On October 18, 2019 a
Response to Request for Production
was filed
involving a dispute between
Thomas, Katina,
and
Depeine, John,
for Auto Negligence
in the District Court of Broward County.
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Filing # 103364489 E-Filed 02/14/2020 04:39:06 PM
IN THE CIRCUIT COURT OF THE 17 JUDICIAL
CIRCUIT IN AND FOR BROWARD COUNTY,
FLORIDA
KATINA THOMAS, CASE NO.: CACE-19-021558 DIV. 05
Plaintiff, FBN 371874
VS.
JOHN DEPEINE,
Defendant,
/
DEFENDANT’S RESPONSE TO PLAINTIFF’S REQUEST FOR PRODUCTION
COMES NOW the Defendant, JOHN DEPEINE, by and through his undersigned
counsel and pursuant to FI. R. C.P. 1.350 hereby files his Response to Plaintiff's
Request for Production, and/or objections thereto, propounded along with Complaint.
1.
Any and all Policies of Insurance that you contend cover or may cover any Defendant for the
allegations contained in Plaintiffs’ Complaint.
3
RESPONSE: - A copy of the Zurich Insurance policy has been requested and will be
supplied upon receipt.
Any and all documents which support the affirmative defenses in your answer.
RESPONSE: Objection, the determination of what documents support an affirmative
defense invades the Defendant's attorney client privilege and work product — seeking
mental impressions and strategy of counsel. Such is protected by the FS § 1.280 and
not subject to discovery.
Any and all reports of expert witnesses who will testify at time of trial pertaining to any issue
involved in this lawsuit.
4,
RESPONSE: Undetermined at this time. Discovery is ongoing.
Any statements of the Plaintiffs taken in connection with the above lawsuit.
RESPONSE: Objection. Any investigation was performed and obtained in anticipation of
litigation and it is therefore protected by the Work Product Privilege FI.R.C.P. 1.280 (c).
Without waiving said objection, none in this Defendant’s care, custody or control.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/14/2020 04:39:06 PM.****Ss. Any model, plat, map, drawing, motion picture, video tape, or photograph pertaining to any fact
or issue involved in this controversy.
RESPONSE: Objection. Any investigation was performed and obtained in anticipation of
litigation and it is therefore protected by the Work Product Privilege FI.R.C.P. 1.280 (c). See
Privilege Log.
PRIVILEGED LOG
Three photographs of Defendant’s subject vehicle taken after the accident.
Twenty photographs of Plaintiff's vehicle provided by GEICO Insurance
Co.
6. A copy of the title and registration for the subject vehicle.
RESPONSE: Registration has been requested from client and will be provided. No title
available — titles held by State of Florida and banki/lender.
7. Any materials you intend to use at trial to impeach the parties, their witnesses or experts,
including impeachment material set forth in and Northup v. Acken 865 So.2d 1267 (Fla. 2004).
RESPONSE: Objection, the determination of what documents support an affirmative
defense invades the Defendant's attorney client privilege and work product - seeking
mental impressions and strategy of counsel. Such is protected by the FS § 1.280 and
not subject to discovery.
WE HEREBY, CERTIFY that a true and correct copy of the above and foregoing
was emailed this day of February, 2020 to Kevin Dennis Esq. Thomas & Pearl,
PA, 2404 NE 9" Street, Ft. Lauderdale, Florida 33304.
GLEN R. GOLDSMITH, P.A.
Attorney for Defendant
9500 S. Dadeland,
Document Filed Date
February 14, 2020
Case Filing Date
October 18, 2019
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Filing # 103364489 E-Filed 02/14/2020 04:39:06 PM IN THE CIRCUIT COURT OF THE 17 JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA KATINA THOMAS, CASE NO.: CACE-19-021558 DIV. 05 Plaintiff, FBN 371874 VS. JOHN DEPEINE, Defendant, / DEFENDANT’S RESPONSE TO PLAINTIFF’S REQUEST FOR PRODUCTION COMES NOW the Defendant, JOHN DEPEINE, by and through his undersigned counsel and pursuant to FI. R. C.P. 1.350 hereby files his Response to Plaintiff's Request for Production, and/or objections thereto, propounded along with Complaint. 1. Any and all Policies of Insurance that you contend cover or may cover any Defendant for the allegations contained in Plaintiffs’ Complaint. 3 RESPONSE: - A copy of the Zurich Insurance policy has been requested and will be supplied upon receipt. Any and all documents which support the affirmative defenses in your answer. RESPONSE: Objection, the determination of what documents support an affirmative defense invades the Defendant's attorney client privilege and work product — seeking mental impressions and strategy of counsel. Such is protected by the FS § 1.280 and not subject to discovery. Any and all reports of expert witnesses who will testify at time of trial pertaining to any issue involved in this lawsuit. 4, RESPONSE: Undetermined at this time. Discovery is ongoing. Any statements of the Plaintiffs taken in connection with the above lawsuit. RESPONSE: Objection. Any investigation was performed and obtained in anticipation of litigation and it is therefore protected by the Work Product Privilege FI.R.C.P. 1.280 (c). Without waiving said objection, none in this Defendant’s care, custody or control. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/14/2020 04:39:06 PM.****Ss. Any model, plat, map, drawing, motion picture, video tape, or photograph pertaining to any fact or issue involved in this controversy. RESPONSE: Objection. Any investigation was performed and obtained in anticipation of litigation and it is therefore protected by the Work Product Privilege FI.R.C.P. 1.280 (c). See Privilege Log. PRIVILEGED LOG Three photographs of Defendant’s subject vehicle taken after the accident. Twenty photographs of Plaintiff's vehicle provided by GEICO Insurance Co. 6. A copy of the title and registration for the subject vehicle. RESPONSE: Registration has been requested from client and will be provided. No title available — titles held by State of Florida and banki/lender. 7. Any materials you intend to use at trial to impeach the parties, their witnesses or experts, including impeachment material set forth in and Northup v. Acken 865 So.2d 1267 (Fla. 2004). RESPONSE: Objection, the determination of what documents support an affirmative defense invades the Defendant's attorney client privilege and work product - seeking mental impressions and strategy of counsel. Such is protected by the FS § 1.280 and not subject to discovery. WE HEREBY, CERTIFY that a true and correct copy of the above and foregoing was emailed this day of February, 2020 to Kevin Dennis Esq. Thomas & Pearl, PA, 2404 NE 9" Street, Ft. Lauderdale, Florida 33304. GLEN R. GOLDSMITH, P.A. Attorney for Defendant 9500 S. Dadeland,