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Filing # 142870756 E-Filed 01/28/2022 01:56:53 PM
IN THE CIRCUIT COURT, FIFTH JUDICIAL CIRCUIT,_
IN AND FOR LAKE COUNTY, FLORIDA
SHAUN WYNN,
Plaintiff, Case No: 2021 CA 1665
v.
KATHRYN SWATMAN
and RORIE ROBERTS,
Defendants.
/
REQUESTS TO PRODUCE
Defendant, KATHRYN SWATMAN by and through the undersigned attorney, and pursuant
to Rule 1.350 of the Florida Rules of Civil Procedure, demands that Plaintiff, SHAUN WYNN,
produce and permit inspection and copying of each of the following documents within thirty (30)
days of service thereof. Copy costs will not be paid without prior written approval:
Copies of all tax returns, W-2 Forms, and any other evidence of income for all years to date,
beginning with the three (3) years preceding the within accident.
Withholding statements, pay envelopes, deposit slips, and any other evidence of income
earned by Plaintiff, SHAUN WYNN, for the current calendar year.
Copies of any and all medical records, hospital records, emergency room records and records
from any health care provider pertaining to the treatment of Plaintiff, SHAUN WYNN, for
any injuries sustained in the incident.
Copies of any and all medical records, hospital records, emergency room records and records
from any health care provider pertaining to the treatment of the Plaintiff SHAUN WYNN,
for any reason in the five (5) years prior to the within incident.
Copies of any and all medical records, hospital records, emergency room records and records
from any health care provider pertaining to the treatment of Plaintiff, SHAUN WYNN, for
any reason since the within accident.
Copies of any and all medical bills and statement for services rendered, paid or unpaid, as a
result of the within incident, including any bills for drugs or other related expenses.
Copies of any and all bills, statements or receipts relating to any non-medical expenses claims
lof3
FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 01/31/2022 04:31:40 PM
as damages in this lawsuit which have not been produced in response.
Any and all videotapes, surveillance films and photographs of either or both Defendants,
KATHRYN SWATMAN and RORIE ROBERTS, taken following the incident that is the
subject of this lawsuit.
Any and all videotapes and photographs of the incident that is the subject of this lawsuit
depicting any damage or injury that was sustained as a result of the subject incident.
10. Any and all videotapes and photographs depicting the scene of the June 2, 2020 incident that
is the subject of this lawsuit.
11 Any and all recorded statements, whether written or otherwise, made by either or both
Defendants, KATHRYN SWATMAN and RORIE ROBERTS, or any of her purported
representatives or agents.
12 Any and all statements, affidavits, recordings, tape recordings, accident reports or other
investigative communications given by you or anyone else regarding the incident that is subject
of this lawsuit.
13. Copies of any and all insurance policies that would inure to the benefit of the Plaintiff herein
together with any declaration of cover page in effect at the time of the incident described in
the Complaint or in effect at any time since that date.
14. Any and all reports from any and all expert witnesses whom you intend to call at the trial of
this case that have been prepared since June 2, 2020.
15. Copies of all documents that the experts have reviewed in arriving at their opinions in this
case.
16 Any and all documentary evidence that the Plaintiff intends to introduce at the trial of this
cause of action.
17. Any and all medical bills or documents evidencing injury incurred by Plaintiff as a result of
the June 2, 2020 incident that is the subject of this lawsuit.
18. All maps, sketches, diagrams or drawings of the incident scene.
19. Copies of any and all letters, correspondence and/or emails from Plaintiff to any insurance
company regarding this claim.
Dated: January 28, 2022
Respectfully Submitted,
2of 3
/s/ Michael Massey
Massey & Duffy, PLLC
Fla. Bar No. 153680
855 E. University Ave.
Gainesville, FL 32601
352-505-8900
Designated Email: Massey@352law.com
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this day, I electronically served the foregoing to all parties of
record.
/s/ Michael Massey
Michael Massey
Fla. Bar No. 153680
30f3
Preview
Filing # 142870756 E-Filed 01/28/2022 01:56:53 PM IN THE CIRCUIT COURT, FIFTH JUDICIAL CIRCUIT,_ IN AND FOR LAKE COUNTY, FLORIDA SHAUN WYNN, Plaintiff, Case No: 2021 CA 1665 v. KATHRYN SWATMAN and RORIE ROBERTS, Defendants. / REQUESTS TO PRODUCE Defendant, KATHRYN SWATMAN by and through the undersigned attorney, and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, demands that Plaintiff, SHAUN WYNN, produce and permit inspection and copying of each of the following documents within thirty (30) days of service thereof. Copy costs will not be paid without prior written approval: Copies of all tax returns, W-2 Forms, and any other evidence of income for all years to date, beginning with the three (3) years preceding the within accident. Withholding statements, pay envelopes, deposit slips, and any other evidence of income earned by Plaintiff, SHAUN WYNN, for the current calendar year. Copies of any and all medical records, hospital records, emergency room records and records from any health care provider pertaining to the treatment of Plaintiff, SHAUN WYNN, for any injuries sustained in the incident. Copies of any and all medical records, hospital records, emergency room records and records from any health care provider pertaining to the treatment of the Plaintiff SHAUN WYNN, for any reason in the five (5) years prior to the within incident. Copies of any and all medical records, hospital records, emergency room records and records from any health care provider pertaining to the treatment of Plaintiff, SHAUN WYNN, for any reason since the within accident. Copies of any and all medical bills and statement for services rendered, paid or unpaid, as a result of the within incident, including any bills for drugs or other related expenses. Copies of any and all bills, statements or receipts relating to any non-medical expenses claims lof3 FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 01/31/2022 04:31:40 PM as damages in this lawsuit which have not been produced in response. Any and all videotapes, surveillance films and photographs of either or both Defendants, KATHRYN SWATMAN and RORIE ROBERTS, taken following the incident that is the subject of this lawsuit. Any and all videotapes and photographs of the incident that is the subject of this lawsuit depicting any damage or injury that was sustained as a result of the subject incident. 10. Any and all videotapes and photographs depicting the scene of the June 2, 2020 incident that is the subject of this lawsuit. 11 Any and all recorded statements, whether written or otherwise, made by either or both Defendants, KATHRYN SWATMAN and RORIE ROBERTS, or any of her purported representatives or agents. 12 Any and all statements, affidavits, recordings, tape recordings, accident reports or other investigative communications given by you or anyone else regarding the incident that is subject of this lawsuit. 13. Copies of any and all insurance policies that would inure to the benefit of the Plaintiff herein together with any declaration of cover page in effect at the time of the incident described in the Complaint or in effect at any time since that date. 14. Any and all reports from any and all expert witnesses whom you intend to call at the trial of this case that have been prepared since June 2, 2020. 15. Copies of all documents that the experts have reviewed in arriving at their opinions in this case. 16 Any and all documentary evidence that the Plaintiff intends to introduce at the trial of this cause of action. 17. Any and all medical bills or documents evidencing injury incurred by Plaintiff as a result of the June 2, 2020 incident that is the subject of this lawsuit. 18. All maps, sketches, diagrams or drawings of the incident scene. 19. Copies of any and all letters, correspondence and/or emails from Plaintiff to any insurance company regarding this claim. Dated: January 28, 2022 Respectfully Submitted, 2of 3 /s/ Michael Massey Massey & Duffy, PLLC Fla. Bar No. 153680 855 E. University Ave. Gainesville, FL 32601 352-505-8900 Designated Email: Massey@352law.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this day, I electronically served the foregoing to all parties of record. /s/ Michael Massey Michael Massey Fla. Bar No. 153680 30f3