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Case Number: CACE-19-025818 Division: 04
Filing # 100396788 E-Filed 12/16/2019 05:33:52 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
ROBENSON HILAIRE
CASE NO.:
Plaintiff,
-VS-
ROBERT JACKSON and PROGRESSIVE
SELECT INSURANCE COMPANY
Defendants.
REQUEST FOR PRODUCTION
COMES NOW the Plaintiff, ROBENSON HILAIRE, by and through the undersigned
counsel and pursuant to Fla. R. Civ. P. 1.350, requests that Defendant, ROBERT JACKSON and
PROGRESSIVE SELECT INSURANCE COMPANY, produce for inspection and copying the
following within 45 days after service of the Summons and Complaint hereof.
1. Any and all policies of insurance, binders, declaration pages, endorsements, MCS-90
forms, memoranda or other documents concerning any insurance coverage which may be applicable
to the incident in this case or covers or may cover the Defendant and/or someone for whom
Defendant may be legally liable for any or all of the allegations set forth in the Complaint filed in
this case. This includes but is not limited to any and all primary, umbrella, uninsured motorist, and
excess policies.
2. Any and all statements, signed or unsigned documents, audio, stenographic and video
recordings, writings, records, memoranda, notes, or other material in the care, custody, possession
or control of the Defendant or the Defendant's attorneys, investigators, agents, representatives,
servants or employees reflecting "statements," including but not limited to those described in Fla.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/17/2019 10:39:39 AM.****R. Civ. P 1.280, made by the Plaintiff or Plaintiff's employees or agents regarding any of the issues
in this case.
3. Any and all statements, signed or unsigned documents, audio, stenographic and video
recordings, writings, records, memoranda, notes, or other material in the care, custody, possession
or control of the Defendant or the Defendant‘s attorneys, investigators, agents, representatives,
servants or employees reflecting "statements," including but not limited to those described in Fla.
R. Civ. P 1.280, made by any and all witnesses regarding any of the issues in this case.
4. Any and all photographs taken by or on behalf of the Defendant or the Defendant‘s
attorneys, investigators, agents, representatives, servants or employees which are in any manner
related to the subject matter of this lawsuit. This request includes, but is not limited to, any and all
photographs depicting the damage to either vehicle, photographs taken of the scene of the accident,
incident or event that is the subject matter of this lawsuit, and photographs taken of the Plaintiff.
If the original was taken digitally, then a copy of the actual digital file(s) is requested on compact
disc or DVD. If the original was taken on film, both a photographic quality print and the negatives
are requested to be produced. If the original source was a non-digital tape, then a copy of the tape
is requested. If the original source was lost, damaged or destroyed, please state same and provide
acolor laser copy of whatever remains in your possession. Plaintiff will pay for the duplication costs
of color copies and/or Compact Discs/DVDs/Videos.
5. Any and all video tapes, graphs, charts, movie film, blue prints, diagrams, surveys,
renderings or drawings in your possession or in the possession of your agents, attorneys or
representatives which are related to this incident, including, but not limited to the vehicles involved
in the incident, the scene of the incident or the injuries caused by or contributed to by the incident
or the activities, demeanor or person of any of the parties to this case. If the original was takendigitally, then a copy of the actual digital file(s) is requested on compact disc or DVD. If the original
was taken on film, both a photographic quality print and the negatives are requested to be produced.
If the original source was a non-digital tape, then a copy of the tape is requested. If the original
source was lost, damaged or destroyed, please state same and provide a color laser copy of whatever
temains in your possession.
6. Any and all movies, motion pictures, videotapes or reproductions of the incident,
incident or event that is the subject matter of this lawsuit taken by or on behalf of the Defendant or
the Defendant's attorneys, investigators, agents, representatives, servants or employees which are
in any manner related to the subject matter of this lawsuit. If the original was taken digitally, then
a copy of the actual digital file(s) is requested on compact disc or DVD. If the original was taken
on film, both a photographic quality print and the negatives are requested to be produced. If the
original source was a non-digital tape, then a copy of the tape is requested. If the original source was
lost, damaged or destroyed, please state same and provide a color laser copy of whatever remains in
your possession.
