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Filing # 102653041 E-Filed 02/03/2020 02:52:35 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
ROBENSON HILAIRE,
Plaintiff,
wv
CASE NO: CACE19025818 (04)
ROBERT JACKSON and PROGRESSIVE CIVIL DIVISION
SELECT INSURANCE COMPANY,
Defendants.
/
DEFENDANT'S RESPONSES TO PLAINTIFF'S REQUEST FOR PRODUCTION
Defendant, PROGRESSIVE SELECT INSURANCE, by and through the undersigned
attorney, files Defendant's Responses to Plaintiff's Request for Production served with Complaint,
and would state as follows:
1. See Dec Page attached.
2. See Plaintiff recorded statement attached.
3. Objection, vague, overbroad, work product and/or attorney-client privilege. Subject
to and without waiving said objections, none other that Plaintiff statement at this time.
4. Objection, vague, overbroad, work product and/or attorney-client privilege. Subject
to and without waiving said objections, see attached for vehicle photographs.
5. Objection, vague, overbroad, work product and/or attorney-client privilege. Subject
to and without waiving said objections, see attached for police report.
6. Objection. Work product. Notwithstanding its objection and without waiver of
same, none at this time.
7. Undetermined at this time. Any and all trial exhibits will be disclosed at the
appropriate time pursuant to this Court’s trial order.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/03/2020 02:52:36 PM.****8.
9.
10.
Case No: CACE19025818 (04)
None other than what Plaintiff provided.
None other than what Plaintiff provided.
None at this time. Any and all expert reports will be disclosed at the appropriate
time pursuant to this Court’s trial order.
11.
Objection. Work product. Witnesses, exhibits, experts and pertinent trial materials
will be disclosed in accordance with the Court’s Trial Order.
12.
13.
14.
15.
16.
17.
18.
19.
None in this Defendants possession.
None in this Defendants possession.
None in this Defendants possession.
None in this Defendants possession.
None in this Defendants possession.
None in this Defendants possession.
None in this Defendants possession.
Objection; overbroad, burdensome, harassing and not reasonably calculated to lead
to admissible evidence.
20.
21.
22.
23.
24.
25.
Not applicable
Not applicable.
Not applicable.
Objection, duplicative. See attached.
See attached.
Objection, vague, overbroad, work product and/or attorney-client privilege. Subject
to and without waiving said objections, see attached for repair estimate.
26.
Objection; overbroad, burdensome, harassing and not reasonably calculated to lead
to admissible evidence.
27.
None in this Defendants possessionCase No: CACE19025818 (04)
28. None in this Defendants possession.
29. None in this Defendants possession.
30. Objection. Work product. Notwithstanding its objection and without waiver of
same, none at this time. Disclosure of surveillance, if obtained, will be disclosed in accordance
with the Court’s Trial Order.
31. None in this Defendants possession.
32. None in this Defendants possession.
33. None in this Defendants possession.
34. None.
35. Objection; overbroad, irrelevant, burdensome and not reasonably calculated to lead
to admissible evidence; also this information is not properly discoverable by Plaintiff.
36. Not applicable.
37. Not applicable.
38. Not applicable.
39. Not applicable.
40. Not applicable.
41. Not applicable.
42. Not applicable.
43. Not applicable.
44. Objection, work product. Notwithstanding its objection and without waiver of
same, none.
45. Objection, work product. Notwithstanding its objection and without waiver of
same, none.
46. Not applicable.
47. None in this Defendants possession.Case No: CACE19025818 (04)
48. None in this Defendants possession.
49. Not applicable.
50. Not applicable.
51. Not applicable.
52. Objection; overbroad, burdensome, harassing and not reasonably calculated to lead
to admissible evidence.
CERTIFICATE OF SERVICE
I] HEREBY CERTIFY that a true and correct copy of the above and foregoing has been
furnished via E-Mail on February 3, 2020 to Rachel Moore, Esquire, Steinger, Greene & Feiner,
PA, Attorney for Plaintiff, Robenson Hilaire,
rmoore@injurylawyers.com;acox@injurylawyers.com;fmercado@injurylawyers.com, (954) 491-
7701/(954) 634-8304 (F).
