Page 1 Filing # 92619087 E-Filed 07/16/2019 11:57:44 AM
IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE-19-EDGAR MONSERRATT, as _ Personal
Representative of THE ESTATE OF
EDGAR MONSERRATT MARTINEZ,
Deceased,
Plaintiff,
Vv.
TESLA, INC. a/k/a TESLA FLORIDA,
INC., HALSTON LOYD, JAMES BB.
RILEY, individually, JAMES B. RILEY as
the Personal Representative of THE
ESTATE OF BARRETT RILEY, Deceased,
and JR CORPORATE SERVICES GROUP
LLC, a Florida limited liability company,
Defendants.
/
PLAINTIFFS’ REQUEST FOR PRODUCTION DIRECTED TO
DEFENDANT, TESLA, INC. a/k/a TESLA FLORIDA, INC.
COMES NOW the Plaintiffs’, EDGAR MONSERRATT, as Personal Representative of
THE ESTATE OF EDGAR MONSERRATT MARTINEZ, Deceased, hereby requests the
Defendant, TESLA, INC. a/k/a TESLA FLORIDA, INC., to produce in the offices of
SCHLESINGER LAW OFFICES, P.A. 1212 Southeast Third Ave., Fort Lauderdale, Florida
33316, for inspection and copying, within the time period specified by the applicable Florida
Rules of Civil Procedure, the following:
1. Any and all policies of insurance that cover or may cover Tesla, Inc. or Tesla Florida,
Inc. for the incident alleged in the complaint.
2. Any and all written communications, including but not limited to letters, emails, faxes,
text messages, and/or instant messages, sent to or received from any party to this lawsuit,
their agents and/or employees and Elon Musk.
*k FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/16/2019 11:57:44 AM *Page 2 10.
11.
12.
13.
Any and all written communications, including but not limited to letters, emails, faxes,
text messages, and/or instant messages, sent to or received from any local/federal
governmental agency, its employees or agents, pertaining to the specific Riley owned
Tesla Model S vehicle at issue in this case.
Any and all written communications, including but not limited to letters, emails, faxes,
text messages, and/or instant messages, sent to or received from any local/federal
governmental agency, its employees or agents, pertaining to Tesla Model S vehicles.
Any and all written communications, including but not limited to letters, emails, faxes,
text messages, and/or instant messages, sent to or received from any local/federal
governmental agency, its employees or agents, pertaining to any igniting, combusting,
catching fire, and/or exploding of a Tesla vehicle.
Any and all written communications, including but not limited to letters, emails, faxes,
text messages, and/or instant messages, sent to or received from Barrett Riley or any
members of the James Riley family regarding the Tesla Model S vehicle at issue in this
case.
Any and all written communications, including but not limited to letters, emails, faxes,
text messages, and/or instant messages, sent by or received by Barrett Riley or any
members of the James Riley family regarding the Tesla Model S vehicle at issue in this
case.
Any and all written communications, including but not limited to letters, emails, faxes,
text messages, and/or instant messages, sent to or received from Barrett Riley regarding
the operation of the Tesla Model S vehicle at issue in this case.
Any and all written communications, including but not limited to letters, emails, faxes,
text messages, and/or instant messages, sent by or received by Barrett Riley or any
members of the James Riley family regarding the operation of the Tesla Model S vehicle
at issue in this case.
Any and all photographs or video recordings of the scene of the incident alleged in the
complaint.
Any and all photographs or video recordings of the vehicles involved in the incident
alleged in the complaint, whether taken prior to or after the incident on May 8, 2018.
Any and all statements, whether written or recorded, of any witness with knowledge of
any issues pertaining to this case.
Any and all written communications, including but not limited to letters, emails, faxes,
text messages, and/or instant messages, sent to or received from any witness with
knowledge of any issues pertaining to this case.Page 3 14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
Any and all maintenance or service records for the Tesla Model S vehicle at issue in this
case.
Any and all operation manuals for the Tesla Model S vehicle at issue in this case.
Any and all warnings and/or warning labels for the Tesla Model S vehicle at issue in this
case.
Any and all crash testing studies for Tesla Model S vehicles.
Any and all studies, reports, analysis, and/or testing results of the batteries utilized in
Tesla Model S vehicles.
Any and all studies, reports, analysis, and/or testing results pertaining to the risk of Tesla
Model S vehicle batteries igniting, combusting, catching fire, and/or exploding.
Any and all studies, reports, analysis, and/or testing results related to the Tesla S door
locking mechanism.
Any and all studies, reports, analysis, and/or testing results regarding any flammability
issues related to Tesla’s use of lithium ion batteries.
Any and all studies, reports, analysis, and/or testing results Tesla has regarding
intumescent material supplied to Tesla’s battery packs.
Any and all studies, reports, analysis, and/or testing results Tesla has regarding thermal
runaway.
Any and all incident reports and/or accident reports which involved any Tesla battery
igniting, combusting, catching fire, and/or exploding.
Any and all written communications, including but not limited to letters, emails, faxes,
text messages, and/or instant messages, sent by any of the Tesla-related defendants in this
lawsuit, its agents or employees, pertaining to a Tesla vehicle battery igniting,
combusting, catching fire, and/or exploding.
Any and all written communications, including but not limited to letters, emails, faxes,
text messages, and/or instant messages, sent by any of the Tesla-related defendants in this
lawsuit, its agents or employees, pertaining to thermal runaway.
Any and all alternative designs for Tesla vehicle batteries.
Any and all written communications, including but not limited to letters, emails, faxes,
text messages, and/or instant messages, sent by or received by any of the Tesla-relatedPage 4 defendants in this lawsuit, its agents or employees, pertaining to any alternative design
and/or safety feature for Tesla vehicle batteries.
29. Any and all policies, procedures, guidelines, and/or standards for the installation and/or
removal of any speed governing device for Tesla vehicles which was in effect on from
January 1, 2018 — May 8, 2018.
30. Any and all policies, procedures, guidelines, and/or standards pertaining to individuals
authorized to install and/or remove a governor or any other device which retards the
ability of a Tesla vehicle to exceed a certain speed.
31. Any and all electronically stored information obtained from the subject Tesla Model S in
this lawsuit after the incident at issue in this case.
32. Any and all information gleaned from the Tesla data responder as it related to
information uploaded into the “cloud” for all events to the Tesla in question going back
twenty-four (24) hours from 7:00 a.m. on May 8, 2018 to 7:00 a.m. May 9, 2018.
33. Any and all reports, memoranda, and/or studies generated with respect to any Tesla
vehicle’s battery igniting, combusting, catching fire, and/or exploding.
34. Any and all photos or videos either transferred to or downloaded to the “cloud” of the
Tesla S in question in this lawsuit from March 1, 2018 to and including May 8, 2018.
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been served
via electronic mail and facsimile this 16 day of July, 2019, to all parties on the attached list.
SCHLESINGER LAW OFFICES, P.A.
Attorneys for Plaintiffs
1212 SE Third Avenue
Fort Lauderdale, Florida
/s/ Zane Ber
Scott P. Schlesinger, Esq.
Florida Bar No.: scott@schlesingerlaw.com
Jonathan R. Gdanski, Esq.
Florida Bar No.: jonathan@schlesingerlaw.com
Zane Berg, Esq.
Florida Bar No.: zane(@schlesingerlaw.comPage 5 SERVICE LIST
SCOTT P. SCHLESINGER, ESQ. PHILIP HARNETT CORBOY, JR., ESQ.
JONATHAN R. GDANSKI, ESQ. CORBOY & DEMETRIO, P.C.
ZANE BERG, ESQ. 33 N. Dearborn Street
SCHLESINGER LAW OFFICES, P.A. Chicago IL
1212 Southeast Third Ave Tel: (312)346-
Fort Lauderdale FL 33316 fhce@corboydemetrio.com
Tel: (954)320-9507 Co-Counsel for Plaintiff
Fax: (954)320-
scott@schelsingerlaw.com
jonathan@schlesingerlaw.com
zane@schelsingerlaw.com
priscilla@schlesingerlaw.com
Attorneys for Plaintiff, Edgar Monserratt, as Personal Representative of The Estate
of Edgar Monserratt Martinez, Deceased
ROBERT J. RUDOCK, ESQ.
WHITNEY V. CRUZ, ESQ.
BOWMAN AND BROOKE LLP
Two Alhambra Plaza, Suite
Coral Gables, FL
Tel: (305) 995-
Fax: (305) 995-
Robert.Rudock@bowmanandbrooke.com
Whitney.Cruz@bowmanandbrooke.com
Attorneys for Defendant, Tesla, Inc. d/b/a Tesla Florida, Inc. and Halston Loyd
LAURIE A. PRIMUS, ESQ.
SELLARS, MARION & BACHI, P.A.
811 North Olive Avenue
West Palm Beach, FL
Telephone: (561) 655-
Facsimile: (561) 655-
Service email: pleadings@smb-law.com
Attorneys for Defendants, James B. Riley and JR Corporate Services Group, LLC
PDF Page 1
PlainSite Cover Page
PDF Page 2
Filing # 92619087 E-Filed 07/16/2019 11:57:44 AM
IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE-19-000422
EDGAR MONSERRATT, as _ Personal
Representative of THE ESTATE OF
EDGAR MONSERRATT MARTINEZ,
Deceased,
Plaintiff,
Vv.
TESLA, INC. a/k/a TESLA FLORIDA,
INC., HALSTON LOYD, JAMES BB.
RILEY, individually, JAMES B. RILEY as
the Personal Representative of THE
ESTATE OF BARRETT RILEY, Deceased,
and JR CORPORATE SERVICES GROUP
LLC, a Florida limited liability company,
Defendants.
/
PLAINTIFFS’ REQUEST FOR PRODUCTION DIRECTED TO
DEFENDANT, TESLA, INC. a/k/a TESLA FLORIDA, INC.
COMES NOW the Plaintiffs’, EDGAR MONSERRATT, as Personal Representative of
THE ESTATE OF EDGAR MONSERRATT MARTINEZ, Deceased, hereby requests the
Defendant, TESLA, INC. a/k/a TESLA FLORIDA, INC., to produce in the offices of
SCHLESINGER LAW OFFICES, P.A. 1212 Southeast Third Ave., Fort Lauderdale, Florida
33316, for inspection and copying, within the time period specified by the applicable Florida
Rules of Civil Procedure, the following:
1. Any and all policies of insurance that cover or may cover Tesla, Inc. or Tesla Florida,
Inc. for the incident alleged in the complaint.
2. Any and all written communications, including but not limited to letters, emails, faxes,
text messages, and/or instant messages, sent to or received from any party to this lawsuit,
their agents and/or employees and Elon Musk.
*k FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/16/2019 11:57:44 AM *
PDF Page 3
10.
11.
12.
13.
Any and all written communications, including but not limited to letters, emails, faxes,
text messages, and/or instant messages, sent to or received from any local/federal
governmental agency, its employees or agents, pertaining to the specific Riley owned
Tesla Model S vehicle at issue in this case.
Any and all written communications, including but not limited to letters, emails, faxes,
text messages, and/or instant messages, sent to or received from any local/federal
governmental agency, its employees or agents, pertaining to Tesla Model S vehicles.
Any and all written communications, including but not limited to letters, emails, faxes,
text messages, and/or instant messages, sent to or received from any local/federal
governmental agency, its employees or agents, pertaining to any igniting, combusting,
catching fire, and/or exploding of a Tesla vehicle.
Any and all written communications, including but not limited to letters, emails, faxes,
text messages, and/or instant messages, sent to or received from Barrett Riley or any
members of the James Riley family regarding the Tesla Model S vehicle at issue in this
case.
Any and all written communications, including but not limited to letters, emails, faxes,
text messages, and/or instant messages, sent by or received by Barrett Riley or any
members of the James Riley family regarding the Tesla Model S vehicle at issue in this
case.
Any and all written communications, including but not limited to letters, emails, faxes,
text messages, and/or instant messages, sent to or received from Barrett Riley regarding
the operation of the Tesla Model S vehicle at issue in this case.
Any and all written communications, including but not limited to letters, emails, faxes,
text messages, and/or instant messages, sent by or received by Barrett Riley or any
members of the James Riley family regarding the operation of the Tesla Model S vehicle
at issue in this case.
Any and all photographs or video recordings of the scene of the incident alleged in the
complaint.
Any and all photographs or video recordings of the vehicles involved in the incident
alleged in the complaint, whether taken prior to or after the incident on May 8, 2018.
Any and all statements, whether written or recorded, of any witness with knowledge of
any issues pertaining to this case.
Any and all written communications, including but not limited to letters, emails, faxes,
text messages, and/or instant messages, sent to or received from any witness with
knowledge of any issues pertaining to this case.
PDF Page 4
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
Any and all maintenance or service records for the Tesla Model S vehicle at issue in this
case.
Any and all operation manuals for the Tesla Model S vehicle at issue in this case.
Any and all warnings and/or warning labels for the Tesla Model S vehicle at issue in this
case.
Any and all crash testing studies for Tesla Model S vehicles.
Any and all studies, reports, analysis, and/or testing results of the batteries utilized in
Tesla Model S vehicles.
Any and all studies, reports, analysis, and/or testing results pertaining to the risk of Tesla
Model S vehicle batteries igniting, combusting, catching fire, and/or exploding.
Any and all studies, reports, analysis, and/or testing results related to the Tesla S door
locking mechanism.
Any and all studies, reports, analysis, and/or testing results regarding any flammability
issues related to Tesla’s use of lithium ion batteries.
Any and all studies, reports, analysis, and/or testing results Tesla has regarding
intumescent material supplied to Tesla’s battery packs.
Any and all studies, reports, analysis, and/or testing results Tesla has regarding thermal
runaway.
Any and all incident reports and/or accident reports which involved any Tesla battery
igniting, combusting, catching fire, and/or exploding.
Any and all written communications, including but not limited to letters, emails, faxes,
text messages, and/or instant messages, sent by any of the Tesla-related defendants in this
lawsuit, its agents or employees, pertaining to a Tesla vehicle battery igniting,
combusting, catching fire, and/or exploding.
Any and all written communications, including but not limited to letters, emails, faxes,
text messages, and/or instant messages, sent by any of the Tesla-related defendants in this
lawsuit, its agents or employees, pertaining to thermal runaway.
Any and all alternative designs for Tesla vehicle batteries.
Any and all written communications, including but not limited to letters, emails, faxes,
text messages, and/or instant messages, sent by or received by any of the Tesla-related
PDF Page 5
defendants in this lawsuit, its agents or employees, pertaining to any alternative design
and/or safety feature for Tesla vehicle batteries.
29. Any and all policies, procedures, guidelines, and/or standards for the installation and/or
removal of any speed governing device for Tesla vehicles which was in effect on from
January 1, 2018 — May 8, 2018.
30. Any and all policies, procedures, guidelines, and/or standards pertaining to individuals
authorized to install and/or remove a governor or any other device which retards the
ability of a Tesla vehicle to exceed a certain speed.
31. Any and all electronically stored information obtained from the subject Tesla Model S in
this lawsuit after the incident at issue in this case.
32. Any and all information gleaned from the Tesla data responder as it related to
information uploaded into the “cloud” for all events to the Tesla in question going back
twenty-four (24) hours from 7:00 a.m. on May 8, 2018 to 7:00 a.m. May 9, 2018.
33. Any and all reports, memoranda, and/or studies generated with respect to any Tesla
vehicle’s battery igniting, combusting, catching fire, and/or exploding.
34. Any and all photos or videos either transferred to or downloaded to the “cloud” of the
Tesla S in question in this lawsuit from March 1, 2018 to and including May 8, 2018.
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been served
via electronic mail and facsimile this 16 day of July, 2019, to all parties on the attached list.
SCHLESINGER LAW OFFICES, P.A.
Attorneys for Plaintiffs
1212 SE Third Avenue
Fort Lauderdale, Florida 33316
/s/ Zane Ber
Scott P. Schlesinger, Esq.
Florida Bar No.: 444952
scott@schlesingerlaw.com
Jonathan R. Gdanski, Esq.
Florida Bar No.: 0032097
jonathan@schlesingerlaw.com
Zane Berg, Esq.
Florida Bar No.: 91317
zane(@schlesingerlaw.com
PDF Page 6
SERVICE LIST
SCOTT P. SCHLESINGER, ESQ. PHILIP HARNETT CORBOY, JR., ESQ.
JONATHAN R. GDANSKI, ESQ. CORBOY & DEMETRIO, P.C.
ZANE BERG, ESQ. 33 N. Dearborn Street
SCHLESINGER LAW OFFICES, P.A. Chicago IL 60602
1212 Southeast Third Ave Tel: (312)346-3191
Fort Lauderdale FL 33316 fhce@corboydemetrio.com
Tel: (954)320-9507 Co-Counsel for Plaintiff
Fax: (954)320-9509
scott@schelsingerlaw.com
jonathan@schlesingerlaw.com
zane@schelsingerlaw.com
priscilla@schlesingerlaw.com
Attorneys for Plaintiff, Edgar Monserratt, as Personal Representative of The Estate
of Edgar Monserratt Martinez, Deceased
ROBERT J. RUDOCK, ESQ.
WHITNEY V. CRUZ, ESQ.
BOWMAN AND BROOKE LLP
Two Alhambra Plaza, Suite 800
Coral Gables, FL 33134
Tel: (305) 995-5600
Fax: (305) 995-6090
Robert.Rudock@bowmanandbrooke.com
Whitney.Cruz@bowmanandbrooke.com
Attorneys for Defendant, Tesla, Inc. d/b/a Tesla Florida, Inc. and Halston Loyd
LAURIE A. PRIMUS, ESQ.
SELLARS, MARION & BACHI, P.A.
811 North Olive Avenue
West Palm Beach, FL 33401
Telephone: (561) 655-8111
Facsimile: (561) 655-4994
Service email: pleadings@smb-law.com
Attorneys for Defendants, James B. Riley and JR Corporate Services Group, LLC
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