IN THE CIRCUIT COURT OF THE
11TH JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA

CASE NO.: 00-xxxx

G.B.,
                             Plaintiff,
  vs.

HISTORIC TOURS OF AMERICA, INC.
d/b/a OLD TOWN TROLLEY TOURS
                             Defendants.
_________________________________/

PLAINTIFF’S REQUEST FOR PRODUCTION TO DEFENDANT

The Plaintiff, G.B., through the undersigned attorney, requests the Defendant, HISTORIC TOURS OF AMERICA, INC. d/b/a OLD TOWN TROLLEY TOURS, to produce, pursuant to Fla.R.Civ.P. 1.350, the following:

1. Photographs of the trolley HISTORIC TOURS OF AMERICA, INC. d/b/a OLD TOWN TROLLEY TOURS was operating at the time of the subject incident.

2. All time sheets or other documents which evidence whether the employee(s) was/were acting in the course and scope of his/her employment with HISTORIC TOURS OF AMERICA, INC. d/b/a OLD TOWN TROLLEY TOURS, at the time of the subject collision.

3. Any statements of the plaintiff taken by or on behalf of any of the defendant or their insurer or reproductions of any recorded statements of the plaintiff.

4. Statements of any witnesses taken by or on behalf of any of the defendant or their insurer.

5. All internal documents evidencing any disciplinary action or any other negative consequence as a result of the subject incident.

6. Declaration sheet of each liability policy insuring any of the defendant for its potential liability for the plaintiff.

7. Copy of the certificate of title or registration for the trolley HISTORIC TOURS OF AMERICA, INC. d/b/a OLD TOWN TROLLEY TOURS was driving at the time of the subject incident.

8. Copy of any lease agreement in existence as of [date], involving the subject trolley that HISTORIC TOURS OF AMERICA, INC. d/b/a OLD TOWN TROLLEY TOURS was driving at the time of the incident described in the complaint.

IT IS HEREBY CERTIFIED that a true and correct copy of the foregoing has been served with the complaint.

LAW OFFICE OF ALAN D. SACKRIN
Attorneys for Plaintiff
2100 East Hallandale Beach Blvd.
Suite 200
Hallandale Beach, FL 33009
Telephone: (954) 455-0800

By________________________________
   ALAN D. SACKRIN
   Florida Bar No. 349070

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The above pleading is a sample of Alan Sackrin's 30-plus years of litigation experience.  To learn more about Alan Sackrin, click on this link:  South Florida Personal Injury Lawyer

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