EXHIBIT 1 

Case 0:20-cv-60931-RAR Document 1-2 Entered on FLSD Docket 05/08/2020 Page 1 of 27
Case Number: CACE-20-004488 Division: 25 

, Filing # 104732867 E-Filed 03l11/2020 04:15:47 PM 

IN THE CIRCUIT COURT OF THE 

17rH JUDICIAL CIRCUIT, IN AND FOR 

BROWARD COUNTY, FLORIDA 

ROGER BEAULIERE, 

CASE NO.: 

Plaintiff, 

vs_ 

JETBLUE AIRWAYS CORPORATION, 

a Foreign Profit Corporation and 

DIRECT AIRLINE SERVICES, INC., 

a Florida Corporation, 

Defendants. 

~.P 

Recei~oed:i

3 G ~q 

Served: 

Richard Ko9®dgy, CPS #204, 

Second Judicia! Circuit 

SUMMONS 

THE STATE OF FLORIDA 

TO EACH SHERIFF OF THE STATE: 

YOU ARE COMMANDED to serve this summons and a copy of the Compiaint, 

Request for Production and Notice of Service of Initial Interrogatories in this action on 

defendant, JETBLUE AIRWAYS CORPORATION, by serving its Registered Agent: 

Corporation Service Company 

1201 Hays Street 

Tallahassee, FL 32301-2525 

Each defendant is required to serve written defenses to the complaint or petition 

on plaintiffs or their attomey, whose name and address is Carlos A. Bodden, BODDEN 

8: BENNE7T LAW GROUP,1880 North Congress Avenue, #401, Boynton Beach, FL 

33426; (561) 806-5229 within 20 days after service of this summons on the defendant, 

exclusive of the day of service, and to fife the original of the defenses with the clerk of this 

court either before service on PlaintifPs attorney or immediately thereafter. If defendant 

fails to do so, a default will be entered against defendant for the relief demanded in the 

complaint or petition. 

WITNESS my hand and Seal of said Court this day of 

MAR 12 2020 

Clerk of the Court 

(COURT SEAL) 

~~ 

`x*3 F1LED: BROWf1RD C:OWi TY. FL BRENDA D_ FOR^4AN. CLERK 03111;2020 04:15:46 PM.**"* 

Case 0:20-cv-60931-RAR Document 1-2 Entered on FLSD Docket 05/08/2020 Page 2 of 27
i Fi3izig # 104732867 E-Filed 03/11/2020 04:15:47 PM 

IN THE CIRCUIT COURT OF THE 

17T" JUDICIAL CIRCUIT, IN AND FOR 

BROWARD COUNTY, FLORIDA 

ROGER BEAULIERE, 

CASE NO.: 

Plaintiff, 

vs. 

JETBLUE AIRWAYS CORPORATION, 

a Foreign Profit Corporation and 

DIRECT AIRLINE SERVICES, INC., 

a Florida Corporation, 

Defendants. 

/ 

COMPL.AINT FOR DAMAGES 

COMES NOW, the Plaintiff, ROGER BEAULIERE, by and through undersigned 

counsel, and sues the Defendant, JETBLUE AIRWAYS CORPORATION, a Foreign Profit 

Corporation and DIRECT AIRLINE SERVICES, INC., a Florida Corporation and alleges 

as follows: 

1. This is an action for damages which exceed the sum of Fifteen Thousand 

Dollars ($15,000.00), exciusive of costs, interest and fees. 

2. At all times material herein, Defendant, JETBLUE AIRWAYS 

CORPORATION, (fiereinafter "JETBLUE") was and is a Foreign Profit Corporation 

authorized to and doing business within the State of Florida, and more specifically, in 

Broward County, Florida. 

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Case 0:20-cv-60931-RAR Document 1-2 Entered on FLSD Docket 05/08/2020 Page 3 of 27
3. At all times material herein, Defendant, DIRECTAIRLINE SERVICES, INC., 

(hereinafter "DAS") was and is a Florida Corporation authorized to and doing business 

within the State of Florida, and more specifically, in Broward County, Florida. 

4. At all times material hereto, the Defendant, JETBLUE, was in the business 

of owning, maintaining and flying commercial airplanes at the Fort Lauderdale-Hollywood 

International Airport. 

5. At ail times material hereto, the Defendant, DAS, was in the business of 

providing wheelchair service and assistance for passengers entering and exiting 

airplanes at the Fort Lauderdale-Hollywood International Airport. 

6. On January 9, 2019, Plaintiff, ROGER BEAULIERE was a passenger on 

JETBLUE Airline Flight Number 1510, which traveled from Port-Au-Prince, Haiti to Fort 

Lauderdale, Florida. 

COUNTI 

NEGLIGENCE OF DEFENDANT JETBLUE AIRWAYS CORPORATION 

Plaintiff, ROGER BEAULIERE, restates and realleges paragraphs 1 through 6 as if 

fully set forth herein and further states: 

7. On or about January 9, 2fl19, the Plaintiff, ROGER BEAULIERE, a business 

invitee on Defendant JETBLUE'S subject airplane, was injured when he fell out of a 

wheelchair that was not properly secured by an employee and/or independent contractor 

of Defendant, JETBLUE shortly after he exited his Jetblue flight. 

8. At all times material hereto, Defendant JETBLUE owed a duty to the 

Plaintiff, ROGER BEAULIERE, and other members of the general public similarly situated 

to keep its wheelchair bound passengers in a reasonably safe condition and to protect 

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Case 0:20-cv-60931-RAR Document 1-2 Entered on FLSD Docket 05/08/2020 Page 4 of 27
Plaintiff, ROGER BEAULIERE from dangers of which the business or its agents or 

employees was or should have been aware. 

7. Defendant, JETBLUE, as owner and/or lessor and/or operator of the 

aforementioned wheelchair, and as the entity that had possession and control of said 

wheelchair, had a duty to operate its wheelchair in a non-negligent manner and implement 

methodology which does not cause or contribute to the creation of dangerous conditions. 

Defendant, JETBLUE also had a duty to avoid injury to the.Plaintiff, ROGER BEAULIERE, 

and other invitees to the Defendant's business, and also have a duty to warn the Plaintiff, 

ROGER BEAULIERE, of all dangerous conditions, including the one herein previously 

alleged, which it knew or should have known existed and which created an unreasonable 

risk of harm to Plaintiff, ROGER BEAULIERE. 

8. At all times material hereto, the Defendant, JETBLUE, negligently breached 

the above-mentioned duties in one or more, but not limited to, the following respects: 

a. creating the condition which caused the Plaintiffs injury; 

b. allowing the dangerous condition to exist by negligently hiring, 

training and/or retaining employees and/or independent contractors 

whose purpose is to assist wheelchair bound passengers as they 

enter and exit airplanes. This dangerous condition created by these 

employees and/or independent contractors that caused the Plaintiff 

to get injured had exited for a sufficient length of time that the 

Defendant knew, or under the exercise of reasonable care shoufd 

have known, that the dangerous condition existed and should be 

ISIS 

Case 0:20-cv-60931-RAR Document 1-2 Entered on FLSD Docket 05/08/2020 Page 5 of 27
promptly addressed. Nevertheless, Defendant did not take any of 

these steps and as a result Plaintiff sustained injuries and related 

damages; and/or 

C. failing to otherwise exercise due care with respect to the matter 

alleged in the Complaint. 

9. As a direct and proximate result of the aforementioned negligence of 

Defendant, JETBLUE, the Plaintiff, ROGER BEAULIERE sustained injuries. 

