FlGG BRIDGE ENGINEERS, INC.,

Plaintiff,

V.

CHARLES GRANDE, EDWARD McKAY, ROGER SHARP and KEVIN STII’4NETTE,

Defendants.

The defendants, CHARLES GRANDE, EDWARD McKAY, ROGER SHARP and KEVIN STINNETTE, pursuant to Fla. R. Civ. P. 1.350, request that the plaintiff, Figg Bridge Engineers, Inc. ("Figg"), produce the following documents:

1. Every document probative of the allegation in paragraph 14 of the Complaint that the "defamatory statements made by Grande, McKay, Stinnette and Sharp were all false and either known to be false to each of them and/or made with reckless disregard for the truth or falsity of the matters asserted."

2. Every document probative of the allegation in paragraph 15 of the Complaint that Figg "has been significantly injured and damaged in its business and reputation," and has incurred damages, including, but "not limited to, loss of business and reputation in various parts of the state of Florida and elsewhere as a result of the defamatory statements of [d]efendants, Grande, McKay, Stinnette and Sharp."

3. Any and every financial statement prepared by Figg or with respect to Figg since January 1, 1997.

4. Any and every profit and loss statement prepared by Figg or with respect to Figg since January 1, 1997.

5. Any and every balance sheet prepared by Figg or with respect to Figg since January 1, 1997.

6. Any and every application for a loan, for a line of credit, for financing, or for any form of credit prepared by Figg or with respect to Figg since January 1, 1997.

7. Any and every private offering circular or memorandum prepared by Figg or with respect to Figg since January 1, 1997.

8. Every letter (or correspondence, however denominated), memorandum, or other document (including Requests for Proposals, advertisements, circulars, Invitations to Bid, or other such documents, however denominated), received by Figg, or generated by Figg, in connection with any business Figg considered doing (or project Figg considered undertaking) since January 1, 1997.

9. Every document supporting a contention that Figg has lost business as a result of the defamation alleged in this action.

10. Every document probative of the allegation in paragraph 20 of the Complaint (the allegation repeated in paragraphs 25, 30, 36,41,46, 56, 62, and 67) that Figg "is not now nor has it ever been" under "a Federal Grand Jury criminal investigation."

11. Every document probative of the allegation in paragraph 30 of the Complaint (the allegation repeated in paragraphs 36, 41, 46, 56, 62, and 67) that Figg "is not now nor has Figg ever been" under "a state criminal investigation."

12. Every document probative of the allegation in paragraph 35 of the Complaint that it is "not true" that "Figg had been fined for ‘environmental fines’ concerning the Garcon Point Bridge."

13. Any and every document that would support a finding that any defendant published any of the allegedly defamatory statements with constitutional actual malice.

14. Any and every document that would support a finding that any defendant published any of the allegedly defamatory statements with common law malice.

15. The subpoena received by Figg from the Federal Grand Jury investigating the Garcon Point Bridge project.

16. Any and every document generated by Figg in connection with, or received by Figg in connection with, the Federal Grand Jury investigation of the Garcon Point Bridge project.

17. Any and every document generated by Figg in connection with, or received by Figg in connection with, the state criminal investigation of the Garcon Point Bridge project.

18. Any and every document generated by Figg in connection with, or received by Figg in connection with, the investigation(s) done by state and/or federal regulatory agencies in connection with the Garcon Point Bridge project.

19. Any and every document, including letters or other correspondence (however denominated), memoranda, e-mails, diary entries, or other communications, received by Figg from the St. Lucie County Expressway and Bridge Authority, or any of its members or employees, or sent by Figg to the St. Lucie County Expressway and Bridge Authority, or any of its members or employees, making any reference to this lawsuit, or to any consideration of whether to bring this lawsuit.

20. Any and every document generated by Figg or received by Figg in connection with any investigation Figg has ever undertaken or caused to be undertaken of any of the defendants in this action.

I HEREBY CERTIFY that a copy of this Defendants’ First Request for Plaintiff to Produce Documents was served by fax and by U.S. Mail on October 16, 2000 upon

counsel for the plaintiff: Harold 0. Melville, Melville & Sowerby, P.L., 2940 5. ₂₅th St., Fort Pierce, FL 34981-5605.