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Case Number:21-000223-CI
Filing # 119694420 E-Filed 01/15/2021 10:49:48 AM
IN THE CIRCUIT COURT IN AND FOR PINELLAS COUNTY, FLORIDA
CASE NO.:
RONALD GICKA,
Plaintiff,
VS.
RICHARD EDWARD NOWAK,
Defendant.
PLAINTIFF'S REOUEST FOR PRODUCTION OF
DOCUMENTS TO DEFENDANT, RICHARD EDWARD NOWAK
COMES NOW, the Plaintiff, RONALD GICKA, by and through his undersigned
attorneys, INGRAM INJURY LAW, P.A., and requests, pursuant to Rule 1.350 of the Florida
Rules of Civil Procedure, within forty-five (45) days after service hereof, the Defendant,
RICHARD EDWARD NOWAK (hereinafter referred to as "Defendant"), to produce and permit
counsel for Plaintiff ft
to inspect and copy the documents requested herein at the offices of INGRAM
INJURY LAW, P.A., 2201 N.E. Coachman Road, Suite 102, Clearwater, Florida, 33765:
1. Please provide copies of any statements obtained by you from any witnesses or any
other individuals pertaining to the collision which is the subject matter of this lawsuit.
2. Please provide copies of and all notes, investigative memoranda,
any reports,
correspondence, or statements relevant to this claim now in the possession of your insurance
carrier, said items obtained prior to this lawsuit and not work product or attorney/clientprivileged.
3. Please provide laser color photographs in the possession of
any your insurance
carrier, your attorney, or yourself of the scene of the collision or of the motor vehicles and trailer
involved in the collision.
***ELECTRONICALLYFILED 01/15/2021 10:49:46 AM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
4. Please provide a copy of the automobile insurance policy or policies covering you
and/or the motor vehicle and trailer you were
operating, including the declaration pages.
5. Please provide each and every insurance agreement or
policy, including binders,
under which insurer may be liable to pay all
an or
part of a judgment entered in this action or to
reimburse Defendant for payments made to satisfy a judgment in this action.
6. Please provide a copy of your driver's license.
7. Please provide a copy of the title and/or registration to the motor vehicle and trailer
you operated at the time of the subject motor vehicle collision.
8. Please provide copies of all repair invoices and estimates for parts or labor which
relate to any malfunction of the motor vehicle and trailer you
operated at the time of the collision
within one year prior to and including the date of the collision.
9. Please provide copies of all repair invoices and appraisals which relate to property
damage to any of the motor vehicles and trailer involved in the collision, which damage is alleged
to have been caused in the collision.
10. Copy of any statements you may have in your possession which the Plaintiff may
have made to anyone concerning the collision.
11. Please provide color copies of any and all surveillance films, photos, reports, or
otherwise reproducible materials evidencing any surveillance, activity check, or other related
investigation pertaining to the Plaintiff in this action.
12. Copies of cellular/mobile telephone bills
your evidencing incoming and/or
outgoing calls and text messages for one hour prior to and one hour after the time of the subject
motor vehicle collision or, if the bill is in your
not possession, please identify your cell phone
number and the and address of the carrier on the date of the
name
subject motor vehicle collision.
CERTIFICATEOF SERVICE
I HEREBY CERTIFY that a copy of the foregoing has been furnished to Defendant,
RICHARD EDWARD NOWAK, by service of together with Summons,
process, Complaint,
Notice of Serving Interrogatories,and Interrogatories.
UR .
LAAWW, P.A.
GKM.2
IiMy
KM
IJ
iMy M?
N: 56
62M
2 4
.IA
Mngrw/Wgure
*mothy
FBN:
M.
1018076
Iggram, Jr.,dbe
2201 N.E. Coachman Road, Suite 102
Clearwater, Florida 33765
Ph: (727) 723-9800 Fax: (727) 723-9866
Primary:
Secondary:
Secondary:
Attorneys for Plaintiff
Preview
Case Number:21-000223-CI Filing # 119694420 E-Filed 01/15/2021 10:49:48 AM IN THE CIRCUIT COURT IN AND FOR PINELLAS COUNTY, FLORIDA CASE NO.: RONALD GICKA, Plaintiff, VS. RICHARD EDWARD NOWAK, Defendant. PLAINTIFF'S REOUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT, RICHARD EDWARD NOWAK COMES NOW, the Plaintiff, RONALD GICKA, by and through his undersigned attorneys, INGRAM INJURY LAW, P.A., and requests, pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, within forty-five (45) days after service hereof, the Defendant, RICHARD EDWARD NOWAK (hereinafter referred to as "Defendant"), to produce and permit counsel for Plaintiff ft to inspect and copy the documents requested herein at the offices of INGRAM INJURY LAW, P.A., 2201 N.E. Coachman Road, Suite 102, Clearwater, Florida, 33765: 1. Please provide copies of any statements obtained by you from any witnesses or any other individuals pertaining to the collision which is the subject matter of this lawsuit. 2. Please provide copies of and all notes, investigative memoranda, any reports, correspondence, or statements relevant to this claim now in the possession of your insurance carrier, said items obtained prior to this lawsuit and not work product or attorney/clientprivileged. 3. Please provide laser color photographs in the possession of any your insurance carrier, your attorney, or yourself of the scene of the collision or of the motor vehicles and trailer involved in the collision. ***ELECTRONICALLYFILED 01/15/2021 10:49:46 AM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** 4. Please provide a copy of the automobile insurance policy or policies covering you and/or the motor vehicle and trailer you were operating, including the declaration pages. 5. Please provide each and every insurance agreement or policy, including binders, under which insurer may be liable to pay all an or part of a judgment entered in this action or to reimburse Defendant for payments made to satisfy a judgment in this action. 6. Please provide a copy of your driver's license. 7. Please provide a copy of the title and/or registration to the motor vehicle and trailer you operated at the time of the subject motor vehicle collision. 8. Please provide copies of all repair invoices and estimates for parts or labor which relate to any malfunction of the motor vehicle and trailer you operated at the time of the collision within one year prior to and including the date of the collision. 9. Please provide copies of all repair invoices and appraisals which relate to property damage to any of the motor vehicles and trailer involved in the collision, which damage is alleged to have been caused in the collision. 10. Copy of any statements you may have in your possession which the Plaintiff may have made to anyone concerning the collision. 11. Please provide color copies of any and all surveillance films, photos, reports, or otherwise reproducible materials evidencing any surveillance, activity check, or other related investigation pertaining to the Plaintiff in this action. 12. Copies of cellular/mobile telephone bills your evidencing incoming and/or outgoing calls and text messages for one hour prior to and one hour after the time of the subject motor vehicle collision or, if the bill is in your not possession, please identify your cell phone number and the and address of the carrier on the date of the name subject motor vehicle collision. CERTIFICATEOF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been furnished to Defendant, RICHARD EDWARD NOWAK, by service of together with Summons, process, Complaint, Notice of Serving Interrogatories,and Interrogatories. UR . LAAWW, P.A. GKM.2 IiMy KM IJ iMy M? N: 56 62M 2 4 .IA Mngrw/Wgure *mothy FBN: M. 1018076 Iggram, Jr.,dbe 2201 N.E. Coachman Road, Suite 102 Clearwater, Florida 33765 Ph: (727) 723-9800 Fax: (727) 723-9866 Primary: Secondary: Secondary: Attorneys for Plaintiff