Party Discovery: MELISSA HINE Vs. JON POSSELT, et al

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                                Case Number:21-003638-CI

Filing # 131742145 E-Filed 07/30/2021 12:27:43 PM



           IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT OF THE STATE OF
                                  FLORIDA    IN AND FOR PINELLAS COUNTY
                                                CIVIL DIVISION


         MELISSA HINE,

                 Plaintiff,                                                      CASE NO.:
         VS.
                                                                                 DIVISION:

         JON POSSELT and
         AMINTA HAZLEWOOD,

                 Defendants.
                                                             /

                              REQUEST FOR PRODUCTION TO THE DEFENDANT

                 Plaintiff,   MELISSA   HINE,     by   and       through   the   undersigned   counsel,   requests   the

         Defendant JON POSSELT to produce to said counsel, within forty-five (45) days from the date

         of service hereof, for the purpose of inspection and copying, the matters described in the attached

         list.

                                         CERTIFICATE OF SERVICE

                 1 HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon

         the Defendant along with a copy of the Summons and Complaint.




                                                                     LAL
                                                                  WILLIAM H. WINTERS, ESQUIRE
                                                                  WINTERS & YONKER, P.A.
                                                                  Post Office Box 3342
                                                                  Tampa, Florida 33601
                                                                  (813) 223-6200
                                                                  (813) 223-6900 fax
                                                                  Florida Bar#: 437263
                                                                  Attorney for Plaintiff




***ELECTRONICALLY FILED 07/30/2021 12:27:40 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
s
ITEMS TO BE PRODUCED


     All automobile declarations pages, insurance cards, and statements of benefits
     for insurance policies that reflect coverage(s) available to the Defendant at the
     time of the subject accident.

     All written documents, repair estimates or reports of examination regarding
     the property damage to the Defendant’s and any other vehicle involved in the
     subject accident.

     All written documents, repair estimates or reports of examination of the
     damage to the Plaintiff's property that occurred as a result of the incident.

     All original photographs or videotapes of the vehicles, the accident scene or
     the parties, and other documentary evidence of the scene or parties pertaining
     to the subject accident.

     All reports, photographs, audiotape, and/or videotapes acquired             by    the
     Defendant through surveillance or other investigative methods.

     All written or recorded statements taken of the Plaintiff or any party or
     witness to this action.

     All evidence of Plaintiff “Release” of any elements of damage claimed in the
     Complaint filed in this matter.

     All excess “umbrella” insurance policies in effect on the date of the subject
     accident, covering the defendant, and/or the motor vehicle involved in said
     accident.

     All reports received from any examining or treating physician regarding the
     Plaintiff and the injuries sustained as a result of the subject accident, including
     x-rays or x-ray reports.

10   All reports from any expert witnesses, intended for use at trial, whether taped,
     written, or notes from oral conversation, regarding the Plaintiff, and the
     injuries sustained as a result of the subject accident, and any reports from any
     expert witnesses regarding the issue of liability.

11   Any accident and/or incident reports filed as a result of the subject accident.