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Filing # 147830902 E-Filed 04/18/2022 10:46:58 AM
IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT
IN AND FOR BREVARD COUNTY, FLORIDA
ANTHONY DAVIS, JR., Case No.: 2020-CA-024628
Plaintiff,
vs.
SECURITY FIRST INSURANCE COMPANY,
Defendant.
/
DEFENDANT’S REQUEST FOR PRODUCTION
TO PLAINTIFFS PURSUANT TO NORTHUP V ACKEN
Defendant, SECURITY FIRST INSURANCE COMPANY by and through its
undersigned counsel and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, requests
that the Plaintiff produce the documents or things designated on the attached Exhibit “A” for
inspection and copying at the offices of Quintairos, Prieto, Wood & Boyer, P.A., 1410 North
Westshore Blvd., Suite 200, Tampa, Florida 33607, or at such other place and time as may be
agreed upon by counsel. Alternatively, the Plaintiff may produce the documents identified
herein by providing legible copies of said documents to counsel for the Defendant in conjunction
with service of their written response to this Request for Production within thirty (30) days from
the date of service hereof.
This Request relates to all documents in the possession, custody or control of the Plaintiff
or any agent or other person acting or allegedly acting on the Plaintiff's behalf.
Pursuant to Rule 1.350(b) of the Florida Rules of Civil Procedure, the documents
produced for inspection pursuant to this Request shall be produced either as they are kept in the
usual course by the Plaintiff, or the Plaintiff shall organize and label the documents to
correspond with the individually numbered categories of this Request.
QUINTAIROS, PRIETO, WOOD & BOYER, P.A., ATTORNEYS AT LAW
1410 NORTH WESTSHORE BOULEVARD, SUITE 200, TAMPA, FLORIDA 33607 ¢ TEL: (813) 286-8818
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Filing 147830902 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX
DEFINITIONS AND INSTRUCTIONS
“Person” means any natural person, corporation, partnership, proprietorship, joint
venture, association, governmental entity or other legal entity.
2. “Agent” means agent, attorney, officer, director, employee or other authorized
representative.
3 “Document” means:
a. All written, printed, typed, recorded or graphic matter of every type and
description, however and by whomever prepared, produced, reproduced, disseminated or made,
in the Plaintiffs’ actual or constructive possession, custody or control, including but not limited
to, all writings, letters, minutes, bulletins, correspondence, telegrams, memoranda, notes,
instructions, literature, work assignments, notebooks, records, agreements, contracts, notations of
telephone or personal conversations or conferences, address books, interoffice communications,
receipts, microfilm, circulars, pamphlets, advertisements, catalogs, studies, notices, summaries,
reports, books, invoices, checks, bills, graphs, photographs, drafts, data sheets, data
compilations, computer data sheets, computer data compilations, work sheets, calendars,
statistics, speeches or other writings, tape recordings, transcripts of tape recordings, phonograph
records or data compilations from which information can be obtained or translated into
reasonably usable form;
b The original and all other copies not absolutely identical; and
Cc. All drafts and notes (whether typed, handwritten or otherwise) made or
prepared in connection with such documents, whether used or not.
4 “Communication” means any contact, oral or written, formal or informal, at any
time or place, under any circumstance, in any manner, whereby a statement of any nature is
QUINTAIROS, PRIETO, WOOD & BOYER, P.A., ATTORNEYS AT LAW
1410 NORTH WESTSHORE BOULEVARD, SUITE 200, TAMPA, FLORIDA 33607 ¢ TEL: (813) 286-8818
2
Filing 147830902 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX
transmitted or transferred, including any meeting or other conversation, and shall include,
without limitation, any document relating to any such contact.
5 The words “and” and “or” shall be construed conjunctively or disjunctively as
necessary to make the specific request inclusive rather than exclusive.
6. “Relating to” means referring to, reflecting, responding to, commenting upon,
recording, discussing, showing, describing, analyzing, constituting or in any way concerning.
7 The terms “you” or “your” refer to Plaintiff(s) in this action.
8 The singular form of a noun or pronoun shall be considered to include within its
meaning the plural form of the noun or pronoun so used, and vice versa; the use of a masculine
form of a pronoun shall be considered to include also within its meaning the feminine form of
the pronoun so used, and vice versa; and the use of any tense of any verb shall be considered to
include also within its meaning all other tenses of the verb so used.
9 If any document requested herein was at one time in existence and under
Plaintiff’s possession, custody or control but has been lost, discarded or destroyed or has been
removed from its possession, custody or control, then Plaintiff shall provide, with respect to each
such document, a description of the document and the date it was lost, discarded, destroyed or
removed.
