On October 21, 2022 a
Party Discovery
was filed
involving a dispute between
Kevin Franklin,
and
Safeco Insurance Company Of Illinois,
for Contract and Indebtedness Division: CV-B
in the District Court of Duval County.
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Filing # 166843830 E-Filed 02/15/2023 11:40:42 AM
IN THE CIRCUIT COURT OF THE
FOURTH JUDICIAL CIRCUIT IN AND
FOR DUVAL COUNTY, FLORIDA
CASE NO: 16-2022-CA-006098-XX
KEVIN FRANKLIN,
Plaintiff,
vs.
SAFECO INSURANCE COMPANY OF ILLINOIS, a
foreign profit corporation,
Defendant.
/
SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION
Defendant, Safeco Insurance Company of Illinois, by and through the undersigned
attorneys and in accordance with Florida Rule of Civil Procedure 1.350, hereby files this
Supplemental Response to Plaintiff’s Request for Production and states as follows:
1. Any and all recorded, transcribed or written statements in any form obtained by
you or anyone else from the Plaintiff, any witnesses, or any other individual(s) pertaining to the
crash that is the subject matter of this lawsuit;
RESPONSE: Objection. The Defendant objects to this request as it seeks documents that
may be privileged under work-product or obtained in anticipation of
litigation and is not subject to discovery, the requested information is only
excluded by the protected work product if it is expected or intended to be
disclosed to the Court or jury at trial. In the event such information is to be
utilized it is to be identified and disclosed in accordance with the Trial
Court’s Order, which does not yet exist in this matter. Defendant further
objects to this request as it is overbroad in time and scope and is so broad
that it invades the attorney client and work product privileges.
Notwithstanding said objection, a copy of Plaintiff’s transcribed statement is
attached.
Case No.: 16-2022-CA-006098-XX
Franklin, Kevin v. Safeco Insurance Company of Illinois
Defendant’s Supplemental Responses to Plaintiff’s Request for Production
Page 1 of 2
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 02/15/2023 12:45:43 PM
2. Any and all documents or notes reflecting statements made by Plaintiff;
RESPONSE: Objection. The Defendant objects to this request as it seeks documents that
may be privileged under work-product or obtained in anticipation of
litigation and is not subject to discovery, the requested information is only
excluded by the protected work product if it is expected or intended to be
disclosed to the Court or jury at trial. In the event such information is to be
utilized it is to be identified and disclosed in accordance with the Trial
Court’s Order, which does not yet exist in this matter. Defendant further
objects to this request as it is overbroad in time and scope and is so broad
that it invades the attorney client and work product privileges.
Notwithstanding said objection, refer to Response to Request for Production
No. 1.
CERTIFICATE OF SERVICE
I certify that the foregoing document has been furnished to Brandi A. Gartrell, Esquire,
Morgan & Morgan, 501 Riverside Ave, Suite 1200, Jacksonville, FL 32202, Primary E-Mail:
bgartrell@forthpeople.com, Secondary E-mail: lharralson@forthepeople.com, by e-mail on this
15th day of February, 2023.
Law Offices of J. Christopher Norris
PO Box 7217
London, KY 40742
Telephone: (407) 563-3416
Attorney for Defendant, Safeco Insurance Company of Illinois
JORDAN D. BROUGHER, FBN #1036574
Primary E-mail (eservice only): OrlandoLegalMail@LibertyMutual.com
Secondary E-mail: jordan.brougher@libertymutual.com
Case No.: 16-2022-CA-006098-XX
Franklin, Kevin v. Safeco Insurance Company of Illinois
Defendant’s Supplemental Responses to Plaintiff’s Request for Production
Page 2 of 2
Document Filed Date
February 15, 2023
Case Filing Date
October 21, 2022
Category
Contract and Indebtedness Division: CV-B
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Filing # 166843830 E-Filed 02/15/2023 11:40:42 AM IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT IN AND FOR DUVAL COUNTY, FLORIDA CASE NO: 16-2022-CA-006098-XX KEVIN FRANKLIN, Plaintiff, vs. SAFECO INSURANCE COMPANY OF ILLINOIS, a foreign profit corporation, Defendant. / SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION Defendant, Safeco Insurance Company of Illinois, by and through the undersigned attorneys and in accordance with Florida Rule of Civil Procedure 1.350, hereby files this Supplemental Response to Plaintiff’s Request for Production and states as follows: 1. Any and all recorded, transcribed or written statements in any form obtained by you or anyone else from the Plaintiff, any witnesses, or any other individual(s) pertaining to the crash that is the subject matter of this lawsuit; RESPONSE: Objection. The Defendant objects to this request as it seeks documents that may be privileged under work-product or obtained in anticipation of litigation and is not subject to discovery, the requested information is only excluded by the protected work product if it is expected or intended to be disclosed to the Court or jury at trial. In the event such information is to be utilized it is to be identified and disclosed in accordance with the Trial Court’s Order, which does not yet exist in this matter. Defendant further objects to this request as it is overbroad in time and scope and is so broad that it invades the attorney client and work product privileges. Notwithstanding said objection, a copy of Plaintiff’s transcribed statement is attached. Case No.: 16-2022-CA-006098-XX Franklin, Kevin v. Safeco Insurance Company of Illinois Defendant’s Supplemental Responses to Plaintiff’s Request for Production Page 1 of 2 ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 02/15/2023 12:45:43 PM 2. Any and all documents or notes reflecting statements made by Plaintiff; RESPONSE: Objection. The Defendant objects to this request as it seeks documents that may be privileged under work-product or obtained in anticipation of litigation and is not subject to discovery, the requested information is only excluded by the protected work product if it is expected or intended to be disclosed to the Court or jury at trial. In the event such information is to be utilized it is to be identified and disclosed in accordance with the Trial Court’s Order, which does not yet exist in this matter. Defendant further objects to this request as it is overbroad in time and scope and is so broad that it invades the attorney client and work product privileges. Notwithstanding said objection, refer to Response to Request for Production No. 1. CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to Brandi A. Gartrell, Esquire, Morgan & Morgan, 501 Riverside Ave, Suite 1200, Jacksonville, FL 32202, Primary E-Mail: bgartrell@forthpeople.com, Secondary E-mail: lharralson@forthepeople.com, by e-mail on this 15th day of February, 2023. Law Offices of J. Christopher Norris PO Box 7217 London, KY 40742 Telephone: (407) 563-3416 Attorney for Defendant, Safeco Insurance Company of Illinois JORDAN D. BROUGHER, FBN #1036574 Primary E-mail (eservice only): OrlandoLegalMail@LibertyMutual.com Secondary E-mail: jordan.brougher@libertymutual.com Case No.: 16-2022-CA-006098-XX Franklin, Kevin v. Safeco Insurance Company of Illinois Defendant’s Supplemental Responses to Plaintiff’s Request for Production Page 2 of 2