On January 16, 2018 a
Party Discovery
was filed
involving a dispute between
Kohn, Jacqueline,
and
State Farm Florida Insurance Company,
for Other - Insurance Claim
in the District Court of Broward County.
Preview
Filing # 68884951 E-Filed 03/06/2018 04:59:02 PM
IN THE CIRCUIT COURT OF THE 17™
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CIRCUIT CIVIL DIVISION
CASE NO.: CACE 18-001121 (Div. 05)
JACQUELINE KOHN,
Plaintiffs,
VS,
STATE FARM FLORIDA INSURANCE
COMPANY,
Defendant.
STATE FARM'S RESPONSE TO REQUEST FOR PRODUCTION
Defendant, STATE FARM FLORIDA INSURANCE COMPANY, hereby responds to
the Request for Production served with the Complaint by Plaintiff JACQUELINE KOHN as
follows:
1 All correspondence exchanged between the parties (or their respective
representatives) will be produced.
2 All reports from consultants, contractors, estimators, and/or public adjusters will
be produced.
3 All communications with third parties, including consultants, will be produced.
4 Any "damage investigation summaries" created by third parties will be produced.
The estimate prepared by State Farm that accompanied payment to Plaintiff will be produced.
The adjuster log notes authored by State Farm claim personnel conceivably might be described
as "damage investigation summaries;" they are privileged as opinion work product of State Farm.
5 All estimates, whether created by third parties or by State Farm, will be produced.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 3/6/2018 4:59:01 PM.****
CASE NO.: CACE 18-001121 (Div. 05)
Response to Request for Production
Page 2
6 All correspondence and estimates accompanying payments will be produced; see,
response to request number | and 5. Copies of checks will be requested from the appropriate
department; they will be produced, if available.
7 None.
8 The only "statement" in State Farm's possession is the signed, sworn statement in
proof loss executed by Plaintiff; it will be produced.
9 All documents provided by the Plaintiff, or by her representatives, will be
produced.
10. None, except what is being produced in response to requests 2, 4, and 5.
11 All such diagrams will be produced.
12. See 8 and 9, above.
13 None, other than what is being produced in response to other requests. See,
response to 2, 3, 4 and 5.
14. All photographs will be produced as they exist in the claim file. Some are in
color; others are in black and white.
15. All such materials are being produced in response to other requests.
CHIMPOULIS, HUNTER & LYNN, P.A.
Attorneys for Defendant STATE FARM
150 S. Pine Island Road
Suite 510
Plantation, FL 33324
Phone: (954) 463-0033
s/ Brian Charlton Hunter
BY
BRIAN CHARLTON HUNTER, ESQ.
Florida Bar No. 981206
bhunter@chl-law.com
CASE NO.: CACE 18-001121 (Div. 05)
Response to Request for Production
Page 3
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of foregoing was served through
the Florida Courts E-filing Portal on this 6th day of March, 2018, upon Donna DeVaney
Stockham, Esq., Attorney for Plaintiffs, at the following address(es):
dstockham@stockhamlaweroup.com
meassida@stockhamlawgroup.com
agonzalez-abreu@estockhamlawgroup.com
CHIMPOULIS, HUNTER & LYNN, P.A.
Attorneys for Defendant STATE FARM
150 S. Pine Island Road
Suite 510
Plantation, FL 33324
Phone: (954) 463-0033
s/ Brian Charlton Hunter
BY:
BRIAN CHARLTON HUNTER, ESQ.
Florida Bar No. 981206
bhunter@chl-law.com
Document Filed Date
March 08, 2018
Case Filing Date
January 16, 2018
Category
Other - Insurance Claim
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing # 68884951 E-Filed 03/06/2018 04:59:02 PM IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIRCUIT CIVIL DIVISION CASE NO.: CACE 18-001121 (Div. 05) JACQUELINE KOHN, Plaintiffs, VS, STATE FARM FLORIDA INSURANCE COMPANY, Defendant. STATE FARM'S RESPONSE TO REQUEST FOR PRODUCTION Defendant, STATE FARM FLORIDA INSURANCE COMPANY, hereby responds to the Request for Production served with the Complaint by Plaintiff JACQUELINE KOHN as follows: 1 All correspondence exchanged between the parties (or their respective representatives) will be produced. 2 All reports from consultants, contractors, estimators, and/or public adjusters will be produced. 3 All communications with third parties, including consultants, will be produced. 4 Any "damage investigation summaries" created by third parties will be produced. The estimate prepared by State Farm that accompanied payment to Plaintiff will be produced. The adjuster log notes authored by State Farm claim personnel conceivably might be described as "damage investigation summaries;" they are privileged as opinion work product of State Farm. 5 All estimates, whether created by third parties or by State Farm, will be produced. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 3/6/2018 4:59:01 PM.**** CASE NO.: CACE 18-001121 (Div. 05) Response to Request for Production Page 2 6 All correspondence and estimates accompanying payments will be produced; see, response to request number | and 5. Copies of checks will be requested from the appropriate department; they will be produced, if available. 7 None. 8 The only "statement" in State Farm's possession is the signed, sworn statement in proof loss executed by Plaintiff; it will be produced. 9 All documents provided by the Plaintiff, or by her representatives, will be produced. 10. None, except what is being produced in response to requests 2, 4, and 5. 11 All such diagrams will be produced. 12. See 8 and 9, above. 13 None, other than what is being produced in response to other requests. See, response to 2, 3, 4 and 5. 14. All photographs will be produced as they exist in the claim file. Some are in color; others are in black and white. 15. All such materials are being produced in response to other requests. CHIMPOULIS, HUNTER & LYNN, P.A. Attorneys for Defendant STATE FARM 150 S. Pine Island Road Suite 510 Plantation, FL 33324 Phone: (954) 463-0033 s/ Brian Charlton Hunter BY BRIAN CHARLTON HUNTER, ESQ. Florida Bar No. 981206 bhunter@chl-law.com CASE NO.: CACE 18-001121 (Div. 05) Response to Request for Production Page 3 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of foregoing was served through the Florida Courts E-filing Portal on this 6th day of March, 2018, upon Donna DeVaney Stockham, Esq., Attorney for Plaintiffs, at the following address(es): dstockham@stockhamlaweroup.com meassida@stockhamlawgroup.com agonzalez-abreu@estockhamlawgroup.com CHIMPOULIS, HUNTER & LYNN, P.A. Attorneys for Defendant STATE FARM 150 S. Pine Island Road Suite 510 Plantation, FL 33324 Phone: (954) 463-0033 s/ Brian Charlton Hunter BY: BRIAN CHARLTON HUNTER, ESQ. Florida Bar No. 981206 bhunter@chl-law.com