10. As a further direct, proximate and foreseeable result of the negligence of 

the Defendant, JETBLUE, the Plaintiff, ROGER BEAULIERE, suffered bodily injury and 

resulting pain and suffering, disabifity, disfigurement, impairment ofworking ability, mental 

anguish, loss of capacity for the enjoyment of life, expense of hospi#aiization, medical and 

nursing care and treatment, loss of earnings, loss of the ability to earn money in the future, 

aggravation of a previously existing condition, and Plaintiff has incurred medical expenses 

in the care and treatment of said injuries. The losses are either permanent or continuing 

in nature and Plaintiff, ROGER BEAULIERE, will suffer said losses in the future. 

COUNT II 

NEGLIGENCE OF DEFENDANT DIRECT AIRLINE SERVICES 

Plaintiff, ROGER BEAULIERE, restates and realleges paragraphs 1 through 6 as if 

fully set forth herein and further states: 

11. On or about January 9, 2019, the Plaintiff, ROGER BEAULIERE, a business 

invitee at Defendant DAS, was injured when he fell out of a wheelchair that was not 

properiy secured by an employee and/or independent contractor of Defendant, DAS 

shortly after he exited his airline flight. 

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Case 0:20-cv-60931-RAR Document 1-2 Entered on FLSD Docket 05/08/2020 Page 6 of 27
12. At all times material hereto, Defendant DAS owed a duty to the Plaintiff, 

ROGER BEAULIERE, and other members of the general public similarly situated to keep 

its wheelchair bound passengers in a reasonably safe condition and to protect Plaintiff, 

ROGER BEAULIERE from dangers of which the business or its agents or employees was 

or should have been aware. 

13. Defendant, DAS, as owner and/or lessor and/or operator of the 

aforementioned wheelchair, and as the entity that had possession and control of said 

wheelchair, had a duty to operate its wheelchair in a non-negligent manner and implement 

methodology which does not cause or contribute to the creation of dangerous conditions. 

Defendant, DAS also had a duty to avoid injury to the Plaintiff, ROGER BEAULIERE, and 

other invitees to the Defendant's business, and also have a duty to warn the Plaintiff, 

ROGER BEAULIERE, of all dangerous conditions, including the one herein previously 

alleged, which it knew or should have known existed and which created an unreasonable 

risk of harm to PlaintifF, ROGER BEAULIERE. 

14. At all times material hereto, the Defendant, DAS, negligently breached the 

above-mentioned duties in one or more, but not limited to, the following respects: 

a, creating the condition which caused the PlaintifPs injury; 

b. allowing the dangerous condition to exist by negligently hiring, 

training andtor retaining employees and/or independent contractors 

whose purpose is to assist wheelchair bound passengers as they 

enter and exit airplanes. This dangerous condition created by these 

employees and/or independent contractors that caused the Plaintiff 

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Case 0:20-cv-60931-RAR Document 1-2 Entered on FLSD Docket 05/08/2020 Page 7 of 27
to get injured had exited for a sufficient length of time that the 

Defendant knew, or under the exercise of reasonable care should 

have known, that the dangerous condition existed and should be 

promptly addressed. Nevertheless, Defendant did not take any of 

these steps and as a result Plaintiff sustained injuries and related 

damages; and/or 

C. failing to otherwise exercise due care with respect to the matter 

alieged in the Complaint. 

15. As a direct and proximate result of the aforementioned negligence of 

Defendant, DAS, the Plaintiff, ROGER BEAULIERE sustained injuries. 

16. As a further direct, proximate and foreseeable result of the negligence of 

the Defendant, DAS, the Plaintiff, ROGER BEAULIERE, suffered bodily injury and 

resulting pain and suffering, disability, disfigurement, impairment of working ability, mental 

anguish, loss of capacity for the enjoyment of life, expense of hospitalization, medical and 

nursing care and treatment, loss of earnings, loss of the ability to earn money in the future, 

aggravation of a previously existing condition, and Plaintiff has incurred medical expenses 

in the care and treatment of said injuries. The iosses are either permanent or continuing 

in nature and Plaintiff, ROGER BEAULIERE, will suffer said losses in the future. 

im 

Case 0:20-cv-60931-RAR Document 1-2 Entered on FLSD Docket 05/08/2020 Page 8 of 27
WHEREFORE, the Plaintiff, ROGER BEAULIERE, demands judgment for 

damages against the Defendant, DIRECT AIRLINES SERVICES, INC., inclusive of costs, 

pre }udgment interest, attorney fees, if allowable by law, and such other further relief as 

the Court deems just and proper, both in law and equity. The Plaintiff further demands 

trial by jury as to all issues triable as a matter or right. 

BODDEN & BENNETT LAW GROUP 

Attorneys for the Plaintiff 

1880 North Congress Avenue, #401 

Boynton Beach, FL 33426 

Telephone: (561)806-5229 

Fac.simile: (561)806-5244 

Desig. Email: fitlaw(cDboddenbennettiaw.com 

By:/s/ Carlos A. Bodden 

Carlos A. Bodden, Esq. 

Florida Bar No.: 093343 

W. David Bennett, Esq. 

Florida Bar No.: 087746 

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Case 0:20-cv-60931-RAR Document 1-2 Entered on FLSD Docket 05/08/2020 Page 9 of 27
Filing # 104732867 E-Filed 03/11/2020 04:15:47 PM 

IN THE CIRCUIT COURT OF THE 17T" 

JUDICIAL CIRCUIT, IN AND FOR 

BROWARD COUNTY, FLORIDA 

ROGER BEAULIERE, 

Plaintiff, CASE NO.: 

vs. 

JETBLUE AIRWAYS CORPORATION, 

a Foreign Profit Corporation and 

DIRECT AIRLINE SERVICES, INC., 

a Florida Corporation, 

Defendants. 

I 

PLAINTIFF'S FIRST SET OF INTERROGATORIES 

TO DEFENDANT, JETBLUE AIRWAYS CORPORATION AND NOTICE OF FILING - 

PURSUANT to Rules 1.280 and 1.340 of the Florida Rules of Civil Procedure, 

Plaintiff propounds to the Defendant, JETBLUE AIRWAYS CORPORATION, the attached 

twenty (20) Interrogatories to be answered under oath and in writing within Forty-Five (45) 

days. 

IT IS HEREBY CERTIFIED that the original and one copy of the foregoing 

Interrogatories attached hereto are being served with the Complaint upon said Defendant. 

BODDEN & BENNETf LAW GROUP 

Attomeys for the Plaintiff 

1880 North Congress Avenue, #401 

Boynton Beach, FL 33426 

Telephone: (561)806-5229 

Desig. Email: iitlaw@boddenbennettlaw.com 

By: /s/ Cardos A. Bodden 

Carlos A. Bodden, Esq. 

Florida Bar No.: 093343 

W. David Bennett, Esq. 

Florida Bar No_: 087746 

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Case 0:20-cv-60931-RAR Document 1-2 Entered on FLSD Docket 05/08/2020 Page 10 of 27
PREMISES LIABILITY INTERROGATORIES 

1_ Please identify yoursetf fully, giving your full name, residence, business address, 

and occupation, and if the defendant is a corporation, the office you hold with the 

defendant. 

2. Was the Defendant's employee andfor independent contractor in charge of 

maintaining, pushing and/or controlling the subject wheelchair at the time and 

place of the alleged occurrence? 

3. lf the Defendant's employee and/or independent contractor was not in control of 

the subject wheelchair, please state the name and address of the person, firm, 

and/or corporation in control of the employee and/or independent contractor who 

was pushing the subject wheelchair on the date of the alleged occurrence. 

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4. Please provide the name and address of each person who observed, or was 

present in the vicinity of, the alleged occurrence. 

5. If any of the persons listed in the answer to the preceding interrogatory are agents 

or employees of the defendant, please: 

(a.) describe in complete detail everything that was seen or noticed by each 

such agent or employee. 

(b.) state where in relation to the point of the alleged occurrence each such 

agent or employee was at the time he or she witnessed the occurrence. 

6. Did you or any agent or employee of the defendant render any assistance to the 

plaintiff immediately after the alleged occurrence? 

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Case 0:20-cv-60931-RAR Document 1-2 Entered on FLSD Docket 05/08/2020 Page 12 of 27
7. If the answer to the preceding interrogatory is in the affirmative, please state: 

(a.) in complete detail, what assistance was rendered to the piaintiff. 

(b.) the name and address of each person rendering assistance of any kind to 

the plaintiff. 

8. Pkease {ist all factors which you contend caused or contributed to cause the alleged 

occurrence. 

9. With respect to the area where the alleged occurrence took place, please indicate 

when you or any agent or employee of the defendant first became aware of the 

subject incident. 

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Case 0:20-cv-60931-RAR Document 1-2 Entered on FLSD Docket 05/08/2020 Page 13 of 27
10. Did you or any agent or empioyee of the defendant observe the condition of the 

wheelchair just before, during, or just after the alleged occurrence? 

11. Please state fully and in compiete detail: 

(a.) the date and time prior to the aiieged occurrence when the subject 

wheeichair was last pushed, inspected, and/or cieaned prior to the time 

Plaintiff fell as is referenced in the subject compiaint? 

(b.) a complete description of such action. 

(c.) the identity, incduding job description, name, and address, ofthe person who 

did such action. 

12. Will the defendant or its attorneys call at the trial of this action any person to testify 

as an expert witness concerning any of the following: the cause of the alleged 

occurrence; the procedures used by the defendant for hiring, training or 

maintaining its employees and/or independent contractors who assist wheel chair 

bound passengers .who enter or exit airlines at the Fort Lauderdale-Hollywood 

airport. 

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Case 0:20-cv-60931-RAR Document 1-2 Entered on FLSD Docket 05/08/2020 Page 14 of 27
13. If the answer to the preceding interrogatory is in the affirmative, please state the 

following as to each such witness: 

(a.) witness' complete identification, including name and address. 

(b.) witness' qualifications as an expert. 

14. Please describe as accurately as possible the place or location of the alleged 

occurrence within the airport, distances in feet to fixed objects or boundaries by 

which the location may be identified. 

15. Please state fully the substance of each and every conversation which took place, 

after the atleged occurrence, between the pfaintiff and you or any agent or 

employee of the defendant. . 

ELM 

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16. Did you or any agent or employee of the defendant ever take or receive any 

statement, either oraf or in writing, from any person, including parties, who had any 

information or knowledge relating to the alfeged occurrence? 

- 

17. If the answer to the preceding interrogatory is in the affirmative, please state as to 

each such person: 

(a.) his or her identification, incfuding name and address. 

(b.) the date of each such statement. 

(c.) the substance in full of each such statement. 

(d.) if any such statement was in writing, either attach a copy to the answer to 

these interrogatories, or indicate where and when each such statement may 

be examined by counsel. 

18. Did any video surveillance recording capture PlaintifPs fall as described in the 

subject complaint? If not, did any video sunreillance capture Plaintiffs image on 

the date referenced in the subject complaint? 

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19. Was surveillance video being used on the date referenced in the complaint? If not, 

when was video surveiilance recording last conducted in the subject area where 

the alleged incident occurred prior to the date of the incident referenced in the 

complaint. 

20. Did you know if any surveillance video in any airport capture the Plaintiff's image 

.on the date referenced in the complaint? If so, have you or anyone on your behalf 

or at your direction reviewed said surveillance video(s)? 

im 

Case 0:20-cv-60931-RAR Document 1-2 Entered on FLSD Docket 05/08/2020 Page 17 of 27
JETBLUE AIRWAYS CORPORATION 

-0 

Authorized Agent 

Printed Name ofAgent 

STATE OF FLORIDA ) 

:SS 

COUNTY OF ) 

The foregoing instrument was acknowledged before me this day of 

, 2020, by , who is 

personaily known to me or who produced as 

identification. 

