Civil 4
Request for Production
THE STATE COURT IN CUYAHOGA COUNTY, OHIO
MATHEWS
Plaintiff,
v.
SALLY SMITH
Defendant.
IN THE STATE COURT IN CUYAHOGA COUNTY, OHIO
CASE NO.
REQUEST FOR PRODUCTION
Plaintiff Mathews asks that defendant Sally Smith, provides the below mentioned documents in connection with this case. If there is any objection to this request, kindly provide the reason for the objection. If you are denying the request, kindly provide in details the reasons as to why the party is not able to provide all the documents requested.
i. The copy of the driver’s license, and any other document that pertains to amendments, or renewals
ii. A copy of the insurance policy of the defendant that provides cover for this occurrence as claimed
iii. All copies of papers that prove ownership of the car by the defendant
iv. Copy of all statements made by witnesses gotten before this lawsuit was filed by insurance agents acting on the behalf of the insurance carrier of the defendant, if any.
v. Copies of all photos that illustrate any damage to the bicycles of the plaintiff, the car of the defendant, and place of the incident claimed
vi. Copies of all writings that deny in whole or partiallt the degree, score and nature of the current medical condition of the plaintiff
vii. Copies of all videotapes, if any, made of the incident
Dated this 14th Day of March, 2020
Attorney
Deposition Notice
MATHEWS
Plaintiff,
v.
SALLY SMITH
Defendant.
IN THE STATE COURT IN CUYAHOGA COUNTY, OHIO
CASE NO.
NOTICE TO TAKE DEPOSITION
The Mathews, who are the defendants, by their lawyer, according to the Ohio Rules of Civil Procedure, will obtain a deposition after conducting an oral examination on the individual referred below on the time and date and at the place stated below prior to an individual suitably sanctioned to direct an oath under the laws set in Ohio. The recordings with regards to the deposition will be done through audio and videotaped means for discovery purposes. The recordings will also be utilized as evidence and/or for any purposes as allowed by the Rules of Civil Procedure in Ohio, encompassing the utilization during court proceedings, and will go on daily until completed.
The documents/things indicated on “Schedule Z” (attached below) will be brought by the Deponent to the Deposition.
Name: Mathews
Date:
Place:
SCHEDULE “Z”
1. Any and all audiotapes, images, diagrams or videotapes, photos or other documents that relate to the incident in any manner
2. Any and every document pointed out in your responses to the interrogatories to this party
3. Any and every document that relate to any release, compromise, settlement provided to, or gotten by, you for any damage or injury resulting from the incident in any manner
4. Every document that serves to bolster special damages (earnings lost, workdays lost, medical costs) which are claimed in this action
5. Each and every document which recognizes everyone or entity that has paid any kind of benefit that are funded by the federal government with respect to the grievances or incident complained of in this lawsuit, and for every such individual or entity, provide all documents which list the kind and amount of benefits paid, contact person, and claim payable to the benefits funded by the federal government
Therefore, TAKE NOTICE that on 15th March, 2020, the Law offices, starting at 11.00am, in the presence of a Notary Public, the undersigned, by counsel, will go on to take Mathews’ deposition, after oral examination. This deposition will be utilized as evidence or discovery in this lawsuit under the Rules of Procedure in Ohio. In the event that the deposition is not complete today, it will resume and continue on another day until its full completion.
