On October 31, 2017 a
Party Discovery
was filed
involving a dispute between
Cornelison, Joyce,
and
Heuyes, Kyle,
Wal-Mart Stores, Inc.,
for Circuit Civil
in the District Court of St. Lucie County.
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Filing # 68278274 E-Filed 02/21/2018 03:47:33 PM
IN THE CIRCUIT OUT OF THE 19TH
JUDICIAL CIRCUIT IN AND FOR ST.
LUCIE COUNTY, FLORIDA
CASE NO.: 2017 CA 001743
JOYCE CORNELISON,
Plaintiff,
Vv.
WAL-MART STORES, INC. and KYLE
HEUYES,
Defendant.
/
DEFENDANT’S PRIVILEGE LOG
Defendant, WALMART STORES, INC., by and through the undersigned counsel,
hereby files its privilege log in support of the objections raised in Defendant’s Answers
to Interrogatories and Response to Request for Production to the initial discovery
propounded upon Defendant along with the Summons and Complaint.
Document(s) Description
Claims file Report created by internal claims management personnel
containing opinions, mental impressions, and conclusions relating
to the accident prepared in anticipation of litigation.
Incident reports Prepared by Wal-Mart employees containing opinions, mental
impressions, and conclusions relating to accident prepared in
anticipation of litigation.
Document log Notes created by claims personnel containing opinions,
notes conclusions, and mental impressions relating to case prepared in
anticipation of litigation.
Investigation Information collected by internal claims management personnel in
performed by anticipation of litigation.
internal claims
handlersCase No.: 2017 CA 001743
Statement of Karl | Prepared by Wal-Mart employees containing opinions, mental
Gable impressions, and conclusions relating to accident prepared in
anticipation of litigation.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that on February 21, 2018, the foregoing was
electronically filed with the Clerk of the Court by using the Florida Courts e-Filing Portal.
It is further certified that a true and correct copy of the foregoing has been furnished via
e-mail to: Chad Hastings, Esquire, Lesser, Lesser, Landy & Smith, PLLC, 101
Northpoint Parkway, West Palm Beach, FL 33407; chastings@lesserlawfirm.com;
jpaz@lesserlawfirm.com; Imckee@lesserlawfirm.com
By: Samuel S. Lewis
Samuel S. Lewis, Esq.
Florida Bar No.: 380261
Marlow Adler Abrams Newman & Lewis
4000 Ponce de Leon Bivd., Suite 570
Coral Gables, FL 33146
Telephone (305)460-6520
(305) 446-3667 Facsimile
E-Mail: slewis@marlowadler.com
jrenwick@marlowadler.com
Attorneys for Wal-Mart Stores, Inc.
20f2
Document Filed Date
February 21, 2018
Case Filing Date
October 31, 2017
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Filing # 68278274 E-Filed 02/21/2018 03:47:33 PM IN THE CIRCUIT OUT OF THE 19TH JUDICIAL CIRCUIT IN AND FOR ST. LUCIE COUNTY, FLORIDA CASE NO.: 2017 CA 001743 JOYCE CORNELISON, Plaintiff, Vv. WAL-MART STORES, INC. and KYLE HEUYES, Defendant. / DEFENDANT’S PRIVILEGE LOG Defendant, WALMART STORES, INC., by and through the undersigned counsel, hereby files its privilege log in support of the objections raised in Defendant’s Answers to Interrogatories and Response to Request for Production to the initial discovery propounded upon Defendant along with the Summons and Complaint. Document(s) Description Claims file Report created by internal claims management personnel containing opinions, mental impressions, and conclusions relating to the accident prepared in anticipation of litigation. Incident reports Prepared by Wal-Mart employees containing opinions, mental impressions, and conclusions relating to accident prepared in anticipation of litigation. Document log Notes created by claims personnel containing opinions, notes conclusions, and mental impressions relating to case prepared in anticipation of litigation. Investigation Information collected by internal claims management personnel in performed by anticipation of litigation. internal claims handlersCase No.: 2017 CA 001743 Statement of Karl | Prepared by Wal-Mart employees containing opinions, mental Gable impressions, and conclusions relating to accident prepared in anticipation of litigation. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that on February 21, 2018, the foregoing was electronically filed with the Clerk of the Court by using the Florida Courts e-Filing Portal. It is further certified that a true and correct copy of the foregoing has been furnished via e-mail to: Chad Hastings, Esquire, Lesser, Lesser, Landy & Smith, PLLC, 101 Northpoint Parkway, West Palm Beach, FL 33407; chastings@lesserlawfirm.com; jpaz@lesserlawfirm.com; Imckee@lesserlawfirm.com By: Samuel S. Lewis Samuel S. Lewis, Esq. Florida Bar No.: 380261 Marlow Adler Abrams Newman & Lewis 4000 Ponce de Leon Bivd., Suite 570 Coral Gables, FL 33146 Telephone (305)460-6520 (305) 446-3667 Facsimile E-Mail: slewis@marlowadler.com jrenwick@marlowadler.com Attorneys for Wal-Mart Stores, Inc. 20f2