Notary Public 

My Commission Expires: 

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Case 0:20-cv-60931-RAR Document 1-2 Entered on FLSD Docket 05/08/2020 Page 18 of 27
Filing # 104732867 E-Filed 03/11/2020 04:15:47 PM 

IN THE CIRCUIT COURT OF THE 

17T" JUDICIAL CIRCUIT, IN AND FOR 

BROWARD COUNTY, FLORIDA 

ROGER BEAULIERE, 

CASE NO.: 

PlaintifF, 

vs. 

JETBLUE AIRWAYS CORPORATION, 

a Foreign Profit Corporation and 

DIRECT AIRLINE SERVICES, INC., 

a Florida Corporation, 

Defendants. 

! 

PLAINTIFF'S FIRST REQUEST fiOR PRODUCTION TO DEFENDANT, JETBLUE 

Plaintiff, ROGER BEAULIERE, by and through undersigned counsel, requests the 

Defendant to produce the following items on the attached sheet pursuant to the applicable 

Florida Rules of Civil Procedure at the offices of PlaintifFs attorney, Carlos A. Bodden, 

Esquire, at 1880 North Congress Avenue, #401, Boynton Beach, FL 33426, within the 

time prescribed by the Florida Rules of Civii Procedure: 

THIS REQUEST FOR PRODUCTION is being senred with the Complaint upon 

said Defendant and compliance herewith must be made pursuant to the applicable rules 

of procedure: 

DEFINITIONS 

As used in this Request: 

(1) The term "document" is intended to be comprehensive and to include, 

without iimitation, all original writings of any nature whatsoever, copies and drafts which, 

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Case 0:20-cv-60931-RAR Document 1-2 Entered on FLSD Docket 05/08/2020 Page 19 of 27
by reason of notes, changes, initials, or identification marks are not identical to the 

original, and all non-identical original copies thereof. In all cases where original or 

non-original copies are not available, "document" also means identical copies of original 

documents and copies of non-identical copies. 

The term "document" includes, but is not limited to, correspondence, memoranda, 

contracts, leases, agreements, invoices, credit memoranda, credit files, records, data 

sheets, electronic mail, purchase orders, tabulations, reports, bilis of lading, evaluations, 

work papers, summaries, opinions, journals, statistical records, sales reports, financial 

reports, checks, notes, transcriptions, telegrams, teletypes, telex messages, telefaxes, 

recordings of telephone calls, and other communications, including but not limited to 

notes, notations, memoranda, and other writings of or relating to telephone conversations 

and conferences, minutes and notes of transcriptions of all meetings and other 

communications of any type, microfiche, microfilms, tapes or other records, logs and any 

other information which is stored or carried electronically, by means of computer 

equipment or otherwise, and which can be retrieved in printed, graphic, or audio form. 

(2) The term "relating to" includes referring to, embodying, in connection with, 

commenting on, corresponding to, sharing, describing, concerning, analyzing, reflecting, 

or constituting. 

(3) Terms in the plural include the singular and terms in the singular include the 

plural. 

(4) A request that the party produce documents in the party's possession 

means that the party must produce all documents in possession of the party, and all 

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Case 0:20-cv-60931-RAR Document 1-2 Entered on FLSD Docket 05/08/2020 Page 20 of 27
documents betonging to the party in the possession of the party's agents, employees, 

representatives or attorneys. 

(5) The terms "you" or "your" refer to your agents, employees, representatives 

and attorneys. 

(6) The term "person" inciudes a corporation, partnership, other business 

association or entity, a natural person, and any govemment or govemmental body, 

commission, board or agency. 

(7) The term "communication" or "communications" means the act or fact of 

communicating, whether by correspondence, telephone, facsimile, electronic mail, 

meeting or any occasion of joint or mutual presence, as well as the transfer of any 

document from one person to another. 

INSTRUCTIONS 

1. With regard to the PlaintifFs Request to Produce herein, for each separate 

item on the Request to Produce which you are withholding production ciaiming any 

privilege (work product/attomey-client/etc.), pfease state with respect to each such 

document the following: 

a) The type of document involved and its general subject matter without 

disclosing its contents; 

b) The names, business addresses, residence addresses, telephone 

numbers, positions and occupations of all persons who prepared each 

document and provide the same information for each person to whom any 

document was directed; 

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Case 0:20-cv-60931-RAR Document 1-2 Entered on FLSD Docket 05/08/2020 Page 21 of 27
c) The number of pages of the document; 

d) The date of the document; 

e) The privilege upon which Defendant relies in withholding the documents; 

f) AII facts upon which Defendant relies in support of the claim of privilege. 

2. If any document described in this request was but no longer is in your 

possession or subject to your custody or control, or in existence, please state whether it 

is missing or lost; whether it has been destroyed; whether it has been transferred, 

voluntarily or involuntarily, to others; or whether it has been disposed of otherwise. in 

each instance explain the circumstances surrounding such disposition and identify the 

person directing or authorizing same, and the date thereof. Identify each such document 

by listing its author, the author's address, type of document (e.g., letter, memorandum, 

telegram, chart, or photograph), date, subject matter, present location and custodian, and 

state whether the document (or copies) are still in existence. 

DOCUMENTS TO BE PRODUCED 

1. Defendant is requested to produce a copy of any and all statements (as 

defined in the Rules of Civil Procedure) concerning this action or the subject matter of this 

action previously made by the Plaintiff. 

2. Defendant is requested to produce a copy of any and all policies of liability 

insurance providing liability coverage to the Defendant for claims arising out of the 

incident described in the Compfaint or copies of any and all policies of insurance which 

allegedly provide liability insurance coverage to the Defendant for the incident described 

in the Complaint. 

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Case 0:20-cv-60931-RAR Document 1-2 Entered on FLSD Docket 05/08/2020 Page 22 of 27
3. Defendant is requested to produce a copy of any and all policies of 

insurance of any kind or nature which would provide benefits to the Plaintiff by reason of 

incidents described in the Complaint. 

4. Defendant is requested to produce copies of any and all photographs taken 

at the scene of the incident described in the Complaint which do or might reveal marks, 

damage or conditions which no longer exist at the said scene orwhich probably no longer 

exist at said scene on the date of the filing of this request: 

5. Defendant is requested to produce any property in the possession of the 

Defendant on the date of the incident described in the Complaint which was involved in 

the incident described in the Complaint and which property contains marks or damage as 

a result of the incident described in the Complaint, or if such property no longer contains 

such marks or damage in the same condition as it did on the date of the incident described 

in the Complaint subsequent to said incident, then produce for examination copies of any 

and all photographs showing such marks or damage. 

6. Defendant is requested to produce any written document, repair estimate or 

report of examination describing in anyway the nature and extent of the condition of the 

subject wheel chair as described in the Complaint or any such documents reflecting 

conditions of the wheel chairs owned and/or controlled by the Defendant immediately 

prior to the incident described in the Complaint which said conditions have subsequently 

been repaired or corrected or no longer exist. 

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Case 0:20-cv-60931-RAR Document 1-2 Entered on FLSD Docket 05/08/2020 Page 23 of 27
7. Defendant is requested to produce all surveillance materials of any kind 

regarding the Plaintifl'; including but not limited to video surveillance that recorded the 

subject incident or indicates the condition of the subject wheel chair immediately before 

or after the alleged incident. 

8. Defendant is requested to produce all photographs, videotapes, slides and 

visual reproductions of any kind depicting the scene of the accident which is the subject 

of this civil action for the date of the alleged incident. 

9. Defendant is requested to produce all photographs, videotapes, slides and 

visual reproductions of any kind depicting the Plaintiff on the subject airline and/or at any 

airport on the date of the subject incident. 

10. Defendant is requested to produce the incident report or accident report in 

connection with the subject incident, as described in the Complaint. 

11. Defendant is requested to produce all studies, reports, analyses, and 

assessments of any kind regarding the condition of the subject wheelchair. 

12. Defendant is requested to produce all complaints and documentation 

arising out of claims that someone made a report of falling and/or almost falling from a 

wheel chair entering or exiting a Jetbiue Airline at the Fort Lauderdale-Hollywood airport 

within three (3) years preceding January 9, 2019. 

13. Defendant is requested to produce any and all correspondence, reports, 

memoranda, documents and papers of any kind whatsoever placing Defendant on notice 

of an airiine passenger falling and/or almost failing from a wheel chair while entering or 

~ 

Case 0:20-cv-60931-RAR Document 1-2 Entered on FLSD Docket 05/08/2020 Page 24 of 27
exiting a Jetblue Airline at the Fort Lauderdale-Hollywood airport within three (3) years 

preceding January 9, 2019. 

14. Defendant is requested to produce the personnel file of the person(s) who 

prepared the accident or incident report in connection with the incident involving the 

Plaintiff on January 9, 2019. 

15. Defendant is requested to produce the records which reflect the identity and 

position of any person(s) who maintained, controlled and/or pushed a wheelchair while 

entering or exiting a Jetblue Airline at the Fort Lauderdale-Hollywood airport on January 

9, 2019. 

16. Defendant is requested to produce all policies, procedures, employee 

manuals, internal memoranda, documents, papers and materials of any kind whatsoever 

which discuss the policies, procedures or practices of airline passenger wheeEchairs with 

respect to maintenance, cleaning and inspection. 

17. Defendant is requested to produce all accident and incident reports, other 

than the accident or incident report involving the Plaintiff, which pertain to someone 

reporting that they had fallen and/or almost fallen from a wheeE chair while entering or 

exiting a Jetblue Airline at the Fort Lauderdale-Hollywood airport within three (3) years 

preceding January 9, 2019. In the event that any work product claims are asserted in 

connection with this request, it is requested that the Defendant provide a log itemizing 

and describing every such document to which a claim of work product protection is 

asserted. 

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Case 0:20-cv-60931-RAR Document 1-2 Entered on FLSD Docket 05/08/2020 Page 25 of 27
18. Defendant is requested to produce a copy of any and ail diagrams of the 

subject wheelchair. 

19. Defendant is requested to produce a copy of any and all contracts or 

agreements between the rDefendant and any third party and/or agreements for 

maintenance andlor repair of the subject wheelchair for the three (3) years prior to 

January 9, 2019. 

20. Copies of each and every piece of paper and other document which is 

presently maintained by the Defendant pertaining to any aspect of the incident described 

in the Complaint filed herein. 

21. Laser color copies (or duplicate photographs) of any and all photographs in 

Defendant's possession of the subject airplane floor or the Plaintiff on the date of the 

incident referenced in the complaint. 

22. Copies of any and all wheel chair inspection forms or checklists maintained 

by any employee or agent of the Defendant on or about January 9, 2019. 

23. Copies of any inspection reports, invoices, estimates andlor permits 

obtained with respect to the maintenance, repair or servicing wheelchairs for passengers 

entering or exiting a Jetblue Airline at the Fort Lauderdale-Hollywood airport within three 

(3) years preceding January 9, 2019. 

~ 

so 

Case 0:20-cv-60931-RAR Document 1-2 Entered on FLSD Docket 05/08/2020 Page 26 of 27
I HEREBY CERTIFY that a true and correct copy of the foregoing Request for 

Production is being served with the Complaint upon the Defendant. 

BODDEN & BENNETT LAW GROUP 

Attorneys for the Plaintiff 

1880 North Congress Avenue, #401 

Boynton Beach, FL 33426 

Telephone: (561)806-5229 

Facsimile: (561)806-5244 

Desig. Email: IittawCcD_boddenbennettlaw.com 

By:/s/ Carlos A. Bodden 

Carlos A. Bodden, Esq. 

Florida Bar No.: 093343 

W. David Bennett, Esq. 

Florida Bar No.: 087746 

ME 

Case 0:20-cv-60931-RAR Document 1-2 Entered on FLSD Docket 05/08/2020 Page 27 of 27