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Filing# 140929758 E-Filed 12/27/2021 08:18:56 AM
In The Circuit Court Of The 17th JudicialCircuit
In And For Broward County, Florida
Selina Curtis,
Case No.: CACE21-016125 (03)
Plaintiff(s),
VS.
State Farm Florida Insurance Company,
Defendant.
PLAINTIFF' S RESPONSE TO DEFENDANT' S FIRST REQUEST FOR PRODUCTION
TO PLAINTIFF
Plaintiff hereby files their response to Defendanf s (the "Insurance Company") First
Request for Production.
Respectfullysubmitted,
The Property People FL, P.A.
Attorneysfor Plaintiffs
78 SW 7TH St,Suite 8-147
Miami FL, 33130
Telephone: 844.776.7364
E-Service:
Service@PropertyPeopleLaw.com
By: /s/ NSH
Daniel M. Ilani,Esq.
Florida Bar No. 116189
Email: Danny@PropertyPeopleLaw.com
Nicole S. Houman, Esq.
Florida Bar No. 1013527
Email: Nicole@PropertyPeopleLaw.com
Tara Khani, Esq.
Florida Bar No. 1002298
Email: Tara@PropertyPeopleLaw.com
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/27/2021 08:18:57 AM.****
PLAINTIFF' S RESPONSE TO DEFENDANT' S FIRST REQUEST FOR PRODUCTION
GENERAL OBJECTIONS
1. Plaintiffobjects
to each instruction,definition,document request, and interrogatory
to the extent
that it purports to impose any requirementor discoveryobligationgreater than or different from
those under the Federal Rules of Civil Procedure and the applicableRules and Orders ofthe Court.
2. Plaintiff objects to each document request and interrogatorythat is overly broad, unduly
burdensome, or not reasonablycalculated to lead to the discoveryof admissible evidence.
3. Plaintiff objectsto each document request to the extent that it calls for productionof a privilege
log for internal documents of Plaintiff. A request for such a log is unreasonable and unduly
burdensome in lightof the work product doctrine,governmental deliberative process privilege,
and other privilegesprotectingsuch internal documents from discovery.
4. Plaintiffobjects
to each instruction,
definition,
document request, and interrogatory
to the extent
that it seeks documents protectedfrom disclosure by the attorney-client
privilege,deliberative
process privilege,
attorney work product doctrine,or any other applicableprivilege.
Should any
such disclosure by Plaintiff occur, it is inadvertent and shall not constitute a waiver of any
privilege.
5.
Plaintiff objectsto each instruction,definition,document request, and interrogatoryas
overbroad and unduly burdensome to the extent it seeks documents or information that are readily
or more accessible to Defendant from Defendant's own files,from documents or information in
Defendant's possession,or from documents or information that Defendant previouslyproduced to
Plaintiff. Responding to such requests and interrogatory
would be oppressive,unduly burdensome,
and unnecessarilyexpensive,and the burden of responding to such requests and interrogatoryis
substantially
the same or less for Defendant as for Plaintiff. This objectionencompasses, but is not
limited to, documents and answers to interrogatories
previouslyproduced by Defendant to Plaintiff
in the course of Plaintiffs civil investigation
of Dentsply'sdistribution and marketing of artificial
teeth, all transcripts
of depositionsof employees and former employees of Defendant, all
correspondencebetween the Plaintiff and Defendant, all other information providedby Defendant
to Plaintiff,and all information produced by Plaintiff to Defendant in response to discovery
requests of Defendant. All such documents and information will not be produced.
6. Defendant's document requests and interrogatorycall for the production of documents and
information that were produced to the Plaintiffbyother entities and that may contain confidential,
proprietary,
or trade secret information.
7. To the extent any of Defendant's document requests or its interrogatoryseek documents or
answers that include expert material,includingbut not limited to survey materials,Plaintiff objects
to any such requests and interrogatory as premature and expresslyreserves the rightto supplement,
clarify,
revise,or correct any or all responses to such requests, and to assert additional objections
or privileges,
in one or more subsequent supplementalresponse(s)in accordance with the time
periodfor exchanging expert reports set by the Court.
8. Plaintiff incorporatesby reference every generalobjectionset forth above into each specific
response set forth below. A specificresponse may repeat a generalobjectionfor emphasis or some
other reason. The failure to include any generalobjectionin any specificresponse does not waive
any generalobjectionto that request. Moreover, Plaintiff does not waive its rightto amend its
responses.
OBJECTIONS AND RESPONSES TO DOCUMENT REQUESTS
1.
Any relevant documents in Plaintiff s possession and control are produced. Plaintiff
reserves the rightto amend this response as discoveryis ongoing.
2.
Any relevant documents in Plaintiff s possessionand control are produced. Plaintiff
reserves the rightto amend this response as discoveryis ongoing.
3.
Any relevant documents in Plaintiff s possession and control are produced. Plaintiff
reserves the rightto amend this response as discoveryis ongoing.
4.
Any relevant documents in Plaintiff s possessionand control are produced. Plaintiff
reserves the rightto amend this response as discoveryis ongoing.
5.
Any relevant documents in Plaintiff s possession and control are produced. Plaintiff
reserves the rightto amend this response as discoveryis ongoing.
6.
Any relevant documents in Plaintiff s possession and control are produced. Plaintiff
reserves the rightto amend this response as discoveryis ongoing.
7.
Any relevant documents in Plaintiff s possession and control are produced. Plaintiff
reserves the rightto amend this response as discoveryis ongoing.
8.
Any relevant documents in Plaintiff s possession and control are produced. Plaintiff
reserves the rightto amend this response as discoveryis ongoing.
9.
Any relevant documents in Plaintiff s possession and control are produced. Plaintiff
reserves the rightto amend this response as discoveryis ongoing.
10. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff
reserves the rightto amend this response as discoveryis ongoing.
11. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff
reserves the rightto amend this response as discoveryis ongoing.
12. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff
reserves the rightto amend this response as discoveryis ongoing.
13. Any relevant documents in Plaintiff s possessionand control are produced. Plaintiff
reserves the rightto amend this response as discoveryis ongoing.
14. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff
reserves the rightto amend this response as discoveryis ongoing.
15. Any relevant documents in Plaintiff s possessionand control are produced. Plaintiff
reserves the rightto amend this response as discoveryis ongoing.
16. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff
reserves the rightto amend this response as discoveryis ongoing.
17. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff
reserves the rightto amend this response as discoveryis ongoing.
18. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff
reserves the rightto amend this response as discoveryis ongoing.
19. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff
reserves the rightto amend this response as discoveryis ongoing.
20. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff
reserves the rightto amend this response as discoveryis ongoing.
21. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff
reserves the rightto amend this response as discoveryis ongoing.
22. Any relevant documents in Plaintiff s possessionand control are produced. Plaintiff
reserves the rightto amend this response as discoveryis ongoing.
23. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff
reserves the rightto amend this response as discoveryis ongoing.
24. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff
reserves the rightto amend this response as discoveryis ongoing.
25. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff
reserves the rightto amend this response as discoveryis ongoing.
26. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff
reserves the rightto amend this response as discoveryis ongoing.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this Deceinber 27, 2021, a true and correct copy of the
foregoinghas been furnished via electronic mail to R. Ryan Smith, Esq.,I
Preview
Filing# 140929758 E-Filed 12/27/2021 08:18:56 AM In The Circuit Court Of The 17th JudicialCircuit In And For Broward County, Florida Selina Curtis, Case No.: CACE21-016125 (03) Plaintiff(s), VS. State Farm Florida Insurance Company, Defendant. PLAINTIFF' S RESPONSE TO DEFENDANT' S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF Plaintiff hereby files their response to Defendanf s (the "Insurance Company") First Request for Production. Respectfullysubmitted, The Property People FL, P.A. Attorneysfor Plaintiffs 78 SW 7TH St,Suite 8-147 Miami FL, 33130 Telephone: 844.776.7364 E-Service: Service@PropertyPeopleLaw.com By: /s/ NSH Daniel M. Ilani,Esq. Florida Bar No. 116189 Email: Danny@PropertyPeopleLaw.com Nicole S. Houman, Esq. Florida Bar No. 1013527 Email: Nicole@PropertyPeopleLaw.com Tara Khani, Esq. Florida Bar No. 1002298 Email: Tara@PropertyPeopleLaw.com *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/27/2021 08:18:57 AM.**** PLAINTIFF' S RESPONSE TO DEFENDANT' S FIRST REQUEST FOR PRODUCTION GENERAL OBJECTIONS 1. Plaintiffobjects to each instruction,definition,document request, and interrogatory to the extent that it purports to impose any requirementor discoveryobligationgreater than or different from those under the Federal Rules of Civil Procedure and the applicableRules and Orders ofthe Court. 2. Plaintiff objects to each document request and interrogatorythat is overly broad, unduly burdensome, or not reasonablycalculated to lead to the discoveryof admissible evidence. 3. Plaintiff objectsto each document request to the extent that it calls for productionof a privilege log for internal documents of Plaintiff. A request for such a log is unreasonable and unduly burdensome in lightof the work product doctrine,governmental deliberative process privilege, and other privilegesprotectingsuch internal documents from discovery. 4. Plaintiffobjects to each instruction, definition, document request, and interrogatory to the extent that it seeks documents protectedfrom disclosure by the attorney-client privilege,deliberative process privilege, attorney work product doctrine,or any other applicableprivilege. Should any such disclosure by Plaintiff occur, it is inadvertent and shall not constitute a waiver of any privilege. 5. Plaintiff objectsto each instruction,definition,document request, and interrogatoryas overbroad and unduly burdensome to the extent it seeks documents or information that are readily or more accessible to Defendant from Defendant's own files,from documents or information in Defendant's possession,or from documents or information that Defendant previouslyproduced to Plaintiff. Responding to such requests and interrogatory would be oppressive,unduly burdensome, and unnecessarilyexpensive,and the burden of responding to such requests and interrogatoryis substantially the same or less for Defendant as for Plaintiff. This objectionencompasses, but is not limited to, documents and answers to interrogatories previouslyproduced by Defendant to Plaintiff in the course of Plaintiffs civil investigation of Dentsply'sdistribution and marketing of artificial teeth, all transcripts of depositionsof employees and former employees of Defendant, all correspondencebetween the Plaintiff and Defendant, all other information providedby Defendant to Plaintiff,and all information produced by Plaintiff to Defendant in response to discovery requests of Defendant. All such documents and information will not be produced. 6. Defendant's document requests and interrogatorycall for the production of documents and information that were produced to the Plaintiffbyother entities and that may contain confidential, proprietary, or trade secret information. 7. To the extent any of Defendant's document requests or its interrogatoryseek documents or answers that include expert material,includingbut not limited to survey materials,Plaintiff objects to any such requests and interrogatory as premature and expresslyreserves the rightto supplement, clarify, revise,or correct any or all responses to such requests, and to assert additional objections or privileges, in one or more subsequent supplementalresponse(s)in accordance with the time periodfor exchanging expert reports set by the Court. 8. Plaintiff incorporatesby reference every generalobjectionset forth above into each specific response set forth below. A specificresponse may repeat a generalobjectionfor emphasis or some other reason. The failure to include any generalobjectionin any specificresponse does not waive any generalobjectionto that request. Moreover, Plaintiff does not waive its rightto amend its responses. OBJECTIONS AND RESPONSES TO DOCUMENT REQUESTS 1. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff reserves the rightto amend this response as discoveryis ongoing. 2. Any relevant documents in Plaintiff s possessionand control are produced. Plaintiff reserves the rightto amend this response as discoveryis ongoing. 3. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff reserves the rightto amend this response as discoveryis ongoing. 4. Any relevant documents in Plaintiff s possessionand control are produced. Plaintiff reserves the rightto amend this response as discoveryis ongoing. 5. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff reserves the rightto amend this response as discoveryis ongoing. 6. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff reserves the rightto amend this response as discoveryis ongoing. 7. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff reserves the rightto amend this response as discoveryis ongoing. 8. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff reserves the rightto amend this response as discoveryis ongoing. 9. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff reserves the rightto amend this response as discoveryis ongoing. 10. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff reserves the rightto amend this response as discoveryis ongoing. 11. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff reserves the rightto amend this response as discoveryis ongoing. 12. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff reserves the rightto amend this response as discoveryis ongoing. 13. Any relevant documents in Plaintiff s possessionand control are produced. Plaintiff reserves the rightto amend this response as discoveryis ongoing. 14. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff reserves the rightto amend this response as discoveryis ongoing. 15. Any relevant documents in Plaintiff s possessionand control are produced. Plaintiff reserves the rightto amend this response as discoveryis ongoing. 16. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff reserves the rightto amend this response as discoveryis ongoing. 17. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff reserves the rightto amend this response as discoveryis ongoing. 18. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff reserves the rightto amend this response as discoveryis ongoing. 19. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff reserves the rightto amend this response as discoveryis ongoing. 20. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff reserves the rightto amend this response as discoveryis ongoing. 21. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff reserves the rightto amend this response as discoveryis ongoing. 22. Any relevant documents in Plaintiff s possessionand control are produced. Plaintiff reserves the rightto amend this response as discoveryis ongoing. 23. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff reserves the rightto amend this response as discoveryis ongoing. 24. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff reserves the rightto amend this response as discoveryis ongoing. 25. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff reserves the rightto amend this response as discoveryis ongoing. 26. Any relevant documents in Plaintiff s possession and control are produced. Plaintiff reserves the rightto amend this response as discoveryis ongoing. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this Deceinber 27, 2021, a true and correct copy of the foregoinghas been furnished via electronic mail to R. Ryan Smith, Esq.,I