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Filing # 173497328 E-Filed 05/18/2023 04:47:10 PM
IN THE CIRCUIT COURT, FOURTH JUDICIAL CIRCUIT
IN AND FOR DUVAL COUNTY, FLORIDA
FRANK JONES,
Plaintiff,
V. CASE NO.: 16-2022-CA-6365
JACKSONVILLE TRANSIT AUTHORITY
and JEA,
Defendants,
PLAINTIFF’S RESPONSE TO DEFENDANT’S
FIRST REQUEST TO PRODUCE
COMES NOW, Plaintiff, FRANK JONES, by and through undersigned counsel, and
hereby responds to the Defendant, JACKSONVILLE TRANSIT AUTHORITY, First Request for
Production dated March 7, 2023, as follows:
1 Plaintiff has provided copies of all medical records in his possession responsive to
Request No. 1.
Plaintiff is not in possession, custody or control of any Personal Injury Protection
claim forms. Plaintiff did not have Personal Injury Protection Coverage responsive
to Request No. 2.
Plaintiff has provided to Defendant copies of hospital records responsive to Request
No. 3.
Plaintiff has provided to Defendant copies of all medical reports related to this incident
responsive to Request No. 4.
Plaintiff is not in possession, custody or control of any written or transcribed
statements made by Plaintiff regarding this claim responsive to Request No. 5.
Plaintiff is not in possession, custody or contro! of any written or transcribed
statement of the Defendant’s agent or employces regarding this claim responsive to
Request No. 6.
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 05/21/2023 04:04:31 PM
Plaintiff is not in possession, custody or control of any photographs, video, or drawings
that depict his injuries related to this incident responsive to Request No, 7.
Plaintiff is not in possession, custody or control of any insurance policies responsive to
Request No. 8.
Plaintiff is not in possession, custody or control of any reports of experts. Experts have
not been retained responsive to Request No. 9.
10. Plaintiff has provided to Defendant-all documents in his-possession that support his claim
responsive to Request No. 10.
11 Plaintiff is not in possession, custody or control of any Tax Returns. Plaintiff has not filed
a Tax Return since before 2020 responsive to Request No. 11.
12. Plaintiff is not in possession, custody or control of any automobile repair bills, repair
estimates or rental bills for damages or loss. Plaintiff was on the city bus responsive to
Request No. 12.
13 Plaintiff has provided to Defendant copies of all collateral source documents in his
possession responsive to Request No. 13.
14 Plaintiff is not in possession, custody or control of any documents related to any prior or
subsequent accidents or incidents responsive to Request No. 14.
15 Plaintiff has provided to Defendant the pre-suit Notice of Claim letter dated August 9, 2021
responsive to Request No. 15.
16. Plaintiff is not in possession, custody or control of any itemized statements of phone
numbers for his cell phone at the time. Plaintiff is the registered account owner at Boost
Mobile for the phone number 904-742-6169 utilized at the time responsive to Request No.
16.
17, Plaintiff is not in possession, custody or control of any diaries, logs or journals from the
date of loss to present. Plaintiff did not keep a journal responsive to Request No. 17.
18 Plaintiff is not in possession, custody or control of any videotapes of the scene of the
incident responsive to Request No. 18.
19 Plaintiff is not in possession, custody or control of any videotapes of himself following this
incident responsive to Request No. 19.
20, Plaintiff has provided to Defendant a copy of his health insurance card front and back
responsive to Request No. 20.
21 Plaintiff has provided to Defendant a copy of his driver’s license front and back responsive
to Request No, 21.
22 Plaintiff is not in possession, custody or control of any policies of health insurance. Plaintiff
has provided a copy of his health insurance card front and back responsive to Request No.
22.
23 Plaintiff is not in possession, custody or control of the owner’s manual for the electric
wheelchair responsive to Request No. 23.
24 Plaintiff is notin ‘possession, custody or contro! of the electric wheelchair. Plaintiffs’
wheelchair stopped working after this incident and it was deposed of responsive to Request
No. 24,
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the above and foregoing has been furnished, by regular
US. mail delivery and/or electronic mail, this Stay of May, 2023 to Sonya Harrell, Esquire, 117
West Duval Street, Suite 480 Jacksonville, FL 32202, SonyaH@coj net; BOsburn@coj.net. Attorney
Sor Defendant.
,
Lae
Jonathan I. Rotstein, Esquire
Law Office of Rotstein, Shiffman & Broderick, LLP
309 Oakridge Bivd., Suite B
Daytona Beach, FL 32118
Florida Bar No. 909580
(386) 252-5560 / (386) 238-6999 fax (al)
Primary: L.bonner@rotstein-shiffman.com
Alternate 1: M.otto@yrotstein-shiffman.com
Alternate 2: ‘T.dallarosa@yotstein-shiffman,com
Attorney for Plaintiff
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Filing # 173497328 E-Filed 05/18/2023 04:47:10 PM IN THE CIRCUIT COURT, FOURTH JUDICIAL CIRCUIT IN AND FOR DUVAL COUNTY, FLORIDA FRANK JONES, Plaintiff, V. CASE NO.: 16-2022-CA-6365 JACKSONVILLE TRANSIT AUTHORITY and JEA, Defendants, PLAINTIFF’S RESPONSE TO DEFENDANT’S FIRST REQUEST TO PRODUCE COMES NOW, Plaintiff, FRANK JONES, by and through undersigned counsel, and hereby responds to the Defendant, JACKSONVILLE TRANSIT AUTHORITY, First Request for Production dated March 7, 2023, as follows: 1 Plaintiff has provided copies of all medical records in his possession responsive to Request No. 1. Plaintiff is not in possession, custody or control of any Personal Injury Protection claim forms. Plaintiff did not have Personal Injury Protection Coverage responsive to Request No. 2. Plaintiff has provided to Defendant copies of hospital records responsive to Request No. 3. Plaintiff has provided to Defendant copies of all medical reports related to this incident responsive to Request No. 4. Plaintiff is not in possession, custody or control of any written or transcribed statements made by Plaintiff regarding this claim responsive to Request No. 5. Plaintiff is not in possession, custody or contro! of any written or transcribed statement of the Defendant’s agent or employces regarding this claim responsive to Request No. 6. ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 05/21/2023 04:04:31 PM Plaintiff is not in possession, custody or control of any photographs, video, or drawings that depict his injuries related to this incident responsive to Request No, 7. Plaintiff is not in possession, custody or control of any insurance policies responsive to Request No. 8. Plaintiff is not in possession, custody or control of any reports of experts. Experts have not been retained responsive to Request No. 9. 10. Plaintiff has provided to Defendant-all documents in his-possession that support his claim responsive to Request No. 10. 11 Plaintiff is not in possession, custody or control of any Tax Returns. Plaintiff has not filed a Tax Return since before 2020 responsive to Request No. 11. 12. Plaintiff is not in possession, custody or control of any automobile repair bills, repair estimates or rental bills for damages or loss. Plaintiff was on the city bus responsive to Request No. 12. 13 Plaintiff has provided to Defendant copies of all collateral source documents in his possession responsive to Request No. 13. 14 Plaintiff is not in possession, custody or control of any documents related to any prior or subsequent accidents or incidents responsive to Request No. 14. 15 Plaintiff has provided to Defendant the pre-suit Notice of Claim letter dated August 9, 2021 responsive to Request No. 15. 16. Plaintiff is not in possession, custody or control of any itemized statements of phone numbers for his cell phone at the time. Plaintiff is the registered account owner at Boost Mobile for the phone number 904-742-6169 utilized at the time responsive to Request No. 16. 17, Plaintiff is not in possession, custody or control of any diaries, logs or journals from the date of loss to present. Plaintiff did not keep a journal responsive to Request No. 17. 18 Plaintiff is not in possession, custody or control of any videotapes of the scene of the incident responsive to Request No. 18. 19 Plaintiff is not in possession, custody or control of any videotapes of himself following this incident responsive to Request No. 19. 20, Plaintiff has provided to Defendant a copy of his health insurance card front and back responsive to Request No. 20. 21 Plaintiff has provided to Defendant a copy of his driver’s license front and back responsive to Request No, 21. 22 Plaintiff is not in possession, custody or control of any policies of health insurance. Plaintiff has provided a copy of his health insurance card front and back responsive to Request No. 22. 23 Plaintiff is not in possession, custody or control of the owner’s manual for the electric wheelchair responsive to Request No. 23. 24 Plaintiff is notin ‘possession, custody or contro! of the electric wheelchair. Plaintiffs’ wheelchair stopped working after this incident and it was deposed of responsive to Request No. 24, CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the above and foregoing has been furnished, by regular US. mail delivery and/or electronic mail, this Stay of May, 2023 to Sonya Harrell, Esquire, 117 West Duval Street, Suite 480 Jacksonville, FL 32202, SonyaH@coj net; BOsburn@coj.net. Attorney Sor Defendant. , Lae Jonathan I. Rotstein, Esquire Law Office of Rotstein, Shiffman & Broderick, LLP 309 Oakridge Bivd., Suite B Daytona Beach, FL 32118 Florida Bar No. 909580 (386) 252-5560 / (386) 238-6999 fax (al) Primary: L.bonner@rotstein-shiffman.com Alternate 1: M.otto@yrotstein-shiffman.com Alternate 2: ‘T.dallarosa@yotstein-shiffman,com Attorney for Plaintiff