Plaintiff's Requests For Production Of Documents To Defendant

To:

Address to defendant and his attorney

  1. This Request for Production of Documents is propounded to you in accordance with Rule 4:9 of the Supreme Court of Virginia. Each Request must be answered separately, fully, in writing, under oath, and a copy served upon counsel for Plaintiff within twenty-one (21) days from the date of receipt of these Requests.
  2. Where the term document is used, document means, unless stated otherwise, the following: All original documents, and any non-identical copy thereof, of any kind of written or graphic matter, however, produced or reproduced, of any kind of description, whether sent or received, or neither, between the litigants or any agent, employee, servant or attorney thereof. The term document includes, but is not limited to the following: Papers, books letters, photographs, videotapes, correspondence, telegrams, cables, telex messages, memoranda, notes, notations, work papers, brochures, inter-office memoranda, notations, work sheets, drafts, notes on negotiations, intra-office communications, inter-departmental communications, transcripts, minutes of meetings, resolutions, reports, recordings of telephone and/or other conversations, or of interviews, conference meetings, affidavits, statements, opinions, court opinions, court pleadings, ledgers, leases, reports, studies, indices, analysis, evaluations contracts, sub-contracts, licenses, license agreements, statistical reports, questionnaires, answers to questionnaires, desk calendars, appointment books, diaries, telephone logs, lists, calendars, tabulations, charts, graphs, sound records, data sheets, computer tapes and disc, magnetic tapes, punch cards, computer programs, emails, computer disks, retrievable computer data, coding sheets, computer printouts, microfilm, receipts, canceled checks, and/or maintenance records.
Requests

1. If you were the owner of the motor vehicle you were operating at the time of the collision, please attach a copy of the complete policy for:

  1. the motor vehicle insurance policy for the motor vehicle you were operating on (date of collision) and
  2. all other motor vehicles in which you were a named insured on said date.

RESPONSE:

2. If you were not the owner of said motor vehicle, please attach the complete policy for:

  1. all motor vehicles you owned or were a named insured on (day of collision), and
  2. all motor vehicles owned by a resident relative on said date.
RESPONSE:

3. Please attach the complete policy for all excess, business and/or umbrella policies which may provide coverage for this accident.

RESPONSE:

4. Please attach a copy of any statements, written or recorded, regarding the collision described in the plaintiff's Complaint or any injuries or property damage arising out of this collision. This request includes any statements made by Plaintiff or Defendant. If you or your counsel believe any such statements are privileged, please identify the statement and the privilege relied upon.

RESPONSE:

5. Please produce color copies or make available for inspection and copying the original of all photographs, drawings or measurements of anything or anyone at the scene of this collision or of any vehicle involved. Plaintiff will pay the cost of reproducing the photographs in color.

RESPONSE:

6. Please attach a copy of any reports, including factual observations and opinions, which have been prepared by your expert. If you or your attorney believe any such documents are privileged, please identify the document (name the author and describe the document, i.e. medical report) and the privilege relied upon.

RESPONSE:

7. Please produce or make available a copy of document subpoenaed by Defendant , including but not limited any medical reports, notes, intake or new patient registration sheets, medical records, x-rays, telephone logs. subpoenaed from any of Plaintiff's healthcare providers or which otherwise reflect medical treatment rendered plaintiff. However, this request is not limited to medical records. (This Request is made pursuant to Virginia Code §8.01-417(B) and does not include those documents provided defendant by plaintiff.) Plaintiff will pay copying charges.

RESPONSE:

8. Please produce a copy of all estimates and appraisals of damage to each vehicle involved in the collision which are in your possession, custody or control.

RESPONSE:

9. Please attach a copy of each and every driver=s license issued to Defendant on the date of the incident, and any licenses issued thereafter through the present time.

RESPONSE:

10. Please attach a copy of the registration for the motor vehicle operated by Defendant at the time of the collision.

RESPONSE:

11. Please attach a copy of any videotape or other recording of the Plaintiff.

RESPONSE:

12. Please attach a copy of any document reflecting prepayment of a fine, or a plea of guilty or nolo contendere to any traffic charge arising out of the collision with Plaintiff.

RESPONSE:

13. Please attach a copy of any document in your possession which tends to establish that you were not at fault for this collision.

RESPONSE:

Respectfully Submitted,

By: _________________________________

Law Offices of Jeremy Flachs

Jeremy Flachs, Esq.

Jeremy.Flachs@Flachslaw.com

Counsel for Plaintiff

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