On September 07, 2021 a
Party Discovery
was filed
involving a dispute between
Montes, Yajaira,
and
Douglas, Dennis,
Douglas, Donna,
Geico General Insurance Company,
for AUTO NEGLIGENCE - CIRCUIT
in the District Court of Pinellas County.
Preview
Case Number:21-004236-CI
Filing # 134086976 E-Filed 09/07/2021 10:14:16 AM
IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT
IN AND FOR THE COUNTY OF PINELLAS, STATE OF FLORIDA
CIVIL DIVISION
YAJAIRA MONTES,
Plaintiff,
vs. CASE NO.:
DIVISION:
DONNA DOUGLAS; DENNIS
DOUGLAS; and GEICO GENERAL
INSURANCE COMPANY,
Defendants.
PLAINTIFF’S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO
DEFENDANT, GEICO GENERAL INSURANCE COMPANY
COMES NOW the Plaintiff, YAJAIRA MONTES, by and through her undersigned
attorney, pursuant to Florida Rules of Civil Procedure, Rule 1.350, requests the Defendant,
GEICO GENERAL INSURANCE COMPANY, produce at the office of Catania & Catania,
P.A., Bank of America Plaza, Suite 2400, 101 E. Kennedy Blvd., Tampa, Florida 33602, within
forty-five (45) days the following documents requested in Schedule A.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished to the
Defendant via service of process.
CATANIA & CATANI.
MARC B. PARISH, ESQUIRE
FBN: 0056714
efiling@cataniaandcatania.com
Bank of America Plaza, Suite 2400
101 E. Kennedy Boulevard
Tampa, FL 33602
813/222-8545
Attorneys for Plaintiff
***ELECTRONICALLY FILED 09/07/2021 10:14:13 AM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
SCHEDULE A
1. Any photographs of the vehicles involved in the accident, any photographs at the
scene of the accident, and any photographs of the Plaintiff in her injured condition, including
photographs illustrating any personal injuries alleged by the Plaintiff.
2. Any and all written or recorded statements taken from the Plaintiff concerning any
issues in this cause.
3. Any and all photographs, graphs, charts, and other documentary evidence of the scene,
parties, or vehicles involved in or pertaining to the subject accident or occurrence or the issues in
this cause.
4. All written statements, including opinion, memoranda and reports of defendant and
defendant's agents and employees which defendant expects to introduced into evidence at the
trial of this case.
5. All written statements, including opinions, memoranda and reports of any and all
witnesses and especially experts which defendant expects to introduce into evidence or utilize at
the trial of this cause.
6. A complete copy of the policy of insurance issued to Plaintiff which is the subject of
this action.
7. Any surveillance movies or photographs which have been made of the Plaintiff.
8. A complete copy of certified declaration and coverage pages any and all policies of
insurance in your possession which provide or which may provide coverage to the Defendant.
Document Filed Date
September 07, 2021
Case Filing Date
September 07, 2021
Category
AUTO NEGLIGENCE - CIRCUIT
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Case Number:21-004236-CI Filing # 134086976 E-Filed 09/07/2021 10:14:16 AM IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR THE COUNTY OF PINELLAS, STATE OF FLORIDA CIVIL DIVISION YAJAIRA MONTES, Plaintiff, vs. CASE NO.: DIVISION: DONNA DOUGLAS; DENNIS DOUGLAS; and GEICO GENERAL INSURANCE COMPANY, Defendants. PLAINTIFF’S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT, GEICO GENERAL INSURANCE COMPANY COMES NOW the Plaintiff, YAJAIRA MONTES, by and through her undersigned attorney, pursuant to Florida Rules of Civil Procedure, Rule 1.350, requests the Defendant, GEICO GENERAL INSURANCE COMPANY, produce at the office of Catania & Catania, P.A., Bank of America Plaza, Suite 2400, 101 E. Kennedy Blvd., Tampa, Florida 33602, within forty-five (45) days the following documents requested in Schedule A. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished to the Defendant via service of process. CATANIA & CATANI. MARC B. PARISH, ESQUIRE FBN: 0056714 efiling@cataniaandcatania.com Bank of America Plaza, Suite 2400 101 E. Kennedy Boulevard Tampa, FL 33602 813/222-8545 Attorneys for Plaintiff ***ELECTRONICALLY FILED 09/07/2021 10:14:13 AM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** SCHEDULE A 1. Any photographs of the vehicles involved in the accident, any photographs at the scene of the accident, and any photographs of the Plaintiff in her injured condition, including photographs illustrating any personal injuries alleged by the Plaintiff. 2. Any and all written or recorded statements taken from the Plaintiff concerning any issues in this cause. 3. Any and all photographs, graphs, charts, and other documentary evidence of the scene, parties, or vehicles involved in or pertaining to the subject accident or occurrence or the issues in this cause. 4. All written statements, including opinion, memoranda and reports of defendant and defendant's agents and employees which defendant expects to introduced into evidence at the trial of this case. 5. All written statements, including opinions, memoranda and reports of any and all witnesses and especially experts which defendant expects to introduce into evidence or utilize at the trial of this cause. 6. A complete copy of the policy of insurance issued to Plaintiff which is the subject of this action. 7. Any surveillance movies or photographs which have been made of the Plaintiff. 8. A complete copy of certified declaration and coverage pages any and all policies of insurance in your possession which provide or which may provide coverage to the Defendant.