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Filing # 133725383 E-Filed 08/31/2021 09:33:57 AM
IN THE CIRCUIT COURT, FOURTH
JUDICIAL CIRCUIT, IN AND FOR
DUVAL COUNTY, FLORIDA
LEISA JONES; and MIA GRAHAM,
Plaintiffs,
Vs.
CASE NO: 2020-CA-6698
JOHN MORRISSEY; C&K TRUCKING, CIVIL DIVISION
LLC; and PROGRESSIVE SELECT
INSURANCE COMPANY,
Defendants.
/
DEFENDANT'S RESPONSES TO PLAINTIFFS' REQUEST FOR PRODUCTION
Defendant, PROGRESSIVE SELECT INSURANCE COMPANY, by and through the
undersigned attorney, files Defendant's Responses to Plaintiffs' Request for Production, and would
state as follows:
1 See attached.
2. See attached.
None in defendant’s possession
See response to #1 above.
Objection, work product. Without waiving said objection, see attached.
Objection, vague, overbroad, unduly burdensome, irrelevant and not reasonably
calculated to lead to the discovery of admissible evidence.
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 08/31/2021 12:46:40 PM
Case No: 2020-CA-6698
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been
furnished via E-Mail on August 31, 2021 to Jeffrey L. Gadd, Esquire, Farah & Farah, P.A.,
Attorney for Plaintiffs, Leisa J. Jones and Mia N. Graham,
jgadd@farahandfarah.com;myanko@farahandfarah.com, C. H. Houston, II, Esquire, Carr
Allison, Attorney for Co-Defendants, John Morrisey and C&K_ Trucking, LLC,
echouston@carrallison.com;asparks@carrallison.com;aabrown@carrallison.com, L Johnson
Sarber, III, Esquire, Carr Allison, Attorney for Co-Defendants, C&K Trucking, LLC and John
Morrisey, jsarber@carrallison.com;asparks@carrallison.com;aabrown@carrallison.com.
Law Office of Terryl Blackmon Walker
Attorneys for Defendant
901 N. Lake Destiny Rd., Suite 105
Maitland, FL 32751
(407) 618-8882 (Asst.)/(904) 699-8208 (Direct)
Fax: (866) 516-8617
SERVICE DESIGNATIONS:
Primary: JaxHC@progressive.com
Secondary: Michelle _L_Smith@progressive.com
hile
MICHELLE L. SMITH, ESQUIRE
Florida Bar No. 25897
“Salaried Employees of Progressive Casualty Insurance Company”
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Filing # 133725383 E-Filed 08/31/2021 09:33:57 AM IN THE CIRCUIT COURT, FOURTH JUDICIAL CIRCUIT, IN AND FOR DUVAL COUNTY, FLORIDA LEISA JONES; and MIA GRAHAM, Plaintiffs, Vs. CASE NO: 2020-CA-6698 JOHN MORRISSEY; C&K TRUCKING, CIVIL DIVISION LLC; and PROGRESSIVE SELECT INSURANCE COMPANY, Defendants. / DEFENDANT'S RESPONSES TO PLAINTIFFS' REQUEST FOR PRODUCTION Defendant, PROGRESSIVE SELECT INSURANCE COMPANY, by and through the undersigned attorney, files Defendant's Responses to Plaintiffs' Request for Production, and would state as follows: 1 See attached. 2. See attached. None in defendant’s possession See response to #1 above. Objection, work product. Without waiving said objection, see attached. Objection, vague, overbroad, unduly burdensome, irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 08/31/2021 12:46:40 PM Case No: 2020-CA-6698 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been furnished via E-Mail on August 31, 2021 to Jeffrey L. Gadd, Esquire, Farah & Farah, P.A., Attorney for Plaintiffs, Leisa J. Jones and Mia N. Graham, jgadd@farahandfarah.com;myanko@farahandfarah.com, C. H. Houston, II, Esquire, Carr Allison, Attorney for Co-Defendants, John Morrisey and C&K_ Trucking, LLC, echouston@carrallison.com;asparks@carrallison.com;aabrown@carrallison.com, L Johnson Sarber, III, Esquire, Carr Allison, Attorney for Co-Defendants, C&K Trucking, LLC and John Morrisey, jsarber@carrallison.com;asparks@carrallison.com;aabrown@carrallison.com. Law Office of Terryl Blackmon Walker Attorneys for Defendant 901 N. Lake Destiny Rd., Suite 105 Maitland, FL 32751 (407) 618-8882 (Asst.)/(904) 699-8208 (Direct) Fax: (866) 516-8617 SERVICE DESIGNATIONS: Primary: JaxHC@progressive.com Secondary: Michelle _L_Smith@progressive.com hile MICHELLE L. SMITH, ESQUIRE Florida Bar No. 25897 “Salaried Employees of Progressive Casualty Insurance Company”