On September 07, 2021 a
Party Discovery
was filed
involving a dispute between
Montes, Yajaira,
and
Douglas, Dennis,
Douglas, Donna,
Geico General Insurance Company,
for AUTO NEGLIGENCE - CIRCUIT
in the District Court of Pinellas County.
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Filing # 140378781 E-Filed 12/14/2021 05:08:38 PM
IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT
IN AND FOR PINELLAS COUNTY, STATE OF FLORIDA
CIVIL DIVISION
YAJAIRA MONTES,
Plaintiff,
v.
CASE NO.: 21-004236-CI-15
DONNA DOUGLAS, DENNIS DOUGLAS,
and GEICO GENERAL INSURANCE
COMPANY,
Defendants.
_____________________________________/
DEFENDANT’S RESPONSE TO
PLAINTIFF’S FIRST REQUEST TO PRODUCE
Defendant, DENNIS DOUGLAS, by and through undersigned counsel, files his
Response to the Plaintiff’s First Request for Production, served with the Complaint with
numbered paragraphs 1 through 7, as follows:
1. Defendant is requested to produce a copy of any and all statements concerning
this action or the subject matter of this action previously made by Yajaira Montes.
RESPONSE: None.
2. Defendant is requested to produce a copy of the declaration and coverage pages of
any and all policies of liability insurance providing coverage to the Defendant for claims arising
out of the accident described in the Complaint.
RESPONSE: Produced herein.
3. Defendant is requested to produce a copy of any and all policies of insurance of
any kind or nature which would provide benefits to the Plaintiff for the accident described in the
Complaint.
RESPONSE: Has been requested and will be produced upon receipt.
353696
***ELECTRONICALLY FILED 12/14/2021 05:08:37 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
4. Defendant is requested to produce copies of any and all photographs or videos
taken at the scene of the accident described in the Complaint.
RESPONSE: None.
5. Defendant is requested to produce photographs showing damages to the vehicle
that was involved in the subject of Complaint.
RESPONSE: None. The vehicle was not damaged.
6. Defendant is requested to produce repair estimates, invoices and receipts
evidencing repair or damage to the vehicle that was involved in the subject of the Complaint.
RESPONSE: None, the vehicle was not damaged.
7. Defendant is requested to produce any surveillance movies or photographs which
have been made of the Plaintiff.
RESPONSE: None presently.
*
Records are being produced on CD by regular mail this same date.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and accurate copy of the above and foregoing has been
furnished by E-Mail to Marc B. Parish, Esquire, Attorney for the Plaintiff,
(efiling@cataniaandcatania.com, Catania & Catania, P.A., 101 E. Kennedy Blvd., Suite 2400,
Tampa, FL, 33602); and Michael Wallace, Esq., Attorney for Geico, (tampageico@geico.com;
4300 W. Cypress Street, #500, Tampa, FL 33607) this 14th day of December, 2021.
By: /s/ Troy J. McRitchie
Troy J. McRitchie, Esquire
Banker Lopez Gassier P.A.
360 Central Avenue, Suite 700
St. Petersburg, FL 33701
Service-tmcritchie@bankerlopez.com
Phone: (727) 825-3600 Fax: (727) 821-1968
FBN: 0513504
Attorney for Defendants Douglas
353696
2
Document Filed Date
December 14, 2021
Case Filing Date
September 07, 2021
Category
AUTO NEGLIGENCE - CIRCUIT
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Filing # 140378781 E-Filed 12/14/2021 05:08:38 PM IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, STATE OF FLORIDA CIVIL DIVISION YAJAIRA MONTES, Plaintiff, v. CASE NO.: 21-004236-CI-15 DONNA DOUGLAS, DENNIS DOUGLAS, and GEICO GENERAL INSURANCE COMPANY, Defendants. _____________________________________/ DEFENDANT’S RESPONSE TO PLAINTIFF’S FIRST REQUEST TO PRODUCE Defendant, DENNIS DOUGLAS, by and through undersigned counsel, files his Response to the Plaintiff’s First Request for Production, served with the Complaint with numbered paragraphs 1 through 7, as follows: 1. Defendant is requested to produce a copy of any and all statements concerning this action or the subject matter of this action previously made by Yajaira Montes. RESPONSE: None. 2. Defendant is requested to produce a copy of the declaration and coverage pages of any and all policies of liability insurance providing coverage to the Defendant for claims arising out of the accident described in the Complaint. RESPONSE: Produced herein. 3. Defendant is requested to produce a copy of any and all policies of insurance of any kind or nature which would provide benefits to the Plaintiff for the accident described in the Complaint. RESPONSE: Has been requested and will be produced upon receipt. 353696 ***ELECTRONICALLY FILED 12/14/2021 05:08:37 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** 4. Defendant is requested to produce copies of any and all photographs or videos taken at the scene of the accident described in the Complaint. RESPONSE: None. 5. Defendant is requested to produce photographs showing damages to the vehicle that was involved in the subject of Complaint. RESPONSE: None. The vehicle was not damaged. 6. Defendant is requested to produce repair estimates, invoices and receipts evidencing repair or damage to the vehicle that was involved in the subject of the Complaint. RESPONSE: None, the vehicle was not damaged. 7. Defendant is requested to produce any surveillance movies or photographs which have been made of the Plaintiff. RESPONSE: None presently. * Records are being produced on CD by regular mail this same date. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and accurate copy of the above and foregoing has been furnished by E-Mail to Marc B. Parish, Esquire, Attorney for the Plaintiff, (efiling@cataniaandcatania.com, Catania & Catania, P.A., 101 E. Kennedy Blvd., Suite 2400, Tampa, FL, 33602); and Michael Wallace, Esq., Attorney for Geico, (tampageico@geico.com; 4300 W. Cypress Street, #500, Tampa, FL 33607) this 14th day of December, 2021. By: /s/ Troy J. McRitchie Troy J. McRitchie, Esquire Banker Lopez Gassier P.A. 360 Central Avenue, Suite 700 St. Petersburg, FL 33701 Service-tmcritchie@bankerlopez.com Phone: (727) 825-3600 Fax: (727) 821-1968 FBN: 0513504 Attorney for Defendants Douglas 353696 2