7. Any charts, drawings, graphs, diagrams or other documentary evidence involving the
subject matter of this lawsuit which are expected to be offered as evidence at trial.
8. Any and all medical records, reports, opinions, or other writings in the care, custody,
possession or control of the Defendant or the Defendant's attorneys, investigators, agents,
representatives, servants or employees, received from doctors, physicians, nurses, other health care
providers or anyone else who saw, examined, or rendered care or treatment to the Plaintiff or from
any hospitals where the Plaintiff was seen, examined or treated for injuries or conditions that were
or may have been sustained as a result of the accident, incident or event that is the subject of this
lawsuit. This request does not include any records provided directly from Plaintiff.9. Any and all other medical reports, opinions, or other writings in the care, custody,
possession or control of the Defendant or the Defendant‘s attorneys, investigators, agents,
representatives, servants or employees, from doctors, physicians, nurses, other health care providers
or anyone else who saw, examined, or rendered care or treatment to the Plaintiff or from any
hospitals where the Plaintiff was seen, examined or treated for injuries or conditions not related to
the accident, incident or event that is the subject of this lawsuit. This request does not include any
records provided directly from Plaintiff.
10. Any and all reports prepared by experts who are expected to testify at the trial of this
cause.
11. Foreach expert whom you expect to call as an expert witness at the trial of this cause,
copies of any and all factual information or data supplied to or relied upon by the expert, copies of
any and all textual material, including, but not limited to, treatises, periodicals, books, dissertations,
pamphlets, journals and other writings on which the expert will or is anticipated to rely or which the
expert alleges supports any of his or her opinions, copies of any and all statutes, ordinances, codes,
safety manuals, regulations, or other standards on which the expert will or is anticipated to rely, and
copies of any and all records, evaluations, charts, graphs, photographs, movies, motion pictures,
slides, films, videotapes, audiotapes, reconstructions and other writings or recorded representations
prepared or generated by or on behalf of the expert that relate in any way to the preparation or
formulation of any of his or her opinions in this case, including but not limited to all books, manuals,
texts or other written or recorded materials referenced by you for the formulation of this opinion
12. Certificate of title and registration for ROBERT JACKSON‘s vehicle, presently in
effect and in effect at the time of the accident, incident or event that is the subject matter of this
lawsuit.13. Any and all contracts, agreements or other writings relating in any way to any
ownership interest in or right to control the vehicle ROBERT JACKSON was operating at the time
of the accident, incident or event that is the subject matter of this lawsuit.
14. Any and all contracts, agreements or other writings relating in any way to any right
to control ROBERT JACKSON at the time of the accident, incident or event that is the subject
matter of this lawsuit.
15. Any and all contracts, agreements, bills, invoices, bills of lading, or other writings
relating in any way to the vehicle operated by ROBERT JACKSON and/or and its trailer, cargo, or
passenger(s) or the trip, errand or travel itself involving or applicable to ROBERT JACKSON or the
vehicle ROBERT JACKSON was operating at the time of the accident, incident or event that is the
subject matter of this lawsuit.
16. | Asto ROBERT JACKSON's vehicle or vehicles sold or transferred to another party
after the date of this incident that were involved in the incident as alleged in the complaint, the bill
of sale, application for new title, cancelled check, receipts of payment, checkbook register, deposit
receipts or any evidences of payment or in reference to this transaction, that would show the value
or price of said vehicle which was sold or transferred.
17. Any and all medical bills, copies of prescriptions, medical reports, hospital records,
bills, statements or invoices in reference to any injuries sustained by ROBERT JACKSON or any
passenger in the same vehicle in reference to the incident in this case.
18. Any and all prescriptions or legible copies thereof of any known medications taken
by ROBERT JACKSON for a period of seventy-two (72) hours prior to the incident as well as any
warnings, instructions, written descriptions of the like provide to or obtained by ROBERT
JACKSON in reference to said medication or contained in the packaging of said medication.19. Any and all correspondence between the parties to this litigation including their
agents, servants, employees or attorneys in any way in reference to the matters alleged in the
complaint that was prior to the date this Defendant was served with the Complaint in this action.
20. | ROBERT JACKSON‘s driver’s license, presently in effect and in effect at the time
of the accident, incident or event that is the subject matter of this lawsuit.
21. ROBERT JACKSON‘s driving record for the past seven (7) years.
22. ROBERT JACKSON‘s social security card.
23. All insurance policies in full force and effect on the date of the accident, incident or
event that is the subject matter of this lawsuit under which the Plaintiff is or might be eligible to
receive, medical, health, hospital, accident, disability, sickness, social security, worker's
compensation, income disability, wage continuation and/or other similar benefits.
24, Any and all traffic crash reports, accident reports and/or incident reports relating in
any way to the accident, incident or event that is the subject matter of this case.
25. Any and all appraisals, estimates, invoices, and other documents pertaining to the
amount, cost or extent of the damage to ROBERT JACKSON ‘s vehicle or to other property in said
vehicle sustained or suffered as a result of the accident, incident or event that is the subject matter
of this lawsuit.
26. Anyand all statements, cancelled checks, damage estimates, purchase orders, drafts,
repair bills, invoices and similar documentation relating to the cost of repair or extent of damage
to any and all vehicles damaged or other property damage or related expenses as a result of the
accident, incident or event that is the subject matter of this lawsuit. This request includes any
documentation irrespective of whether or not said vehicle or property was repaired or repaired by
that person giving the estimate. or generating the document.27. Any and all repair bills, estimates, invoices, statements or cancelled checks,
checkbook registers or other evidence of payment, cost or value for repair or replacement of the tires,
lights, brakes, steering column, clutch, gas pedal, windshield wiper or turning signal indicator of
ROBERT JACKSON's vehicle or vehicles involved in this incident as alleged in the Complaint that
were incurred, obtained, paid or performed within the eight weeks prior to the date of this incident
as described in the complaint.
28. Any and all repair bills, estimates, invoices, statements or cancelled checks,
checkbook registers or other evidence of payment, cost or value for repair or replacement of any part
of the vehicle driven by ROBERT JACKSON or towed by it or vehicles involved in this incident as
alleged in the Complaint that were incurred, obtained, paid or performed within the eight weeks prior
to the date of this incident as described in the complaint.
29. Any and all repair bills, estimates, invoices, statements or cancelled checks,
checkbook registers or other evidence of payment, cost or value for repair, modification or
replacement of any part of the vehicle driven by ROBERT JACKSON or towed by it or vehicles
involved in this incident as alleged in the Complaint that were incurred, obtained, paid or performed
since the incident as described in the complaint.
30. Any and all photographs, movies, motion pictures, slides, films, videotapes,
audiotapes, records, reports and other writings or recorded representations relating in any way to any
surveillance conducted on the Plaintiff by the Defendant or the Defendant's attorneys, investigators,
agents, representatives, servants or employees. If the original was taken digitally, then a copy of the
actual digital file(s) is requested on compact disc or DVD. If the original was taken on film, both
a photographic quality print and the negatives are requested to be produced. If the original source
was a non-digital tape, then a copy of the tape is requested. If the original source was lost, damagedor destroyed, please state same and provide a color laser copy of whatever remains in your
possession.
31. Any citations and other reports or evidence of charges of any violation of law
ROBERT JACKSON received as a result of the accident, incident or event that is the subject matter
of this lawsuit.
32. All records, reports, forms or other written evidence of the disposition of any citations
or charges of any violation of law ROBERT JACKSON received as a result of the accident, incident
or event that is the subject matter of this lawsuit.
33. Any and all traffic court or other transcripts involving the incident set forth in the
Complaint.
34. Any and all agreements the Defendant has made with anyone that would limit that
party’s liability to anyone for any of the damages in this case.
35. Any and all claims indexes or similar documents relating to Plaintiff.
36. Alldocuments in ROBERT JACKSON’ s possession, custody or control that evidence
other collisions in which ROBERT JACKSON was involved.
37. Alldocuments in ROBERT JACKSON’s possession, custody or control that evidence
other claims or lawsuits in which it was alleged ROBERT JACKSON either caused or was involved
in a collision.
38. All citations and tickets ROBERT JACKSON received in the past ten (10) years for
violations of traffic laws.
