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Filing # 182550883 E-Filed 09/25/2023 05:32:49 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,
EMANUBL JACKSON,
Defendants.
/
PLAINTIFF’S SUPPLMENTAL REQUEST FOR PRODUCTION TO DEFENDANT
Plaintiff, LINDA NOLAN POTTER, by and through undersigned counsel, and pursuant to
Florida Rules of Civil Procedure 1.350 propounds the following Supplemental Request For Pro-
duction To Defendant Emanuel Jackson,
1. All medical bills, doctors' reports and hospital records that you have regarding care
and treatment rendered to LINDA POTTER, as a result of the incident described in the Com-
plaint filed herein from the date of her 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 of LINDA POTTER for any other reason from the date of her 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 LINDA
POTTER has taken either in-state, out-of state, or internationally from March 3, 2023 to present.
This request 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 documents reflecting any collateral source payments made
on LINDA POTTER’S 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.
Filing 182550883 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX
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 7th, 2020 motor
vehicle accident described in the Plaintiff's Complaint from the date of her 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 does not
place any restrictions related to daily living on the Plaintiff, LINDA NOLAN POTTER regard-
ing the injuries she has alleged were sustained in the December 7th, 2020 accident described in
the Plaintiff's Complaint and/or which opines as to the lack of her needing for any future medical
treatments from the date of her Responses to Defendant, EMANUEL JACKSON’S, prior Second
Supplemental Request to Produce dated March 3, 2023 through the present date.
8. Any surveillance footage depicting LINDA POTTER which was taken after
December 7, 2020.
9. A-copy of the materials which were provided to Defendant’s retained witness, Dr.
Silas regarding Linda Potter.
10. A copy of any report of any radiologist hired by Defendant and/or Defendant's rep-
resentatives regarding this case.
il. A copy of any report for any retained witness hired by Defendant and/or Defend-
ant’s representatives regarding LINDA POTTER.
12. A copy of any medical records of LINDA POTTER created prior to December 7,
2020 which indicates that she had preexisting injuries to her cervical spine.
13. A copy of any medical record of LINDA POTTER created between December 1,
2019 and December 1, 2020 which indicates or tends to indicate that LINDA POTTER was ex-
periencing neck pain.
14. A copy of any medical record of LINDA POTTER created between December 1,
2019 and December 1, 2020 which indicates or tends to indicate that LINDA POTTER was ex-
periencing back pain.
15. A copy of any medical record of LINDA POTTER created between December 1,
2019 and December 1, 2020 which indicates or tends to indicate that LINDA POTTER was
Filing 182550883 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX
Experiencing left shoulder pain.
16. A copy of any medical record of LINDA POTTER created between December 1,
2019 and December 1, 2020 which indicates or tends to indicate that LINDA POTTER was ex-
periencing right shoulder pain.
17. A copy of any report ever created by Dr. Silas where he was hired on behalf of a De-
fendant in a lawsuit where he has opined that a Plaintiff has a permanent impairment which was
caused by the Defendant in that case.
18. A copy of any report ever created by Dr. Silas where he was hired on behalf of a De-
fendant in a lawsuit where he has not opined that a Plaintiff claiming neck or back injuries has
degenerative disc disease or disc osteophyte complex.
19. A copy of any items or document received in this case by Defense counsel pursuant
to a response to a subpoena or medical authorization which has not previous been provided to
Plaintiff.
CERTIFICATE OF SERVICE
THEREBY CERTIFY that a true and correct copy of the foregoing has been electronically
filed and served using the Florida Courts E-Filing portal to Sebastian C. Mejia, Esq., SCM-
KD@kubickidraper.com, on this the 25" day of September, 2023.
GILLIN GILLIN & LINDBAEK, P.A.
Attorneys for Plaintiff
222 N. Harbor City Bivd.
Melbourne, Florida 32935
Telephone: (321) 729-1444
By_/s/_Eric S. Gillin
ERIC S. GILLIN, ESQ.
Florida Bar No. 168629
Primary email: eric@brevardjustice.com
Filing 182550883 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX
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Filing # 182550883 E-Filed 09/25/2023 05:32:49 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, EMANUBL JACKSON, Defendants. / PLAINTIFF’S SUPPLMENTAL REQUEST FOR PRODUCTION TO DEFENDANT Plaintiff, LINDA NOLAN POTTER, by and through undersigned counsel, and pursuant to Florida Rules of Civil Procedure 1.350 propounds the following Supplemental Request For Pro- duction To Defendant Emanuel Jackson, 1. All medical bills, doctors' reports and hospital records that you have regarding care and treatment rendered to LINDA POTTER, as a result of the incident described in the Com- plaint filed herein from the date of her 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 of LINDA POTTER for any other reason from the date of her 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 LINDA POTTER has taken either in-state, out-of state, or internationally from March 3, 2023 to present. This request 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 documents reflecting any collateral source payments made on LINDA POTTER’S 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. Filing 182550883 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX 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 7th, 2020 motor vehicle accident described in the Plaintiff's Complaint from the date of her 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 does not place any restrictions related to daily living on the Plaintiff, LINDA NOLAN POTTER regard- ing the injuries she has alleged were sustained in the December 7th, 2020 accident described in the Plaintiff's Complaint and/or which opines as to the lack of her needing for any future medical treatments from the date of her Responses to Defendant, EMANUEL JACKSON’S, prior Second Supplemental Request to Produce dated March 3, 2023 through the present date. 8. Any surveillance footage depicting LINDA POTTER which was taken after December 7, 2020. 9. A-copy of the materials which were provided to Defendant’s retained witness, Dr. Silas regarding Linda Potter. 10. A copy of any report of any radiologist hired by Defendant and/or Defendant's rep- resentatives regarding this case. il. A copy of any report for any retained witness hired by Defendant and/or Defend- ant’s representatives regarding LINDA POTTER. 12. A copy of any medical records of LINDA POTTER created prior to December 7, 2020 which indicates that she had preexisting injuries to her cervical spine. 13. A copy of any medical record of LINDA POTTER created between December 1, 2019 and December 1, 2020 which indicates or tends to indicate that LINDA POTTER was ex- periencing neck pain. 14. A copy of any medical record of LINDA POTTER created between December 1, 2019 and December 1, 2020 which indicates or tends to indicate that LINDA POTTER was ex- periencing back pain. 15. A copy of any medical record of LINDA POTTER created between December 1, 2019 and December 1, 2020 which indicates or tends to indicate that LINDA POTTER was Filing 182550883 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX Experiencing left shoulder pain. 16. A copy of any medical record of LINDA POTTER created between December 1, 2019 and December 1, 2020 which indicates or tends to indicate that LINDA POTTER was ex- periencing right shoulder pain. 17. A copy of any report ever created by Dr. Silas where he was hired on behalf of a De- fendant in a lawsuit where he has opined that a Plaintiff has a permanent impairment which was caused by the Defendant in that case. 18. A copy of any report ever created by Dr. Silas where he was hired on behalf of a De- fendant in a lawsuit where he has not opined that a Plaintiff claiming neck or back injuries has degenerative disc disease or disc osteophyte complex. 19. A copy of any items or document received in this case by Defense counsel pursuant to a response to a subpoena or medical authorization which has not previous been provided to Plaintiff. CERTIFICATE OF SERVICE THEREBY CERTIFY that a true and correct copy of the foregoing has been electronically filed and served using the Florida Courts E-Filing portal to Sebastian C. Mejia, Esq., SCM- KD@kubickidraper.com, on this the 25" day of September, 2023. GILLIN GILLIN & LINDBAEK, P.A. Attorneys for Plaintiff 222 N. Harbor City Bivd. Melbourne, Florida 32935 Telephone: (321) 729-1444 By_/s/_Eric S. Gillin ERIC S. GILLIN, ESQ. Florida Bar No. 168629 Primary email: eric@brevardjustice.com Filing 182550883 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX