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Filing # 75488308 E-Filed 07/25/2018 01:05:04 PM
IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT, IN AND FOR
ORANGE COUNTY, FLORIDA
CASE NO:
CARLOS OSWALDO RUIZ and
KAREN Y. RAPALO PALACIOS,
Plaintiffs,
vs.
ALEA D. WOODS and
KELLY LYNN WOODS,
Defendants.
___________________________________/
REQUEST FOR PRODUCTION TO DEFENDANT, ALEA D. WOODS
YOU ARE HEREBY requested to produce for inspection and copying, pursuant to Rule
1.350 of the Florida Rules of Civil Procedure, within (45) days from the date of this Request, at the
offices of McBride, Scicchitano and Leacox, P.A., 800 N. Magnolia Avenue, Suite 1800, Orlando,
FL 32803, the following:
1. All written or recorded statements made by any witness or party, concerning any issue in
this lawsuit.
2. All statements made by Plaintiff pertaining to or concerning the subject accident, damages
or any other matter related to this lawsuit.
3. All pictures, motion pictures, movies, films, or photographic material of any kind
concerning the scene, surrounding areas, vehicles, products or the events and happenings
made the basis of Plaintiff’s lawsuit taken before, during or after the accident in question
which are in the possession, constructive possession, custody, control of you, your attorney,
or anyone acting on your behalf.
4. A copy of estimates, invoices, and/or any other written documentation which was prepared
as a result of the damage to any vehicles involved in the accident made the basis of
Plaintiff’s lawsuit.
5. A copy of any medical records of any sort in your possession or control which relate to
Plaintiff.
6. Surveillance films, photographs, or graphic depictions of any sort which purport to show
Plaintiff herein.
7. All photographs of Plaintiff depicting injuries received in the subject accident.
8. Documents relating to or discussing any statements made by you.
9. Documents relating to or discussing any statements made by Plaintiff.
10. A copy of any and all insurance agreements, insurance policies or agreements of any kind
or nature under which any person or company carrying on an insurance business may be
liable to satisfy part or all of a judgment which may be entered in this action or to
indemnify or reimburse any payments made to satisfy any such judgment or settlement,
including but not limited to a certified copy of the declarations sheet as to each such policy.
11. A copy of your Social Security card and drivers’ license, including any commercial
drivers’ license you hold.
12. A copy of your driving record.
13. A copy of the registration of the motor vehicle you were driving at the time of the accident.
14. A copy of the title of the motor vehicle you were driving at the time of the accident.
15. A copy of any “Mary Carter Agreements” entered into by you or on your behalf with any
other defendant or person, firm, or corporation who you contend may be responsible for the
subject accident.
16. A copy of any and all documents reflecting whether or not you received any
compensation from your own insurance company or from any other insurance company
as a result of the subject accident.
17. All correspondence to or from any company, individual or entity regarding the subject
accident.
18. A copy of any damage appraisal made of the motor vehicle you were driving at the time
of the accident.
19. Any reservation of rights letter or other correspondence or documents sent to you by any
insurers regarding your insurance coverage or any question concerning insurance
coverage for the subject accident.
20. A copy of any and all mobile, cellular and/or automobile telephone records including text
messages phone calls and data usage, for any and all mobile, cellular and/or automobile
telephones you possessed or in your custody or control, on the date of the accident that is
the subject of Plaintiff’s Complaint.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via
service of process along with the Complaint, Request for Admissions and Interrogatories to
Defendant, ALEA D. WOODS.
/s/ Zachary A. Leacox
______________________________
Zachary A. Leacox, Esquire
Florida Bar No.: 0548571
zacharyefiling@williammcbride.com
McBride, Scicchitano & Leacox, P.A.
800 N. Magnolia Avenue, Suite 1800
Orlando, FL 32803
Telephone (407) 650-1700
Facsimile (407) 849-0448
Attorneys for Plaintiff
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Filing # 75488308 E-Filed 07/25/2018 01:05:04 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR ORANGE COUNTY, FLORIDA CASE NO: CARLOS OSWALDO RUIZ and KAREN Y. RAPALO PALACIOS, Plaintiffs, vs. ALEA D. WOODS and KELLY LYNN WOODS, Defendants. ___________________________________/ REQUEST FOR PRODUCTION TO DEFENDANT, ALEA D. WOODS YOU ARE HEREBY requested to produce for inspection and copying, pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, within (45) days from the date of this Request, at the offices of McBride, Scicchitano and Leacox, P.A., 800 N. Magnolia Avenue, Suite 1800, Orlando, FL 32803, the following: 1. All written or recorded statements made by any witness or party, concerning any issue in this lawsuit. 2. All statements made by Plaintiff pertaining to or concerning the subject accident, damages or any other matter related to this lawsuit. 3. All pictures, motion pictures, movies, films, or photographic material of any kind concerning the scene, surrounding areas, vehicles, products or the events and happenings made the basis of Plaintiff’s lawsuit taken before, during or after the accident in question which are in the possession, constructive possession, custody, control of you, your attorney, or anyone acting on your behalf. 4. A copy of estimates, invoices, and/or any other written documentation which was prepared as a result of the damage to any vehicles involved in the accident made the basis of Plaintiff’s lawsuit. 5. A copy of any medical records of any sort in your possession or control which relate to Plaintiff. 6. Surveillance films, photographs, or graphic depictions of any sort which purport to show Plaintiff herein. 7. All photographs of Plaintiff depicting injuries received in the subject accident. 8. Documents relating to or discussing any statements made by you. 9. Documents relating to or discussing any statements made by Plaintiff. 10. A copy of any and all insurance agreements, insurance policies or agreements of any kind or nature under which any person or company carrying on an insurance business may be liable to satisfy part or all of a judgment which may be entered in this action or to indemnify or reimburse any payments made to satisfy any such judgment or settlement, including but not limited to a certified copy of the declarations sheet as to each such policy. 11. A copy of your Social Security card and drivers’ license, including any commercial drivers’ license you hold. 12. A copy of your driving record. 13. A copy of the registration of the motor vehicle you were driving at the time of the accident. 14. A copy of the title of the motor vehicle you were driving at the time of the accident. 15. A copy of any “Mary Carter Agreements” entered into by you or on your behalf with any other defendant or person, firm, or corporation who you contend may be responsible for the subject accident. 16. A copy of any and all documents reflecting whether or not you received any compensation from your own insurance company or from any other insurance company as a result of the subject accident. 17. All correspondence to or from any company, individual or entity regarding the subject accident. 18. A copy of any damage appraisal made of the motor vehicle you were driving at the time of the accident. 19. Any reservation of rights letter or other correspondence or documents sent to you by any insurers regarding your insurance coverage or any question concerning insurance coverage for the subject accident. 20. A copy of any and all mobile, cellular and/or automobile telephone records including text messages phone calls and data usage, for any and all mobile, cellular and/or automobile telephones you possessed or in your custody or control, on the date of the accident that is the subject of Plaintiff’s Complaint. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via service of process along with the Complaint, Request for Admissions and Interrogatories to Defendant, ALEA D. WOODS. /s/ Zachary A. Leacox ______________________________ Zachary A. Leacox, Esquire Florida Bar No.: 0548571 zacharyefiling@williammcbride.com McBride, Scicchitano & Leacox, P.A. 800 N. Magnolia Avenue, Suite 1800 Orlando, FL 32803 Telephone (407) 650-1700 Facsimile (407) 849-0448 Attorneys for Plaintiff