople.com "2024CA000579AX" 195991977 Filed at Manatee County Clerk 04/11/2024 01:08:51 PM EDT