Law Offices of Michael W. Carroll
Attorneys for Defendant
3230 West Commercial Blvd., Suite 400
Fort Lauderdale, FL 33309
(954) 903-6543 (Asst.)/(954) 903-6564 (Direct)
Fax: (866) 841-8921
SERVICE DESIGNATIONS:
Primary: FtLauderdaleHC@Progressive.com
Secondary: CFranzol@Progressive.com
iy
CHRISTOPHER FRANZOI, ESQUIRE
Florida Bar No. 122179
“Salaried Employees of Progressive Casualty Insurance Company”
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Filing # 102653041 E-Filed 02/03/2020 02:52:35 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA ROBENSON HILAIRE, Plaintiff, wv CASE NO: CACE19025818 (04) ROBERT JACKSON and PROGRESSIVE CIVIL DIVISION SELECT INSURANCE COMPANY, Defendants. / DEFENDANT'S RESPONSES TO PLAINTIFF'S REQUEST FOR PRODUCTION Defendant, PROGRESSIVE SELECT INSURANCE, by and through the undersigned attorney, files Defendant's Responses to Plaintiff's Request for Production served with Complaint, and would state as follows: 1. See Dec Page attached. 2. See Plaintiff recorded statement attached. 3. Objection, vague, overbroad, work product and/or attorney-client privilege. Subject to and without waiving said objections, none other that Plaintiff statement at this time. 4. Objection, vague, overbroad, work product and/or attorney-client privilege. Subject to and without waiving said objections, see attached for vehicle photographs. 5. Objection, vague, overbroad, work product and/or attorney-client privilege. Subject to and without waiving said objections, see attached for police report. 6. Objection. Work product. Notwithstanding its objection and without waiver of same, none at this time. 7. Undetermined at this time. Any and all trial exhibits will be disclosed at the appropriate time pursuant to this Court’s trial order. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/03/2020 02:52:36 PM.****8. 9. 10. Case No: CACE19025818 (04) None other than what Plaintiff provided. None other than what Plaintiff provided. None at this time. Any and all expert reports will be disclosed at the appropriate time pursuant to this Court’s trial order. 11. Objection. Work product. Witnesses, exhibits, experts and pertinent trial materials will be disclosed in accordance with the Court’s Trial Order. 12. 13. 14. 15. 16. 17. 18. 19. None in this Defendants possession. None in this Defendants possession. None in this Defendants possession. None in this Defendants possession. None in this Defendants possession. None in this Defendants possession. None in this Defendants possession. Objection; overbroad, burdensome, harassing and not reasonably calculated to lead to admissible evidence. 20. 21. 22. 23. 24. 25. Not applicable Not applicable. Not applicable. Objection, duplicative. See attached. See attached. Objection, vague, overbroad, work product and/or attorney-client privilege. Subject to and without waiving said objections, see attached for repair estimate. 26. Objection; overbroad, burdensome, harassing and not reasonably calculated to lead to admissible evidence. 27. None in this Defendants possessionCase No: CACE19025818 (04) 28. None in this Defendants possession. 29. None in this Defendants possession. 30. Objection. Work product. Notwithstanding its objection and without waiver of same, none at this time. Disclosure of surveillance, if obtained, will be disclosed in accordance with the Court’s Trial Order. 31. None in this Defendants possession. 32. None in this Defendants possession. 33. None in this Defendants possession. 34. None. 35. Objection; overbroad, irrelevant, burdensome and not reasonably calculated to lead to admissible evidence; also this information is not properly discoverable by Plaintiff. 36. Not applicable. 37. Not applicable. 38. Not applicable. 39. Not applicable. 40. Not applicable. 41. Not applicable. 42. Not applicable. 43. Not applicable. 44. Objection, work product. Notwithstanding its objection and without waiver of same, none. 45. Objection, work product. Notwithstanding its objection and without waiver of same, none. 46. Not applicable. 47. None in this Defendants possession.Case No: CACE19025818 (04) 48. None in this Defendants possession. 49. Not applicable. 50. Not applicable. 51. Not applicable. 52. Objection; overbroad, burdensome, harassing and not reasonably calculated to lead to admissible evidence. CERTIFICATE OF SERVICE I] HEREBY CERTIFY that a true and correct copy of the above and foregoing has been furnished via E-Mail on February 3, 2020 to Rachel Moore, Esquire, Steinger, Greene & Feiner, PA, Attorney for Plaintiff, Robenson Hilaire, rmoore@injurylawyers.com;acox@injurylawyers.com;fmercado@injurylawyers.com, (954) 491- 7701/(954) 634-8304 (F). Law Offices of Michael W. Carroll Attorneys for Defendant 3230 West Commercial Blvd., Suite 400 Fort Lauderdale, FL 33309 (954) 903-6543 (Asst.)/(954) 903-6564 (Direct) Fax: (866) 841-8921 SERVICE DESIGNATIONS: Primary: FtLauderdaleHC@Progressive.com Secondary: CFranzol@Progressive.com iy CHRISTOPHER FRANZOI, ESQUIRE Florida Bar No. 122179 “Salaried Employees of Progressive Casualty Insurance Company”