39. Any bills for the month of the crash for the cellular telephone, satellite phone, Iphone,
smartphone, Ipad, computer, and any other wireless communication device owned by ROBERT
JACKSON .40. Any bills for the month of the crash for the cellular telephone, satellite phone, Iphone,
smartphone, Ipad, computer, and any other wireless communication device available to ROBERT
JACKSON .
41. Any bills for the month of the crash for the cellular telephone, satellite phone, Iphone,
smartphone, Ipad, computer, and any other wireless communication device owned in whole or in part
by ROBERT JACKSON .
42. Any bills for the month of the crash for the cellular telephone, satellite phone, Iphone,
smartphone, Ipad and any other wireless communication device provided to or for the use of
ROBERT JACKSON.
43. All documentation and reports from any data recorder in your vehicle in both raw and
printed form for the month of the crash. This specifically includes but is not limited Progressive
Snapshot device, SmithSafe, Smith360 GOS, Fleetmatics, Geotab, Qualcomm system,
SensorTRACS, TrailerTRACS, ViaWeb, JTRACS, ProOmiOne, OmniExpress, FleetAdvisor,
QTRACS fleet management system, TruckMail, GlobalTRACS, Telematics, telemetrics modules,
event data recorders, black boxes, gps, Electronic Logging Devices, infotainment systems, "Ride
Check," etc.
44. — Any bills for the month of the crash for any type of communication device, Ipod,
radio, GPS, Progressive Snapshot device, SmithSafe, Smith360 GOS, Fleetmatics, Geotab,
Qualcomm system, SensorTRACS, TrailerTRACS, ViaWeb, JTRACS, ProOmiOne, OmniExpress,
FleetAdvisor, QTRACS fleet management system, TruckMail, GlobalTRACS, Telematics,
telemetrics modules, event data recorders, black boxes, gps, infotainment systems, telemetrics
modules, wi-fi, data or satellite system, Electronic Logging Devices or other broadcasting, datacollection, or receiving unit available to or owned by you or in the motor vehicle involved in the
crash on the date of the incident alleged in the Complaint.
45. All data and documents for the 72 hours before the crash and six hours after the crash
any type of communication device, Ipod, radio, GPS, Progressive Snapshot device, SmithSafe,
Smith360 GOS, Fleetmatics, Geotab, Qualcomm system, Sensor !RACS, TrailerTRACS, ViaWeb,
JTRACS, ProOmiOne, OmniExpress, FleetAdvisor, QTRACS fleet management system, TruckMail,
GlobalTRACS, Telematics, telemetrics modules, event data recorders, black boxes, gps,
infotainment systems, telemetrics modules, wi-fi, data or satellite system, Electronic Logging
Devices or other broadcasting, data collection, or receiving unit available to or owned by you or in
the motor vehicle involved in the crash on the date of the incident alleged in the Complaint.
46. — Allevidence of complaints received by you about the driving of your vehicle involved
in the crash including fleet monitoring, calls to toll-free numbers, third-party monitoring companies
ie. SmithSafe, correspondence, emails,
47. Allreceipts and other documentation of gas purchases for the vehicle in the crash the
day of (and prior to) the crash.
48. All receipts and other documentation of meal purchases from the vehicle or by the
driver on the day of (and prior to) the crash.
49. All receipts and other documentation of other purchases from the vehicle or by the
driver on the day of (and prior to) the crash.
50. All other documentation of the location on the vehicle involved in the crash on the
day of (and prior to) the crash.
51. Anyand all incident reports, photographs, repair bills, estimates, medical bills and/or
records, hospital bills and/or records, ambulance/fire department bills and/or records, CME/IME
10reports, recorded statements, and correspondence that relate or refer to any incident other than the
subject collision, in which you contend that the plaintiff, was or might possibly have sustained
personal injuries and/or property damage.
THEREBY CERTIFY that a copy of the foregoing has been served on the above Defendant,
ROBERT JACKSON and PROGRESSIVE SELECT INSURANCE COMPANY, with the
Complaint.
STEINGER, GREENE & FEINER
2727 NW 62nd Street
Fort Lauderdale, FL 33309
Telephone: (954) 491-7701
Facsimile: (954) 492-2289
Email: rmoore@injurylawyers.com
acox@injurylawyers.com
Attorneys for Plaintiff
Florida Bar No.: 115358
Preview
Case Number: CACE-19-025818 Division: 04 Filing # 100396788 E-Filed 12/16/2019 05:33:52 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA ROBENSON HILAIRE CASE NO.: Plaintiff, -VS- ROBERT JACKSON and PROGRESSIVE SELECT INSURANCE COMPANY Defendants. REQUEST FOR PRODUCTION COMES NOW the Plaintiff, ROBENSON HILAIRE, by and through the undersigned counsel and pursuant to Fla. R. Civ. P. 1.350, requests that Defendant, ROBERT JACKSON and PROGRESSIVE SELECT INSURANCE COMPANY, produce for inspection and copying the following within 45 days after service of the Summons and Complaint hereof. 1. Any and all policies of insurance, binders, declaration pages, endorsements, MCS-90 forms, memoranda or other documents concerning any insurance coverage which may be applicable to the incident in this case or covers or may cover the Defendant and/or someone for whom Defendant may be legally liable for any or all of the allegations set forth in the Complaint filed in this case. This includes but is not limited to any and all primary, umbrella, uninsured motorist, and excess policies. 2. Any and all statements, signed or unsigned documents, audio, stenographic and video recordings, writings, records, memoranda, notes, or other material in the care, custody, possession or control of the Defendant or the Defendant's attorneys, investigators, agents, representatives, servants or employees reflecting "statements," including but not limited to those described in Fla. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/17/2019 10:39:39 AM.****R. Civ. P 1.280, made by the Plaintiff or Plaintiff's employees or agents regarding any of the issues in this case. 3. Any and all statements, signed or unsigned documents, audio, stenographic and video recordings, writings, records, memoranda, notes, or other material in the care, custody, possession or control of the Defendant or the Defendant‘s attorneys, investigators, agents, representatives, servants or employees reflecting "statements," including but not limited to those described in Fla. R. Civ. P 1.280, made by any and all witnesses regarding any of the issues in this case. 4. Any and all photographs taken by or on behalf of the Defendant or the Defendant‘s attorneys, investigators, agents, representatives, servants or employees which are in any manner related to the subject matter of this lawsuit. This request includes, but is not limited to, any and all photographs depicting the damage to either vehicle, photographs taken of the scene of the accident, incident or event that is the subject matter of this lawsuit, and photographs taken of the Plaintiff. If the original was taken digitally, then a copy of the actual digital file(s) is requested on compact disc or DVD. If the original was taken on film, both a photographic quality print and the negatives are requested to be produced. If the original source was a non-digital tape, then a copy of the tape is requested. If the original source was lost, damaged or destroyed, please state same and provide acolor laser copy of whatever remains in your possession. Plaintiff will pay for the duplication costs of color copies and/or Compact Discs/DVDs/Videos. 5. Any and all video tapes, graphs, charts, movie film, blue prints, diagrams, surveys, renderings or drawings in your possession or in the possession of your agents, attorneys or representatives which are related to this incident, including, but not limited to the vehicles involved in the incident, the scene of the incident or the injuries caused by or contributed to by the incident or the activities, demeanor or person of any of the parties to this case. If the original was takendigitally, then a copy of the actual digital file(s) is requested on compact disc or DVD. If the original was taken on film, both a photographic quality print and the negatives are requested to be produced. If the original source was a non-digital tape, then a copy of the tape is requested. If the original source was lost, damaged or destroyed, please state same and provide a color laser copy of whatever temains in your possession. 6. Any and all movies, motion pictures, videotapes or reproductions of the incident, incident or event that is the subject matter of this lawsuit taken by or on behalf of the Defendant or the Defendant's attorneys, investigators, agents, representatives, servants or employees which are in any manner related to the subject matter of this lawsuit. If the original was taken digitally, then a copy of the actual digital file(s) is requested on compact disc or DVD. If the original was taken on film, both a photographic quality print and the negatives are requested to be produced. If the original source was a non-digital tape, then a copy of the tape is requested. If the original source was lost, damaged or destroyed, please state same and provide a color laser copy of whatever remains in your possession. 7. Any charts, drawings, graphs, diagrams or other documentary evidence involving the subject matter of this lawsuit which are expected to be offered as evidence at trial. 8. Any and all medical records, reports, opinions, or other writings in the care, custody, possession or control of the Defendant or the Defendant's attorneys, investigators, agents, representatives, servants or employees, received from doctors, physicians, nurses, other health care providers or anyone else who saw, examined, or rendered care or treatment to the Plaintiff or from any hospitals where the Plaintiff was seen, examined or treated for injuries or conditions that were or may have been sustained as a result of the accident, incident or event that is the subject of this lawsuit. This request does not include any records provided directly from Plaintiff.9. Any and all other medical reports, opinions, or other writings in the care, custody, possession or control of the Defendant or the Defendant‘s attorneys, investigators, agents, representatives, servants or employees, from doctors, physicians, nurses, other health care providers or anyone else who saw, examined, or rendered care or treatment to the Plaintiff or from any hospitals where the Plaintiff was seen, examined or treated for injuries or conditions not related to the accident, incident or event that is the subject of this lawsuit. This request does not include any records provided directly from Plaintiff. 10. Any and all reports prepared by experts who are expected to testify at the trial of this cause. 11. Foreach expert whom you expect to call as an expert witness at the trial of this cause, copies of any and all factual information or data supplied to or relied upon by the expert, copies of any and all textual material, including, but not limited to, treatises, periodicals, books, dissertations, pamphlets, journals and other writings on which the expert will or is anticipated to rely or which the expert alleges supports any of his or her opinions, copies of any and all statutes, ordinances, codes, safety manuals, regulations, or other standards on which the expert will or is anticipated to rely, and copies of any and all records, evaluations, charts, graphs, photographs, movies, motion pictures, slides, films, videotapes, audiotapes, reconstructions and other writings or recorded representations prepared or generated by or on behalf of the expert that relate in any way to the preparation or formulation of any of his or her opinions in this case, including but not limited to all books, manuals, texts or other written or recorded materials referenced by you for the formulation of this opinion 12. Certificate of title and registration for ROBERT JACKSON‘s vehicle, presently in effect and in effect at the time of the accident, incident or event that is the subject matter of this lawsuit.13. Any and all contracts, agreements or other writings relating in any way to any ownership interest in or right to control the vehicle ROBERT JACKSON was operating at the time of the accident, incident or event that is the subject matter of this lawsuit. 14. Any and all contracts, agreements or other writings relating in any way to any right to control ROBERT JACKSON at the time of the accident, incident or event that is the subject matter of this lawsuit. 15. Any and all contracts, agreements, bills, invoices, bills of lading, or other writings relating in any way to the vehicle operated by ROBERT JACKSON and/or and its trailer, cargo, or passenger(s) or the trip, errand or travel itself involving or applicable to ROBERT JACKSON or the vehicle ROBERT JACKSON was operating at the time of the accident, incident or event that is the subject matter of this lawsuit. 16. | Asto ROBERT JACKSON's vehicle or vehicles sold or transferred to another party after the date of this incident that were involved in the incident as alleged in the complaint, the bill of sale, application for new title, cancelled check, receipts of payment, checkbook register, deposit receipts or any evidences of payment or in reference to this transaction, that would show the value or price of said vehicle which was sold or transferred. 17. Any and all medical bills, copies of prescriptions, medical reports, hospital records, bills, statements or invoices in reference to any injuries sustained by ROBERT JACKSON or any passenger in the same vehicle in reference to the incident in this case. 18. Any and all prescriptions or legible copies thereof of any known medications taken by ROBERT JACKSON for a period of seventy-two (72) hours prior to the incident as well as any warnings, instructions, written descriptions of the like provide to or obtained by ROBERT JACKSON in reference to said medication or contained in the packaging of said medication.19. Any and all correspondence between the parties to this litigation including their agents, servants, employees or attorneys in any way in reference to the matters alleged in the complaint that was prior to the date this Defendant was served with the Complaint in this action. 