Party Discovery: LISA EWELL Vs. MARION CLARK

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                                Filing #     122891301 E-Filed 03/11/2021                07:53:53 AM
                  0498242718.1 OPA
                  Total Pages: 2




                                    IN THE COUNTY COURT OF THE SIXTH JUDICIAL CIRCUIT
                                               IN AND FOR PINELLAS COUNTY, FLORIDA
                                                                 CIVIL DIVISION


                  LISA EWELL,                                                      CASE NO.
                                                                                   21-000240-CI
                      PLAINTIFF,

                  VS.


                  MARION CLARK,


                      DEFENDANT.


                                 DEFENDANT'S RESPONSE TO REQUEST FOR PRODUCTION


                           Defendant,     MARION        CLARK,       by  and   through    the   undersigned     counsel,    files  this

                  Response     to Plaintiff,  LISA    EWELL,      Request    for  Production served      February     19, 2021,    and

                  would state:

                  1.       All statements,    whether written     or  recorded, which you have received           from   any witness
                  who may
                  possess knowledge which is relevant:
                  (a)      to any of the claims alleged in the Plaintiffs Complaint;

                  (b)      to any of the   damages alleged in the      Plaintiffs Complaint; and/or

                  (c)      to any of the defenses alleged in your Answer.
                  RESPONSE:          Defendant      objects    to   this   request    because     it  seeks    documents      and/or
                  information which        was
                                                 prepared in      anticipation    of litigation,   is attorney-client privileged
                  information      and    is protected     under     the  work-product        doctrine.    Statements      made     by
                  witnesses to,     and   statements     made    by   a party    or  its agents    are  non-discoverable       work-
                  product. Notwithstanding          said  objection, and by way         of privilege log the undersigned is in

                  possession     of  a  recorded     statement     from   Defendant      taken    on  April    12,  2018.   Without
                  waiving said objection, see Plaintiff's recorded statement attached.

                  2.       All  drawings,    photographs, digital      images,   and/or   video   recordings    of any   kind   which
                  may relate:
                  (a)      to any of the claims alleged in the Plaintiffs Complaint;

                  (b)      to any of the   damages alleged in the Plaintiffs Complaint;
                  (c)      to any of the defenses     alleged in your Answer;
                  (d)      to all vehicles of any kind which       were  involved in the    accident; and/or
                  (e)      to the scene of the accident.
                  Color copies of any and all photographs and/or           digital images are requested.
                  RESPONSE: See attached property damage                   photographs otherwise none.




    ***ELECTRONICALLYFILED 03/11/2021              07:53:53 AM:   KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
                  CASE NO.       21-000240-CI




                  3.       All  written   estimates,   supplemental estimates, repair        invoices,   and   other  repair records
                  which reflect the     damage    to your motor vehicle       as  a result  of the  auto   accident   alleged in   the
                  Plaintiffs Complaint.
                  RESPONSE: See attached.


                  4.       The   certificate of title   to your   motor vehicle     which    was   involved in    the  auto  accident
                  alleged in the Plaintiffs Complaint.
                  RESPONSE: See the attached             registration otherwise none.

                  5.       Any and all    traffic citations which you received from any law enforcementofficer related
                  to the auto accident alleged in the Plaintiffs Complaint.
                  RESPONSE: None in Defendant's possession.


                           I HEREBY CERTIFY that on the                 11th   day of             March            ,2021,




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                  CASE NO.       21-000240-CI




                  pursuant    to  Administrative      Order    No.   AOSC13-49,        a  copy   of   the  foregoing    Defendant's

                  Response     to Request for Production has         been electronically filed and       served using the     Florida

                  Courts E-Filing Portal to:

                  James W.    Holliday, Esquire
                  HOLLIDAY KARATINOS LAW FIRM, PLLC
                  18920 North Dale Mabry Highway, Suite 101

                  Lutz, Florida 33548
                  (813)  868-1887

                  (813)  909-8535


                  Florida Bar No. 45284

                  Attorney for Plaintiff

                                                                     LAW OFFICES OF ROBERT J. SMITH
                                                                     101 East Kennedy       Boulevard, Suite     800

                                                                     Tampa,    FL 33602-5173

                                                                     Telephone:              (813) 222-8074
                                                                     Toll Freer              (877) 886-2591 ext.     2228074
                                                                     Attorney   Direct:      (813) 226-2839
                                                                     Fax:                    (877) 420-9512


                                                                             D-MMWU
                                                                     By:
                                                                            DONNA FERRELL
                                                                            FL Bar No.     62481

                                                                            Attorney for Defendant
                                                                            MARION CLARK
                                                                            PRINCIPAL E-MAIL ADDRESS:


                                                                            Personal E-mail Address
                                                                            (NOT for Service of Pleadings and Documents):




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