Requests for Production of Documents in an West Palm Beach Automobile Accident Case, Call 1-800-74-TRIAL

NOW COMES the plaintiff, by and through counsel, who requests pursuant to Rule 34 of the State Rules of Civil Procedure that the defendant produce for inspection and/or copying by plaintiff's counsel the following documents set forth below. As an alter¬native the defendant may produce true and accurate photocopies of the documents set forth. Such documents requested shall be produced at the offices of the undersigned counsel within thirty days from the date of service or at such other time or place as mutually agreed upon by the parties.

If any of the documents requested are not produced because of privilege or other reason, please identify such documents, state the nature of the objection or nature of the privilege or other reason for nonproduction so the plaintiff may take appropriate remedial steps if necessary.

The word document shall include, but not necessarily be limited to, all written or printed matter of any kind, copies of books, records, reports, sketches, drawings, ad¬vertisements, notes, letters, schedules, contracts, purchase orders, bills, or any other document relating to this claim which is discoverable by law, as well as any other tan¬gible thing upon which information is recorded in writing.

DOCUMENTS REQUESTED:

1. Copies of any photographs in defendant's possession including photographs of the automobiles of both plaintiff and defendant, scene of the accident, or any other photographs relating to this claim.

2. A copy of the automobile policy of the defendant which relates to this claim.

3. A copy of the so called declaration page of defendant's insurance policy which was in effect on the date which is the subject of this claim, to wit: October 1, 199 with the indication of policy limits on such declaration page.

4. Copies of statements obtained by any witness which are not privileged and which have been reduced to writing in some fashion.

5. Copies of the driving record of the defendant if obtained by any office or official agency of this state.

6. Copies of the repair estimates of defendant's vehicle which resulted from the claim which is the subject of this matter.

7. Copies of any medical reports or records relating to the plaintiff in the posses¬sion of the defendant whether or not such records or reports are for injuries sustained in this incident or at any other time unless previously obtained by the defendant from the undersigned counsel.

8. Copies of any police reports or records obtained which in any way relate to the incident which is the subject of this claim.

9. Copies of any employment records relating to the plaintiff which have been obtained by the defendant unless such records were actually produced by the undersigned counsel.

10. If the defendant was not the owner of the subject vehicle, a copy of the reg¬istration form or certificate of title of such vehicle.

11. Copies of any traffic citations or complaints relating to this incident which may have been issued to the defendant or any other party.

12. Copies of any drawings, maps, charts, diagrams, or other representation of the scene of the accident or of any other aspect of the accident which is the sub¬ject of this claim.

13. Copies of any photographs of the plaintiff taken subsequent to the incident which is the subject of this claim including any surveillance photos.

14. Copies of any motion pictures or video tapes taken of the plaintiff subse¬quent to the incident which is the subject of this claim.