20. | ROBERT JACKSON‘s driver’s license, presently in effect and in effect at the time of the accident, incident or event that is the subject matter of this lawsuit. 21. ROBERT JACKSON‘s driving record for the past seven (7) years. 22. ROBERT JACKSON‘s social security card. 23. All insurance policies in full force and effect on the date of the accident, incident or event that is the subject matter of this lawsuit under which the Plaintiff is or might be eligible to receive, medical, health, hospital, accident, disability, sickness, social security, worker's compensation, income disability, wage continuation and/or other similar benefits. 24, Any and all traffic crash reports, accident reports and/or incident reports relating in any way to the accident, incident or event that is the subject matter of this case. 25. Any and all appraisals, estimates, invoices, and other documents pertaining to the amount, cost or extent of the damage to ROBERT JACKSON ‘s vehicle or to other property in said vehicle sustained or suffered as a result of the accident, incident or event that is the subject matter of this lawsuit. 26. Anyand all statements, cancelled checks, damage estimates, purchase orders, drafts, repair bills, invoices and similar documentation relating to the cost of repair or extent of damage to any and all vehicles damaged or other property damage or related expenses as a result of the accident, incident or event that is the subject matter of this lawsuit. This request includes any documentation irrespective of whether or not said vehicle or property was repaired or repaired by that person giving the estimate. or generating the document.27. Any and all repair bills, estimates, invoices, statements or cancelled checks, checkbook registers or other evidence of payment, cost or value for repair or replacement of the tires, lights, brakes, steering column, clutch, gas pedal, windshield wiper or turning signal indicator of ROBERT JACKSON's vehicle or vehicles involved in this incident as alleged in the Complaint that were incurred, obtained, paid or performed within the eight weeks prior to the date of this incident as described in the complaint. 28. Any and all repair bills, estimates, invoices, statements or cancelled checks, checkbook registers or other evidence of payment, cost or value for repair or replacement of any part of the vehicle driven by ROBERT JACKSON or towed by it or vehicles involved in this incident as alleged in the Complaint that were incurred, obtained, paid or performed within the eight weeks prior to the date of this incident as described in the complaint. 29. Any and all repair bills, estimates, invoices, statements or cancelled checks, checkbook registers or other evidence of payment, cost or value for repair, modification or replacement of any part of the vehicle driven by ROBERT JACKSON or towed by it or vehicles involved in this incident as alleged in the Complaint that were incurred, obtained, paid or performed since the incident as described in the complaint. 30. Any and all photographs, movies, motion pictures, slides, films, videotapes, audiotapes, records, reports and other writings or recorded representations relating in any way to any surveillance conducted on the Plaintiff by the Defendant or the Defendant's attorneys, investigators, agents, representatives, servants or employees. If the original was taken digitally, then a copy of the actual digital file(s) is requested on compact disc or DVD. If the original was taken on film, both a photographic quality print and the negatives are requested to be produced. If the original source was a non-digital tape, then a copy of the tape is requested. If the original source was lost, damagedor destroyed, please state same and provide a color laser copy of whatever remains in your possession. 31. Any citations and other reports or evidence of charges of any violation of law ROBERT JACKSON received as a result of the accident, incident or event that is the subject matter of this lawsuit. 32. All records, reports, forms or other written evidence of the disposition of any citations or charges of any violation of law ROBERT JACKSON received as a result of the accident, incident or event that is the subject matter of this lawsuit. 33. Any and all traffic court or other transcripts involving the incident set forth in the Complaint. 34. Any and all agreements the Defendant has made with anyone that would limit that party’s liability to anyone for any of the damages in this case. 35. Any and all claims indexes or similar documents relating to Plaintiff. 36. Alldocuments in ROBERT JACKSON’ s possession, custody or control that evidence other collisions in which ROBERT JACKSON was involved. 37. Alldocuments in ROBERT JACKSON’s possession, custody or control that evidence other claims or lawsuits in which it was alleged ROBERT JACKSON either caused or was involved in a collision. 38. All citations and tickets ROBERT JACKSON received in the past ten (10) years for violations of traffic laws. 39. Any bills for the month of the crash for the cellular telephone, satellite phone, Iphone, smartphone, Ipad, computer, and any other wireless communication device owned by ROBERT JACKSON .40. Any bills for the month of the crash for the cellular telephone, satellite phone, Iphone, smartphone, Ipad, computer, and any other wireless communication device available to ROBERT JACKSON . 41. Any bills for the month of the crash for the cellular telephone, satellite phone, Iphone, smartphone, Ipad, computer, and any other wireless communication device owned in whole or in part by ROBERT JACKSON . 42. Any bills for the month of the crash for the cellular telephone, satellite phone, Iphone, smartphone, Ipad and any other wireless communication device provided to or for the use of ROBERT JACKSON. 43. All documentation and reports from any data recorder in your vehicle in both raw and printed form for the month of the crash. This specifically includes but is not limited Progressive Snapshot device, SmithSafe, Smith360 GOS, Fleetmatics, Geotab, Qualcomm system, SensorTRACS, TrailerTRACS, ViaWeb, JTRACS, ProOmiOne, OmniExpress, FleetAdvisor, QTRACS fleet management system, TruckMail, GlobalTRACS, Telematics, telemetrics modules, event data recorders, black boxes, gps, Electronic Logging Devices, infotainment systems, "Ride Check," etc. 44. — Any bills for the month of the crash for any type of communication device, Ipod, radio, GPS, Progressive Snapshot device, SmithSafe, Smith360 GOS, Fleetmatics, Geotab, Qualcomm system, SensorTRACS, TrailerTRACS, ViaWeb, JTRACS, ProOmiOne, OmniExpress, FleetAdvisor, QTRACS fleet management system, TruckMail, GlobalTRACS, Telematics, telemetrics modules, event data recorders, black boxes, gps, infotainment systems, telemetrics modules, wi-fi, data or satellite system, Electronic Logging Devices or other broadcasting, datacollection, or receiving unit available to or owned by you or in the motor vehicle involved in the crash on the date of the incident alleged in the Complaint. 45. All data and documents for the 72 hours before the crash and six hours after the crash any type of communication device, Ipod, radio, GPS, Progressive Snapshot device, SmithSafe, Smith360 GOS, Fleetmatics, Geotab, Qualcomm system, Sensor !RACS, TrailerTRACS, ViaWeb, JTRACS, ProOmiOne, OmniExpress, FleetAdvisor, QTRACS fleet management system, TruckMail, GlobalTRACS, Telematics, telemetrics modules, event data recorders, black boxes, gps, infotainment systems, telemetrics modules, wi-fi, data or satellite system, Electronic Logging Devices or other broadcasting, data collection, or receiving unit available to or owned by you or in the motor vehicle involved in the crash on the date of the incident alleged in the Complaint. 46. — Allevidence of complaints received by you about the driving of your vehicle involved in the crash including fleet monitoring, calls to toll-free numbers, third-party monitoring companies ie. SmithSafe, correspondence, emails, 47. Allreceipts and other documentation of gas purchases for the vehicle in the crash the day of (and prior to) the crash. 48. All receipts and other documentation of meal purchases from the vehicle or by the driver on the day of (and prior to) the crash. 49. All receipts and other documentation of other purchases from the vehicle or by the driver on the day of (and prior to) the crash. 50. All other documentation of the location on the vehicle involved in the crash on the day of (and prior to) the crash. 51. Anyand all incident reports, photographs, repair bills, estimates, medical bills and/or records, hospital bills and/or records, ambulance/fire department bills and/or records, CME/IME 10reports, recorded statements, and correspondence that relate or refer to any incident other than the subject collision, in which you contend that the plaintiff, was or might possibly have sustained personal injuries and/or property damage. THEREBY CERTIFY that a copy of the foregoing has been served on the above Defendant, ROBERT JACKSON and PROGRESSIVE SELECT INSURANCE COMPANY, with the Complaint. STEINGER, GREENE & FEINER 2727 NW 62nd Street Fort Lauderdale, FL 33309 Telephone: (954) 491-7701 Facsimile: (954) 492-2289 Email: rmoore@injurylawyers.com acox@injurylawyers.com Attorneys for Plaintiff Florida Bar No.: 115358