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Filing # 201250446 E-Filed 06/25/2024 08:59:28 AM
IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
OF THE STATE OF FLORIDA, IN AND FOR HILLSBOROUGH COUNTY
CIVIL DIVISION
RADCLIFFE R. MCLEAN,
Plaintiff(s), Case No.:
vs. Div.:
AKEEM R. WELCH and
ALEXANDER G. AGNELLI,
Defendant(s).
/
PLAINTIFF’S REQUEST TO PRODUCE
The Plaintiff(s), RADCLIFFE R. MCLEAN, pursuant to Fla.R.Civ.P. 1.350, request(s) the
Defendant(s), ALEXANDER G. AGNELLI, to produce for inspection, copying, and all other
purposes within the scope of the Florida Rules of Civil Procedure at the office of the undersigned
law firm within forty-five (45) days from the date of service of this Request, the following:
1. Defendant(s) is/are hereby requested to produce a copy of any and all statements (as
defined in the Rules of Civil Procedure) concerning this action or the subject matter of
this action previously made by the Plaintiff.
2. Defendant(s) is/are requested to produce a copy of any and all policies of liability
insurance providing liability coverage to one or more of the Defendant(s) for claims
arising out of the incident described in the Complaint, or, copies of any and all policies
of insurance which allegedly provide liability insurance coverage to the Defendant(s) for
the incident described in the Complaint.
3. Defendant(s) is/are requested to produce a copy of any and all policies of insurance of
any kind or nature which would, or may, provide benefits to the Plaintiff by reason of
incidents described in the Complaint.
4. Defendant(s) is/are requested to produce copies of any and all photographs taken at
the scene of the incident described in the Complaint which do or might reveal marks,
6/25/2024 8:59 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
damage or conditions which no longer exist at said scene or which probably no longer
exist at said scene on the date of the filing of this request.
5. Defendant(s) is/are requested to produce any property in the possession of any
Defendant(s) on the date of the incident described in the Complaint which was involved
in the incident described in the Complaint and which property contains marks or
damage as a result of the incident described in the Complaint, or if such property no
longer contains such marks or damage in the same condition as it did on the date of
the incident described in the Complaint subsequent to said incident, then produce for
examination copies of any and all photographs showing such marks or damage.
6. Defendant(s) is/are requested to produce Defendant's, OR ANY OTHER, motor vehicle
described in the Complaint, or if said motor vehicle is no longer available, any and all
photographs of Defendant's, OR ANY OTHER, motor vehicle in the possession of the
Defendant(s).
7. Defendant(s) is/are requested to produce any photographs of the Plaintiff's vehicle, OR
ANY OTHER VEHICLE INVOLVED IN THIS INCIDENT, showing any marks or damage
on said vehicle which were the result of the incident described in the Complaint.
8. Defendant(s) is/are requested to produce any written document, repair estimate or
report of examination describing in anyway the nature and extent of the damage to
Defendant(s) and/or Plaintiff’s property which occurred as a result of the incident
described in the Complaint or any such documents reflecting conditions of the
Defendant(s) and/or Plaintiff’s property immediately prior to the incident described in
the Complaint which said conditions have subsequently been repaired or corrected or
no longer exist.
9. Any and all statements, transcripts, recorded statements in your possession of any
witness, party, or other individual who may have any information regarding the subject
matter of this lawsuit.
6/25/2024 8:59 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
10. Any and all surveillance of the Plaintiff including but not limited to videotapes,
audiotapes, photographs, pictures, reports, etc.
11. Names, addresses, and telephone numbers of any and all persons including agents of
the Defendant(s) and/or attorneys for the Defendant(s) who have performed any
surveillance of the Plaintiff.
12. Any and all reports of experts, including, but not limited to, medical record reviews,
nurse’s notes, reports, or opinions, film reviews, IME reports, accident reconstruction
reports, notes, or opinions, biomechanical reports, notes, or opinions or other
engineering reports, notes, or opinions.
13. Any and all data from any type of telematic device on the vehicle the defendant was
driving.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing has been furnished together with a copy
of the summons and complaint to the below party(ies):
ALEXANDER G. AGNELLI
4737 Greencroft Road
Sarasota, FL 34235
KINNEY, FERNANDEZ & BOIRE, P.A.
By:________________________
Marcus Fernandez, Esquire
Florida Bar No.: 055806
Attorney for Plaintiff
3128 W. Kennedy Blvd.
Tampa, FL 33609
Telephone: (813) 875-5445
Facsimile: (813) 872-8125
Service E-Mail: marcus@kfblaw.com
6/25/2024 8:59 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3
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Filing # 201250446 E-Filed 06/25/2024 08:59:28 AM IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT OF THE STATE OF FLORIDA, IN AND FOR HILLSBOROUGH COUNTY CIVIL DIVISION RADCLIFFE R. MCLEAN, Plaintiff(s), Case No.: vs. Div.: AKEEM R. WELCH and ALEXANDER G. AGNELLI, Defendant(s). / PLAINTIFF’S REQUEST TO PRODUCE The Plaintiff(s), RADCLIFFE R. MCLEAN, pursuant to Fla.R.Civ.P. 1.350, request(s) the Defendant(s), ALEXANDER G. AGNELLI, to produce for inspection, copying, and all other purposes within the scope of the Florida Rules of Civil Procedure at the office of the undersigned law firm within forty-five (45) days from the date of service of this Request, the following: 1. Defendant(s) is/are hereby requested to produce a copy of any and all statements (as defined in the Rules of Civil Procedure) concerning this action or the subject matter of this action previously made by the Plaintiff. 2. Defendant(s) is/are requested to produce a copy of any and all policies of liability insurance providing liability coverage to one or more of the Defendant(s) for claims arising out of the incident described in the Complaint, or, copies of any and all policies of insurance which allegedly provide liability insurance coverage to the Defendant(s) for the incident described in the Complaint. 3. Defendant(s) is/are requested to produce a copy of any and all policies of insurance of any kind or nature which would, or may, provide benefits to the Plaintiff by reason of incidents described in the Complaint. 4. Defendant(s) is/are requested to produce copies of any and all photographs taken at the scene of the incident described in the Complaint which do or might reveal marks, 6/25/2024 8:59 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 damage or conditions which no longer exist at said scene or which probably no longer exist at said scene on the date of the filing of this request. 5. Defendant(s) is/are requested to produce any property in the possession of any Defendant(s) on the date of the incident described in the Complaint which was involved in the incident described in the Complaint and which property contains marks or damage as a result of the incident described in the Complaint, or if such property no longer contains such marks or damage in the same condition as it did on the date of the incident described in the Complaint subsequent to said incident, then produce for examination copies of any and all photographs showing such marks or damage. 6. Defendant(s) is/are requested to produce Defendant's, OR ANY OTHER, motor vehicle described in the Complaint, or if said motor vehicle is no longer available, any and all photographs of Defendant's, OR ANY OTHER, motor vehicle in the possession of the Defendant(s). 7. Defendant(s) is/are requested to produce any photographs of the Plaintiff's vehicle, OR ANY OTHER VEHICLE INVOLVED IN THIS INCIDENT, showing any marks or damage on said vehicle which were the result of the incident described in the Complaint. 8. Defendant(s) is/are requested to produce any written document, repair estimate or report of examination describing in anyway the nature and extent of the damage to Defendant(s) and/or Plaintiff’s property which occurred as a result of the incident described in the Complaint or any such documents reflecting conditions of the Defendant(s) and/or Plaintiff’s property immediately prior to the incident described in the Complaint which said conditions have subsequently been repaired or corrected or no longer exist. 9. Any and all statements, transcripts, recorded statements in your possession of any witness, party, or other individual who may have any information regarding the subject matter of this lawsuit. 6/25/2024 8:59 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2 10. Any and all surveillance of the Plaintiff including but not limited to videotapes, audiotapes, photographs, pictures, reports, etc. 11. Names, addresses, and telephone numbers of any and all persons including agents of the Defendant(s) and/or attorneys for the Defendant(s) who have performed any surveillance of the Plaintiff. 12. Any and all reports of experts, including, but not limited to, medical record reviews, nurse’s notes, reports, or opinions, film reviews, IME reports, accident reconstruction reports, notes, or opinions, biomechanical reports, notes, or opinions or other engineering reports, notes, or opinions. 13. Any and all data from any type of telematic device on the vehicle the defendant was driving. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been furnished together with a copy of the summons and complaint to the below party(ies): ALEXANDER G. AGNELLI 4737 Greencroft Road Sarasota, FL 34235 KINNEY, FERNANDEZ & BOIRE, P.A. By:________________________ Marcus Fernandez, Esquire Florida Bar No.: 055806 Attorney for Plaintiff 3128 W. Kennedy Blvd. Tampa, FL 33609 Telephone: (813) 875-5445 Facsimile: (813) 872-8125 Service E-Mail: marcus@kfblaw.com 6/25/2024 8:59 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3