Document for TAYLOR GUTHRIE, DIMITRIet al. vs. HINTZMAN, FREDERICKet al.

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                                THE CIRCUIT COURT OF THE
                                                                                 NINTH JUDICIAL CIRCUIT IN AND
                                                                                 FOR ORANGE COUNTY, FLORIDA
                  DMITRI TAYLOR-GUTHRIE and
                  DENTON GUTHRIE,
                                                                                 CASE NO.:         08-CA-7930
                  Plamtiffs,                                                     Section:          39



                  FREDERICK HINTZMAN and
                  CHY OF ORLANDO, a political
                  subdivision ofthe   State ofFlorida.

                  Defendan t(s)
                                                               /

                                                            REQUEST       TO   PRODUCE

                           Defendant,   FREDERICK       HINTZMAN,       by  and  through  itsundersigned    counsel,  ai^tLplirsuant  to

                  Rule   1.351  of  the  Florida   Rules   of Civil  Procedure,    requests  the  Plaintiffs,  DIMITRJ     TAYLOR-

                  GUTHRIE and DENTON GUTHRIE, to produce                   for the purpose   of inspection,   copying,   and all of the

                  purposes permitted bythe      rule, at the officeof the undersigned law fimi during normal working hours on

                  or before thirty (30) days from the.date of service hereof, the follovving      material:

                           1.      All  reports   of physicians,    psychologists   ariti/or'psychological    of  other   health; care
                                   providers   and  all  bills for medical    and/or  psychological    care,  medicine,   or  medical
                                   supplies for the care and treatment of Plaintiffs'    injuries arising from the incident alleged
                                   ih the Complaint

                          2.       Color   copies  of  ati photographs     of the  accident   scene.  Plaintiffs'  injuries, and   any
                                   vehicles involved    in the accident.

                          3.       All photographs Plaintiffs    intend to use at trial.

                          4.       All maps, sketches, diagrams or drawings of the accident         scene.

                          5.       All  statements,   tape-recorded    or  written,  of  the  Defendant     (If the  Defendant    is a
                                   corporation, all statements, tape-recorded or written, ofits      officers or directors.)

                          6.       Copies   ofall  personal'and    business/cbiporate   income    tax retums   filed by  the Plaintiffs
                 ,  ,.- •:   :-;•,, for. the past five (5) calendar years.

                 -  .;t_-..:.7.-;; Any.and    ah  documentation     which   supports  or con-oborates    the Plaintiffs' ciaim(s)   for
                                   damages.                    •                    •                     -   ..     ;•     : . ,-.
                           8.       A copy ofthe    Drivers License and    Social  Securiiy card ol'the   Plaintiffs.

                           9.       Copies ofall   x-rays, MRI films, bone scan       films, etc. taken  ofthe  Plaintiffs at any  time
                                    with regard to the alleged   accident.

                           10.      Copies   ofany    and  all insurance   policies, contracts   or agieements    pursuant    to which
                                    health  benefits  or lost wages have been      paid  or are payable   to Plaintiffs  as a result of
                                    the incident complained      of

                           11.      Any and all reports from expert witnesses you intend to use at trial.


                                                          CERTIFICATE         OF   SERVICE

                           I HEREBY      CERTIFY     that a true and  coirect  copy of the   foregoing  has  been  furnished  via hand

                  courier  or U.S. Mail   to:  CHARLES      LAYCOCK,       ESQUUIE,      123 First  Street North,  Winter   Haven,   FL

                  33881, this Sth day ofMay,     2008.

                                                                        RIGDON, ALEXANDER & RIGDON, LLP



                                                                        BY:     ^^:ct:^y.y^Ua7^yyt^/y/ofi
                                                                        KURT E. ALEXANDER, ESQ.
                                                                        Fla. Bar No. 795755
                                                                        7165 Muirell Road, Suite 101
                                                                        Melbourne, FL     32941-2169
                                                                        (321) 242-1661; (321) 242-0010 Fax
                                                                        Attomey for Defendant