On July 23, 2009 a
Party Discovery
was filed
involving a dispute between
Hanson, Velta,
and
Teti, Alma,
for Negligence - Other Negligence
in the District Court of Collier County.
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IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
COLLIER COUNTY, FLORIDA CIVIL ACTION
ELLIS HANSON and VELTA HANSON,
Plaintiffs,
v. Case No. 09-6515-CA
ALMA TETI, =
Defendant.
PLAINTIFF’S, ELLIS HANSON, PRIVILEGED
DOCUMENT SCHEDULE IN RESPONSE TO DEFEND.
FIRST REQUEST FOR PRODUCTION TO PLAINTIFF, ELLIS
Plaintiff, Ellis Hanson, hereby files his document schedule pursuant to Rule
1.280, Florida Rules of Civil Procedure, in response to Defendant’s, Alma Teti, First
Request for Production to Plaintiff, Ellis Hanson.
General Statement
This document schedule is provided in a good faith effort to comply with Rule
1.280, Florida Rules of Civil Procedure, as interpreted by case law. The listing of a
document or thing on this schedule shall not be deemed an admission that the document
is relevant, reasonably calculated to lead the discovery of admissible evidence, or
discoverable even if any asserted privilege is determined not to be applicable.
Privilege Identification
The documents disclosed in this Document Schedule are protected by attorney-
client privilege under Florida law.
Persons Identified
The parties referred to in this Document Schedule are as follows: Velta Hanson;
Ellis Hanson; and Todd M. Rich, Esq.
If it should be discovered that any particular document was shown to a person
not identified, then Ellis Hanson reserves the right to assert any privilege with respect to
such disclosure.
seyndwog ul! pails
NDINVY ‘VVDocument Number Date Description Privilege
EVH000023- Undated | Communications between Velta Attorney-
EVH000024 Hanson on behalf of Velta Hanson and | client
Ellis Hanson to Todd M. Rich privilege
EVH000025- Undated | Communications between Velta Attorney-
EVH000026 Hanson on behalf of Velta Hanson and | client
Ellis Hanson to Todd M. Rich privilege
Inadvertent Disclosure
There is no intention to disclose any privileged material or documents. If
privileged material or documents are included with the material or documents produced,
please return all such materials and documents to us without retaining any copies. The
inadvertent inclusion of any privileged material or documents shall not be deemed a
waiver of the privilege specific to the material and documents, or the subject matter to the
material and documents.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished by facsimile and U.S. mail to D. Keith Wickenden, Esq., Grant, Fridkin,
Pearson, Athan & Crown, P.A., 5551 Ridgewood Drive, Suite 501, Naples, Florida 34108
on this 4th day of November, 2009.
Coleman, Yovanovich & Koester, P.A.
wor (Law rE— TD
Todd M. Rich
Florida Bar No. 51451
Edmond E. Koester
Florida Bar No. 87882
4001 Tamiami Trail North, Suite 300
Naples, FL 34103
239.435.3535
239.435.1218 Facsimile
Attorneys for Ellis and Velta Hanson
\aVv
Document Filed Date
November 06, 2009
Case Filing Date
July 23, 2009
Category
Negligence - Other Negligence
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® ® . | IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA CIVIL ACTION ELLIS HANSON and VELTA HANSON, Plaintiffs, v. Case No. 09-6515-CA ALMA TETI, = Defendant. PLAINTIFF’S, ELLIS HANSON, PRIVILEGED DOCUMENT SCHEDULE IN RESPONSE TO DEFEND. FIRST REQUEST FOR PRODUCTION TO PLAINTIFF, ELLIS Plaintiff, Ellis Hanson, hereby files his document schedule pursuant to Rule 1.280, Florida Rules of Civil Procedure, in response to Defendant’s, Alma Teti, First Request for Production to Plaintiff, Ellis Hanson. General Statement This document schedule is provided in a good faith effort to comply with Rule 1.280, Florida Rules of Civil Procedure, as interpreted by case law. The listing of a document or thing on this schedule shall not be deemed an admission that the document is relevant, reasonably calculated to lead the discovery of admissible evidence, or discoverable even if any asserted privilege is determined not to be applicable. Privilege Identification The documents disclosed in this Document Schedule are protected by attorney- client privilege under Florida law. Persons Identified The parties referred to in this Document Schedule are as follows: Velta Hanson; Ellis Hanson; and Todd M. Rich, Esq. If it should be discovered that any particular document was shown to a person not identified, then Ellis Hanson reserves the right to assert any privilege with respect to such disclosure. seyndwog ul! pails NDINVY ‘VVDocument Number Date Description Privilege EVH000023- Undated | Communications between Velta Attorney- EVH000024 Hanson on behalf of Velta Hanson and | client Ellis Hanson to Todd M. Rich privilege EVH000025- Undated | Communications between Velta Attorney- EVH000026 Hanson on behalf of Velta Hanson and | client Ellis Hanson to Todd M. Rich privilege Inadvertent Disclosure There is no intention to disclose any privileged material or documents. If privileged material or documents are included with the material or documents produced, please return all such materials and documents to us without retaining any copies. The inadvertent inclusion of any privileged material or documents shall not be deemed a waiver of the privilege specific to the material and documents, or the subject matter to the material and documents. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by facsimile and U.S. mail to D. Keith Wickenden, Esq., Grant, Fridkin, Pearson, Athan & Crown, P.A., 5551 Ridgewood Drive, Suite 501, Naples, Florida 34108 on this 4th day of November, 2009. Coleman, Yovanovich & Koester, P.A. wor (Law rE— TD Todd M. Rich Florida Bar No. 51451 Edmond E. Koester Florida Bar No. 87882 4001 Tamiami Trail North, Suite 300 Naples, FL 34103 239.435.3535 239.435.1218 Facsimile Attorneys for Ellis and Velta Hanson \aVv