Party Discovery: WYNN, SHAUN

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                                Filing # 141365265 E-Filed 01/05/2022 09:29:57 AM



                                                            IN THE CIRCUIT COURT, FIFTH
                                                            JUDICIAL CIRCUIT, IN AND FOR
                                                            LAKE COUNTY, FLORIDA

                                                            CASE NO. :     2021 CA 1665

            SHAUN WYNN,

                     Plaintiff,

            Vv.


            KATHRYN SWATMAN
            And RORIE ROBERTS
                  Defendants.
                                             /

                                         PLAINTIFF'S REQUEST TO PRODUCE

                     COMES NOW, the Plaintiff, SHAUN WYNN , by and through the undersigned attomey,

            and hereby requests the Defendant, KATHRYN SWATMAN, produce and permit the review

            and/or copying of the documents listed below which are in the possession, custody and control of

            the Defendant and not in the possession of the Plaintiff and which constitutes tangible things within

            the scope of discovery and under Rule 1.350 of the Florida Rules of Civil Procedure. Production is

            being made to Jonathan I. Rotstein, Esquire, within thirty (30) days from the date of service hereof

            at 309 Oakridge Boulevard, Suite B, Daytona Beach, Florida 32118.

                         1    Defendants are requested to produce a copy of any and all statements, as defined in

            the Rules of Civil Procedure, concerning the subject matter of this action previously made by the

            Plaintiff.

                     2.       Defendants are requested to produce a copy of any and all policies of liability

            insurance providing liability coverage to one or more of the Defendants, or copies of any and all

            policies of insurance which allegedly provide liability insurance coverage to the Defendants for the

            incident described in the Complaint.




FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 01/05/2022 09:30:47 AM
3       Defendants are requested to produce a copy of any and all policies of insurance of

any kind or nature which could provide benefits to the Plaintiff by reason of the incidents described

in the Complaint, for claims arising out of the incident described in the Complaint.

        4        Defendants are requested to produce a copy of any and all photographs taken at the

scene of the incident described in the Complaint which do or might reveal marks, damage or

conditions which no longer exist at said scene or which probably no longer exist at said scene on the

date of filing this request.

        5        Defendants      are requested   to produce   any    property   in the possession     of the

Defendants on the date of the incident described in the Complaint which was involved in the

incident in question and which property contains marks or damage as a result of the incident herein,

or if such property no longer contains such marks or damages as it did on the date of the incident

described in the Complaint then produce for examination copies of any and all photographs

showing such marks or damage.

        6        Defendants are requested to produce any and all photographs, motion picture films,

tapes, whether recordings as they relate to the subject matter herein and/or that the Defendants will

use as evidence substantially for impeachment or rebuttal in this matter.

        7.       Defendants      are requested   to produce    any   and    all surveillance   films, tapes,

photographs, activity records, witness canvassing, etc., and the results thereof obtained with regard

to the Plaintiff herein        and/or that the Defendants     will use     as evidence   substantively,   for

impeachment or rebuttal in this matter.

        8        Defendants are requested to produce copies of any reports made by the employees of

the Defendants or representatives thereof, including the circumstances of the incident in question.
9      Defendants are requested to produce any reports, records, documentation, index,

logs, or other evidence, which indicates prior claims made by the Plaintiff or that the Defendants

will use as evidence substantively for impeachment or rebuttal in this matter,



        J HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
via electronic email service on this 3rd day of January, 2022, to Heath Nailos, Esq., 1635 East
highway 50, Suite 300, Clermont, FL 34711 hnailos@benlawfirm.com;
lacosta@bcnlawfirm.com. Attorney for Rorie Roberts and Michael Massey, Esq., Massey &
Duffy, PLLC, 855 E. University Ave., Gainsville, FL 32601, massey@352law.com attorney for
Kathryn Swatman


                                            SO      en                 7

                                       Jonathan I. Rotstein, Esquire
                                       Law Office of Rotstein & Shiffman, LLP
                                       309 Oakridge Blvd., Suite B
                                       Daytona Beach, FL 32118
                                       Florida Bar No. 909580
                                       (386) 252-5560 / (386) 238-6999 fax (nh)
                                       Primary: L.Bonner@rotstein-shiffman.com
                                       Secondary 1: M.Otto@rotstein-shiffman.com
                                       Secondary 2: T.Dallarosa@rotstein-shiffman.com
                                       Attorney for Plaintiff