On July 08, 1984 a
was filed
involving a dispute between
Yue, Xiao,
and
Chapp, Inc.,
Foerster, Cynthia,
for CIRCUIT CIVIL
in the District Court of Osceola County.
Preview
Filing # 106530745 E-Filed 04/21/2020 05:13:26 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY, FLORIDA
CASE NO:
XIAO SHENG YUE,
Plaintiff,
vs.
CYNTHIA M. FOERSTER AND
CHAPP, INC.,
Defendants.
/
PLAINTIFF’S REQUEST TO PRODUCE TO DEFENDANT, CYNTHIA M. FOERSTER
Pursuant to the provisions of Rule 1.350, Florida Rules of Civil Procedure, the undersigned
counsel requests that the Defendant, CYNTHIA M. FOERSTER, produce and permit the
inspection, copying, testing, sampling, measuring, surveying, photographing or otherwise
examining the following:
1. All statements made by any occupants of the vehicles involved in the subject incident.
2. All statements made by any witnesses to the subject accident.
3. All statements made by the Plaintiff(s) pertaining to or concerning the subject matter.
4. All photographs of the vehicles involved in the subject accident.
5. All photographs ofthe Plaintiff(s) depicting injuries received in the subject accident.
6. All photographs of the subject accident scene.
7. Documents relating to or discussing repairs or maintenance to Defendant’s(s’) vehicle that
were done for the six (6) months 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.
8. The repair bill and estimates for the repairs to any of the vehicles involved in the accident
for damages incurred in the accident.
9. Any and all policies of liability insurance in effect on the date of the subject accident,
providing coverage to the defendant herein.
10. Appraisals of all property damage sustained by Defendants’ vehicle in the subject accident.
11. = Appraisals of the property damage sustained by Plaintiff's vehicle in the subject accident.
12. A copy of any and all surveillance films, photos, or depictions taken of the Plaintiff as a
result of the subject accident.
13. A-copy of any and all insurance agreements, insurance policies or agreements of any kind or
nature under which any person or company carrying on an insurance business may be liable
to satisfy part or all of a judgment which may be entered in this action or to indemnify or
reimburse any payments made to satisfy any such judgment or settlement, including but not
limited to a certified copy of the declarations sheet as to each such policy.
14. Copies of any and all computer generated documents in the possession of the Defendant(s)
or any agent, servant and/or employee of the Defendant(s), which pertains or relate, in any
manner or fashion, to and any past claims history of the Plaintiff(s) in this lawsuit.
15. Copies of any and all checks issued by the Defendant(s) or any agent, servant and/or
employee of the Defendant(s) to any other person, firm or company making a claim arising
out of the same accident or incident which is the basis of this lawsuit.
16. All payout records for the insurer of the Defendant(s) for benefits paid to or on behalf of
Plaintiff(s) under the personal injury protection and medical payment coverage of the policy.
17. A copy of the driver’s license of the driver involved in the subject accident that existed on
the date of the accident as well as the current driver’s license.
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18. Any and all documentation reflecting the time and duration of any incoming or outgoing
call, email and text message on the date of the accident, September 11, 2018, with regard
to Defendant’s cellular telephone records.
It is requested that the above document be furnished or produced on or before forty-five (45)
days from the date of service hereof, to Manuel F. Stefan, Esquire at the Law Offices of Morgan &
Morgan, P.A., 4495 South Semoran Blvd., Orlando, Florida 32822.
In support of this Request To Produce, it is shown that the documents and/or materials being
herein requested are believed to be in the possession, custody or control of the party to whom this
request is directed. The information sought by this request is relevant to the subject matter of this
action and cannot otherwise be obtained without undue hardship. In the event that all or part of the
documents, and/or materials herein requested are not in the possession or control of the above-
named Defendant addressee, then the undersigned counsel further requests the identity and location
all persons having such possession and control. This request is made in good faith and for the
purposes herein expressed.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that the same has been furnished by Process Server to the
Defendant addressed the same date of service as that of the Summons and Complaint.
/s/ Manuel Stefan, Esq.
Manuel “Manny” Stefan, Esq.
Florida Bar No.: 0103389
MORGAN & MORGAN, P.A.
4495 South Semoran Blvd.
Orlando, FL 32822
Telephone No.: (407) 452-6982
Facsimile No.: (407) 572-0124
Primary email: MStefan@forthepeople.com
Secondary email: EDiaz@forthepeople.com
Attorneyfor Plaintiff
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Document Filed Date
November 03, 2023
Case Filing Date
July 08, 1984
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