10. If any document or portion thereof is or will be withheld because of a claim of
privilege or work product, state the following:
a. The basis on which the privilege is or will be claimed;
b The author or the document;
QUINTAIROS, PRIETO, WOOD & BOYER, P.A., ATTORNEYS AT LAW
1410 NORTH WESTSHORE BOULEVARD, SUITE 200, TAMPA, FLORIDA 33607 ¢ TEL: (813) 286-8818
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Filing 147830902 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX
Cc. The identity of each person to whom the document indicates the original
or a copy was sent, and any other person who at any time possessed the document
or a copy thereof.
d The date of the document;
e. The general subject matter of the document or portion thereof for which
privilege is claimed; and
f. The type of document (e.g., memorandum, report, draft, letter, etc.).
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the above and foregoing has
been furnished via Florida Court’s E-Filing Portal to: Gina Kimmel, Esq., Morgan & Morgan,
P.A. 20 N Orange Avenue, 4" Floor, Orlando, Florida at LRolon@forthepeople.com;
gkimmel@forthepeople.com, on April 18, 2022.
Quintairos, Prieto, Wood and Boyer, P.A.
/s/ Ashley Ward-Singleton
Jennifer L. Velazco, Esq. FBN: 27199
Iniv Gabay, Esq. FBN: 37487
Ashley N. Ward-Singleton, FBN: 89426
1410 North Westshore Boulevard, Suite 200
Tampa, Florida 33607
T: 813-286-8818 / F: 813-286-9998
Attorneys for Defendant
QUINTAIROS, PRIETO, WOOD & BOYER, P.A., ATTORNEYS AT LAW
1410 NORTH WESTSHORE BOULEVARD, SUITE 200, TAMPA, FLORIDA 33607 ¢ TEL: (813) 286-8818
4
Filing 147830902 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX
EXHIBIT A- DOCUME 'S TO BE PRODUCED
1 All impeachment materials that you intend to use at trial in this matter pursuant to
Northup v. Acken, M.D., 865 So.2d 1267 (Fla. 2004).
QUINTAIROS, PRIETO, WOOD & BOYER, P.A., ATTORNEYS AT LAW
1410 NORTH WESTSHORE BOULEVARD, SUITE 200, TAMPA, FLORIDA 33607 ¢ TEL: (813) 286-8818
5
Filing 147830902 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX
Preview
Filing # 147830902 E-Filed 04/18/2022 10:46:58 AM IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT IN AND FOR BREVARD COUNTY, FLORIDA ANTHONY DAVIS, JR., Case No.: 2020-CA-024628 Plaintiff, vs. SECURITY FIRST INSURANCE COMPANY, Defendant. / DEFENDANT’S REQUEST FOR PRODUCTION TO PLAINTIFFS PURSUANT TO NORTHUP V ACKEN Defendant, SECURITY FIRST INSURANCE COMPANY by and through its undersigned counsel and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, requests that the Plaintiff produce the documents or things designated on the attached Exhibit “A” for inspection and copying at the offices of Quintairos, Prieto, Wood & Boyer, P.A., 1410 North Westshore Blvd., Suite 200, Tampa, Florida 33607, or at such other place and time as may be agreed upon by counsel. Alternatively, the Plaintiff may produce the documents identified herein by providing legible copies of said documents to counsel for the Defendant in conjunction with service of their written response to this Request for Production within thirty (30) days from the date of service hereof. This Request relates to all documents in the possession, custody or control of the Plaintiff or any agent or other person acting or allegedly acting on the Plaintiff's behalf. Pursuant to Rule 1.350(b) of the Florida Rules of Civil Procedure, the documents produced for inspection pursuant to this Request shall be produced either as they are kept in the usual course by the Plaintiff, or the Plaintiff shall organize and label the documents to correspond with the individually numbered categories of this Request. QUINTAIROS, PRIETO, WOOD & BOYER, P.A., ATTORNEYS AT LAW 1410 NORTH WESTSHORE BOULEVARD, SUITE 200, TAMPA, FLORIDA 33607 ¢ TEL: (813) 286-8818 1 Filing 147830902 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX DEFINITIONS AND INSTRUCTIONS “Person” means any natural person, corporation, partnership, proprietorship, joint venture, association, governmental entity or other legal entity. 2. “Agent” means agent, attorney, officer, director, employee or other authorized representative. 