On January 05, 2018 a
Party Discovery
was filed
involving a dispute between
Guzman, Noralys,
and
Mohammed, Ayesha,
Tahseen, Nighat Aziz,
for Auto Negligence
in the District Court of Broward County.
Preview
Filing # 85430289 E-Filed 02/25/2019 12:27:23 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
Case No.: CACE18000390 (25)
NORALYS GUZMAN,
Plaintiff(s),
v.
AYESHA MOHAMMED, owner, and
NIGHAT AZIZ TAHSEEN, driver,
Defendant(s).
/
RESPONSE TO REQUEST FOR PRODUCTION
COMES NOW the Defendant, Ayesha Mohammed, by and through the
undersigned attorney, files this Response to Plaintiff's Request for Production, and states
as follows:
As to each of the Requests, Defendant will provide those documents which
Defendant has been able to locate at this time. Defendant reserves the right to
supplement these Responses upon further investigation and discovery.
1. See photos attached.
2. See photos attached.
3. None.
4, See photos attached.
5. None.
6. See estimates attached.
7. See estimates attached.
8. None.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 2/25/2019 12:27:23 PM.****10.
11.
12.
13.
14.
15.
16.
17.
None.
None.
None.
See GEICO policy attached. Our response will be supplemented with a
copy of the umbrella policy if there was one, in force and effect at the time
of the accident.
See DL attached.
See police report attached.
None.
Objection. Overbroad, overly burdensome, irrelevant and not reasonably
calculated to arrive at admissible evidence. Notwithstanding the objection
and without waiver thereof, the vehicle is no longer in Defendant's
possession, ownership, or control as it was a total loss.
Defendant no longer has possession, ownership or control of the vehicle.
Further, Defendant did not retain a copy of the vehicle registration for the
vehicle involved in this case.
CERTIFICATE OF SERVICE| HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished by Electronic Mail on this the 25" day of February, 2019 to the following
designated service email address(es): Berkin Aslan, Esq., Kanner & Pintaluga, P A,
Pleadings13@kpattorney.com, baslan@kpattorney.com.
The Law Office of George L. Cimballa, III
ts/_ Giselle Defalla_
Giselle Defalla, Esq.
(Employees of GEICO General Insurance Company)
Florida Bar No: 127121
8151 Peters Road, Suite 1700
Plantation, FL 33324
Phone: 954-472-6585
Facsimile: 954-472-6586
Attorney for Defendants: Ayesha Mohammed and
Nighat Tahseen.
Service Email: ftigeico@geico.com;
gdefalla@geico.com
Preview
Filing # 85430289 E-Filed 02/25/2019 12:27:23 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA Case No.: CACE18000390 (25) NORALYS GUZMAN, Plaintiff(s), v. AYESHA MOHAMMED, owner, and NIGHAT AZIZ TAHSEEN, driver, Defendant(s). / RESPONSE TO REQUEST FOR PRODUCTION COMES NOW the Defendant, Ayesha Mohammed, by and through the undersigned attorney, files this Response to Plaintiff's Request for Production, and states as follows: As to each of the Requests, Defendant will provide those documents which Defendant has been able to locate at this time. Defendant reserves the right to supplement these Responses upon further investigation and discovery. 1. See photos attached. 2. See photos attached. 3. None. 4, See photos attached. 5. None. 6. See estimates attached. 7. See estimates attached. 8. None. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 2/25/2019 12:27:23 PM.****10. 11. 12. 13. 14. 15. 16. 17. None. None. None. See GEICO policy attached. Our response will be supplemented with a copy of the umbrella policy if there was one, in force and effect at the time of the accident. See DL attached. See police report attached. None. Objection. Overbroad, overly burdensome, irrelevant and not reasonably calculated to arrive at admissible evidence. Notwithstanding the objection and without waiver thereof, the vehicle is no longer in Defendant's possession, ownership, or control as it was a total loss. Defendant no longer has possession, ownership or control of the vehicle. Further, Defendant did not retain a copy of the vehicle registration for the vehicle involved in this case. CERTIFICATE OF SERVICE| HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Electronic Mail on this the 25" day of February, 2019 to the following designated service email address(es): Berkin Aslan, Esq., Kanner & Pintaluga, P A, Pleadings13@kpattorney.com, baslan@kpattorney.com. The Law Office of George L. Cimballa, III ts/_ Giselle Defalla_ Giselle Defalla, Esq. (Employees of GEICO General Insurance Company) Florida Bar No: 127121 8151 Peters Road, Suite 1700 Plantation, FL 33324 Phone: 954-472-6585 Facsimile: 954-472-6586 Attorney for Defendants: Ayesha Mohammed and Nighat Tahseen. Service Email: ftigeico@geico.com; gdefalla@geico.com