On December 28, 2022 a
Party Discovery
was filed
involving a dispute between
Sabrina Abid,
and
Layla Bahabri,
Murie Bahabri,
Progressive American Insurance Company,
for Other Negligence - Other
in the District Court of Duval County.
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Filing # 169507986 E-Filed 03/23/2023 03:56:07 PM
IN THE CIRCUIT COURT, IN AND
FOR THE FOURTH JUDICIAL
CIRCUIT, DUVAL COUNTY,
FLORIDA.
CASE NO.: 2023. CA 000017
DIVISION: CV-B
SABRINA ABID,
Plaintiff,
Vv.
PROGRESSIVE AMERICAN INSURANCE COMPANY,
a foreign for profit corporation, MURIE BAHABRI,
an individual, and LAYLA BAHABRI, an individual,
Defendants.
PLAINTIFF’S RESPONSE TO DEFENDANT PROGRESSIVE’S
FIRST REQUEST FOR PRODUCTION TO PLANTIFF
Will produce tax transcripts from 2019-2021, and W-2 forms from 2018-2022.
Will be produced.
Will be produced.
Will be produced.
Will be produced.
6: Will not be produced. None in possession.
Will not be produced. None in possession
Will produce worker’s compensation records. See #1 above for income records. No
other documents in possession.
9 Will agree to sign an acceptable authorization.
10. Will be produced.
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 03/26/2023 09:42:13 AM
11. Will not be produced. None.
12. Will be produced in a timely manner when required by trial order.
13. Will be produced in a timely manner when required by trial order.
if. Will be produced.
15. Will be produced.
16. Will be produced.
17. Will not be produced. None.
18. Will be produced.
19. Will be produced.
20. Will be produced.
21. Will be produced.
22. Will be produced.
23. Will be produced.
CERTIFICATE OF SERVICE
1 HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
to Carr Allison, Jennifer A. Sullivan ESQ., 305 South Gadsden Street Tallahassee, Florida
32301, via e-mail delivery to jsullivan@carrallison.com, mcampbell@carrallison.com, and
shavers@carrallison.com on thiso-S day of March 2023.
KULIK LAW FIRM, P.A.
Robert F. Kulik, Esquire
Florida Bar No.: 974544
554 Lomax Street
Jacksonville, Florida 32204
rfk@kuliklawfirm.com
assistant@kuliklawfirm.com
Telephone: (904) 389-1988
Facsimile: (904) 389-0882
Attorney for Plaintiffs
Document Filed Date
March 23, 2023
Case Filing Date
December 28, 2022
Category
Other Negligence - Other
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Filing # 169507986 E-Filed 03/23/2023 03:56:07 PM IN THE CIRCUIT COURT, IN AND FOR THE FOURTH JUDICIAL CIRCUIT, DUVAL COUNTY, FLORIDA. CASE NO.: 2023. CA 000017 DIVISION: CV-B SABRINA ABID, Plaintiff, Vv. PROGRESSIVE AMERICAN INSURANCE COMPANY, a foreign for profit corporation, MURIE BAHABRI, an individual, and LAYLA BAHABRI, an individual, Defendants. PLAINTIFF’S RESPONSE TO DEFENDANT PROGRESSIVE’S FIRST REQUEST FOR PRODUCTION TO PLANTIFF Will produce tax transcripts from 2019-2021, and W-2 forms from 2018-2022. Will be produced. Will be produced. Will be produced. Will be produced. 6: Will not be produced. None in possession. Will not be produced. None in possession Will produce worker’s compensation records. See #1 above for income records. No other documents in possession. 9 Will agree to sign an acceptable authorization. 10. Will be produced. ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 03/26/2023 09:42:13 AM 11. Will not be produced. None. 12. Will be produced in a timely manner when required by trial order. 13. Will be produced in a timely manner when required by trial order. if. Will be produced. 15. Will be produced. 16. Will be produced. 17. Will not be produced. None. 18. Will be produced. 19. Will be produced. 20. Will be produced. 21. Will be produced. 22. Will be produced. 23. Will be produced. CERTIFICATE OF SERVICE 1 HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to Carr Allison, Jennifer A. Sullivan ESQ., 305 South Gadsden Street Tallahassee, Florida 32301, via e-mail delivery to jsullivan@carrallison.com, mcampbell@carrallison.com, and shavers@carrallison.com on thiso-S day of March 2023. KULIK LAW FIRM, P.A. Robert F. Kulik, Esquire Florida Bar No.: 974544 554 Lomax Street Jacksonville, Florida 32204 rfk@kuliklawfirm.com assistant@kuliklawfirm.com Telephone: (904) 389-1988 Facsimile: (904) 389-0882 Attorney for Plaintiffs