On December 29, 2017 a
Party Discovery
was filed
involving a dispute between
R And B Auto Body Transport Refinishing Llc,
and
Alexanders Property Maintenance Inc,
for CONTRACTS AND INDEBTEDNESS - COUNTY
in the District Court of Pinellas County.
Preview
Filing # 79317143 E-Filed 10/15/2018 11:18:45 AM
IN THE COUNTY COURT OF
THE SIXTH JUDICIAL CIRCUIT
IN AND FOR PINELLAS COUNTY, FLORIDA
CIVIL ACTION
R & B AUTO BODY TRANSPORT
REFINISHING, LLC,
Plaintiff,
Case No: 17-010423-CO
v.
Division:
ALEXANDERS PROPERTY
MAINTENANCE, INC.,
Defendant.
/
REQUEST TO PRODUCE
PLAINTIFF, by and through their undersigned attorney, and in accordance with Rule
1.350 of the Florida Rules of Civil Procedure, requests the Defendant produce to the Plaintiff
at the office of Benjamin G. DeBerg, Esquire, 1915 Tyrone Blvd North, St. Petersburg,
Florida 33710, within thirty (30) days of service hereof, for inspection and/or copying, the
following:
1. Any photographs (color laser copies or reprints) depicting Defendant's vehicle
before and after the work done by R & B Auto Body Transport Refinishing, LLC.
These photographs are otherwise unavailable to Plaintiff and impossible for
Plaintiff to obtain by other means.
2. Any and all vehicle repair estimates, bills or total loss documents regarding
revised work necessary to correct the alleged damage done to Defendant's
vehicles due to the work performed by R & B Auto Body Transport Refinishing,
LLC including but not limited to the work performed by Southwest Auto
Collision. These estimates are otherwise unavailable to Plaintiff and impossible
for Plaintiff to obtain by other means.
***ELECTRONICALLY FILED 10/15/2018 11:18:45 AM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
3. Any and all invoices for parts purchased to replace parts that were allegedly
damaged by the work done by R & B Auto Body Transport Refinishing, LLC.
4. Any and all canceled checks for parts and labor related to revised work necessary
to correct the alleged damage done to Defendant's vehicles due to the work
performed by R & B Auto Body Transport Refinishing, LLC.
5. Any and all credit card statements showing charges for parts and labor related to
revised work necessary to correct the alleged damage done to Defendant's
vehicles due to the work performed by R & B Auto Body Transport Refinishing,
LLC.
6. Any and all invoices from “Ford Mike” related to parts allegedly lost by R&B
Auto Body Transport Refinishing, LLC.
7. Any and all invoices from “Ford Mike” related to replacement parts purchased to
replace the parts allegedly lost by R & B Auto Body Transport Refinishing, LLC.
8. Any and all invoices and/0r receipts related to cost of towing for the truck
referenced in invoice number 13227.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served
15th
electronically this day of October, 2018, upon: Philip Dragonetti, Esquire, McFarland.
Gould, Lyons, Sullivan & Hogan, P.A., pdasst@mcfarlandg0uldlaw.com.
Ema/m4)» fiagmg
BENJAMIN G. DeBERG, ESQUIRE
DeBerg & DeBerg, PA.
1915 Tyrone Boulevard
St. Petersburg, Florida 33710
(727) 344-5573
BAR NO.: 0076678
SPN NO.: 00798050
Primary e-mail: dana@deberglaw.com
Secondary e-mail: allison@deberglaw.com
Document Filed Date
October 15, 2018
Case Filing Date
December 29, 2017
Category
CONTRACTS AND INDEBTEDNESS - COUNTY
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Filing # 79317143 E-Filed 10/15/2018 11:18:45 AM IN THE COUNTY COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CIVIL ACTION R & B AUTO BODY TRANSPORT REFINISHING, LLC, Plaintiff, Case No: 17-010423-CO v. Division: ALEXANDERS PROPERTY MAINTENANCE, INC., Defendant. / REQUEST TO PRODUCE PLAINTIFF, by and through their undersigned attorney, and in accordance with Rule 1.350 of the Florida Rules of Civil Procedure, requests the Defendant produce to the Plaintiff at the office of Benjamin G. DeBerg, Esquire, 1915 Tyrone Blvd North, St. Petersburg, Florida 33710, within thirty (30) days of service hereof, for inspection and/or copying, the following: 1. Any photographs (color laser copies or reprints) depicting Defendant's vehicle before and after the work done by R & B Auto Body Transport Refinishing, LLC. These photographs are otherwise unavailable to Plaintiff and impossible for Plaintiff to obtain by other means. 2. Any and all vehicle repair estimates, bills or total loss documents regarding revised work necessary to correct the alleged damage done to Defendant's vehicles due to the work performed by R & B Auto Body Transport Refinishing, LLC including but not limited to the work performed by Southwest Auto Collision. These estimates are otherwise unavailable to Plaintiff and impossible for Plaintiff to obtain by other means. ***ELECTRONICALLY FILED 10/15/2018 11:18:45 AM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** 3. Any and all invoices for parts purchased to replace parts that were allegedly damaged by the work done by R & B Auto Body Transport Refinishing, LLC. 4. Any and all canceled checks for parts and labor related to revised work necessary to correct the alleged damage done to Defendant's vehicles due to the work performed by R & B Auto Body Transport Refinishing, LLC. 5. Any and all credit card statements showing charges for parts and labor related to revised work necessary to correct the alleged damage done to Defendant's vehicles due to the work performed by R & B Auto Body Transport Refinishing, LLC. 6. Any and all invoices from “Ford Mike” related to parts allegedly lost by R&B Auto Body Transport Refinishing, LLC. 7. Any and all invoices from “Ford Mike” related to replacement parts purchased to replace the parts allegedly lost by R & B Auto Body Transport Refinishing, LLC. 8. Any and all invoices and/0r receipts related to cost of towing for the truck referenced in invoice number 13227. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been served 15th electronically this day of October, 2018, upon: Philip Dragonetti, Esquire, McFarland. Gould, Lyons, Sullivan & Hogan, P.A., pdasst@mcfarlandg0uldlaw.com. Ema/m4)» fiagmg BENJAMIN G. DeBERG, ESQUIRE DeBerg & DeBerg, PA. 1915 Tyrone Boulevard St. Petersburg, Florida 33710 (727) 344-5573 BAR NO.: 0076678 SPN NO.: 00798050 Primary e-mail: dana@deberglaw.com Secondary e-mail: allison@deberglaw.com