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Plaintiff’s Demand for Identification, Production and Inspection of Documents and Other
Tangible Things--Driscoll
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DAVID G. WOTTON SBN 172882
Maiolo Campbell & Wotton
235 East Washington Street
Petaluma, CA 94952
Telephone: (707) 799-1400
Facsimile: (707) 799-1411
Attorney for Plaintiff(s)
IZABELLA DANIELLI
SUPERIOR COURT OF THE STATE OF CALIFORNIA, COUNTY OF SONOMA
IZABELLA DANIELLI,
Plaintiff,
vs.
NORMANDY MEATS, LLC, et al.,
Defendants
Case No.: 2875
PLAINTIFF’S DEMAND FOR
IDENTIFICATION, PRODUCTION AND
INSPECTION OF DOCUMENTS AND
OTHER TANGIBLE THINGS TO
DEFENDANT
DANTE DRISCOLL
PROPOUNDING PARTIES: Plaintiff IZABELLA DANIELLI
RESPONDING PARTY: Defendant DANTE DRISCOLL
SET NUMBER: ONE
Plaintiff IZABELLA DANIELLI hereby demands, pursuant to Code Civ. Proc.,
§2013.010, that defendant DANTE DRISCOLL produce the following documents for inspection
and/or copying at the law office of David G. Wotton, 235 East Washington Street
Petaluma, CA 94952.

2. 2
Plaintiff’s Demand for Identification, Production and Inspection of Documents and Other
Tangible Things--Driscoll
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DEFINITIONS
1. “INCIDENT” refers to the collision on April 25, 2013 in Santa Rosa, CA, where
Stony Point Road intersects with West College Ave., which is the subject matter of
plaintiff’s complaint herein.
2. “VEHICLE” refers to the vehicle that DANTE DRISCOLL was operating at the time
of the INCIDENT. In this case, the vehicle in question was a white Normandy Meats
tractor-trailer delivery truck.
3. “YOU” and/or “YOUR” includes you, your agents, your employees, your insurance
companies, their agents, their employees, your attorneys, your accountants, your
investigators, and anyone else acting on your or their behalf.
DEMANDS
1. All statements, in any form, of persons who witnessed or claim to have witnessed the
subject INCIDENT that do not reflect an attorney’s impressions, conclusions,
opinions, theories, or legal research, together with the name, address, and telephone
number of each such witness.
2. As to each statement requested in No. 1 above and not produced, please provide a
privilege log specifying whether the statement is written or recorded, the name and
address of each witness, the date each statement was obtained, and the name and
address of each person conducting the interview.
3. All statements, in any form, of persons who have knowledge of the facts leading up to
the subject INCIDENT and/or knowledge of facts pertaining to the issues of the
subject litigation that do not reflect an attorney’s impressions, conclusions, opinions,
theories.

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Plaintiff’s Demand for Identification, Production and Inspection of Documents and Other
Tangible Things--Driscoll
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4. As to each statement requested in No. 3 above and not produced, please provide a
privilege log specifying whether the statement is written or recorded, the name and
address of each witness, the date each statement was obtained, and the name and
address of each person conducting the interview.
5. Any drawings, diagrams, photos, or videos of the scene and/or vehicles.
6. Any driver’s licenses, certificates, or special training that YOU possessed at the time
of the INCIDENT.
The above listed documents and other tangible things shall be produced for inspection
and copying at the law offices of Maiolo Campbell & Wotton, 235 East Washington Street,
Petaluma, CA on February 26, 2014.
DATED: February 20, 2014 _________________________________
DAVID G. WOTTON
Attorney for Plaintiff(s)