On April 16, 2021 a
Party Discovery
was filed
involving a dispute between
Mcgirt, Michael Daniel,
and
Archer, Randy J.,
for Auto Negligence
in the District Court of Broward County.
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Case Number: CACE-21-007761 Division: 18
Filing # 125100105 E-Filed 04/16/2021 04:35:48 PM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT,
IN AND FOR BROWARD COUNTY, FLORIDA.
CASE NO:
MICHAEL DANIEL MCGIRT,
VS.
Plaintiff,
RANDY J. ARCHER
Defendant.
/
RE! 'T TO PRODUCE TO DEFENDANT
RANDY J. ARCHER
YOU ARE HEREBY requested to produce for inspection and copying, pursuant to Rule
1.350 of the Florida Rules of Civil Procedure, within (45) days from the date of this Request, at the
offices of ..., the following:
1.
All written or recorded statements made by any witness or party, concerning any issue in this
lawsuit.
All statements made by Plaintiff pertaining to or concerning the subject accident, damages
or any other matter related to this lawsuit.
All pictures, motions pictures, movies, films, or photographic material of any kind
concerning the scene, surrounding areas, vehicles, products or the events and happenings
made the basis of Plaintiff's lawsuit taken before, during or after the accident in question
which are in the possession, constructive possession, custody, control of Defendant,
Defendant’s attorney, or anyone acting on Defendant’s behalf.
Copies of estimates, invoices, and/or any other written documentation which was prepared
as a result of the damage to any vehicles involved in the accident made the basis of Plaintiff's
lawsuit.
Copies of any medical records of any sort in your possession or control which relate to
Plaintiff.
Surveillance films, photographs, or graphic depictions of any sort which purport to show
Plaintiff herein.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/16/2021 04:35:46 PM.****10.
11.
12.
13.
14.
15.
16.
17.
18.
20.
All photographs of Plaintiff depicting injuries received in the subject accident.
Documents relating to or discussing any statements made by Defendant.
Documents relating to or discussing any statements made by Plaintiff.
A copy of any and all insurance agreements, insurance policies or agreements of any kind or
nature under which any person or company carrying on an insurance business may be liable
to satisfy part or all of a judgment which may be entered in this action or to indemnify or
reimburse any payments made to satisfy any such judgment or settlement, including but not
limited to a certified copy of the declarations sheet as to each such policy.
Copies of Defendant’s Social Security Card and Driver’s License, including any
commercial driver’s license held by Defendant.
A copy of Defendant’s driving record.
A copy of the registration of the motor vehicle driven by Defendant at the time of the
accident.
A copy of the title of the motor vehicle driven by Defendant at the time of the accident.
Copies of any “Mary Carter Agreements” entered into by you or on your behalf with any
other Defendant or person, firm, or corporation who you contend may be responsible for
the subject accident.
Copies of any and all documents reflecting whether or not you received any
compensation from your own insurance company or from any other insurance company
as a result of the subject accident.
All correspondence to or from any company, individual or entity regarding the subject
accident.
A copy of any damage appraisal made of the Defendant’s motor vehicle.
Any reservation of rights letter or other correspondence or documents sent to you by any
insurers regarding your insurance coverage or any question concerning insurance
coverage for the subject accident.
Copies of any and all mobile, cellular and/or automobile telephone records including text
messages phone calls and data usage, for any and all mobile, cellular and/or automobile
telephones possessed by Defendant or in Defendant’s custody or control, on the date of the
accident that is the subject of Plaintiff's complaint.CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via
service of process along with the Complaint and Interrogatories to Defendant, RANDY J.
ARCHER.
Dated: April 16, 2021
STEWAR Hag: SQ.
Florida Bar No.: 0106733
Tavarez Law, P.A.
230 E. MONUMENT AVE., STE A5S
KISSIMMEE, FL 34741
Tel: (407) 459-7679
Fax: (407) 517-4348
Email: stewar@tavarezlaw.com
Attorneys for Plaintiff
Document Filed Date
April 16, 2021
Case Filing Date
April 16, 2021
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Case Number: CACE-21-007761 Division: 18 Filing # 125100105 E-Filed 04/16/2021 04:35:48 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA. CASE NO: MICHAEL DANIEL MCGIRT, VS. Plaintiff, RANDY J. ARCHER Defendant. / RE! 'T TO PRODUCE TO DEFENDANT RANDY J. ARCHER YOU ARE HEREBY requested to produce for inspection and copying, pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, within (45) days from the date of this Request, at the offices of ..., the following: 1. All written or recorded statements made by any witness or party, concerning any issue in this lawsuit. All statements made by Plaintiff pertaining to or concerning the subject accident, damages or any other matter related to this lawsuit. All pictures, motions pictures, movies, films, or photographic material of any kind concerning the scene, surrounding areas, vehicles, products or the events and happenings made the basis of Plaintiff's lawsuit taken before, during or after the accident in question which are in the possession, constructive possession, custody, control of Defendant, Defendant’s attorney, or anyone acting on Defendant’s behalf. Copies of estimates, invoices, and/or any other written documentation which was prepared as a result of the damage to any vehicles involved in the accident made the basis of Plaintiff's lawsuit. Copies of any medical records of any sort in your possession or control which relate to Plaintiff. Surveillance films, photographs, or graphic depictions of any sort which purport to show Plaintiff herein. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/16/2021 04:35:46 PM.****10. 11. 12. 13. 14. 15. 16. 17. 18. 20. All photographs of Plaintiff depicting injuries received in the subject accident. Documents relating to or discussing any statements made by Defendant. Documents relating to or discussing any statements made by Plaintiff. A copy of any and all insurance agreements, insurance policies or agreements of any kind or nature under which any person or company carrying on an insurance business may be liable to satisfy part or all of a judgment which may be entered in this action or to indemnify or reimburse any payments made to satisfy any such judgment or settlement, including but not limited to a certified copy of the declarations sheet as to each such policy. Copies of Defendant’s Social Security Card and Driver’s License, including any commercial driver’s license held by Defendant. A copy of Defendant’s driving record. A copy of the registration of the motor vehicle driven by Defendant at the time of the accident. A copy of the title of the motor vehicle driven by Defendant at the time of the accident. Copies of any “Mary Carter Agreements” entered into by you or on your behalf with any other Defendant or person, firm, or corporation who you contend may be responsible for the subject accident. Copies of any and all documents reflecting whether or not you received any compensation from your own insurance company or from any other insurance company as a result of the subject accident. All correspondence to or from any company, individual or entity regarding the subject accident. A copy of any damage appraisal made of the Defendant’s motor vehicle. Any reservation of rights letter or other correspondence or documents sent to you by any insurers regarding your insurance coverage or any question concerning insurance coverage for the subject accident. Copies of any and all mobile, cellular and/or automobile telephone records including text messages phone calls and data usage, for any and all mobile, cellular and/or automobile telephones possessed by Defendant or in Defendant’s custody or control, on the date of the accident that is the subject of Plaintiff's complaint.CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via service of process along with the Complaint and Interrogatories to Defendant, RANDY J. ARCHER. Dated: April 16, 2021 STEWAR Hag: SQ. Florida Bar No.: 0106733 Tavarez Law, P.A. 230 E. MONUMENT AVE., STE A5S KISSIMMEE, FL 34741 Tel: (407) 459-7679 Fax: (407) 517-4348 Email: stewar@tavarezlaw.com Attorneys for Plaintiff