3 “Document” means: a. All written, printed, typed, recorded or graphic matter of every type and description, however and by whomever prepared, produced, reproduced, disseminated or made, in the Plaintiffs’ actual or constructive possession, custody or control, including but not limited to, all writings, letters, minutes, bulletins, correspondence, telegrams, memoranda, notes, instructions, literature, work assignments, notebooks, records, agreements, contracts, notations of telephone or personal conversations or conferences, address books, interoffice communications, receipts, microfilm, circulars, pamphlets, advertisements, catalogs, studies, notices, summaries, reports, books, invoices, checks, bills, graphs, photographs, drafts, data sheets, data compilations, computer data sheets, computer data compilations, work sheets, calendars, statistics, speeches or other writings, tape recordings, transcripts of tape recordings, phonograph records or data compilations from which information can be obtained or translated into reasonably usable form; b The original and all other copies not absolutely identical; and Cc. All drafts and notes (whether typed, handwritten or otherwise) made or prepared in connection with such documents, whether used or not. 4 “Communication” means any contact, oral or written, formal or informal, at any time or place, under any circumstance, in any manner, whereby a statement of any nature is QUINTAIROS, PRIETO, WOOD & BOYER, P.A., ATTORNEYS AT LAW 1410 NORTH WESTSHORE BOULEVARD, SUITE 200, TAMPA, FLORIDA 33607 ¢ TEL: (813) 286-8818 2 Filing 147830902 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX transmitted or transferred, including any meeting or other conversation, and shall include, without limitation, any document relating to any such contact. 5 The words “and” and “or” shall be construed conjunctively or disjunctively as necessary to make the specific request inclusive rather than exclusive. 6. “Relating to” means referring to, reflecting, responding to, commenting upon, recording, discussing, showing, describing, analyzing, constituting or in any way concerning. 7 The terms “you” or “your” refer to Plaintiff(s) in this action. 8 The singular form of a noun or pronoun shall be considered to include within its meaning the plural form of the noun or pronoun so used, and vice versa; the use of a masculine form of a pronoun shall be considered to include also within its meaning the feminine form of the pronoun so used, and vice versa; and the use of any tense of any verb shall be considered to include also within its meaning all other tenses of the verb so used. 9 If any document requested herein was at one time in existence and under Plaintiff’s possession, custody or control but has been lost, discarded or destroyed or has been removed from its possession, custody or control, then Plaintiff shall provide, with respect to each such document, a description of the document and the date it was lost, discarded, destroyed or removed. 10. If any document or portion thereof is or will be withheld because of a claim of privilege or work product, state the following: a. The basis on which the privilege is or will be claimed; b The author or the document; QUINTAIROS, PRIETO, WOOD & BOYER, P.A., ATTORNEYS AT LAW 1410 NORTH WESTSHORE BOULEVARD, SUITE 200, TAMPA, FLORIDA 33607 ¢ TEL: (813) 286-8818 3 Filing 147830902 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX Cc. The identity of each person to whom the document indicates the original or a copy was sent, and any other person who at any time possessed the document or a copy thereof. d The date of the document; e. The general subject matter of the document or portion thereof for which privilege is claimed; and f. The type of document (e.g., memorandum, report, draft, letter, etc.). CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the above and foregoing has been furnished via Florida Court’s E-Filing Portal to: Gina Kimmel, Esq., Morgan & Morgan, P.A. 20 N Orange Avenue, 4" Floor, Orlando, Florida at LRolon@forthepeople.com; gkimmel@forthepeople.com, on April 18, 2022. Quintairos, Prieto, Wood and Boyer, P.A. /s/ Ashley Ward-Singleton Jennifer L. Velazco, Esq. FBN: 27199 Iniv Gabay, Esq. FBN: 37487 Ashley N. Ward-Singleton, FBN: 89426 1410 North Westshore Boulevard, Suite 200 Tampa, Florida 33607 T: 813-286-8818 / F: 813-286-9998 Attorneys for Defendant QUINTAIROS, PRIETO, WOOD & BOYER, P.A., ATTORNEYS AT LAW 1410 NORTH WESTSHORE BOULEVARD, SUITE 200, TAMPA, FLORIDA 33607 ¢ TEL: (813) 286-8818 4 Filing 147830902 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX EXHIBIT A- DOCUME 'S TO BE PRODUCED 1 All impeachment materials that you intend to use at trial in this matter pursuant to Northup v. Acken, M.D., 865 So.2d 1267 (Fla. 2004). QUINTAIROS, PRIETO, WOOD & BOYER, P.A., ATTORNEYS AT LAW 1410 NORTH WESTSHORE BOULEVARD, SUITE 200, TAMPA, FLORIDA 33607 ¢ TEL: (813) 286-8818 5 Filing 147830902 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX