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Filing # 182521312 E-Filed 09/25/2023 01:17:40 PM
IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT
IN AND FOR BREVARD COUNTY, FLORIDA
LINDA NOLAN POTTER, CASE NO.: 05-2021-CA-019085-0
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_ THIRD
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 Second
Supplemental Request to Produce dated March 3, 2023 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 Second Supplemental Request to Produce dated
March 3, 2023 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 March 3, 2023 to present. This request
Filing 182521312 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX
CASE NO.: 05-2021-CA-019085-O
encompasses and is not limited to proofs or airline ticket purchases, receipt for hotel stays, guided
tours, excursions, cruises, etc.
4 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 your
response to Defendant’s prior Second Supplemental Request to Produce dated March 3, 2023
through the present date.
5 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 from the date of your Responses to Defendant, EMANUEL JACKSON’S, prior
Second Supplemental Request to Produce dated March 3, 2023 through the present date.
6. 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 from the date of your Responses to
Defendant, EMANUEL JACKSON’S, prior Second Supplemental Request to Produce dated
March 3, 2023 through the present date.
7. Any and all reports from any medical expert, or economic expert which places
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 medical expense from the date of your Responses to Defendant,
EMANUEL JACKSON’S, prior Second Supplemental Request to Produce dated March 3, 2023
through the present date.
2
Filing 182521312 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX
CASE NO.: 05-2021-CA-019085-O
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on September 25, 2023, 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).
/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
3
Filing 182521312 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX
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Filing # 182521312 E-Filed 09/25/2023 01:17:40 PM IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT IN AND FOR BREVARD COUNTY, FLORIDA LINDA NOLAN POTTER, CASE NO.: 05-2021-CA-019085-0 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_ THIRD 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 Second Supplemental Request to Produce dated March 3, 2023 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 Second Supplemental Request to Produce dated March 3, 2023 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 March 3, 2023 to present. This request Filing 182521312 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX CASE NO.: 05-2021-CA-019085-O encompasses and is not limited to proofs or airline ticket purchases, receipt for hotel stays, guided tours, excursions, cruises, etc. 4 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 your response to Defendant’s prior Second Supplemental Request to Produce dated March 3, 2023 through the present date. 5 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 from the date of your Responses to Defendant, EMANUEL JACKSON’S, prior Second Supplemental Request to Produce dated March 3, 2023 through the present date. 6. 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 from the date of your Responses to Defendant, EMANUEL JACKSON’S, prior Second Supplemental Request to Produce dated March 3, 2023 through the present date. 7. Any and all reports from any medical expert, or economic expert which places 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 medical expense from the date of your Responses to Defendant, EMANUEL JACKSON’S, prior Second Supplemental Request to Produce dated March 3, 2023 through the present date. 2 Filing 182521312 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX CASE NO.: 05-2021-CA-019085-O CERTIFICATE OF SERVICE I HEREBY CERTIFY that on September 25, 2023, 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). /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 3 Filing 182521312 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX