On March 18, 2023 a
No Value
was filed
involving a dispute between
Slipp, Dana,
and
Popper, Paul,
for Auto Negligence
in the District Court of Charlotte County.
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Filing # 175145123 E-Filed 06/12/2023 04:53:14 PM
IN THE CIRCUIT COURT OF THE TWENTIETH
JUDICIAL CIRCUIT IN AND FOR CHARLOTTE
COUNTY, FLORIDA
CIVIL DIVISION
CASE NO. 23-000557-CA
DANA SLIPP,
Plaintiff,
v.
PAUL POPPER,
Defendant.
PAUL POPPER’S RESPONSES
TO PLAINTIFF’S REQUEST FOR PRODUCTION
Defendant, PAUL POPPER, pursuant to Rule 1.350 of the Florida Rules of Civil
Procedure, hereby files his/her response to Plaintiff, DANA SLIPP’s Request to Produce, served
with the Complaint, and states as follows:
All statements made by any occupants of the vehicles involved in the subject incident.
RESPONSE: None to produce.
All statements made by any witnesses to the subject accident or from individuals who
have knowledge of alleged injuries and prior subsequent accidents.
RESPONSE: None to produce.
All statements made by the Plaintiff pertaining to or concerning the subject matter.
RESPONSE: None to produce.
All photographs of the vehicles involved in the subject accident.
RESPONSE: Please see attached photographs.
All photographs of the Plaintiff depicting injuries received in the subject accident.
RESPONSE: None to produce.
All photographs of the subject accident scene.
RESPONSE: None to produce.
Copy of any dashboard camera videos from the vehicles involved in the subject
accident that recorded the accident and events prior and after the accident.
RESPONSE: None to produce.
Copy of any videos that document the subject accident and events prior to and after
the accident.
RESPONSE: None to produce.
Copy of any photographs or videos of the Plaintiff posted on social
media/YouTube/internet.
RESPONSE: None to produce.
Copy of downloaded data of the subject accident from any electronic control module
(ECM/event recorder (“black box”) from the subject vehicles operated on the date of
the accident.
RESPONSE: None to produce.
Copy of any recorded data on the date of accident from a GPS system/ Fleet Tracker
and/or other monitoring system/On-Star or other emergency call system for the
subject vehicles involved in the accident.
RESPONSE: None to produce.
Copy of 911 emergency calls reporting the subject accident.
RESPONSE: None to produce.
Documents relating to or discussing repairs or maintenance to Defendant’s vehicle
that were done for the six (6) months period of time preceding and including the date
of the accident and for the six (6) month period of time following the date of the
accident.
RESPONSE: None to produce.
The repair bill and estimates for the repairs to any of the vehicles involved in the
accident for damages incurred in the accident.
RESPONSE: Please see attached repair estimates.
Any and all policies of liability insurance in effect on the date of the subject,
providing coverage to the defendant herein.
RESPONSE: Please see attached redacted insurance declarations page.
Appraisals of the property damage sustained by Defendant’s vehicle in the subject
accident.
RESPONSE: Please see attached repair estimates.
Appraisals of the property damage sustained by the Plaintiff’s vehicle in the subject
accident.
RESPONSE: Please see attached repair estimates.
A copy of any and all surveillance films, photos, or depictions taken of the Plaintiff as
a result of the subject accident.
RESPONSE: None to produce.
A copy of any and all insurance agreements, insurance policies or agreements of any
kind or nature under which any person or company carrying on an insurance business
may be liable to satisfy part or all of a judgement which may be entered in this action
or to indemnify or reimburse any payments made to satisfy any such judgement or
settlement, including but not limited to a certified copy of the declarations sheet as to
each such policy.
RESPONSE: Please see attached redacted insurance declarations page.
Copies of any and all computer-generated documents in the possession of the
Defendant or any agent, servant and/or employee of the Defendant, which pertains or
relate, in any manner or fashion, to and any past claims history of the Plaintiff in this
lawsuit.
RESPONSE: None to produce.
Copies of any and all checks issued by the Defendant or any agent, servant and/or
employee of the Defendant to any other person, firm or company making a claim
arising out of the same accident or incident which is the basis of this lawsuit.
RESPONSE: None to produce.
All payout records for the insurer of the Defendant for benefits paid to or on behalf on
Plaintiff under the personal injury protection and medical payment coverage of the
policy.
RESPONSE: None to produce.
A copy of the driver’s license of the driver involved in the subject accident that
existed on the date of the accident as well as the current driver’s license.
RESPONSE: This information has been requested and will be produced upon
receipt.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on June 9, 2023, I electronically filed the foregoing with the
Clerk of the Court using the Florida E-Portal system. I further certify that a true and correct copy
hereof has been furnished via email to: Jason Gelinas, Esquire, Morgan & Morgan, P.A.
(jgelinas@forthepeople.com; dayanahernandez@forthepeople.com; iquinones@forthepeople.com).
/s/Skylar D. Stewart
ERIC F. OCHOTORENA, ESQUIRE
Florida Bar No.: 0048786
Email: efo.service@rissman.com
SKYLAR STEWART, ESQUIRE
Florida Bar No. 1004398
Email: sds.service@rissman.com
RISSMAN, BARRETT, HURT,
DONAHUE, McLAIN & MANGAN, P.A.
1 N. Dale Mabry Hwy., 11th Floor
Tampa, FL 33609
Telephone: (813) 221-3114
Facsimile: (813) 221-3033
Attorneys for Defendant,
Paul Popper
SDS/snp
Document Filed Date
November 07, 2023
Case Filing Date
March 18, 2023
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Filing # 175145123 E-Filed 06/12/2023 04:53:14 PM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL DIVISION CASE NO. 23-000557-CA DANA SLIPP, Plaintiff, v. PAUL POPPER, Defendant. PAUL POPPER’S RESPONSES TO PLAINTIFF’S REQUEST FOR PRODUCTION Defendant, PAUL POPPER, pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, hereby files his/her response to Plaintiff, DANA SLIPP’s Request to Produce, served with the Complaint, and states as follows: All statements made by any occupants of the vehicles involved in the subject incident. RESPONSE: None to produce. All statements made by any witnesses to the subject accident or from individuals who have knowledge of alleged injuries and prior subsequent accidents. RESPONSE: None to produce. All statements made by the Plaintiff pertaining to or concerning the subject matter. RESPONSE: None to produce. All photographs of the vehicles involved in the subject accident. RESPONSE: Please see attached photographs. All photographs of the Plaintiff depicting injuries received in the subject accident. RESPONSE: None to produce. All photographs of the subject accident scene. RESPONSE: None to produce. Copy of any dashboard camera videos from the vehicles involved in the subject accident that recorded the accident and events prior and after the accident. RESPONSE: None to produce. Copy of any videos that document the subject accident and events prior to and after the accident. RESPONSE: None to produce. Copy of any photographs or videos of the Plaintiff posted on social media/YouTube/internet. RESPONSE: None to produce. Copy of downloaded data of the subject accident from any electronic control module (ECM/event recorder (“black box”) from the subject vehicles operated on the date of the accident. RESPONSE: None to produce. Copy of any recorded data on the date of accident from a GPS system/ Fleet Tracker and/or other monitoring system/On-Star or other emergency call system for the subject vehicles involved in the accident. RESPONSE: None to produce. Copy of 911 emergency calls reporting the subject accident. RESPONSE: None to produce. Documents relating to or discussing repairs or maintenance to Defendant’s vehicle that were done for the six (6) months period of time preceding and including the date of the accident and for the six (6) month period of time following the date of the accident. RESPONSE: None to produce. The repair bill and estimates for the repairs to any of the vehicles involved in the accident for damages incurred in the accident. RESPONSE: Please see attached repair estimates. Any and all policies of liability insurance in effect on the date of the subject, providing coverage to the defendant herein. RESPONSE: Please see attached redacted insurance declarations page. Appraisals of the property damage sustained by Defendant’s vehicle in the subject accident. RESPONSE: Please see attached repair estimates. Appraisals of the property damage sustained by the Plaintiff’s vehicle in the subject accident. RESPONSE: Please see attached repair estimates. A copy of any and all surveillance films, photos, or depictions taken of the Plaintiff as a result of the subject accident. RESPONSE: None to produce. A copy of any and all insurance agreements, insurance policies or agreements of any kind or nature under which any person or company carrying on an insurance business may be liable to satisfy part or all of a judgement which may be entered in this action or to indemnify or reimburse any payments made to satisfy any such judgement or settlement, including but not limited to a certified copy of the declarations sheet as to each such policy. RESPONSE: Please see attached redacted insurance declarations page. Copies of any and all computer-generated documents in the possession of the Defendant or any agent, servant and/or employee of the Defendant, which pertains or relate, in any manner or fashion, to and any past claims history of the Plaintiff in this lawsuit. RESPONSE: None to produce. Copies of any and all checks issued by the Defendant or any agent, servant and/or employee of the Defendant to any other person, firm or company making a claim arising out of the same accident or incident which is the basis of this lawsuit. RESPONSE: None to produce. All payout records for the insurer of the Defendant for benefits paid to or on behalf on Plaintiff under the personal injury protection and medical payment coverage of the policy. RESPONSE: None to produce. A copy of the driver’s license of the driver involved in the subject accident that existed on the date of the accident as well as the current driver’s license. RESPONSE: This information has been requested and will be produced upon receipt. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on June 9, 2023, I electronically filed the foregoing with the Clerk of the Court using the Florida E-Portal system. I further certify that a true and correct copy hereof has been furnished via email to: Jason Gelinas, Esquire, Morgan & Morgan, P.A. (jgelinas@forthepeople.com; dayanahernandez@forthepeople.com; iquinones@forthepeople.com). /s/Skylar D. Stewart ERIC F. OCHOTORENA, ESQUIRE Florida Bar No.: 0048786 Email: efo.service@rissman.com SKYLAR STEWART, ESQUIRE Florida Bar No. 1004398 Email: sds.service@rissman.com RISSMAN, BARRETT, HURT, DONAHUE, McLAIN & MANGAN, P.A. 1 N. Dale Mabry Hwy., 11th Floor Tampa, FL 33609 Telephone: (813) 221-3114 Facsimile: (813) 221-3033 Attorneys for Defendant, Paul Popper SDS/snp