On December 08, 2015 a
Party Discovery
was filed
involving a dispute between
Webb, Cedric L,
Webb, Sarah M,
and
Baker, James A,
Baker, Makayla S,
for AUTO NEGLIGENCE
in the District Court of Alachua County.
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Filing # 36169949 E-Filed 01/05/2016 03:17:21 PM
IN THE CIRCUIT COURT, IN AND
FOR ALACHUA COUNTY, FLORIDA
CASE NO.: 01-15-CA-4367
CEDRIC L. WEBB, an individual DIVISION:
and SARAH M. WEBB, an individual,
Plaintiffs,
Vv.
MAKAYLA S. BAKER, an individual
and JAMES A. BAKER, an individual,
Defendants.
7 /
DEFENDANTS’ REQUEST TO PRODUCE TO PLAINTIFF
The Defendants, MAKAYLA S$. BAKER and JAMES A. BAKER, by and through
undersigned counsel, pursuant to Florida Rules of Civil Procedure, request Plaintiff,
CEDRIC L. WEBB to provide the following for inspection and/or copying:
1 Copies of Federal Income Tax Returns, W-2 withholding tax statements, any
and all other business records and/or income records, and other evidence of income for
the past five (5) years, together with evidence of current income to date.
2. Bills and/or estimates for repair to the vehicle and/or damaged property
and the costs of temporary or permanent replacement thereof, including rental vehicle
charges.
3 Any and all medical or related bills, paid or owing, allegedly resulting from
the within accident or occurrence.
4 Any and all medical reports, doctors’ reports, or reports rendered by
experts applicable to any and all issues in this cause.
5
3, Any and all written or recorded statements taken from any of the
Defendants concerning any issue in this cause.
"2015 CA 004367" 36169949 Filed at Alachua County Clerk 01/05/2016 03:17:43 PM EST
6 The name and address of any person from whom you or your attorneys or
their representatives have obtained a written or recorded statement and the date taken.
7, Any and all photographs, graphs, charts and other documentary evidence
of the scene, parties or vehicles involved in or pertaining to the subject accident,
occurrence or issues in this cause.
8 Any and all insurance policies providing benefits or coverage to the
Plaintiff for any claimed injury or damage for the subject accident or occurrence.
As grounds for this request, the Defendant shows unto the Court that these items
are relevant, material and reasonably calculated to lead to the discovery of admissible
evidence in this cause. The Defendant will examine these documents at the office of either
Defendant's altorneys or Plaintiff's attorneys, or at Court Chambers at any time
convenient to the parties, within thirty-five (35) days from the date of this request of
availability by counsel for the party producing the documents.
1 HEREBY CERTIFY that a copy of the foregoing has been sent by e-mail in
accordance with Rule 2.516, Fla. R. Jud. Admin. to Paul B. Brockway, Esquire at
litigationfiling@bagenlaw.com, paul@bagenlaw.com and Melinda@bagenlaw.com, this
5th day of January, 2016.
om,
“
CHOB! PA
Fla. Bar No. 218294
Service Address: service@ebbetslaw.com
138 Live Oak Avenue
Daytona Beach, Florida 32114
Tel. (386) 253-2288 Fax (386) 257-1253
Attorney for Defendants, Baker
Document Filed Date
January 05, 2016
Case Filing Date
December 08, 2015
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Filing # 36169949 E-Filed 01/05/2016 03:17:21 PM IN THE CIRCUIT COURT, IN AND FOR ALACHUA COUNTY, FLORIDA CASE NO.: 01-15-CA-4367 CEDRIC L. WEBB, an individual DIVISION: and SARAH M. WEBB, an individual, Plaintiffs, Vv. MAKAYLA S. BAKER, an individual and JAMES A. BAKER, an individual, Defendants. 7 / DEFENDANTS’ REQUEST TO PRODUCE TO PLAINTIFF The Defendants, MAKAYLA S$. BAKER and JAMES A. BAKER, by and through undersigned counsel, pursuant to Florida Rules of Civil Procedure, request Plaintiff, CEDRIC L. WEBB to provide the following for inspection and/or copying: 1 Copies of Federal Income Tax Returns, W-2 withholding tax statements, any and all other business records and/or income records, and other evidence of income for the past five (5) years, together with evidence of current income to date. 2. Bills and/or estimates for repair to the vehicle and/or damaged property and the costs of temporary or permanent replacement thereof, including rental vehicle charges. 3 Any and all medical or related bills, paid or owing, allegedly resulting from the within accident or occurrence. 4 Any and all medical reports, doctors’ reports, or reports rendered by experts applicable to any and all issues in this cause. 5 3, Any and all written or recorded statements taken from any of the Defendants concerning any issue in this cause. "2015 CA 004367" 36169949 Filed at Alachua County Clerk 01/05/2016 03:17:43 PM EST 6 The name and address of any person from whom you or your attorneys or their representatives have obtained a written or recorded statement and the date taken. 7, Any and all photographs, graphs, charts and other documentary evidence of the scene, parties or vehicles involved in or pertaining to the subject accident, occurrence or issues in this cause. 8 Any and all insurance policies providing benefits or coverage to the Plaintiff for any claimed injury or damage for the subject accident or occurrence. As grounds for this request, the Defendant shows unto the Court that these items are relevant, material and reasonably calculated to lead to the discovery of admissible evidence in this cause. The Defendant will examine these documents at the office of either Defendant's altorneys or Plaintiff's attorneys, or at Court Chambers at any time convenient to the parties, within thirty-five (35) days from the date of this request of availability by counsel for the party producing the documents. 1 HEREBY CERTIFY that a copy of the foregoing has been sent by e-mail in accordance with Rule 2.516, Fla. R. Jud. Admin. to Paul B. Brockway, Esquire at litigationfiling@bagenlaw.com, paul@bagenlaw.com and Melinda@bagenlaw.com, this 5th day of January, 2016. om, “ CHOB! PA Fla. Bar No. 218294 Service Address: service@ebbetslaw.com 138 Live Oak Avenue Daytona Beach, Florida 32114 Tel. (386) 253-2288 Fax (386) 257-1253 Attorney for Defendants, Baker