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Case Number: CACE-21-009583 Division: 21
Filing # 126770334 E-Filed 05/13/2021 03:18:51 PM
IN THE CIRCUIT COURT OF THE 17°
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.:
HEATHER GRANT,
Plaintiff,
vs.
DAVID VADILLO and
LYFT FLORIDA, INC.
d/b/a LYFT, INC.,
Defendants.
/
REQUEST TO PRODUCE TO DEFENDANT, LYFT FLORIDA, INC.
d/b/a LYFT, INC.
Plaintiff, HEATHER GRANT, by and through her undersigned counsel, requests
the Defendant, LYFT FLORIDA, INC. d/b/a LYFT, INC. to produce at the offices of the
undersigned, within forty- five (45) days of service, the following for inspection, copying
and/or photocopying:
1 Certified copies of any and all policies of insurance, including excess and
umbrella insurance, which cover you for the allegations contained in the Complaint.
2. Any and all declaration sheets in effect for all automobile insurance
policies including excess and umbrella policies in effect on May 3, 2019.
3 Any and all statements in the possession of the Defendant from any and all
witnesses to the incident, which is the subject matter of this proceeding.
4 Any and all statements of the Plaintiff taken regarding this incident.
5 Any and all surveillance, photographs, DVDs, videotapes or any pictorial
images of the Plaintiffon May 3, 2019.
#** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/13/2021 03:18:47 PM.**#*
6. Any and all repair bills or estimates for repair for the motor vehicle the
Defendant, DAVID VADILLO, was operating on May 3, 2019 that was involved in the
subject incident with the Plaintiff, HEATHER GRANT.
7
Any and all computer data or reports generated from computers on the
motor vehicle the Defendant, DAVID VADILLO was driving from 15 minutes before the
subject incident to 15 minutes after the subject incident.
8 Any and all photographs, DVDs, videotapes or any pictorial images of the
scene of the subject incident on May 3, 2019.
9. The results of any drug testing or alcohol testing done on the Defendant,
DAVID VADILLO following the incident of May 3, 2019.
10. Any and all photographs taken of both vehicles involved in the subject
incident.
12. The registration for the motor vehicle involved in the subject incident.
13 A copy of your driver’s license, front and back.
14 Any and all photographs, DVDs, videotapes or any pictorial images of
your vehicle and Plaintiff's vehicle at or after the incident of May 3, 2019.
15. The title for the motor vehicle involved in the subject incident in effect on
May 3, 2019.
16. The cell phone billing records for the Defendant, DAVID VADILLO for
May 3, 2019 from 3 hours before until 3 hours after the subject incident.
17. The Defendant’s, DAVID VADILLO’S entire trip history recorded through
the LYFT App including destination history and payment history for May 3, 2019 from
4:00 p.m.- 6:00 p.m.
17. Any and all written agreements and/or contracts between the Defendant,
DAVID VADILLO and the Defendant, LYFT FLORIDA, INC., d/b/a LYFT, INC. in
effect on May 3, 2019.
/s/Jon A. Zepnick, Esq.
Jon A. Zepnick, Esq.
Florida Bar No.: 586951
ANSEL & MILLER, LLC
Counsel for the Plaintiff
1939 Tyler Street
Hollywood, Florida 33020
Phone: (954) 922-9100
Fax: (954) 922-9176
jonzepnick@anselmiler.com
Makethecall03@aol.com
shields@anselmiller.com
ansel@anselmiller.com
Preview
Case Number: CACE-21-009583 Division: 21 Filing # 126770334 E-Filed 05/13/2021 03:18:51 PM IN THE CIRCUIT COURT OF THE 17° JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: HEATHER GRANT, Plaintiff, vs. DAVID VADILLO and LYFT FLORIDA, INC. d/b/a LYFT, INC., Defendants. / REQUEST TO PRODUCE TO DEFENDANT, LYFT FLORIDA, INC. d/b/a LYFT, INC. Plaintiff, HEATHER GRANT, by and through her undersigned counsel, requests the Defendant, LYFT FLORIDA, INC. d/b/a LYFT, INC. to produce at the offices of the undersigned, within forty- five (45) days of service, the following for inspection, copying and/or photocopying: 1 Certified copies of any and all policies of insurance, including excess and umbrella insurance, which cover you for the allegations contained in the Complaint. 2. Any and all declaration sheets in effect for all automobile insurance policies including excess and umbrella policies in effect on May 3, 2019. 3 Any and all statements in the possession of the Defendant from any and all witnesses to the incident, which is the subject matter of this proceeding. 4 Any and all statements of the Plaintiff taken regarding this incident. 5 Any and all surveillance, photographs, DVDs, videotapes or any pictorial images of the Plaintiffon May 3, 2019. #** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/13/2021 03:18:47 PM.**#* 6. Any and all repair bills or estimates for repair for the motor vehicle the Defendant, DAVID VADILLO, was operating on May 3, 2019 that was involved in the subject incident with the Plaintiff, HEATHER GRANT. 7 Any and all computer data or reports generated from computers on the motor vehicle the Defendant, DAVID VADILLO was driving from 15 minutes before the subject incident to 15 minutes after the subject incident. 8 Any and all photographs, DVDs, videotapes or any pictorial images of the scene of the subject incident on May 3, 2019. 9. The results of any drug testing or alcohol testing done on the Defendant, DAVID VADILLO following the incident of May 3, 2019. 10. Any and all photographs taken of both vehicles involved in the subject incident. 12. The registration for the motor vehicle involved in the subject incident. 13 A copy of your driver’s license, front and back. 14 Any and all photographs, DVDs, videotapes or any pictorial images of your vehicle and Plaintiff's vehicle at or after the incident of May 3, 2019. 15. The title for the motor vehicle involved in the subject incident in effect on May 3, 2019. 16. The cell phone billing records for the Defendant, DAVID VADILLO for May 3, 2019 from 3 hours before until 3 hours after the subject incident. 17. The Defendant’s, DAVID VADILLO’S entire trip history recorded through the LYFT App including destination history and payment history for May 3, 2019 from 4:00 p.m.- 6:00 p.m. 17. Any and all written agreements and/or contracts between the Defendant, DAVID VADILLO and the Defendant, LYFT FLORIDA, INC., d/b/a LYFT, INC. in effect on May 3, 2019. /s/Jon A. Zepnick, Esq. Jon A. Zepnick, Esq. Florida Bar No.: 586951 ANSEL & MILLER, LLC Counsel for the Plaintiff 1939 Tyler Street Hollywood, Florida 33020 Phone: (954) 922-9100 Fax: (954) 922-9176 jonzepnick@anselmiler.com Makethecall03@aol.com shields@anselmiller.com ansel@anselmiller.com