On December 21, 2017 a
Party Discovery
was filed
involving a dispute between
Graziano, Anthony W,
and
Johnston, Kaylin I,
for Auto Negligence
in the District Court of Collier County.
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Filing # 69197250 E-Filed 03/13/2018 02:32:59 PM
0414803320.1 BMC
Total Pages: 3
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR COLLIER COUNTY, FLORIDA
CIVIL DIVISION
ANTHONY W. GRAZIANO, CASE NO.
2017-CA-002200
PLAINTIFF,
VS.
KAYLIN I. JOHNSTON,
DEFENDANT.
DEFENDANT’S RESPONSE TO REQUEST FOR PRODUCTION
Defendant, KAYLIN I. JOHNSTON, by and through the undersigned counsel, files this
Response to Plaintiff's, ANTHONY W. GRAZIANO, Request for Production served with the
Summons and Complaint, and would state:
1. None in Defendant’s possession.
None in Defendant’s possession.
None in Defendant’s possession.
Photographs of Plaintiff's vehicle provided this date.
None in Defendant’s possession.
None in Defendant’s possession.
None in Defendant’s possession.
Repair estimate for Plaintiffs vehicle provided this date.
CPN nM YPN
Policy provided this date.
—
S
None in Defendant’s possession.
11. Repair estimate for Plaintiff's vehicle provided this date.
12. Objection; work product and/or privileged information. Without waiving said
objection, none in Defendant’s possession.
13. Policy provided this date.
14. Objection; seeks information protected by the work product privilege. See attached
Privilege Log.
15. Objection; information requested is not reasonably calculated to lead to discovery of
admissible evidence.
FILED: COLLIER COUNTY, DWIGHT E. BROCK, CLERK, 03/13/2018 03:25:33 PMCASE NO. 2017-CA-002200
16. Not in Defendant’s possession. These materials may be acquired through non-party
production.
17. This information has been requested and will be provided upon receipt.
18. This information has been requested and will be provided upon receipt.
19. Objection; no authorization was attached.
I HEREBY CERTIFY that onthe 13" day of March , 2018,
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:
Attorney for Plaintiff
Alexander Billias, Esquire
Morgan & Morgan
3360 Pine Ridge Road, Suite 203
Naples, FL 34109
abservice@forthepeople.com
kcowhig@forthepeople.com
LAW OFFICES OF ROBERT J. SMITH
12751 New Brittany Boulevard, Suite 403
Ft. Myers, FL 33907-3694
Telephone: (239) 334-2351
Toll Free: (877) 431-2896 Ext 3342351
Attorney Direct: (239) 334-2069
Fax: (866) 303-4759
By: faxes Signed
JOSEPH DERNBACH
FL Bar No. 103274
Attorney for Defendant
KAYLIN I. JOHNSTON
PRINCIPAL E-MAIL ADDRESS:
FTMYERSLEGAL@ALLSTATE.COM
Personal E-mail Address
(NOT for Service of Pleadings and Documents):
Joseph.Dernbach@allstate.comCASE NO. 2017-CA-002200
PRIVILEGE LOG
14. ISO Claims Search obtained by Allstate Insurance company in anticipation of litigation
Case Filing Date
December 21, 2017
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Filing # 69197250 E-Filed 03/13/2018 02:32:59 PM 0414803320.1 BMC Total Pages: 3 IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA CIVIL DIVISION ANTHONY W. GRAZIANO, CASE NO. 2017-CA-002200 PLAINTIFF, VS. KAYLIN I. JOHNSTON, DEFENDANT. DEFENDANT’S RESPONSE TO REQUEST FOR PRODUCTION Defendant, KAYLIN I. JOHNSTON, by and through the undersigned counsel, files this Response to Plaintiff's, ANTHONY W. GRAZIANO, Request for Production served with the Summons and Complaint, and would state: 1. None in Defendant’s possession. None in Defendant’s possession. None in Defendant’s possession. Photographs of Plaintiff's vehicle provided this date. None in Defendant’s possession. None in Defendant’s possession. None in Defendant’s possession. Repair estimate for Plaintiffs vehicle provided this date. CPN nM YPN Policy provided this date. — S None in Defendant’s possession. 11. Repair estimate for Plaintiff's vehicle provided this date. 12. Objection; work product and/or privileged information. Without waiving said objection, none in Defendant’s possession. 13. Policy provided this date. 14. Objection; seeks information protected by the work product privilege. See attached Privilege Log. 15. Objection; information requested is not reasonably calculated to lead to discovery of admissible evidence. FILED: COLLIER COUNTY, DWIGHT E. BROCK, CLERK, 03/13/2018 03:25:33 PMCASE NO. 2017-CA-002200 16. Not in Defendant’s possession. These materials may be acquired through non-party production. 17. This information has been requested and will be provided upon receipt. 18. This information has been requested and will be provided upon receipt. 19. Objection; no authorization was attached. I HEREBY CERTIFY that onthe 13" day of March , 2018, 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: Attorney for Plaintiff Alexander Billias, Esquire Morgan & Morgan 3360 Pine Ridge Road, Suite 203 Naples, FL 34109 abservice@forthepeople.com kcowhig@forthepeople.com LAW OFFICES OF ROBERT J. SMITH 12751 New Brittany Boulevard, Suite 403 Ft. Myers, FL 33907-3694 Telephone: (239) 334-2351 Toll Free: (877) 431-2896 Ext 3342351 Attorney Direct: (239) 334-2069 Fax: (866) 303-4759 By: faxes Signed JOSEPH DERNBACH FL Bar No. 103274 Attorney for Defendant KAYLIN I. JOHNSTON PRINCIPAL E-MAIL ADDRESS: FTMYERSLEGAL@ALLSTATE.COM Personal E-mail Address (NOT for Service of Pleadings and Documents): Joseph.Dernbach@allstate.comCASE NO. 2017-CA-002200 PRIVILEGE LOG 14. ISO Claims Search obtained by Allstate Insurance company in anticipation of litigation