WEST PALM BEACH CAR ACCIDENT PLAINTIFFS’ REQUEST FOR PRODUCTION OF DOCUMENTS

West Palm Beach Car Accident West Palm Beach Car Accident PLAINTIFFs, by and through counsel, and pursuant to MCR 2.310, hereby request that Defendant produce for inspection and copying at the Law Offices of __________________a complete and legible copy of the hereafter designated documents concerning the within action, which are in your possession, custody or control.
Instructions:
a) You must serve a written response within twenty-eight (28) days after service of this request. Your response must state that production and related activities will be permitted as requested or that the requested production is objected to, in which event the reasons for your objection must be stated.
b) Documents produced for inspection must be produced as they are kept in the usual course of business or be organized and labeled to correspond with the categories in this request.
c) If you do not agree to allow the requested production at a reasonable time and on reasonable conditions, a motion may be filed seeking a court order requiring the requested production.
d) The word “documents” means writings, drawings, graphs, charts, photographs, phone records, and other data compilations from which information can be obtained and translated into a reasonably usable form.
e) The words “you” and “your” mean you, your representatives, agents, insurers, attorneys, employees, directors, officers, subsidiaries, affiliates, and all others over whom you have control.
f) The words “possession, custody, or control” mean all documents and things belonging to you that are in your possession, all documents and things belonging to others over which you have custody, and all documents and things in the custody of others over which you have the right to control.
g) The word “occurrence” shall mean the motor vehicle accident which occurred on subject date of accident.
Documents to Produce
1. Copy of Defendant’s Driver’s License, front and back.
2. Copy of Defendant’s registration, front and back.
3. Complete copy of the automobile insurance policy for the vehicle that was involved in the above-referenced accident, including the Declaration page.
4. All statement(s) a party has given to some person and/or entity other than his/her attorney.
5. The name, address and telephone number of all witnesses, or other participant(s), who have, or may have claimed, knowledge of the occurrence, and/or the damages resulting therefrom, and a copy of all statements by these individuals.
6. All photographs, slides, motion pictures, diagrams, video tapes, maps, schematics, graphs, models, and other illustrative representations pertaining to the parties hereto, the instrumentalities and/or physical objects, injuries and/or abilities involved, the scene of the occurrence and vehicles involved.
7. All reports made as a result of any inspection, examination, or investigation by any person acting on behalf of Defendant as a result of the occurrence, and the name, address and telephone number of said individual(s).
8. All policies which cover or may cover the occurrence or any matters alleged in the West Palm Beach Car Accident West Palm Beach Car Accident PLAINTIFFs’ complaint, including umbrella policies.
9. Notes, worksheets, test data and reports, correspondence, memorandums, opinions, and conclusions of all expert witnesses who will or may testify at trial on behalf of Defendant.
10. All documents identified or referred to in Defendant’s Answers to West Palm Beach Car Accident West Palm Beach Car Accident PLAINTIFFs’ Interrogatories.
11. All documents related to the damage of Defendant’s vehicle, including but not limited to: estimates, repair orders, photographs, videos and the like.
12. Copies of any and all exhibits that this Defendant plans on using at Case Evaluation.
13. Copies of any videotapes, photographs or other documents depicting the West Palm Beach Car Accident PLAINTIFF, whether it be through surveillance or by any other method, to include all surveillance, including written logs, surveillance video tapes or audio tapes, photographs or any other type of surveillance to include costs, billings, payments for the surveillance.
14. Copies of any and all exhibits that this Defendant plans on using at Trial.
LAW OFFICES OF
Attorneys for West Palm Beach Car Accident West Palm Beach Car Accident PLAINTIFFs
________________________________________
[Name]
[Address]
[Phone]
Dated: