On August 11, 2017 a
Party Discovery
was filed
involving a dispute between
Rustam Imangulov,
and
Ilias Dimopoulos,
for CA - Auto Negligence
in the District Court of Orange County.
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Filing # 60296529 E-Filed 08/11/2017 02:28:33 PM
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT IN
AND FOR ORANGE COUNTY,
FLORIDA
CASE NO:
RUSTAM IMANGULOV
Plaintiff,
vs.
ILIAS DIMOPOULOS
Defendant.
____________________________________/
REQUEST TO PRODUCE TO DEFENDANT
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 Beregovich Law Firm, P.A. 210 North Mills Avenue, Orlando, FL 32801, the
following:
1. All written or recorded statements made by any witness or party, concerning any issue in this
lawsuit.
2. All statements made by the Plaintiff pertaining to or concerning the subject accident,
damages or any other matter related to this lawsuit.
3. 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 the Defendant,
Defendant’s attorney, or anyone acting on Defendant’s behalf.
4. 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.
5. Copies of any medical records of any sort in your possession or control which relate to the
Plaintiff.
6. Copies of any and all of Defendant’s medical records, including but not limited to, EMS and
hospital records for the date of the subject accident.
7. Surveillance films, photographs, or graphic depictions of any sort which purport to show
Plaintiff herein.
8. All photographs of Plaintiff depicting injuries received in the subject accident.
9. Documents relating to or discussing any statements made by Defendant.
10. Documents relating to or discussing any statements made by Plaintiff.
11. 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.
12. Copies of Defendant’s Social Security Card and Driver’s License, including any commercial
driver’s license held by Defendant.
13. Copies of Defendant’s driving record.
14. A copy of the registration for the vehicle you were driving at the time of the accident.
15. 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.
16. 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.
17. All correspondence to or from any company, individual or entity regarding the subject
accident.
18. A copy of any damage appraisal made of the Defendant’s motor vehicle.
19. 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.
Pursuant to F. R. C.P. Rule 26 and Universal City Dev. Partners, Ltd. v. Ride & Show Eng'g, 230
F.R.D. 688, 695 (M.D.Fla.2005), you are hereby commanded to provide a Privilege Log for any
discovery documents and/or items that are sought to be protected.
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, Request for Admissions, and Interrogatories to the
Defendant.
/s/ Andres I. Beregovich
___________________________________
ANDRES I. BEREGOVICH, ESQUIRE
Florida Bar No.: 0097812
The Beregovich Law Firm, P.A.
210 N. Mills Avenue
Orlando, FL 32801
Telephone: (407) 809-9000
Facsimile: (407) 809-9001
Service Email: eservice@beregovichlaw.com
Attorney for Plaintiff
Document Filed Date
August 11, 2017
Case Filing Date
August 11, 2017
Category
CA - Auto Negligence
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Filing # 60296529 E-Filed 08/11/2017 02:28:33 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CASE NO: RUSTAM IMANGULOV Plaintiff, vs. ILIAS DIMOPOULOS Defendant. ____________________________________/ REQUEST TO PRODUCE TO DEFENDANT 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 Beregovich Law Firm, P.A. 210 North Mills Avenue, Orlando, FL 32801, the following: 1. All written or recorded statements made by any witness or party, concerning any issue in this lawsuit. 2. All statements made by the Plaintiff pertaining to or concerning the subject accident, damages or any other matter related to this lawsuit. 3. 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 the Defendant, Defendant’s attorney, or anyone acting on Defendant’s behalf. 4. 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. 5. Copies of any medical records of any sort in your possession or control which relate to the Plaintiff. 6. Copies of any and all of Defendant’s medical records, including but not limited to, EMS and hospital records for the date of the subject accident. 7. Surveillance films, photographs, or graphic depictions of any sort which purport to show Plaintiff herein. 8. All photographs of Plaintiff depicting injuries received in the subject accident. 9. Documents relating to or discussing any statements made by Defendant. 10. Documents relating to or discussing any statements made by Plaintiff. 11. 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. 12. Copies of Defendant’s Social Security Card and Driver’s License, including any commercial driver’s license held by Defendant. 13. Copies of Defendant’s driving record. 14. A copy of the registration for the vehicle you were driving at the time of the accident. 15. 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. 16. 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. 17. All correspondence to or from any company, individual or entity regarding the subject accident. 18. A copy of any damage appraisal made of the Defendant’s motor vehicle. 19. 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. Pursuant to F. R. C.P. Rule 26 and Universal City Dev. Partners, Ltd. v. Ride & Show Eng'g, 230 F.R.D. 688, 695 (M.D.Fla.2005), you are hereby commanded to provide a Privilege Log for any discovery documents and/or items that are sought to be protected. 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, Request for Admissions, and Interrogatories to the Defendant. /s/ Andres I. Beregovich ___________________________________ ANDRES I. BEREGOVICH, ESQUIRE Florida Bar No.: 0097812 The Beregovich Law Firm, P.A. 210 N. Mills Avenue Orlando, FL 32801 Telephone: (407) 809-9000 Facsimile: (407) 809-9001 Service Email: eservice@beregovichlaw.com Attorney for Plaintiff