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wes CASE NUMBER: 502021CA004393XXXXMB Div: AH ****
Filing # 124254313 E-Filed 04/02/2021 02:42:34 PM
IN THE CIRCUIT COURT OF THE 15™
JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA
MATTIE SINGLETARY, CASE NO.
Plaintiff,
VS.
JD THORNTON NURSERIES, INC., a
Florida Profit Corporation, and LEE
EDWARD THOMPSON,
Defendants.
!
REQUEST TO PRODUCE TO DEFENDANT, LEE EDWARD THOMP:
COMES NOW Plaintiff, MATTIE SINGLETARY, by and through the undersigned attomey,
pursuant to the Florida Rules of Civil Procedure, hereby requests the Defendant, LEE EDWARD
THOMPSON, within forty-five (45) days from the date of service of process to produce the
following documents:
1. Copies of any and all liability insurance policies and any and all excess or umbrella
liability insurance policies providing coverage on the vehicle which was involved in the collision
in this case.
2. Any and all statements given by the Defendant, LEE EDWARD THOMPSON, to any
person other than his attorney or insurer, relative to this accident.
3. Any and all graphs, charts, statements, models, maps, drawings, motion pictures,
photographs or writings pertaining to any fact involved in this lawsuit.
4. Copies of all writings, recordings, memoranda, notes or other material reflecting
statements made by the Plaintiff, MATTIE SINGLETARY, regarding the issues in this case.
CHEN. DAIAARCACUAAIINTY Cl INGEDU ARDIIV7ZN FLEDIZ AAINIINNA NO.A0.2/4 DNA
Pn. PAL DLA VUUINE TT, PL, JUOL IE mDNUeey, ULUIAN, Ute cue) Ue.te.0t Div3. Any and all repair bills and/or repair statements on the involved Defendant, LEE
EDWARD THOMPSON’, vehicle after this accident.
6. Any and all photographs taken by the Defendant, LEE EDWARD THOMPSON, his
attorneys, investigators, agents, servants or employees, after the accident referred to in the complaint
which are in any manner related to the subject matter of this lawsuit. Please provide these
documents in color, preferably on CD or digital medial.
7. Any and all statements of any witness that you, your agents or attorneys have in
your/their possession.
8 A legible copy of the front and back of your driver's license.
9. Any and all cellular telephone billing records from your cellular phone service for the
billing month that includes the date of this collision.
10. Any and all vehicle and/or trailer maintenance and repair records regarding all
vehicles and/or trailers involved in the subject incident.
11. Copies of any and all black box download, the event data recorder (EDR), the
accident data recorder (ADR) and information contained in the vehicles computer system.
oy)
DATED this “2! ~day of April, 2021.
LAW OFFICES OF DAVID M. GASPARI, P.A.
270 S. Central Blvd., Suite 108
Jupiter, FL 33458
(561) 257-4848
Attorney for Piaintitt
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wes CASE NUMBER: 502021CA004393XXXXMB Div: AH **** Filing # 124254313 E-Filed 04/02/2021 02:42:34 PM IN THE CIRCUIT COURT OF THE 15™ JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA MATTIE SINGLETARY, CASE NO. Plaintiff, VS. JD THORNTON NURSERIES, INC., a Florida Profit Corporation, and LEE EDWARD THOMPSON, Defendants. ! REQUEST TO PRODUCE TO DEFENDANT, LEE EDWARD THOMP: COMES NOW Plaintiff, MATTIE SINGLETARY, by and through the undersigned attomey, pursuant to the Florida Rules of Civil Procedure, hereby requests the Defendant, LEE EDWARD THOMPSON, within forty-five (45) days from the date of service of process to produce the following documents: 1. Copies of any and all liability insurance policies and any and all excess or umbrella liability insurance policies providing coverage on the vehicle which was involved in the collision in this case. 2. Any and all statements given by the Defendant, LEE EDWARD THOMPSON, to any person other than his attorney or insurer, relative to this accident. 3. Any and all graphs, charts, statements, models, maps, drawings, motion pictures, photographs or writings pertaining to any fact involved in this lawsuit. 4. Copies of all writings, recordings, memoranda, notes or other material reflecting statements made by the Plaintiff, MATTIE SINGLETARY, regarding the issues in this case. CHEN. DAIAARCACUAAIINTY Cl INGEDU ARDIIV7ZN FLEDIZ AAINIINNA NO.A0.2/4 DNA Pn. PAL DLA VUUINE TT, PL, JUOL IE mDNUeey, ULUIAN, Ute cue) Ue.te.0t Div3. Any and all repair bills and/or repair statements on the involved Defendant, LEE EDWARD THOMPSON’, vehicle after this accident. 6. Any and all photographs taken by the Defendant, LEE EDWARD THOMPSON, his attorneys, investigators, agents, servants or employees, after the accident referred to in the complaint which are in any manner related to the subject matter of this lawsuit. Please provide these documents in color, preferably on CD or digital medial. 7. Any and all statements of any witness that you, your agents or attorneys have in your/their possession. 8 A legible copy of the front and back of your driver's license. 9. Any and all cellular telephone billing records from your cellular phone service for the billing month that includes the date of this collision. 10. Any and all vehicle and/or trailer maintenance and repair records regarding all vehicles and/or trailers involved in the subject incident. 11. Copies of any and all black box download, the event data recorder (EDR), the accident data recorder (ADR) and information contained in the vehicles computer system. oy) DATED this “2! ~day of April, 2021. LAW OFFICES OF DAVID M. GASPARI, P.A. 270 S. Central Blvd., Suite 108 Jupiter, FL 33458 (561) 257-4848 Attorney for Piaintitt