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Filing # 120794810 E-Filed 02/04/2021 08:09:57 AM
IN THE CIRCUIT COURT, FOURTH
JUDICIAL CIRCUIT, IN AND FOR
DUVAL COUNTY, FLORIDA
CASE NO. 2020-CA-6698
DIVISION CV-F
LEISA JONES and MIA GRAHAM,
Plaintiffs,
vs.
JOHN MORRISEY; C&K TRUCKING, LLC;
and PROGRESSIVE SELECT INSURANCE
COMPANY,
Defendants.
DEFENDANT C&K TRUCKING, LLC’S FIRST REQUEST TO PRODUCE
TO PLAINTIFF LEISA JONES
TO: Plaintiff Leisa Jones
c/o Jeffrey L. Gadd, Esq.
FARAH & FARAH, P.A.
1534 Kingsley Avenue
Orange Park, Florida 32073
Primary: jgadd@farahandfarah.com
Secondary email: myanko@farahandfarah.com
Defendant, C&K Trucking, LLC, requests that Plaintiff, Leisa Jones, produce the following
documents for inspection, copying, or photographing at the offices of CARR ALLISON, within
thirty (30) days from the date hereof:
1 All medical and hospital bills, including prescription bills, claimed to have been
incurred as a result of the injuries or conditions sustained in this cause by Plaintiff.
2 All claim forms or medical reports submitted on Plaintiffs behalf under medical
payments or personal injury protection coverage of any insurance policy.
3. All hospital records for hospitalizations which resulted from the incident described
in the Complaint.
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 02/04/2021 10:45:30 AM
4. All medical reports, opinions, records and any other written documents from
doctors, nurses, other medical practitioners, or other expert witnesses, relating to the evaluation
and/or treatment of Plaintiff's injuries or conditions allegedly received in the incident described in
the Complaint.
5. All “letters of protection” or the substantial equivalent, which have been entered
into between Plaintiff and/or Plaintiff's attorney and any health care provider.
6 All documents, reports, records, receipts, statements, notes, memoranda, and
other similar documents, which support or document the amount of loss allegedly sustained from
inability or diminished ability to earn a living as a result of the incident described in the Complaint.
7 Copies of all income tax returns filed by Plaintiff, jointly or individually, for the three
tax years immediately prior to the date of the incident, and all income tax returns filed subsequent
to the date of the incident, together with records of Plaintiff's earnings to date during this period.
8 All models, plats, maps, drawings, motion pictures, videotapes, and photographs
depicting Plaintiffs claimed damages, the scene of the incident described in the Complaint, the
occurrence of the incident, or any other fact or issue relevant to the allegations in the Complaint.
9. Copies of all statements, written or recorded, of any witness to the incident.
10. Any documents evidencing payment of medical bills or lost earnings by collateral
sources.
11. All bills, statements or receipts relating to any non-medical expenses claimed as
damages in this lawsuit.
12. Copies of Social Security computer printout reflecting the name and address of
each employer who has ever withheld Social Security payments from the earnings of Plaintiff.
13. Copies of your Social Security disability file.
14. If you have ever served in the military, please identify which branch and provide
copies of all documents, including but not limited to enlistment, separation, medical, duty rosters,
and all other documents reflecting any military and/or VA records.
15. Copies of all documents reflecting any workers’ compensation claim and/or injury
you have reported, filed, or otherwise made known to any employer.
16. If Plaintiff was covered under a group health policy at the time of the incident
alleged in the Complaint, a copy of the health insurance card.
17. If Plaintiff has ever applied for unemployment benefits, a copy of any application
or documents submitted for unemployment benefits upon which Plaintiffs based her claim for
benefits.
18. If Plaintiff has ever applied for disability benefits, copies of all documents submitted
to and received from any third party for disability benefits.
19. A legible copy of your motor vehicle driver's license and a copy of your social
security card.
20. Copies of all documents reflecting or evidencing any claimed losses, injuries,
conditions, or damages as a result of the incident described in the Complaint.
21. For each social networking account listed in response to the interrogatories, please
provide copies or screenshots of all photographs and videos of the Plaintiff associated with that
account, including those posted by others and/or those in which the Plaintiff has been “tagged”
by others, during the two (2) years prior to the date of loss.
22. For each social networking account listed in the Interrogatories, provide copies or
screenshots of all photographs and videos of the Plaintiff associated with that account, including
those posted by others and/or those in which the Plaintiff has been “tagged” by others, from the
date of loss to present.
23. For each cellular phone listed in the Interrogatories, please provide copies or
screenshots of all photographs associated with that account during the two years prior to the date
of loss.
24. For each cellular phone listed in response to the Interrogatories, please provide
copies or screenshots of all photographs associated with that account from the date of loss to
present.
25. For each cellular phone listed in the Interrogatories, please provide copies or
screenshots of the data from all fitness, health, or tracking applications associated with that
account/phone during the two years prior to the date of loss.
26. For each cellular phone listed in the Interrogatories, please provide copies or
screenshots of the data from all fitness, health, or tracking applications associated with that
account/phone from the date of loss to present.
27. For each cellular phone listed in the Interrogatories, please provide copies of any
documentation outlining what calls were made or received on the date of loss.
28. All incident reports filed by Plaintiff for any purpose, including, but not limited to,
reports to her employer(s) and/or insurance company regarding the incident, if applicable, or any
other reports filled out by Plaintiff, which relate to the incident giving rise to this action.
29. Any and all correspondence whereby the provider of any collateral sources was
sent by certified registered mail notifying of Plaintiff's intent to claim damages from a tortfeasor.
30. Any and all documentation to include copies of the pleadings, responses to
interrogatories, responses to request for production, deposition transcripts, releases and/or
judgments involving Plaintiff from any other legal proceeding in which Plaintiff claimed personal
injuries.
31. All statements not protected by the attorney-client privilege, including but not
limited to, recorded telephone interviews, tapes, written statements, whether signed or unsigned,
of Plaintiff, or any of her agents, servants or employees relative to the incident and any other
issue which involves the instant litigation.
32. Any and all documents received from the provider of collateral sources,
specifically, Defendant requests copies of statements asserting the collateral source provider's
tight to payment of collateral source benefits and right of subrogation or reimbursement,
notification by the provider of collateral sources that no right of subrogation or reimbursement
exists for the collateral sources paid, and/or notification by the collateral source provider of its
intent to waive right of subrogation or reimbursement.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that on this 4th day of February, 2021, | electronically filed the
foregoing with the Florida Courts E-Filing Portal, which will serve it on the following counsel of
record via electronic mail:
Jeffrey L. Gadd, Esq.
FARAH & FARAH, P.A.
1534 Kingsley Avenue
Orange Park, Florida 32073
Primary: jgadd@farahandfarah.com
Secondary email: myanko@farahandfarah.com
Attorneys for Plaintiffs
/s/ L. Johnson Sarber, Ill
L. Johnson Sarber, III
Florida Bar No. 0104116
C. H. Houston, III
Florida Bar No. 100268
CARR ALLISON
The Greenleaf and Crosby Building
208 North Laura Street, Suite 1100
Jacksonville, Florida 32202
Telephone: (904) 328-6456
Facsimile: (904) 328-6473
Email: jsarber@carrallison.com
Email: chhouston@carrallison.com
Secondary Email: asparks@carrallison.com
Secondary Email: aabrown@carrallison.com
Attorneys for Defendant C&K Trucking, LLC
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Filing # 120794810 E-Filed 02/04/2021 08:09:57 AM IN THE CIRCUIT COURT, FOURTH JUDICIAL CIRCUIT, IN AND FOR DUVAL COUNTY, FLORIDA CASE NO. 2020-CA-6698 DIVISION CV-F LEISA JONES and MIA GRAHAM, Plaintiffs, vs. JOHN MORRISEY; C&K TRUCKING, LLC; and PROGRESSIVE SELECT INSURANCE COMPANY, Defendants. DEFENDANT C&K TRUCKING, LLC’S FIRST REQUEST TO PRODUCE TO PLAINTIFF LEISA JONES TO: Plaintiff Leisa Jones c/o Jeffrey L. Gadd, Esq. FARAH & FARAH, P.A. 1534 Kingsley Avenue Orange Park, Florida 32073 Primary: jgadd@farahandfarah.com Secondary email: myanko@farahandfarah.com Defendant, C&K Trucking, LLC, requests that Plaintiff, Leisa Jones, produce the following documents for inspection, copying, or photographing at the offices of CARR ALLISON, within thirty (30) days from the date hereof: 1 All medical and hospital bills, including prescription bills, claimed to have been incurred as a result of the injuries or conditions sustained in this cause by Plaintiff. 2 All claim forms or medical reports submitted on Plaintiffs behalf under medical payments or personal injury protection coverage of any insurance policy. 3. All hospital records for hospitalizations which resulted from the incident described in the Complaint. ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 02/04/2021 10:45:30 AM 4. All medical reports, opinions, records and any other written documents from doctors, nurses, other medical practitioners, or other expert witnesses, relating to the evaluation and/or treatment of Plaintiff's injuries or conditions allegedly received in the incident described in the Complaint. 5. All “letters of protection” or the substantial equivalent, which have been entered into between Plaintiff and/or Plaintiff's attorney and any health care provider. 6 All documents, reports, records, receipts, statements, notes, memoranda, and other similar documents, which support or document the amount of loss allegedly sustained from inability or diminished ability to earn a living as a result of the incident described in the Complaint. 7 Copies of all income tax returns filed by Plaintiff, jointly or individually, for the three tax years immediately prior to the date of the incident, and all income tax returns filed subsequent to the date of the incident, together with records of Plaintiff's earnings to date during this period. 8 All models, plats, maps, drawings, motion pictures, videotapes, and photographs depicting Plaintiffs claimed damages, the scene of the incident described in the Complaint, the occurrence of the incident, or any other fact or issue relevant to the allegations in the Complaint. 9. Copies of all statements, written or recorded, of any witness to the incident. 10. Any documents evidencing payment of medical bills or lost earnings by collateral sources. 11. All bills, statements or receipts relating to any non-medical expenses claimed as damages in this lawsuit. 12. Copies of Social Security computer printout reflecting the name and address of each employer who has ever withheld Social Security payments from the earnings of Plaintiff. 13. Copies of your Social Security disability file. 14. If you have ever served in the military, please identify which branch and provide copies of all documents, including but not limited to enlistment, separation, medical, duty rosters, and all other documents reflecting any military and/or VA records. 15. Copies of all documents reflecting any workers’ compensation claim and/or injury you have reported, filed, or otherwise made known to any employer. 16. If Plaintiff was covered under a group health policy at the time of the incident alleged in the Complaint, a copy of the health insurance card. 17. If Plaintiff has ever applied for unemployment benefits, a copy of any application or documents submitted for unemployment benefits upon which Plaintiffs based her claim for benefits. 18. If Plaintiff has ever applied for disability benefits, copies of all documents submitted to and received from any third party for disability benefits. 19. A legible copy of your motor vehicle driver's license and a copy of your social security card. 20. Copies of all documents reflecting or evidencing any claimed losses, injuries, conditions, or damages as a result of the incident described in the Complaint. 21. For each social networking account listed in response to the interrogatories, please provide copies or screenshots of all photographs and videos of the Plaintiff associated with that account, including those posted by others and/or those in which the Plaintiff has been “tagged” by others, during the two (2) years prior to the date of loss. 22. For each social networking account listed in the Interrogatories, provide copies or screenshots of all photographs and videos of the Plaintiff associated with that account, including those posted by others and/or those in which the Plaintiff has been “tagged” by others, from the date of loss to present. 23. For each cellular phone listed in the Interrogatories, please provide copies or screenshots of all photographs associated with that account during the two years prior to the date of loss. 24. For each cellular phone listed in response to the Interrogatories, please provide copies or screenshots of all photographs associated with that account from the date of loss to present. 25. For each cellular phone listed in the Interrogatories, please provide copies or screenshots of the data from all fitness, health, or tracking applications associated with that account/phone during the two years prior to the date of loss. 26. For each cellular phone listed in the Interrogatories, please provide copies or screenshots of the data from all fitness, health, or tracking applications associated with that account/phone from the date of loss to present. 27. For each cellular phone listed in the Interrogatories, please provide copies of any documentation outlining what calls were made or received on the date of loss. 28. All incident reports filed by Plaintiff for any purpose, including, but not limited to, reports to her employer(s) and/or insurance company regarding the incident, if applicable, or any other reports filled out by Plaintiff, which relate to the incident giving rise to this action. 29. Any and all correspondence whereby the provider of any collateral sources was sent by certified registered mail notifying of Plaintiff's intent to claim damages from a tortfeasor. 30. Any and all documentation to include copies of the pleadings, responses to interrogatories, responses to request for production, deposition transcripts, releases and/or judgments involving Plaintiff from any other legal proceeding in which Plaintiff claimed personal injuries. 31. All statements not protected by the attorney-client privilege, including but not limited to, recorded telephone interviews, tapes, written statements, whether signed or unsigned, of Plaintiff, or any of her agents, servants or employees relative to the incident and any other issue which involves the instant litigation. 32. Any and all documents received from the provider of collateral sources, specifically, Defendant requests copies of statements asserting the collateral source provider's tight to payment of collateral source benefits and right of subrogation or reimbursement, notification by the provider of collateral sources that no right of subrogation or reimbursement exists for the collateral sources paid, and/or notification by the collateral source provider of its intent to waive right of subrogation or reimbursement. CERTIFICATE OF SERVICE | HEREBY CERTIFY that on this 4th day of February, 2021, | electronically filed the foregoing with the Florida Courts E-Filing Portal, which will serve it on the following counsel of record via electronic mail: Jeffrey L. Gadd, Esq. FARAH & FARAH, P.A. 1534 Kingsley Avenue Orange Park, Florida 32073 Primary: jgadd@farahandfarah.com Secondary email: myanko@farahandfarah.com Attorneys for Plaintiffs /s/ L. Johnson Sarber, Ill L. Johnson Sarber, III Florida Bar No. 0104116 C. H. Houston, III Florida Bar No. 100268 CARR ALLISON The Greenleaf and Crosby Building 208 North Laura Street, Suite 1100 Jacksonville, Florida 32202 Telephone: (904) 328-6456 Facsimile: (904) 328-6473 Email: jsarber@carrallison.com Email: chhouston@carrallison.com Secondary Email: asparks@carrallison.com Secondary Email: aabrown@carrallison.com Attorneys for Defendant C&K Trucking, LLC