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Filing # 162870013 E-Filed 12/12/2022 04:35:56 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, REQUEST TO PRODUCE TO PLAINTIFF'S
DISCLOSED EXPERT WITNESSES
Pursuant to FLA. R. CIv. P. 1.350, Plaintiff, LINDA NOLAN POTTER, is requested to
produce to Defendant, EMANUEL JACKSON, in the time required by Rule 1.350, at the
offices of the undersigned counsel, the following:
DEFINITIONS:
For purposes of these requests, the words "expert witness" shall mean retained and non
retained treating physicians who were listed on Plaintiff's Expert Witness Disclosure dated
December 8, 2022.
1 Any notes, documents, memoranda, records, reports, or any other means of
recording information regarding this case prepared by or for Plaintiff's expert witnesses.
2. Any engagement letters or emails regarding Plaintiff's expert witnesses in this
case.
3 Any available lists itemizing charges or prices charged by Plaintiff's expert
witnesses and/or witnesses' employer for any witness and/or consulting services provided by or
available from witnesses or witnesses’ employer; i.e. any price lists.
Filing 162870013 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX
4 Any ledger(s), time sheets, or other record reflecting work done and time spent
on this case by Plaintiff's expert witnesses and anybody employed at the expert witnesses’ firm.
5 List of all cases in which Plaintiff's expert witnesses testified in deposition
during the last three years, including case name, case number, venue, and whether the experts
testified for a plaintiff or a defendant.
6. List of all cases in which Plaintiffs expert witnesses testified at trial during the
last three years, case name, case number, venue, and whether the experts testified for a plaintiff
or a defendant.
7
Any and all materials reviewed by Plaintiff's expert witnesses, the witnesses’
agents or the witnesses’ principles, in relation to this case.
8 Any and all materials received by Plaintiff's expert witnesses, the witnesses’
agents or the witnesses’ principles, in relation to this case.
9. Copy of any presentation or outline regarding any speaking engagements or
speeches made by Plaintiff's expert witnesses to any group or organization during the last three
years.
10. List of all cases in which the experts have been retained by The Bagen Law Firm
as an expert witness during the last three years.
11. Any treatise(s) or publication(s) authored by Plaintiffs expert witnesses.
12. Any treatise(s) or other publication(s) relied on in any way by Plaintiff’s expert
witnesses regarding this case.
13. Any treatise(s) or other publication(s) related to the subject matter of Plaintiff’s
expert witnesses' opinions in this case which the respective witness find authoritative.
14. Any treatise(s) or other publication(s) related to the subject matter of Plaintiff’s
expert witnesses' opinions in this case which the respective witness find reliable.
2
Filing 162870013 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX
15. Copies of any advertisements and any documents related to advertisements by
Plaintiff's expert witnesses or Plaintiff’s expert witnesses’ firm or company for expert witnesses
and/or consulting services.
16. Any documents, tables, charts and data relied on and/or referenced by the
Plaintiff's expert witnesses in this case.
17. All raw testing data, test responses, industry standards, or other tests upon which
experts are relying or which were conducted at his/her request.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on December 12, 2022 a true and correct copy of the
foregoing has been filed via Florida’s E-Filing Portal to the following: Erie S. Gillin, Esq.;
Gillin, Gillin, & Lindbaek, P.A., 222 N. Harbor City Boulevard, Melbourne, Florida 32935
(Email: eric@brevardjustice.com).
Ls SebastianC. 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
3
Filing 162870013 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX
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Filing # 162870013 E-Filed 12/12/2022 04:35:56 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, REQUEST TO PRODUCE TO PLAINTIFF'S DISCLOSED EXPERT WITNESSES Pursuant to FLA. R. CIv. P. 1.350, Plaintiff, LINDA NOLAN POTTER, is requested to produce to Defendant, EMANUEL JACKSON, in the time required by Rule 1.350, at the offices of the undersigned counsel, the following: DEFINITIONS: For purposes of these requests, the words "expert witness" shall mean retained and non retained treating physicians who were listed on Plaintiff's Expert Witness Disclosure dated December 8, 2022. 1 Any notes, documents, memoranda, records, reports, or any other means of recording information regarding this case prepared by or for Plaintiff's expert witnesses. 2. Any engagement letters or emails regarding Plaintiff's expert witnesses in this case. 3 Any available lists itemizing charges or prices charged by Plaintiff's expert witnesses and/or witnesses' employer for any witness and/or consulting services provided by or available from witnesses or witnesses’ employer; i.e. any price lists. Filing 162870013 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX 4 Any ledger(s), time sheets, or other record reflecting work done and time spent on this case by Plaintiff's expert witnesses and anybody employed at the expert witnesses’ firm. 5 List of all cases in which Plaintiff's expert witnesses testified in deposition during the last three years, including case name, case number, venue, and whether the experts testified for a plaintiff or a defendant. 6. List of all cases in which Plaintiffs expert witnesses testified at trial during the last three years, case name, case number, venue, and whether the experts testified for a plaintiff or a defendant. 7 Any and all materials reviewed by Plaintiff's expert witnesses, the witnesses’ agents or the witnesses’ principles, in relation to this case. 8 Any and all materials received by Plaintiff's expert witnesses, the witnesses’ agents or the witnesses’ principles, in relation to this case. 9. Copy of any presentation or outline regarding any speaking engagements or speeches made by Plaintiff's expert witnesses to any group or organization during the last three years. 10. List of all cases in which the experts have been retained by The Bagen Law Firm as an expert witness during the last three years. 11. Any treatise(s) or publication(s) authored by Plaintiffs expert witnesses. 12. Any treatise(s) or other publication(s) relied on in any way by Plaintiff’s expert witnesses regarding this case. 13. Any treatise(s) or other publication(s) related to the subject matter of Plaintiff’s expert witnesses' opinions in this case which the respective witness find authoritative. 14. Any treatise(s) or other publication(s) related to the subject matter of Plaintiff’s expert witnesses' opinions in this case which the respective witness find reliable. 2 Filing 162870013 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX 15. Copies of any advertisements and any documents related to advertisements by Plaintiff's expert witnesses or Plaintiff’s expert witnesses’ firm or company for expert witnesses and/or consulting services. 16. Any documents, tables, charts and data relied on and/or referenced by the Plaintiff's expert witnesses in this case. 17. All raw testing data, test responses, industry standards, or other tests upon which experts are relying or which were conducted at his/her request. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on December 12, 2022 a true and correct copy of the foregoing has been filed via Florida’s E-Filing Portal to the following: Erie S. Gillin, Esq.; Gillin, Gillin, & Lindbaek, P.A., 222 N. Harbor City Boulevard, Melbourne, Florida 32935 (Email: eric@brevardjustice.com). Ls SebastianC. 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 3 Filing 162870013 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX