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Case Number: CACE-19-011695 Division: 09
Filing # 90393197 E-Filed 05/31/2019 02:40:06 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR
ASHAUNA HACKER,
BROWARD COUNTY, FLORIDA
Plaintiff,
Case no.
vs.
Division
VICTORIA SHARP and KATHERINE
IRENE SHARP ,
Defendants.
/
PLAINTIFF’S REQUEST TO PRODUCE TO
DEFENDANT, VICTORIA SHARP
Plaintiff, ASHAUNA HACKER, by and through undersigned counsel, files this First
Request for Production of Documents, pursuant to Florida Rules of Civil Procedure, Rule
1.350, and requests Defendant , VICTORIA SHARP , to produce the following items in
accordance with Rule 1.350:
1. Any and all titles (front and back), rental agreements, lease agreements,
registrations, or other papers regarding any legal or equitable interest in any motor vehicle
involved in the motor vehicle accident that occurred on September 25", 2018.
2. All property damage estimates, copies of property damage reimbursement drafts
and/or payment of property damage claim(s), repair bills, supplemental estimates and all
other written or electronic documents relating to the damage sustained to any of the
vehicles involved in the subject motor vehicle accident that occurred on September 25",
2018.
3. All color photographs of all motor vehicles involved in the motor vehicle accident
You created this" PBF-HOmBAQPpBRG MRT nbt iBsHSSa to PrihOBMdVaPOE BRAD (Atta OAMAR-AG Ve RMeoityof September 23%, 2018, that are and/or may be in the possession, custody or control of
the Defendant, his attorneys or insurance carrier, or anyone acting on his behalf.
4. Any and all color photographs, videotapes or drawings in the possession,
custody or control of the Defendant, his attorneys or insurance carrier, or anyone acting
on his behalf, of the scene of the motor vehicle accident of September 23, 2019, either
before or after its occurrence of the crash.
5. Any and all statements, whether written, taped, stenographically recorded or
videotaped from any of the Plaintiff herein.
6. Any and all statements, whether written, taped, stenographically recorded or
videotaped from any person or potential witness regarding the facts of this lawsuit.
7. Any and all incident reports, or other papers describing the motor vehicle
accident of September 23%, 2018, which are in Defendant's, possession, custody, or
control and the Defendant's agents or attorneys, that was or were prepared in connection
with the subject motor vehicle accident.
8. The front and back side of your driver's license as of the date of the incident
described in the Complaint. If that driver's license or copies of it no longer exist, the front
and back of any and all of your most recent driver's license.
9. Allinsurance policies, including liability, excess, umbrella, and the like, including
the declaration page or face sheet showing the dollar limits of coverage, that provides
insurance coverage or that may provide insurance coverage for the injuries and damages
the Plaintiff has sustained, as more fully set forth in Plaintiff's Complaint.
10. Allsurveillance reports, videotapes or photographs of any kind of the Plaintiff(s).
11. All documents reflecting any settlement with any other person, firm or
You created this PDF from an application that is not licensed to print to novaPDF printer (http://www.novapdf.comcorporation arising out of the motor vehicle accident that occurred on September 23°,
2018.
12. All reports made by, for, or on behalf of any expert witness employed by the
Defendant, his attorneys or other representatives, and which such opinions relate in any
way to the motor vehicle accident on September 23%, 2018.
13. A copy of any and all cellular phone records for all cell phones in Defendant's
possession at the time of the occurrence of the subject motor vehicle accident on
September 23%, 2018. Time frame requested: Two (2) hours before and after the
occurrence of said motor vehicle accident. PLEASE NOTE: If the Defendant does not
have cellular phone statements, please execute the attached cellular phone authorization
under oath and return original to Plaintiff.
14. All documents reflecting any settlement with any other person, firm or
corporation arising out of the motor vehicle accident that occurred on September 23,
2018.
15. All medical records of the Plaintiff which are in the Defendant’s possession,
custody and/or control, as well as the Defendant’s agents, employees, and representatives.
16. Any electronic data, or print out of any electronic data from any on board “black
box” or other data storage or recovery system in the motor vehicle that Defendant,
VICTORIA SHARP, operated at the time of the motor vehicle accident that occurred on
September 23%, 2018.
17. Produce the on board “black box” or other data storage or recovery system in
the motor vehicle that Defendant, VICTORIA SHARP , operated at the time of the motor
vehicle accident that occurred on September 23", 2018.
You created this PDF from an application that is not licensed to print to novaPDF printer (http://www.novapdf.comDated this 31* day of May, 2019.
THE LAW OFFICES OF
BERMAN & BERMAN, P.A.
Attorneys for the Plaintiff
PO Box 272789
Boca Raton, FL 33427
Tel: (661) 826-5200
Fax: (561) 826-5201
By: /s/ Thomas K. Fichtelman, Esq.
Thomas K. Fichtelman, Esq.
Florida Bar No.: 125843
service@thebermanlawgroup.com
You created this PDF from an application that is not licensed to print to novaPDF printer (http://www.novapdf.com
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Case Number: CACE-19-011695 Division: 09 Filing # 90393197 E-Filed 05/31/2019 02:40:06 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR ASHAUNA HACKER, BROWARD COUNTY, FLORIDA Plaintiff, Case no. vs. Division VICTORIA SHARP and KATHERINE IRENE SHARP , Defendants. / PLAINTIFF’S REQUEST TO PRODUCE TO DEFENDANT, VICTORIA SHARP Plaintiff, ASHAUNA HACKER, by and through undersigned counsel, files this First Request for Production of Documents, pursuant to Florida Rules of Civil Procedure, Rule 1.350, and requests Defendant , VICTORIA SHARP , to produce the following items in accordance with Rule 1.350: 1. Any and all titles (front and back), rental agreements, lease agreements, registrations, or other papers regarding any legal or equitable interest in any motor vehicle involved in the motor vehicle accident that occurred on September 25", 2018. 2. All property damage estimates, copies of property damage reimbursement drafts and/or payment of property damage claim(s), repair bills, supplemental estimates and all other written or electronic documents relating to the damage sustained to any of the vehicles involved in the subject motor vehicle accident that occurred on September 25", 2018. 3. All color photographs of all motor vehicles involved in the motor vehicle accident You created this" PBF-HOmBAQPpBRG MRT nbt iBsHSSa to PrihOBMdVaPOE BRAD (Atta OAMAR-AG Ve RMeoityof September 23%, 2018, that are and/or may be in the possession, custody or control of the Defendant, his attorneys or insurance carrier, or anyone acting on his behalf. 4. Any and all color photographs, videotapes or drawings in the possession, custody or control of the Defendant, his attorneys or insurance carrier, or anyone acting on his behalf, of the scene of the motor vehicle accident of September 23, 2019, either before or after its occurrence of the crash. 5. Any and all statements, whether written, taped, stenographically recorded or videotaped from any of the Plaintiff herein. 6. Any and all statements, whether written, taped, stenographically recorded or videotaped from any person or potential witness regarding the facts of this lawsuit. 7. Any and all incident reports, or other papers describing the motor vehicle accident of September 23%, 2018, which are in Defendant's, possession, custody, or control and the Defendant's agents or attorneys, that was or were prepared in connection with the subject motor vehicle accident. 8. The front and back side of your driver's license as of the date of the incident described in the Complaint. If that driver's license or copies of it no longer exist, the front and back of any and all of your most recent driver's license. 9. Allinsurance policies, including liability, excess, umbrella, and the like, including the declaration page or face sheet showing the dollar limits of coverage, that provides insurance coverage or that may provide insurance coverage for the injuries and damages the Plaintiff has sustained, as more fully set forth in Plaintiff's Complaint. 10. Allsurveillance reports, videotapes or photographs of any kind of the Plaintiff(s). 11. All documents reflecting any settlement with any other person, firm or You created this PDF from an application that is not licensed to print to novaPDF printer (http://www.novapdf.comcorporation arising out of the motor vehicle accident that occurred on September 23°, 2018. 12. All reports made by, for, or on behalf of any expert witness employed by the Defendant, his attorneys or other representatives, and which such opinions relate in any way to the motor vehicle accident on September 23%, 2018. 13. A copy of any and all cellular phone records for all cell phones in Defendant's possession at the time of the occurrence of the subject motor vehicle accident on September 23%, 2018. Time frame requested: Two (2) hours before and after the occurrence of said motor vehicle accident. PLEASE NOTE: If the Defendant does not have cellular phone statements, please execute the attached cellular phone authorization under oath and return original to Plaintiff. 14. All documents reflecting any settlement with any other person, firm or corporation arising out of the motor vehicle accident that occurred on September 23, 2018. 15. All medical records of the Plaintiff which are in the Defendant’s possession, custody and/or control, as well as the Defendant’s agents, employees, and representatives. 16. Any electronic data, or print out of any electronic data from any on board “black box” or other data storage or recovery system in the motor vehicle that Defendant, VICTORIA SHARP, operated at the time of the motor vehicle accident that occurred on September 23%, 2018. 17. Produce the on board “black box” or other data storage or recovery system in the motor vehicle that Defendant, VICTORIA SHARP , operated at the time of the motor vehicle accident that occurred on September 23", 2018. You created this PDF from an application that is not licensed to print to novaPDF printer (http://www.novapdf.comDated this 31* day of May, 2019. THE LAW OFFICES OF BERMAN & BERMAN, P.A. Attorneys for the Plaintiff PO Box 272789 Boca Raton, FL 33427 Tel: (661) 826-5200 Fax: (561) 826-5201 By: /s/ Thomas K. Fichtelman, Esq. Thomas K. Fichtelman, Esq. Florida Bar No.: 125843 service@thebermanlawgroup.com You created this PDF from an application that is not licensed to print to novaPDF printer (http://www.novapdf.com