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Filing # 66042073 E-Filed 01/03/2018 01:58:52 PM
IN THE CIRCUIT COURT OF THE
15TH JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
Case No.: 502017CA007186
BEVERLY LEVINE and KEITH LEVINE, her
husband,
Piaintifis,
VS.
OVERLAND CONSTRUCTION COMPANY, INC.
and EDWIN GILES, individually and jointly,
Tale Annte
vociiuains,
PLAINTIFFS’ REQUEST FOR PRODUCTION - SURVEILLANCE TO DEFENDANTS
Plaintiffs, BEVERLY LEVINE and KEITH LEVINE, by and through their undersigned
attorney, and, pursuant to Rule 1350, Florida Rules of ©
Procedure, herehy reanests the
Defendants, OVERLAND CONSTRUCTION COMPANY, INC. and EDWIN GILES, to
produce for inspection and copying at the offices of Hicks & Motto, 3399 PGA Boulevard, Suite
300, Palm Beach Gardens, Florida 33410, within thirty (30) days, the following items or things
described below:
1. All surveillance tapes, photographs, moving pictures video of the Plaintiffs.
2. The entire, unedited, video surveillance in your possession or in the possession of
your attorney and/or other agents or representatives.
3. Any and all cancelled checks or invoices indicating the amount paid for
surveillance of the Plaintiffs in this case.
4. Any and all Surveillance Notes (not reports) regarding the Plaintiffs.
Page 1 of 3
CHEN. DAIAARECACUAAIINTY Cl CHADAND ANY FLEDY n4iIn2iNn41a 4-59-69 DAA
PILL. PAL DLA VUUINE TT, FL, GHIA. DUUR, ULLIAN, Uluru tu UL. u.e Civ5. If you have shown surveillance tapes, photographs, moving pictures video of the
Plaintiffs to any of your retained experts, please produce the transmittal letter to each expert and.
any films, photographs, DVD's or other surveillance materials given to them.
6. Copies of all written rules or standards used by the person taking the surveillance
of the Plaintiffs that govern the taking of surveillance films.
7. All written instructions given to the person taking the surveillance of the
Plaintiffs.
8. All documentation, including reports summaries outlining the surveillance or
observation of the Plaintiffs.
9. All impeachment evidence of the Plaintiffs. Such evidence includes, but is not
limited to: any and all surveillance tapes, surveillance films, photographs, digital images, any
and all prior lawsuits, claims, convictions, court orders, or other documentary impeachment
evidence.
10. All materials of any kind or nature reasonably expected or intended to be used at
trial, including documents, other than produced herein in response to Requests # I through #9
above, intended solely for impeachment of the Piaintiff.
IMPORTANT: All copies provided shall be clear and legible. Photographs should be copied
in color.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
by Email to James O. Williams, Jr., Esquire (eService @wlclaw.com), Williams, Leininger &
Page 2 of 3Cosby, P.A., 11300 US Highway One, Suite 300, North Palm Beach, FL 33408, this 3rd day of
January, 2018.
Page 3 of 3
s/James H. Hicks
James H. Hicks, Esquire
Florida Bar No.: 307696
HICKS & MOTTO, P.A.
arnanns 4
33595 PGA Biva.,
Palm Beach Gardens, Florida 33410
Telephone: (561) 683-2300
Facsimile: (561) 697-3852
Primary Email: jhicks@hmelawfirm.com
Secondary: ncoull@hmelawfirm.com
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Filing # 66042073 E-Filed 01/03/2018 01:58:52 PM IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No.: 502017CA007186 BEVERLY LEVINE and KEITH LEVINE, her husband, Piaintifis, VS. OVERLAND CONSTRUCTION COMPANY, INC. and EDWIN GILES, individually and jointly, Tale Annte vociiuains, PLAINTIFFS’ REQUEST FOR PRODUCTION - SURVEILLANCE TO DEFENDANTS Plaintiffs, BEVERLY LEVINE and KEITH LEVINE, by and through their undersigned attorney, and, pursuant to Rule 1350, Florida Rules of © Procedure, herehy reanests the Defendants, OVERLAND CONSTRUCTION COMPANY, INC. and EDWIN GILES, to produce for inspection and copying at the offices of Hicks & Motto, 3399 PGA Boulevard, Suite 300, Palm Beach Gardens, Florida 33410, within thirty (30) days, the following items or things described below: 1. All surveillance tapes, photographs, moving pictures video of the Plaintiffs. 2. The entire, unedited, video surveillance in your possession or in the possession of your attorney and/or other agents or representatives. 3. Any and all cancelled checks or invoices indicating the amount paid for surveillance of the Plaintiffs in this case. 4. Any and all Surveillance Notes (not reports) regarding the Plaintiffs. Page 1 of 3 CHEN. DAIAARECACUAAIINTY Cl CHADAND ANY FLEDY n4iIn2iNn41a 4-59-69 DAA PILL. PAL DLA VUUINE TT, FL, GHIA. DUUR, ULLIAN, Uluru tu UL. u.e Civ5. If you have shown surveillance tapes, photographs, moving pictures video of the Plaintiffs to any of your retained experts, please produce the transmittal letter to each expert and. any films, photographs, DVD's or other surveillance materials given to them. 6. Copies of all written rules or standards used by the person taking the surveillance of the Plaintiffs that govern the taking of surveillance films. 7. All written instructions given to the person taking the surveillance of the Plaintiffs. 8. All documentation, including reports summaries outlining the surveillance or observation of the Plaintiffs. 9. All impeachment evidence of the Plaintiffs. Such evidence includes, but is not limited to: any and all surveillance tapes, surveillance films, photographs, digital images, any and all prior lawsuits, claims, convictions, court orders, or other documentary impeachment evidence. 10. All materials of any kind or nature reasonably expected or intended to be used at trial, including documents, other than produced herein in response to Requests # I through #9 above, intended solely for impeachment of the Piaintiff. IMPORTANT: All copies provided shall be clear and legible. Photographs should be copied in color. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Email to James O. Williams, Jr., Esquire (eService @wlclaw.com), Williams, Leininger & Page 2 of 3Cosby, P.A., 11300 US Highway One, Suite 300, North Palm Beach, FL 33408, this 3rd day of January, 2018. Page 3 of 3 s/James H. Hicks James H. Hicks, Esquire Florida Bar No.: 307696 HICKS & MOTTO, P.A. arnanns 4 33595 PGA Biva., Palm Beach Gardens, Florida 33410 Telephone: (561) 683-2300 Facsimile: (561) 697-3852 Primary Email: jhicks@hmelawfirm.com Secondary: ncoull@hmelawfirm.com