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Filing # 122943547 E-Filed 03/11/2021 03:04:24 PM
IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT IN AND FOR
BREVARD COUNTY, FLORIDA
LINDA NOLAN POTTER
CASE NO.: 05-2021-CA-019085-XXXX-XX
Plaintiff
VS.
EMANUEL JACKSON, and UNITED
SERVICES AUTOMOBILE ASSOCIATION,
a foreign for-profit corporation, and
GOVERNMENT EMPLOYEES INSURANCE
COMPANY, a foreign for-profit corporation
Defendant.
/
REQUEST FOR PRODUCTION TO DEFENDANT
GOVERNMENT EMPLOYEES INSURANCE COMPANY
The Plaintiff, LINDA NOLAN POTTER, by and through the undersigned attorney,
pursuant to Florida Rules of Civil Procedure, Rule 1.350, request the Defendant, GOVERNMENT
EMPLOYEES INSURANCE COMPANY produce at the office of Gillin, Gillin & Lindbaek, P.A.,
222 N. Harbor City Blvd., Melbourne Florida 32935 within 45 days the following documents
requested in Schedule A.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
via Service of process along with the Summons and Complaint to Defendant GOVERNMENT
EMPLOYEES INSURANCE COMPANY.
GILLIN GILLIN & LINDBAEK, P.A.
Attorneys for Plaintiff
222 N. Harbor City Blvd.
Melbourne, Florida 32935
Telephone: (321) 729-1444
By_/s/_Eric S. Gillin
ERIC S. GILLIN
Florida Bar No. 168629
Primary email: eric@brevardjustice.com
Filing 122943547 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX
SCHEDULE A
1 Defendant is requested to produce a copy of any and all policies of liability insurance
providing liability coverage to one or more of the Defendants for claims arising out of the incident
described in the Complaint, or copies of any and all policies of insurance which allegedly provide
liability insurance coverage to the Defendant for the incident described in the Complaint.
2 Defendant is requested to produce a copy of any and all policies of insurance of any kind
or nature which would, or may, provide benefits to the Plaintiff by reason of incidents described
in the Complaint.
3 Defendant is hereby requested to produce a copy of any and all statements (as defined in
the Rules of Civil Procedure) concerning this action or the subject matter of this action previously
made by the Plaintiff.
4 Defendant is requested to produce copies of any and all photographs taken at the scene of
the incident described in the Complaint which do or might reveal marks, damage or conditions
which no longer exist at said scene or which probably no longer exist at said scene on the date of
the filing of this request.
5 Defendant is requested to produce any property in the possession of any Defendant on the
date of the incident described in the Complaint which was involved in the incident described in
the Complaint and which property contains marks or damage as a result of the incident described
in the Complaint, or if such property no longer contains such marks or damage in the same
condition as it did on the date of the incident described in the Complaint subsequent to said
incident, then produce for examination copies of any and all photographs showing such marks or
damage.
6 Defendant is requested to produce Defendant's, OR ANY OTHER, motor vehicle described
in the Complaint, or if said motor vehicle is no longer available, any and all photographs of
Defendant's, OR ANY OTHER, motor vehicle in the possession of the Defendant.
7
Defendant is requested to produce any photographs of the Plaintiff's vehicle, OR ANY
OTHER VEHICLES INVOLVED IN THIS INCIDENT, showing any marks or damage on said
vehicle which were the result of the incident described in the Complaint.
8 Defendant is requested to produce any written document, repair estimate or report of
examination describing in anyway the nature and extent of the damage to Defendant or Plaintiff's
Filing 122943547 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX
property which occurred as a result of the incident described in the Complaint or any such
documents reflecting conditions of the Defendant or Plaintiffs property immediately prior to the
incident described in the Complaint which said conditions have subsequently been repaired or
corrected or no longer exist.
9. Any and all statements, transcripts, recorded statements in your possession of any witness,
party, or other individual who may have any information regarding the subject matter of this
lawsuit.
10. Any and all surveillance of the Plaintiff including but not limited to videotapes, audiotapes,
photographs, pictures, reports, etc.
11. Names, addresses, and telephone numbers of any and all persons including agents of the
Defendant and /or attorneys for the Defendant who have performed any surveillance of the
Plaintiff.
12. Any and all reports of experts, including, but not limited to, medical record reviews,
nurse’s notes, reports, or opinions, film reviews, IME reports, accident reconstruction reports,
notes, or opinions, biomechanical reports, notes, or opinions regarding Plaintiffs.
13. Any and all medical reports regarding Plaintiffs.
14. Any and all non-privileged information regarding any of the persons involved in the subject
incident.
15. Statements from any witnesses to the subject motor vehicle crash.
Filing 122943547 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX
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Filing # 122943547 E-Filed 03/11/2021 03:04:24 PM IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT IN AND FOR BREVARD COUNTY, FLORIDA LINDA NOLAN POTTER CASE NO.: 05-2021-CA-019085-XXXX-XX Plaintiff VS. EMANUEL JACKSON, and UNITED SERVICES AUTOMOBILE ASSOCIATION, a foreign for-profit corporation, and GOVERNMENT EMPLOYEES INSURANCE COMPANY, a foreign for-profit corporation Defendant. / REQUEST FOR PRODUCTION TO DEFENDANT GOVERNMENT EMPLOYEES INSURANCE COMPANY The Plaintiff, LINDA NOLAN POTTER, by and through the undersigned attorney, pursuant to Florida Rules of Civil Procedure, Rule 1.350, request the Defendant, GOVERNMENT EMPLOYEES INSURANCE COMPANY produce at the office of Gillin, Gillin & Lindbaek, P.A., 222 N. Harbor City Blvd., Melbourne Florida 32935 within 45 days the following documents requested in Schedule A. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via Service of process along with the Summons and Complaint to Defendant GOVERNMENT EMPLOYEES INSURANCE COMPANY. GILLIN GILLIN & LINDBAEK, P.A. Attorneys for Plaintiff 222 N. Harbor City Blvd. Melbourne, Florida 32935 Telephone: (321) 729-1444 By_/s/_Eric S. Gillin ERIC S. GILLIN Florida Bar No. 168629 Primary email: eric@brevardjustice.com Filing 122943547 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX SCHEDULE A 1 Defendant is requested to produce a copy of any and all policies of liability insurance providing liability coverage to one or more of the Defendants for claims arising out of the incident described in the Complaint, or copies of any and all policies of insurance which allegedly provide liability insurance coverage to the Defendant for the incident described in the Complaint. 2 Defendant is requested to produce a copy of any and all policies of insurance of any kind or nature which would, or may, provide benefits to the Plaintiff by reason of incidents described in the Complaint. 3 Defendant is hereby requested to produce a copy of any and all statements (as defined in the Rules of Civil Procedure) concerning this action or the subject matter of this action previously made by the Plaintiff. 4 Defendant is requested to produce copies of any and all photographs taken at the scene of the incident described in the Complaint which do or might reveal marks, damage or conditions which no longer exist at said scene or which probably no longer exist at said scene on the date of the filing of this request. 5 Defendant is requested to produce any property in the possession of any Defendant on the date of the incident described in the Complaint which was involved in the incident described in the Complaint and which property contains marks or damage as a result of the incident described in the Complaint, or if such property no longer contains such marks or damage in the same condition as it did on the date of the incident described in the Complaint subsequent to said incident, then produce for examination copies of any and all photographs showing such marks or damage. 6 Defendant is requested to produce Defendant's, OR ANY OTHER, motor vehicle described in the Complaint, or if said motor vehicle is no longer available, any and all photographs of Defendant's, OR ANY OTHER, motor vehicle in the possession of the Defendant. 7 Defendant is requested to produce any photographs of the Plaintiff's vehicle, OR ANY OTHER VEHICLES INVOLVED IN THIS INCIDENT, showing any marks or damage on said vehicle which were the result of the incident described in the Complaint. 8 Defendant is requested to produce any written document, repair estimate or report of examination describing in anyway the nature and extent of the damage to Defendant or Plaintiff's Filing 122943547 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX property which occurred as a result of the incident described in the Complaint or any such documents reflecting conditions of the Defendant or Plaintiffs property immediately prior to the incident described in the Complaint which said conditions have subsequently been repaired or corrected or no longer exist. 9. Any and all statements, transcripts, recorded statements in your possession of any witness, party, or other individual who may have any information regarding the subject matter of this lawsuit. 10. Any and all surveillance of the Plaintiff including but not limited to videotapes, audiotapes, photographs, pictures, reports, etc. 11. Names, addresses, and telephone numbers of any and all persons including agents of the Defendant and /or attorneys for the Defendant who have performed any surveillance of the Plaintiff. 12. Any and all reports of experts, including, but not limited to, medical record reviews, nurse’s notes, reports, or opinions, film reviews, IME reports, accident reconstruction reports, notes, or opinions, biomechanical reports, notes, or opinions regarding Plaintiffs. 13. Any and all medical reports regarding Plaintiffs. 14. Any and all non-privileged information regarding any of the persons involved in the subject incident. 15. Statements from any witnesses to the subject motor vehicle crash. Filing 122943547 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX