[System]
You are a lawyer with 10 years of experience. Based on the complaint, create up to 20 questions for the defendant.

The questions should follow the format and style of this example response to a car accident complaint:
1. All photographs, diagrams, or other printed or written material describing or attempting to describe the scene of the accident alleged in the Complaint, or any person described in the Complaint.
2. Documentation substantiating health insurance coverage available to Plaintiff on the date of the accident sued upon.
3. Any cellular phones or other mobile communication system telephone bills, invoices, statements, itemized accounts, or other data compilation for the equipment owned or used by Plaintiffs for the months relevant to the incident.
4. Any and all films, diagnostic tests, MRIs, X-rays, storage devices, digital images, intra-operative photographs, and/or data compilations from which information can be obtained.
5. If a claim is made for lost wages and/or loss of earning capacity in the future, provide specific documentation like Federal Income Tax Returns and W-2 Forms.

Be specific, detailed and relevant to the complaint's allegations. Avoid generic requests for "all documents" or "all evidence". Each question should request specific items, time periods, or information directly related to the complaint's claims.

[User] **IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT** **IN AND FOR PALM BEACH COUNTY, FLORIDA** SARAH SMITH, Plaintiff, v. JUSTIN STAER, VALENTINA PARRISH, and ACE AMERICAN INSURANCE COMPANY, Defendants. ________________________________________/ **COMPLAINT AND DEMAND FOR JURY TRIAL** Plaintiff, SARAH SMITH, by and through undersigned counsel, sue the Defendants, JUSTIN STAER, VALENTINA PARRISH, and ACE AMERICAN INSURANCE COMPANY, as grounds thereof, states as follows: **PARTIES, JURISDICTION AND VENUE** This is an action for damages that exceeds the sum of FIFTY THOUSAND DOLLARS ($50, 000. 00), exclusive of costs, interest, and attorneys’ fees (The estimated value of Plaintiff’s claim is in excess of the minimum jurisdictional threshold required by this Court). Accordingly, Plaintiff has entered “$50, 001” in the civil cover sheet for the “estimated amount of the claim” as required in the preamble to the civil cover sheet for jurisdictional purposes only (the Florida Supreme Court has ordered that the estimated “amount of claim” be set forth in the civil cover sheet for data collection and clerical purposes only). The actual value of Plaintiff’s claim will be determined by a fair and just jury in accordance with Article 1, Section 21, Fla. Const. At all times material hereto and at the time of the incident complained of, Plaintiff, SARAH SMITH (hereinafter “Plaintiff”), was a resident of Broward County, Florida, and was otherwise sui juris. Page | 1 ----- At all times material hereto and at the time of the incident complained of, the Defendants, JUSTIN STAER (hereinafter “STAER”), and VALENTINA PARRISH (hereinafter “PARRISH”), were residents of Palm Beach County, Florida and were otherwise sui juris. At all times material hereto and at the time of the incident complained of, Defendant, ACE AMERICAN INSURANCE COMPANY (hereinafter “ACE AMERICAN”) was and is an insurance company authorized to do business in the State of Florida and was so doing. The subject matter that forms the basis this Complaint in occurred in Palm Beach County, Florida; therefore, venue is proper. **GENERAL ALLEGATIONS** At all times material hereto and at the time of the incident complained of, Defendants, STAER, and PARRISH, were the registered owners, who controlled and maintained a 2015 Chevrolet Silverado K1500 LT, bearing Florida Tag No. Y94NRK, (hereinafter “2015 Chevy Truck”). At all times material hereto and at the time of the incident complained of the Plaintiff operated a 2022 Ford E350 Utility Vehicle, bearing Florida Tag No. MIM93N (hereinafter “2022 Ford” or “vehicle”). At all times material hereto, and at the time of the incident complained of, Defendant, ACE AMERICAN, issued an automobile insurance policy, bearing policy number: ISAH25562434 (hereinafter “policy”) which insured the 2022 Ford that Plaintiff operated. At all times material hereto, and at the time of the incident complained of, the policy which Defendant, ACE AMERICAN, issued provided for uninsured/underinsured motorist benefits coverage, among other coverages, which was in full force and effect by virtue of payment of the policy premiums. Page | 2 ----- On November 30, 2022, Defendant, STAER, operated the 2015 Chevy Truck, while traveling on West Drive, from the intersection of Okeechobee Boulevard, in unincorporated Palm Beach County, Florida, when he crashed into the 2022 Ford that Plaintiff operated, causing the motor vehicle accident to occur (referred to throughout the instant Complaint as “the crash”). As a result of the crash, the Plaintiff sustained serious and permanent injuries and damages as described below. Plaintiff has complied with all conditions precedent to the filing of this action have been satisfied, met, and/or waived, regarding the policy issued by Defendant, ACE AMERICAN, which insured the 2022 Ford. **COUNT I** **PLAINTIFF’S NEGLIGENCE CLAIM AGAINST** **DEFENDANT, JUSTIN STAER** Plaintiff, reavers and adopts all allegations contained in paragraphs 1 through 12 as though more fully set forth herein, and further states as follows: At the time of the crash, Defendant, STAER, owed a duty of care to the Plaintiff to operate the 2015 Chevy Truck in a safe and prudent manner; to maintain a proper lookout; to maintain control of the 2015 Chevy Truck; to obey all traffic regulations; and to maintain a safe distance between the 2015 Chevy Truck and the vehicle that Plaintiff operated. At the time of the crash, Defendant, STAER while operating the 2015 Chevy Truck breached his duty of care by crashing into the vehicle that Plaintiff operated, causing Plaintiff to sustain serious and permanent injuries and damages. As a direct and proximate result of the Defendant, STAER’s negligence, Plaintiff suffered bodily injuries and damages, and resulting pain and suffering, disability, disfigurement, mental anguish, scarring, loss of capacity for the enjoyment of life, medical treatment and care, Page | 3 ----- future cost of medical treatment and care, loss of earnings, loss of ability to earn money in the future, property damage and/or aggravation of a previously existing condition. The losses and damages are either permanent or continuing, and they will suffer such losses in the future. WHEREFORE, Plaintiff, SARAH SMITH, demands judgment against the Defendant, JUSTIN STAER, for damages that exceeds Fifty Thousand Dollars ($50, 000. 00), taxable costs, pre-judgment interest, attorney’s fees and any other such relief to which the Plaintiff may be entitled. The Plaintiff further demands a trial by jury of all issues so triable. **COUNT II** **PLAINTIFF’S VICARIOUS LIABILITY CLAIM AGAINST** **DEFENDANT, VALENTINA PARRISH** _(Doctrine of Dangerous Instrumentality)_ Plaintiff reavers and adopts all allegations contained in Paragraphs 1 through 12 as though more fully set forth herein, and further states as follows: At the time of the crash, Defendant, PARRISH, was the legal co-owner of the 2015 Chevy Truck that Defendant, STAER, operated. At the time of the crash, Defendant, STAER, operated the 2015 Chevy Truck with the complete permission and full consent of Defendant, PARRISH. At the time of the crash, Defendant, PARRISH, by and through Defendant, STAER, owed a duty of care to the Plaintiff to operate the 2015 Chevy Truck in a safe and prudent manner; to maintain a proper lookout; to maintain control of the 2015 Chevy Truck; to obey all traffic regulations; and to maintain a safe distance between the 2015 Chevy Truck, and Plaintiff’s 2015 Chevy Truck. At the time of the crash, Defendant, STAER, while operating the 2015 Chevy Truck breached his duty of care by crashing into the vehicle that Plaintiff operated, causing Plaintiff’s serious and permanent injuries and damages. Page | 4 ----- As a direct and proximate result of the negligence of Defendant, STAER, Plaintiff suffered bodily injuries and damages, resulting pain and suffering, disability, disfigurement, mental anguish, scarring, loss of capacity for the enjoyment of life, medical treatment and care, future cost of medical treatment and care, loss of earnings, loss of ability to earn money in the future, property damage and/or aggravation of a previously existing condition. The losses and damages are either permanent or continuing, and they will suffer such losses in the future. WHEREFORE, Plaintiff, SARAH SMITH, demands judgment against the Defendant, VALENTINA PARRISH, for damages that exceeds Fifty Thousand Dollars ($50, 000. 00), taxable costs, pre-judgment interest, attorney’s fees and any other such relief to which the Plaintiff may be entitled. Plaintiff further demands trial by jury. **COUNT III** **PLAINTIFF’S UNINSURED/UNDERINSURED MOTORIST CLAIM AGAINST** **DEFENDANT, ACE AMERICAN INSURANCE COMPANY** Plaintiff reavers and adopts all allegations contained in paragraphs 1 through 12, as though more fully set forth herein, and further states: The policy issued by Defendant, ACE AMERICAN, provided uninsured/underinsured motorist coverage (hereinafter “UM”). On theof the crash, and pursuant to the policy language, Plaintiff was considered a “covered person” as more fully defined in the terms and conditions of the subject insurance company issued by Defendant, ACE AMERICAN. On theof the crash, Defendants, STAER and PARRISH were either uninsured, and/or underinsured, based upon the value of Plaintiff’s personal injury damages. Plaintiff has brought this cause of action, pursuant to the terms and conditions of the policy issued by Defendant, ACE AMERICAN, which provides for payment of compensatory Page | 5 ----- damages for bodily injuries that Plaintiff sustained and is legally entitled to recover under the policy. As a result of Defendants, STAER, and PARRISH’s negligence, Plaintiff, sustained permanent injuries and damages which are permanent and/or continuing in nature. Plaintiff and Defendant, ACE AMERICAN, have been unable to agree on the value of Plaintiff’s compensatory damages, which Plaintiff further contends should include pain, suffering, and mental anguish, since Plaintiff has suffered serious and permanent injuries and damages. Therefore, Plaintiff brings this action to determine the value of the damages and to obtain the UM benefits available from Defendant, ACE AMERICAN. WHEREFORE, Plaintiff, SARAH SMITH, demands judgment against Defendant, ACE AMERICAN INSURANCE COMPANY, for the compensatory damages for which he is entitled to under the policy, in an amount that exceeds Fifty Thousand Dollars ($50, 000. 00) and no/cents, plus interest and costs, and any such other relief the Court may deem just and proper. Plaintiff further demands a trial by jury all of issues so triable. **CERTIFICATE OF SERVICE** I HEREBY CERTIFY that the foregoing has been electronically filed with Florida’s Court E-Filing Portal on March 23, 2023. **LONG, JEAN & WECHSLER, P. A. ** Attorneys for Plaintiff 1937 E. Atlantic Blvd. , #205 Pompano Beach, FL 33060 Phone: (954) 597-6770 pleadings@ljwlegal. com (designated service email) [lyle@ljwlegal. com](mailto:lyle@ljwlegal. com) [renee@ljwlegal. com](mailto:renee@ljwlegal. com) By: /s/ Lyle R. Long Lyle R. Long, Esq. Florida Bar No. 101740 Page | 6 -----

[Assistant] IN THE CIRCUIT COURT OF THE 15[th] JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA SARAH SMITH, Plaintiff, v. JUSTIN STAER, VALENTINA PARRISH, and ACE AMERICAN INSURANCE COMPANY, Defendants. ____________________________________/ **FIRST REQUEST TO PRODUCE TO DEFENDANT, ** **ACE AMERICAN INSURANCE COMPANY** The Plaintiff, SARAH SMITH, by and through undersigned counsel, and files this First Request for Production, directed to Defendant, ACE AMERICAN INSURANCE COMPANY, pursuant to Florida Rules of Civil Procedure, Rule 1. 350, and requests said Defendant respond in accordance with Rule 1. 350 and produce the following items: **INSTRUCTIONS AND DEFINITIONS** a) The Responding Party, “Defendant” and "you" mean Defendant, ACE AMERICAN INSURANCE COMPANY, its agents, consultants, representatives, employees, servants, and all other persons acting or purporting to act on its behalf or under the responding party's control. b) The term "possession, custody and/or control" refers to ACE AMERICAN INSURANCE COMPANY's possession, custody and/or control and ACE AMERICAN INSURANCE COMPANY 's consultants, representatives, employees, servants and all other persons acting or its behalf. c) In the event a response includes any person(s) or entity different from the Responding Party of, please indicate the identity of such person or entity. d) Document means each and every document, as defined by Fla. R. Civ. P. 1. 340, in the possession, custody or control of the Responding Party, however and by whomever prepared, produced, reproduced, disseminated, or made, in any form, wherever located, whether a ----- copy, draft or original, including, but not limited to, the following: letters, minutes, correspondence, notes or summaries of conversation, inter and intra office memoranda, contracts, agreements, desk calendars, appointment books, diaries, books, manuals, bulletins, circulars, catalogs, charts, transcripts, reports, studies, evaluations, analyses, graphs, worksheets, notices, notes, notebooks, journals, statistical records, maps, surveys, drawings, blueprints, sketches, data sheets, data compilations, computer data sheets, photographs, movie film, video tape, sound recordings, microfilm, microfiche and any other written, printed, typed, recorded or graphic matter from which information can be obtained or can be translated through detection devices in a reasonably usable form. e) Identify and identification when used in reference to an individual person mean to state his full name, present address, if known, and his present employment position and business affiliation. When used in reference to a person other than an individual person, identify or organization, and the name, present and last known address and principal place of its business. Once any person has been identified properly, it shall be sufficient thereafter when identifying that person to state only his name. f) Identify and identification when used in reference to a document or documents mean to state the, the author (or, if different, the signor or signors), the address, type of document (e. g. , letter, memorandum, telegram, chart, sketch, or diagram) and any other means of identifying with sufficient particularity to meet the requirements for its inclusion in a request for production of documents pursuant to Fla. R. Civ. P. 1. 350. If any such document was but no longer is in possession or subject to control, state what disposition was made of it and the reason for that disposition. In lieu of identifying any document, a true and correct copy may be annexed to and incorporated herein. If any document has already been furnished to the Plaintiff, only one reference to it is necessary to enable the Plaintiff to identify it. g) The term "communication" means each and every disclosure, transfer or exchange of information, whether oral or in writing, and whether in person, by telephone, by mail or otherwise, including, but not limited to, discussions, statements, negotiations, inquiries, requests, notices, responses, demands or complaints. h) The term "crash" refers to the motor vehicle accident that occurred on November 30, 2022, in Palm Beach Gardens, Palm Beach County, Florida as more fully described in Plaintiff’s complaint. i) The term "and/or" shall be construed conjunctively or disjunctively as necessary to make the Request for Production inclusive rather than exclusive. j) The term "any and all” shall be considered to include each and every item requested. k) If you do not clearly understand, or have any questions about, these definitions or instructions, please have your attorney contact undersigned counsel promptly for clarification. ----- l) The term "policy" or "insurance policy" shall include any and all policies of insurance issued by ACE AMERICAN INSURANCE COMPANY, which were in full force and effect on November 30, 2022. m) The term "policy of insurance" refers to the complete policy including all endorsements, declaration's page, and exclusions and contract thereof. ----- **PLAINTIFF’S FIRST REQUEST TO PRODUCE** Any and all statements, whether written, taped or videotaped or otherwise taken from Plaintiff. Any and all statements, whether written, taped or videotaped taken from any person or potential witness regarding the facts of this lawsuit. All insurance policies, including liability, excess, umbrella, uninsured/under insured, and the like, including the declaration page or face sheet showing the dollar limits of coverage for all policy(ies) of insurance, that cover or that may cover damages sustained by the Plaintiff in the subject accident as described in the Plaintiff’s complaint. Any and all photographs in the possession, custody and/or control of this Defendant, its agents, servants and/or attorneys, depicting the property damage to all motor vehicles involved in the subject accident; the occurrence of the subject accident; the scene of the subject accident and/or the intersection scene of the subject accident; the Plaintiff; street view or aerial view where the subject accident occurred; and any other photographs in your possession, custody and/or control relating to all subject matter set forth in the Plaintiff’s complaint. Any and all medical records showing that Plaintiff suffered from any preexisting injuries of any kind. Any and all letters sent to or received from the Plaintiff or Plaintiff's representative regarding the subject accident; Plaintiff’s uninsured motorist claim; Plaintiff’s personal injury protection claim; and any other subject matter in connection with the subject accident as described in Plaintiff’s complaint. Any and all documents of any kind that you contend must be filled out or completed as a condition precedent to perfecting an uninsured/under insured motorist claim or to bringing this lawsuit. Any and all property damage estimates, valuation reports, supplemental property damage estimates, bills, invoices, and photographs showing the extent of damage to the any of the motor vehicles involved in the subject accident. All documents regarding any prior or subsequent losses or claims made by Plaintiff in the possession custody, and/or control of Defendant. Any and all surveillance photographs, movies, video, and any other type of electronic data which depicts the Plaintiff performing any type of activity subsequent to theof the subject accident. (If claiming work product, please provide a privilege log pursuant to Florida Rules of Civil Procedure, Rule 1. 280, and please provide the name ----- of the surveillance company or individual retained to perform surveillance, and alls that surveillance was conducted). Any and all reports prepared by a retainer individual that the Defendant may rely upon during the litigation of this case. (If claiming work product, please provide a privilege log pursuant to Florida Rules of Civil Procedure, Rule 1. 280 and include the name of the expert retained, the subject upon which the expert was retained for, and thethat the work was performed). All crash data documents and/or electronic digital data files, that were retrieved or anyone on your behalf, after the occurrence of the subject accident for the vehicle operated by Plaintiff at the time of the crash. Copies of all independent medical examination reports which the Defendant has received in connection with Plaintiff's uninsured/underinsured motorist claim. The Defendant's uninsured/underinsured motorist claim file, which is not work product or privilege, such as the adjusters’ daily activity sheets, correspondence, status sheets, status ups, and any other discoverable materials under Florida Rules of Civil Procedure, Rule 1. 350 and Rule 1. 280. Any and all tangible evidence, material and document used in preparation of the valuation of the Plaintiff's uninsured/underinsured claim upon any offer communicated by Defendant, its agents, employees, and representatives, which sent to Plaintiff and/or Plaintiff’s attorneys prior to the filing of the instant lawsuit. Any other documents whatsoever referred to in Defendant's Answers to Interrogatories which have not been produced in your responses herein. Color photographs of any vehicle involved in the subject accident. All incident reports, crash reports, police reports, CAD reports, body cam videos obtained from the policing authorities, and any other documents or materials which describes and/or memorializes the occurrence of the subject accident. All documents reflecting any settlement with any other person, firm or corporation arising out of the subject accident. All reports made by, for, or on behalf of any expert witness employed by the Defendant, his attorneys, or other representatives, and which such opinions relate in any way to the subject accident. All documents obtained during Defendant’s asset investigation into SARAH SMITH. All documents obtained during Defendant’s investigation into SARAH SMITH’s financial health. ----- **CERTIFICATE OF SERVICE** WE HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon the Defendant along with the Complaint and Summons. **LONG, JEAN & WECHSLER, P. A. ** **Attorneys for Plaintiff** 1937 East Atlantic Boulevard, Suite 205 Pompano Beach, FL 33060 Phone: (954) 597-6770 Fax: (954) 691-3906 Email: lyle@ljwlegal. com By: **_/s/ Lyle R. Long______** LYLE R. LONG, ESQ. Florida Bar No. 101740 Service email: pleadings@ljwlegal. com -----