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Filing # 155619360 E-Filed 08/18/2022 12:57:16 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-O
Plaintiff,
vs.
EMANUEL JACKSON, and
UNITED SERVICES AUTOMOBILE ASSOCIATION,
a foreign for profit corporation, and GEICO GENERAL
INSURANCE COMPANY,
a foreign for profit corporation,
Defendants.
/
DEFENDANT, EMANUEL JACKSON’S
SUPPLEMENTAL REQUEST TO PRODUCE TO PLAINTIFF
Defendant, EMANUEL JACKSON, by and through the undersigned counsel, pursuant to
Rule 1.350, hereby requests that Plaintiff, LINDA NOLAN POTTER produce the following on
or before thirty (30) days from the date of service below:
1 All medical bills, doctors’ reports and hospital records that you have regarding care
and treatment rendered to you, as a result of the incident described in the Complaint filed herein
from the date of your Responses to Defendant, EMANUEL JACKSON’S , prior Request to
Produce dated April 1%, 2021 through the present date.
2. All medical bills, doctors’ reports and hospital records that you have regarding the
care and treatment rendered to you for any other reason from the date of your Responses to
Defendant, EMANUEL JACKSON’S prior Requests to Produce, dated April 1°, 2021, through
the present date.
3 Copies of any and all records indicating and/or documenting vacations you have
taken either in-state, out-of state, or internationally from December 7", 2020 to present. This
Filing 155619360 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX
CASE NO.: 05-2021-CA-
019085-O
request encompasses and is not limited to proofs or airline ticket purchases, receipt for hotel stays,
guided tours, excursions, cruises, etc.
4 Any and all photographs depicting you in your injured condition.
5 Copies of any and all records indicating, tending to indicate, or upon which you
intend to rely to indicate, the nature and extent of any payments, charges or debts incurred, which
constitute special damages sought as a result of the incident described in the Complaint, since prior
Requests to Produce were served upon you on April 1‘, 2021.
6. Copies of any and all documents reflecting any collateral source payments made on
your behalf for expenses, which you attribute to the Defendants’ conduct as described in the
Complaint.
7 Copies of any job applications you have filled out or submitted for employment since
the date of your Responses to Defendant, EMANUEL JACKSON’S, prior Requests to Produce,
dated April 1‘, 2021 through the present date.
8 Copies of the W-2 Withholding Tax Statements and any and all other business
records or income records and other evidence of income, beginning with the five (5) years
preceding the subject accident, if not previously produced.
9 Evidence of 2019, 2020, 2021, 2022 and income to date, and/or since your
Responses to Defendant, EMANUEL JACKSON’S prior Requests to Produce, dated April 1‘,
2021 through the present date.
10. Any and all self-tracking device data, such as Fitbits, Jawbones, Samsung Gear,
heart rate monitors, etc., and copies of the complete data for the thirty (30) days prior to the
subject accident to present.
2
Filing 155619360 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX
CASE NO.: 05-2021-CA-
019085-O
ll. Any and all data from vehicle monitoring devices that you currently utilize or
utilized at the time of the subject motor vehicle accident, installed personally or by an insurance
company, for thirty (30) days before the subject accident to present.
12. Any and all, vehicle dash cam self recording system’s video footage , photographs
and/or data, for one (1) hour before the subject motor vehicle accident and one (1) hour past the
subject motor vehicle accident.
13. Any and all records, statements or other documentation related to medical care of
the Plaintiff, LINDA NOLAN POTTER paid by any PIP/automobile for injuries sustained by
the Plaintiff as a result of the December 7", 2020 motor vehicle accident described in the
Plaintiff's Complaint.
14. Any and all records, statements or liens related to medical care of the Plaintiff,
LINDA NOLAN POTTER paid by any health care provider, including medicaid, medicare, or
social security for injuries sustained by the Plaintiff as a result of the December 7", 2020 motor
vehicle accident described in the Plaintiff's Complaint.
15, Any and all reports from any medical expert, or economic expert which places
work restrictions or restrictions related to daily living on the Plaintiff, LINDA NOLAN
POTTER, based on the injuries sustained in the December 7", 2020 accident described in the
Plaintiff's Complaint and/or which opines as to future lost wages or future medical expense.
CERTIFICATE OF SERVICE
1 HEREBY CERTIFY that on August 18", 2022 , a true and correct copy of the
foregoing has been filed via Florida’s E-Filing Portal to the following: Eric S. Gillin, Esq.,
Gillin, Gillin & Lindbaek, P.A., 222 N. Harbor City Boulevard, Melbourne, Florida
32935 , Morgan & Morgan, P.A., 20 N. Orange Ave., 16" Floor, Orlando, FL 32801
(Email: eric@brevardjustice.com).
3
Filing 155619360 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX
CASE NO.: 05-2021-CA-
019085-O
/S/ SEBASTIAN C. MEJIA
SEBASTIAN C. MEJIA, ESQUIRE
Fla. Bar No. 117540
TARA B, RATANUN, ESQUIRE
Fla. Bar No. 121904
KUBICKI DRAPER
201 South Orange Avenue, Suite 475
Orlando, Florida 32801
Telephone: (407) 245-3630
Facsimile: (407) 245-7685
Service Email: SCM-KD@kubickidraper.com
Counsel for Defendant, Jackson
4
Filing 155619360 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX
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Filing # 155619360 E-Filed 08/18/2022 12:57:16 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-O Plaintiff, vs. EMANUEL JACKSON, and UNITED SERVICES AUTOMOBILE ASSOCIATION, a foreign for profit corporation, and GEICO GENERAL INSURANCE COMPANY, a foreign for profit corporation, Defendants. / DEFENDANT, EMANUEL JACKSON’S SUPPLEMENTAL REQUEST TO PRODUCE TO PLAINTIFF Defendant, EMANUEL JACKSON, by and through the undersigned counsel, pursuant to Rule 1.350, hereby requests that Plaintiff, LINDA NOLAN POTTER produce the following on or before thirty (30) days from the date of service below: 1 All medical bills, doctors’ reports and hospital records that you have regarding care and treatment rendered to you, as a result of the incident described in the Complaint filed herein from the date of your Responses to Defendant, EMANUEL JACKSON’S , prior Request to Produce dated April 1%, 2021 through the present date. 2. All medical bills, doctors’ reports and hospital records that you have regarding the care and treatment rendered to you for any other reason from the date of your Responses to Defendant, EMANUEL JACKSON’S prior Requests to Produce, dated April 1°, 2021, through the present date. 3 Copies of any and all records indicating and/or documenting vacations you have taken either in-state, out-of state, or internationally from December 7", 2020 to present. This Filing 155619360 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX CASE NO.: 05-2021-CA- 019085-O request encompasses and is not limited to proofs or airline ticket purchases, receipt for hotel stays, guided tours, excursions, cruises, etc. 4 Any and all photographs depicting you in your injured condition. 5 Copies of any and all records indicating, tending to indicate, or upon which you intend to rely to indicate, the nature and extent of any payments, charges or debts incurred, which constitute special damages sought as a result of the incident described in the Complaint, since prior Requests to Produce were served upon you on April 1‘, 2021. 6. Copies of any and all documents reflecting any collateral source payments made on your behalf for expenses, which you attribute to the Defendants’ conduct as described in the Complaint. 7 Copies of any job applications you have filled out or submitted for employment since the date of your Responses to Defendant, EMANUEL JACKSON’S, prior Requests to Produce, dated April 1‘, 2021 through the present date. 8 Copies of the W-2 Withholding Tax Statements and any and all other business records or income records and other evidence of income, beginning with the five (5) years preceding the subject accident, if not previously produced. 9 Evidence of 2019, 2020, 2021, 2022 and income to date, and/or since your Responses to Defendant, EMANUEL JACKSON’S prior Requests to Produce, dated April 1‘, 2021 through the present date. 10. Any and all self-tracking device data, such as Fitbits, Jawbones, Samsung Gear, heart rate monitors, etc., and copies of the complete data for the thirty (30) days prior to the subject accident to present. 2 Filing 155619360 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX CASE NO.: 05-2021-CA- 019085-O ll. Any and all data from vehicle monitoring devices that you currently utilize or utilized at the time of the subject motor vehicle accident, installed personally or by an insurance company, for thirty (30) days before the subject accident to present. 12. Any and all, vehicle dash cam self recording system’s video footage , photographs and/or data, for one (1) hour before the subject motor vehicle accident and one (1) hour past the subject motor vehicle accident. 13. Any and all records, statements or other documentation related to medical care of the Plaintiff, LINDA NOLAN POTTER paid by any PIP/automobile for injuries sustained by the Plaintiff as a result of the December 7", 2020 motor vehicle accident described in the Plaintiff's Complaint. 14. Any and all records, statements or liens related to medical care of the Plaintiff, LINDA NOLAN POTTER paid by any health care provider, including medicaid, medicare, or social security for injuries sustained by the Plaintiff as a result of the December 7", 2020 motor vehicle accident described in the Plaintiff's Complaint. 15, Any and all reports from any medical expert, or economic expert which places work restrictions or restrictions related to daily living on the Plaintiff, LINDA NOLAN POTTER, based on the injuries sustained in the December 7", 2020 accident described in the Plaintiff's Complaint and/or which opines as to future lost wages or future medical expense. CERTIFICATE OF SERVICE 1 HEREBY CERTIFY that on August 18", 2022 , a true and correct copy of the foregoing has been filed via Florida’s E-Filing Portal to the following: Eric S. Gillin, Esq., Gillin, Gillin & Lindbaek, P.A., 222 N. Harbor City Boulevard, Melbourne, Florida 32935 , Morgan & Morgan, P.A., 20 N. Orange Ave., 16" Floor, Orlando, FL 32801 (Email: eric@brevardjustice.com). 3 Filing 155619360 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX CASE NO.: 05-2021-CA- 019085-O /S/ SEBASTIAN C. MEJIA SEBASTIAN C. MEJIA, ESQUIRE Fla. Bar No. 117540 TARA B, RATANUN, ESQUIRE Fla. Bar No. 121904 KUBICKI DRAPER 201 South Orange Avenue, Suite 475 Orlando, Florida 32801 Telephone: (407) 245-3630 Facsimile: (407) 245-7685 Service Email: SCM-KD@kubickidraper.com Counsel for Defendant, Jackson 4 Filing 155619360 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX