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Filing # 60280145 E-Filed 08/11/2017 11:34:01 AM
IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT IN AND FOR
ORANGE COUNTY, FLORIDA
JEAN DUME,
Case No.:
Plaintiff,
vs.
JONATHAN BURGIEL,
Defendant.
__________________________________/
FIRST REQUESTS TO PRODUCE TO DEFENDANT
COMES NOW, JEAN DUME, the Plaintiff in the above-styled action (hereinafter
referred to by name or as “Plaintiff”), by and through his undersigned counsel, and, pursuant to
Fla. R. Civ. P Rule 1.350, hereby requests Defendant, JONATHAN BURGIEL (hereinafter
referred to by name or collectively as “Defendant” or “you”), to produce for inspection and/or
copying by counsel for Plaintiff the following designated documents, items or matters at the
offices of Hogan & Hogan, 906 E Michigan Street, Orlando, FL 32806, within the time period
allowed by the Florida Rules of Civil Procedure, and the documentation/information requested is
as follows:
1. Copies of all correspondence between Plaintiff, or anyone acting on his behalf, and
Defendant, or anyone acting on his behalf.
2. Copies of all documents which record refer or relate to any communication between
Defendant, and anyone working on his behalf, and the Plaintiff, or anyone acting on his behalf.
3. Copies of Defendant's driver license in effect at the time of the incident described
in the Complaint.
4. Copies of Defendant's driver license currently in effect.
5. Any and all written or recorded statements taken from the Plaintiff or any parties or
witnesses concerning any issue in this cause.
6. Any and all photographs, graphs, charts depictions and other documentary evidence
of the scene, parties and/or pertaining to the subject accident, occurrence or issues in this cause.
Likewise, any and all other photographs in Defendant's possession that Defendant believes are
relevant to this lawsuit.
7. Any photographs, sketches and/or diagrams which purport to depict any alleged
injury or damages suffered by the Plaintiff in the incident described in the Complaint and/or which
depict the scene of the alleged incident.
8. Any written reports rendered by any expert (retained or consulted) including any
accident reconstruction expert, pertaining to and/or referring to any issue in this cause of action.
9. Any and all records indicating collateral sources paid or payable to the Plaintiff or
paid on her behalf as a result of the incident described in the Complaint; collateral sources being
those defined by applicable Florida Statutes.
10. Any and all records in your possession custody or control indicating or referring to
any payment of benefits to the Plaintiff or on his behalf in connection with and/or as an alleged
result of the incident described in the Complaint.
11. Any and all letters from any and all insurance carriers to Defendant, regarding
any and all coverage issues, benefits, defenses, and/or denials related to the collision described in
the Complaint, including but not limited to, any and all demands for indemnity, defense, or
settlement pursuant to the terms of any applicable insurance policies.
12. A complete and certified copy of any and all insurance agreements or insurance
policies under which any person or entity carrying on an insurance business may be liable to
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satisfy part or all of a judgment which may be rendered in this action or to indemnify or
reimburse for payments made to satisfy the judgment, including but not limited to any liability
insurance policy covering you, Defendant and/or the vehicle owned by you, at the time of the
incident which is the subject of Plaintiff’s Complaint.
13. Any and all photographs that you, Defendant, have in your possession, custody or
control, which depict any of the vehicles involved in the incident which is the subject of Plaintiff’s
Complaint and any photographs which depict the scene the incident which is the subject of
Plaintiff’s Complaint.
14. Any and all photographs in Defendants’ possession custody or control, that
Defendants believes are relevant to any of the issues in this lawsuit and/or which Defendants
intend to present at trial in this matter.
15. Any and all correspondence, documents, emails or other form of communication,
or reports, which have been obtained from any expert, regarding any issue in this cause of action
and if a report has not been prepared, the preparation of a report is hereby requested.
16. Any and all photographs and damage appraisals, or estimates, that Defendant has
in your possession, custody or control, which depict Defendant's motor vehicle.
17. Any and all photographs and damage appraisals, or estimates that Defendant has
in your possession, custody or control, which depict Plaintiff’s motor vehicle.
18. A complete and certified copy of any and all insurance agreements or policies,
including but not limited to, a certified copy of the declaration page, of any liability insurance
policy covering Defendant, or the automobile being driven by you on February 11, 2015.
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19. A copy of any and all insurance applications completed and signed by you, and
approved and accepted by your insurance carrier, including but not limited to GEICO General
Insurance Company, policy # 4313438303.
20. Any and all statements previously made by either Plaintiff or any other persons
involved in or witness to the incident giving rise to this lawsuit concerning the subject matter of
this lawsuit, including any written statement signed or otherwise adopted or approved by the
Plaintiff hereto and any stenographic, mechanical, electrical or other type of recording or any
transcription thereof.
21. Any and all models, motion pictures, videotapes, drawings, maps or sketches of
the scene of the accident which has been made the basis of this lawsuit.
22. Any and all documents reflecting an employment relationship relative to your
ownership, possession or control of the vehicle made the subject of this action.
23. Any and all documents reflecting an independent contractor relationship relative
to your ownership, possession or control of the vehicle made the subject of this action.
24. Copies of any and all medical records in your possession, custody, or control,
which relate to the Plaintiff or any issue in this cause of action.
28. Any surveillance movies, photographs, surveillance reports, internet searches, or
any other material relating to the surveillance of Plaintiff.
29. Documents relating to or discussing repairs or maintenance to Defendant's vehicle
that were done for the six (6) month period of time preceding and including the date of the
accident and for the six (6) month period of time following the date of the accident.
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30. All payout records for the insurer of the Defendant for benefits paid to or on
behalf of the Plaintiff under the personal injury protection and medical payments coverage of the
policy
CERTIFICATE OF SERVICE
HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished to Defendant with the Summons and Complaint in this matter
/s/ Jeremy Hogan
Jeremy L. Hogan, Esq.
Florida Bar No.: 12578
Riley J. Cho, Esq.
Florida Bar No.: 116891
jhogan@hoganlegal.com
rcho@hoganlegal.com
scunningham@hoganlegal.com (secondary)
HOGAN & HOGAN, P.A.
906 East Michigan Street
Orlando, FL 32806
Tel. 407.422.2188 | Fax 407.422.3291
Attorneys for Plaintiff
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Preview
Filing # 60280145 E-Filed 08/11/2017 11:34:01 AM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA JEAN DUME, Case No.: Plaintiff, vs. JONATHAN BURGIEL, Defendant. __________________________________/ FIRST REQUESTS TO PRODUCE TO DEFENDANT COMES NOW, JEAN DUME, the Plaintiff in the above-styled action (hereinafter referred to by name or as “Plaintiff”), by and through his undersigned counsel, and, pursuant to Fla. R. Civ. P Rule 1.350, hereby requests Defendant, JONATHAN BURGIEL (hereinafter referred to by name or collectively as “Defendant” or “you”), to produce for inspection and/or copying by counsel for Plaintiff the following designated documents, items or matters at the offices of Hogan & Hogan, 906 E Michigan Street, Orlando, FL 32806, within the time period allowed by the Florida Rules of Civil Procedure, and the documentation/information requested is as follows: 1. Copies of all correspondence between Plaintiff, or anyone acting on his behalf, and Defendant, or anyone acting on his behalf. 2. Copies of all documents which record refer or relate to any communication between Defendant, and anyone working on his behalf, and the Plaintiff, or anyone acting on his behalf. 3. Copies of Defendant's driver license in effect at the time of the incident described in the Complaint. 4. Copies of Defendant's driver license currently in effect. 5. Any and all written or recorded statements taken from the Plaintiff or any parties or witnesses concerning any issue in this cause. 6. Any and all photographs, graphs, charts depictions and other documentary evidence of the scene, parties and/or pertaining to the subject accident, occurrence or issues in this cause. Likewise, any and all other photographs in Defendant's possession that Defendant believes are relevant to this lawsuit. 7. Any photographs, sketches and/or diagrams which purport to depict any alleged injury or damages suffered by the Plaintiff in the incident described in the Complaint and/or which depict the scene of the alleged incident. 8. Any written reports rendered by any expert (retained or consulted) including any accident reconstruction expert, pertaining to and/or referring to any issue in this cause of action. 9. Any and all records indicating collateral sources paid or payable to the Plaintiff or paid on her behalf as a result of the incident described in the Complaint; collateral sources being those defined by applicable Florida Statutes. 10. Any and all records in your possession custody or control indicating or referring to any payment of benefits to the Plaintiff or on his behalf in connection with and/or as an alleged result of the incident described in the Complaint. 11. Any and all letters from any and all insurance carriers to Defendant, regarding any and all coverage issues, benefits, defenses, and/or denials related to the collision described in the Complaint, including but not limited to, any and all demands for indemnity, defense, or settlement pursuant to the terms of any applicable insurance policies. 12. A complete and certified copy of any and all insurance agreements or insurance policies under which any person or entity carrying on an insurance business may be liable to 2 satisfy part or all of a judgment which may be rendered in this action or to indemnify or reimburse for payments made to satisfy the judgment, including but not limited to any liability insurance policy covering you, Defendant and/or the vehicle owned by you, at the time of the incident which is the subject of Plaintiff’s Complaint. 13. Any and all photographs that you, Defendant, have in your possession, custody or control, which depict any of the vehicles involved in the incident which is the subject of Plaintiff’s Complaint and any photographs which depict the scene the incident which is the subject of Plaintiff’s Complaint. 14. Any and all photographs in Defendants’ possession custody or control, that Defendants believes are relevant to any of the issues in this lawsuit and/or which Defendants intend to present at trial in this matter. 15. Any and all correspondence, documents, emails or other form of communication, or reports, which have been obtained from any expert, regarding any issue in this cause of action and if a report has not been prepared, the preparation of a report is hereby requested. 16. Any and all photographs and damage appraisals, or estimates, that Defendant has in your possession, custody or control, which depict Defendant's motor vehicle. 17. Any and all photographs and damage appraisals, or estimates that Defendant has in your possession, custody or control, which depict Plaintiff’s motor vehicle. 18. A complete and certified copy of any and all insurance agreements or policies, including but not limited to, a certified copy of the declaration page, of any liability insurance policy covering Defendant, or the automobile being driven by you on February 11, 2015. 3 19. A copy of any and all insurance applications completed and signed by you, and approved and accepted by your insurance carrier, including but not limited to GEICO General Insurance Company, policy # 4313438303. 20. Any and all statements previously made by either Plaintiff or any other persons involved in or witness to the incident giving rise to this lawsuit concerning the subject matter of this lawsuit, including any written statement signed or otherwise adopted or approved by the Plaintiff hereto and any stenographic, mechanical, electrical or other type of recording or any transcription thereof. 21. Any and all models, motion pictures, videotapes, drawings, maps or sketches of the scene of the accident which has been made the basis of this lawsuit. 22. Any and all documents reflecting an employment relationship relative to your ownership, possession or control of the vehicle made the subject of this action. 23. Any and all documents reflecting an independent contractor relationship relative to your ownership, possession or control of the vehicle made the subject of this action. 24. Copies of any and all medical records in your possession, custody, or control, which relate to the Plaintiff or any issue in this cause of action. 28. Any surveillance movies, photographs, surveillance reports, internet searches, or any other material relating to the surveillance of Plaintiff. 29. Documents relating to or discussing repairs or maintenance to Defendant's vehicle that were done for the six (6) month period of time preceding and including the date of the accident and for the six (6) month period of time following the date of the accident. 4 30. All payout records for the insurer of the Defendant for benefits paid to or on behalf of the Plaintiff under the personal injury protection and medical payments coverage of the policy CERTIFICATE OF SERVICE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to Defendant with the Summons and Complaint in this matter /s/ Jeremy Hogan Jeremy L. Hogan, Esq. Florida Bar No.: 12578 Riley J. Cho, Esq. Florida Bar No.: 116891 jhogan@hoganlegal.com rcho@hoganlegal.com scunningham@hoganlegal.com (secondary) HOGAN & HOGAN, P.A. 906 East Michigan Street Orlando, FL 32806 Tel. 407.422.2188 | Fax 407.422.3291 Attorneys for Plaintiff 5