Preview
Filing # 159528183 E-Filed 10/19/2022 11:25:56 AM
IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT, INAND FOR
OSCEOLA COUNTY, FLORIDA
CASE NO.: 2022-CA-002181
VIRGINIA AYALA
Plaintiff,
V.
DOLGENCORP, LLC, D/B/A
DOLLAR GENERAL
Defendant.
/
DEFENDANT’S FIRST REQUEST FOR PRODUCTION
OF DOCUMENTS TO PLAINTIFF
Defendant, through counsel, hereby requests Plaintiff to produce for inspection and
copying the following listed documents at the offices of Carr Allison, 121 S. Orange Ave., Suite
1500, Orlando, FL 32801, pursuant to Rule 1.350, Federal Rules of Civil Procedure, within the
required time period.
DEFINITIONS
As used herein, the term "document" means any medium upon which intelligence or
information can be recorded or retrieved, and includes, without limitation, the original and each
copy, regardless of origin and location, of any book, pamphlet, periodical, letter, memorandum
(including any memorandum or report of a meeting or conversation), invoice, bill, order, form,
receipt, financial statement, accounting entry, diary, calendar, telex, telegram, cable, report,
record, contract, agreement, study, handwritten note, draft, working paper, chart, paper, print,
laboratory record, drawing, sketch, graph, index, list, tape, photograph, microfilm, data sheet or
data processing card, or any other written, recorded, transcribed, punched, taped, filmed or
graphic matter, however produced or reproduced, which is in your possession, custody or control
or which was, but is no longer in your possession, custody or control.
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DOCUMENTS TO BE PRODUCED ARE AS FOLLOWS:
1) Federal Income Tax Returns and W-2 Forms for Plaintiff from 2013 to the present.
2) Any and all photographs or videos in the possession of the Plaintiff, Plaintiff's
Attorneys, investigators, agents, servants, or employees which are in any manner related to the
subject matter of this lawsuit, specifically including but not limited to, any and all photographs or
videos of the parties, as well as photographs or videos of the scene of the subject incident.
3) All medical bills, doctor bills, hospital bills, medication bills, nursing bills,
ambulance bills, and bills for similar expenses incurred by or on behalf of the Plaintiff as a result
of the incident which is the subject matter of this lawsuit.
4) Copies of all medical reports received by the Plaintiff, Plaintiff's attorneys,
investigators, agents, servants, or employees, from any doctor, physician, nurse or anyone else
who has examined or rendered treatment to the Plaintiff for the injuries incurred as a result of the
incident which is the subject matter of this lawsuit.
5) A copy of all documents, x-rays or records from any hospital, medical provider or
health care facility where the Plaintiff was a patient, or where the Plaintiff received treatment,
subsequent to the incident which is the subject matter of this lawsuit, which are in the possession
of the Plaintiff, Plaintiffs attorneys, investigators, agents, servants or employees.
6) A copy of all documents, x-rays or records from any hospital, medical provider or
health care facility where the Plaintiff was a patient, or where the Plaintiff received treatment any
time during the ten years prior to the incident which is the subject matter of this lawsuit, which are
in the possession of the Plaintiff, Plaintiff's attorneys, investigators, agents, servants or
employees.
7) A transcript or copy of all statements, whether handwritten, typewritten, video or
audio, made by Defendant, or Defendant’s employees, that is in the possession of Plaintiff or
Plaintiff's attorneys, agents or servants, regarding the incident which is the subject matter of this
lawsuit.
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8) A transcript or copy of all statements, whether handwritten, typewritten, video or
audio, made by any witness regarding the incident which forms the basis for this lawsuit, which is
in the possession of the Plaintiff, Plaintiff's attorneys, agents or servants.
9) All employment records relating in any way to the Plaintiff, whether employed or
self-employed, records relating to the fact and duration of unemployment, records of workmen's
compensation, unemployment insurance, welfare, and applications for assistance from any
governmental agency because of unemployment or ill health, and all income records for a period
of five (5) years prior to the time of the occurrence alleged in the Plaintiff's Complaint up to and
including the present date.
10) All documentation of any insurance payments, governmental or private payments
received by or made on behalf of Plaintiff as a result of any alleged injuries, medical or mental
treatment or care received by the Plaintiff as a result of the injuries alleged in this suit.
11) Copies of any social security disability income applications, and benefit award
letters or notices, if filed or received.
12) Any written reports, correspondence, documents or exhibits prepared by any
experts expected to be called at trial, relative to the facts known, or opinions held concerning any
of the issues to be tried in this case.
13) | Any claim letters or demand letters or other such correspondence from insurance
companies or governmental agencies which are claiming rights of subrogation or liens or
indemnification from any recovery in this suit.
14) Copies of any liens or subrogation rights filed by any such insurance companies
or governmental agencies which are or could be assessed against.
15) Copies of any policies of insurance providing benefits to Plaintiff or otherwise
indemnifying Plaintiff for any of the injuries alleged in this suit.
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16) Copies of all invoices, claims, reports, payment records or any other documenta-
tion which supports Plaintiffs claim for expenses or hospitalization, medical and nursing care and
treatment.
17) Any and all documents or materials used to calculate Plaintiff's alleged damages
identified in response to interrogatories in Defendant's First Set of Interrogatories.
18) Copies of any and all reports or correspondence from any health care providers
assigning an impairment rating to Plaintiff, using the American Medical Association Guide to the
Evaluation of Permanent Injuries, or any other similar type of rating guide.
19) | The shoes, footwear and clothes you wore at the time of this incident. These items
can remain in your lawyer's possession but must be made available for inspection and
photographing.
20) Any and all documents or materials used to calculate the damages.
21) For each social networking account listed in response to the interrogatories, please
provide copies or screenshots of all photographs and videos of the Plaintiff associated with that
account, including those posted by others and/or those in which the Plaintiff has been “tagged”
by others, during the two (2) years prior to the date of loss.
22) For each social networking account listed in the interrogatories, provide copies or
screenshots of all photographs and videos of the Plaintiff associated with that account, including
those posted by others and/or those in which the Plaintiff has been “tagged” by others, from the
date of loss to present.
23) For each cellular phone listed in the interrogatories, please provide copies of any
documentation outlining what calls were made or received on the date of loss.
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CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the foregoing has been served
by Florida Courts E-Filing Portal, Email, U.S. Mail, Hand Delivery, or Personal Process Server
to the following this 19 day of October , 2022.
Jason Recksiedler, Esq.
Caroline Fischer ESPI, Esq.
First Choice Law, P.A.
1137 Edgewater Drive
Orlando, Florida 32804
Phone: (321) 999-1111
Jason@FirstChoiceLaw.com
Caroline@FirstChoiceLaw.com
Litigation@FirstChoiceLaw.com
Attorneys for Plaintiff
Lwkeeta Wl. Geltoon, Cag.
Jennifer A. Hoffman, Esq.
Florida Bar No.: 981605
Lakeena M. Gillion, Esq.
Florida Bar No.: 121520
CARR ALLISON
121 S. Orange Avenue, Suite 1500
Orlando, Florida 32801
Phone: (407) 783-6090
Facsimile: (904) 328-6473
JHoffman@CarrAllison.com
KGillion@CarrAllison.com
KPollak@CarrAllison.com
Attorneys for Defendant
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Preview
Filing # 159528183 E-Filed 10/19/2022 11:25:56 AM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, INAND FOR OSCEOLA COUNTY, FLORIDA CASE NO.: 2022-CA-002181 VIRGINIA AYALA Plaintiff, V. DOLGENCORP, LLC, D/B/A DOLLAR GENERAL Defendant. / DEFENDANT’S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO PLAINTIFF Defendant, through counsel, hereby requests Plaintiff to produce for inspection and copying the following listed documents at the offices of Carr Allison, 121 S. Orange Ave., Suite 1500, Orlando, FL 32801, pursuant to Rule 1.350, Federal Rules of Civil Procedure, within the required time period. DEFINITIONS As used herein, the term "document" means any medium upon which intelligence or information can be recorded or retrieved, and includes, without limitation, the original and each copy, regardless of origin and location, of any book, pamphlet, periodical, letter, memorandum (including any memorandum or report of a meeting or conversation), invoice, bill, order, form, receipt, financial statement, accounting entry, diary, calendar, telex, telegram, cable, report, record, contract, agreement, study, handwritten note, draft, working paper, chart, paper, print, laboratory record, drawing, sketch, graph, index, list, tape, photograph, microfilm, data sheet or data processing card, or any other written, recorded, transcribed, punched, taped, filmed or graphic matter, however produced or reproduced, which is in your possession, custody or control or which was, but is no longer in your possession, custody or control. 1 DOCUMENTS TO BE PRODUCED ARE AS FOLLOWS: 1) Federal Income Tax Returns and W-2 Forms for Plaintiff from 2013 to the present. 2) Any and all photographs or videos in the possession of the Plaintiff, Plaintiff's Attorneys, investigators, agents, servants, or employees which are in any manner related to the subject matter of this lawsuit, specifically including but not limited to, any and all photographs or videos of the parties, as well as photographs or videos of the scene of the subject incident. 3) All medical bills, doctor bills, hospital bills, medication bills, nursing bills, ambulance bills, and bills for similar expenses incurred by or on behalf of the Plaintiff as a result of the incident which is the subject matter of this lawsuit. 4) Copies of all medical reports received by the Plaintiff, Plaintiff's attorneys, investigators, agents, servants, or employees, from any doctor, physician, nurse or anyone else who has examined or rendered treatment to the Plaintiff for the injuries incurred as a result of the incident which is the subject matter of this lawsuit. 5) A copy of all documents, x-rays or records from any hospital, medical provider or health care facility where the Plaintiff was a patient, or where the Plaintiff received treatment, subsequent to the incident which is the subject matter of this lawsuit, which are in the possession of the Plaintiff, Plaintiffs attorneys, investigators, agents, servants or employees. 6) A copy of all documents, x-rays or records from any hospital, medical provider or health care facility where the Plaintiff was a patient, or where the Plaintiff received treatment any time during the ten years prior to the incident which is the subject matter of this lawsuit, which are in the possession of the Plaintiff, Plaintiff's attorneys, investigators, agents, servants or employees. 7) A transcript or copy of all statements, whether handwritten, typewritten, video or audio, made by Defendant, or Defendant’s employees, that is in the possession of Plaintiff or Plaintiff's attorneys, agents or servants, regarding the incident which is the subject matter of this lawsuit. 2 8) A transcript or copy of all statements, whether handwritten, typewritten, video or audio, made by any witness regarding the incident which forms the basis for this lawsuit, which is in the possession of the Plaintiff, Plaintiff's attorneys, agents or servants. 9) All employment records relating in any way to the Plaintiff, whether employed or self-employed, records relating to the fact and duration of unemployment, records of workmen's compensation, unemployment insurance, welfare, and applications for assistance from any governmental agency because of unemployment or ill health, and all income records for a period of five (5) years prior to the time of the occurrence alleged in the Plaintiff's Complaint up to and including the present date. 10) All documentation of any insurance payments, governmental or private payments received by or made on behalf of Plaintiff as a result of any alleged injuries, medical or mental treatment or care received by the Plaintiff as a result of the injuries alleged in this suit. 11) Copies of any social security disability income applications, and benefit award letters or notices, if filed or received. 12) Any written reports, correspondence, documents or exhibits prepared by any experts expected to be called at trial, relative to the facts known, or opinions held concerning any of the issues to be tried in this case. 13) | Any claim letters or demand letters or other such correspondence from insurance companies or governmental agencies which are claiming rights of subrogation or liens or indemnification from any recovery in this suit. 14) Copies of any liens or subrogation rights filed by any such insurance companies or governmental agencies which are or could be assessed against. 15) Copies of any policies of insurance providing benefits to Plaintiff or otherwise indemnifying Plaintiff for any of the injuries alleged in this suit. 3 16) Copies of all invoices, claims, reports, payment records or any other documenta- tion which supports Plaintiffs claim for expenses or hospitalization, medical and nursing care and treatment. 17) Any and all documents or materials used to calculate Plaintiff's alleged damages identified in response to interrogatories in Defendant's First Set of Interrogatories. 18) Copies of any and all reports or correspondence from any health care providers assigning an impairment rating to Plaintiff, using the American Medical Association Guide to the Evaluation of Permanent Injuries, or any other similar type of rating guide. 19) | The shoes, footwear and clothes you wore at the time of this incident. These items can remain in your lawyer's possession but must be made available for inspection and photographing. 20) Any and all documents or materials used to calculate the damages. 21) For each social networking account listed in response to the interrogatories, please provide copies or screenshots of all photographs and videos of the Plaintiff associated with that account, including those posted by others and/or those in which the Plaintiff has been “tagged” by others, during the two (2) years prior to the date of loss. 22) For each social networking account listed in the interrogatories, provide copies or screenshots of all photographs and videos of the Plaintiff associated with that account, including those posted by others and/or those in which the Plaintiff has been “tagged” by others, from the date of loss to present. 23) For each cellular phone listed in the interrogatories, please provide copies of any documentation outlining what calls were made or received on the date of loss. 4 CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the foregoing has been served by Florida Courts E-Filing Portal, Email, U.S. Mail, Hand Delivery, or Personal Process Server to the following this 19 day of October , 2022. Jason Recksiedler, Esq. Caroline Fischer ESPI, Esq. First Choice Law, P.A. 1137 Edgewater Drive Orlando, Florida 32804 Phone: (321) 999-1111 Jason@FirstChoiceLaw.com Caroline@FirstChoiceLaw.com Litigation@FirstChoiceLaw.com Attorneys for Plaintiff Lwkeeta Wl. Geltoon, Cag. Jennifer A. Hoffman, Esq. Florida Bar No.: 981605 Lakeena M. Gillion, Esq. Florida Bar No.: 121520 CARR ALLISON 121 S. Orange Avenue, Suite 1500 Orlando, Florida 32801 Phone: (407) 783-6090 Facsimile: (904) 328-6473 JHoffman@CarrAllison.com KGillion@CarrAllison.com KPollak@CarrAllison.com Attorneys for Defendant 5