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Filing # 25972567 E-Filed 04/10/2015 05:19:33 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL
CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA
CIVIL DIVISION
SUELI ALVES, CASE NO.
2015-CA-000590-O
PLAINTIFF,
VS.
ALLSTATE PROPERTY &
CASUALTY INSURANCE
COMPANY,
DEFENDANT.
DEFENDANT’S RESPONSE TO REQUEST FOR PRODUCTION
Defendant, ALLSTATE PROPERTY & CASUALTY INSURANCE COMPANY, by and
through the undersigned counsel, files this Response to Plaintiff, SUELI ALVES, Request for
Production served with Complaint, and would state:
1. Counsel for Plaintiff is in possession of the policy of insurance. It was attached as
Exhibit “A” to the Complaint.
2. Objection on grounds of work product, trade secret, attorney client privilege,
irrelevant and not reasonably calculated to lead to the discovery of admissible evidence.
3. Objection on grounds of work product, trade secret, attorney client privilege,
irrelevant and not reasonably calculated to lead to the discovery of admissible evidence.
4. Objection on grounds of work product, trade secret, attorney client privilege,
irrelevant and not reasonably calculated to lead to the discovery of admissible evidence.
5. Objection on grounds of work product, trade secret, attorney client privilege,
irrelevant and not reasonably calculated to lead to the discovery of admissible evidence.
6. Objection on grounds of work product, trade secret, attorney client privilege,
irrelevant and not reasonably calculated to lead to the discovery of admissible evidence.
CASE NO. 2015-CA-000590-O
7. Objection on grounds of work product, trade secret, attorney client privilege,
irrelevant and not reasonably calculated to lead to the discovery of admissible evidence.
8. Objection on grounds of work product, trade secret, attorney client privilege,
irrelevant and not reasonably calculated to lead to the discovery of admissible evidence.
9. Objection on grounds of work product, trade secret, attorney client privilege,
irrelevant and not reasonably calculated to lead to the discovery of admissible evidence.
10. Objection on grounds of work product, trade secret, attorney client privilege,
irrelevant and not reasonably calculated to lead to the discovery of admissible evidence.
11. Objection on grounds of work product, trade secret, attorney client privilege,
irrelevant and not reasonably calculated to lead to the discovery of admissible evidence.
12. Objection on grounds of work product, trade secret, attorney client privilege,
irrelevant and not reasonably calculated to lead to the discovery of admissible evidence.
13. Objection on grounds of work product. Information requested concerning Plaintiff’s
claims history is personally known by Plaintiff.
14. Objection on grounds of work product, attorney client privilege. Not withstanding
the objection, none at this time.
15. Objection on grounds of work product, attorney client privilege, overbroad.
Notwithstanding the objection, the PIP will be requested via subpoena and copies of all non-
privileged relevant materials will be provided upon receipt.
16. None.
17. Objection on grounds of work product, however, without waiving the objection,
included on attached cd are thirteen (13) color photos of Plaintiff’s vehicle.
18. Objection on grounds of work product, however, without waiving the objection,
none.
19. Objection on grounds of work product, however, without waiving the objection,
included on attached cd is a copy of the repair estimate for Plaintiff.
20. Objection on grounds of work product, however, without waiving the objection,
none.
21. Objection on grounds of work product, however, without waiving the objection,
none.
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CASE NO. 2015-CA-000590-O
I HEREBY CERTIFY that on the 10th day of April , 2015,
a copy of the foregoing Defendant(s) Response to Request for Production has been furnished by
E-mail to:
Attorney for Plaintiff
Louis A. DeFreitas, Jr., Esquire
Morgan & Morgan, P.A.
198 Broadway Ave
Kissimmee, FL 34741
407-452-6990
LDeFreitas@forthepeople.com
LAW OFFICES OF SUZANNE F. VILLA
390 North Orange Avenue, Suite 1550
Orlando, FL 32801-1675
Telephone: (407) 236-0551
Toll Free: (877) 536-5404 ext 2360551
Attorney Direct: (407) 236-0553
Fax: (877) 437-1334
By:
MICHELLE GERJEL
FL Bar No. 0838772
Attorney for Defendant(s)
ALLSTATE PROPERTY & CASUALTY
INSURANCE COMPANY
PRINCIPAL E-MAIL ADDRESS:
ORLANDOLEGAL@ALLSTATE.COM
Personal E-mail Address
(NOT for Service of Pleadings and Documents):
Michelle.Gerjel@Allstate.com
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Filing # 25972567 E-Filed 04/10/2015 05:19:33 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CIVIL DIVISION SUELI ALVES, CASE NO. 2015-CA-000590-O PLAINTIFF, VS. ALLSTATE PROPERTY & CASUALTY INSURANCE COMPANY, DEFENDANT. DEFENDANT’S RESPONSE TO REQUEST FOR PRODUCTION Defendant, ALLSTATE PROPERTY & CASUALTY INSURANCE COMPANY, by and through the undersigned counsel, files this Response to Plaintiff, SUELI ALVES, Request for Production served with Complaint, and would state: 1. Counsel for Plaintiff is in possession of the policy of insurance. It was attached as Exhibit “A” to the Complaint. 2. Objection on grounds of work product, trade secret, attorney client privilege, irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. 3. Objection on grounds of work product, trade secret, attorney client privilege, irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. 4. Objection on grounds of work product, trade secret, attorney client privilege, irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. 5. Objection on grounds of work product, trade secret, attorney client privilege, irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. 6. Objection on grounds of work product, trade secret, attorney client privilege, irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. CASE NO. 2015-CA-000590-O 7. Objection on grounds of work product, trade secret, attorney client privilege, irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. 8. Objection on grounds of work product, trade secret, attorney client privilege, irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. 9. Objection on grounds of work product, trade secret, attorney client privilege, irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. 10. Objection on grounds of work product, trade secret, attorney client privilege, irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. 11. Objection on grounds of work product, trade secret, attorney client privilege, irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. 12. Objection on grounds of work product, trade secret, attorney client privilege, irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. 13. Objection on grounds of work product. Information requested concerning Plaintiff’s claims history is personally known by Plaintiff. 14. Objection on grounds of work product, attorney client privilege. Not withstanding the objection, none at this time. 15. Objection on grounds of work product, attorney client privilege, overbroad. Notwithstanding the objection, the PIP will be requested via subpoena and copies of all non- privileged relevant materials will be provided upon receipt. 16. None. 17. Objection on grounds of work product, however, without waiving the objection, included on attached cd are thirteen (13) color photos of Plaintiff’s vehicle. 18. Objection on grounds of work product, however, without waiving the objection, none. 19. Objection on grounds of work product, however, without waiving the objection, included on attached cd is a copy of the repair estimate for Plaintiff. 20. Objection on grounds of work product, however, without waiving the objection, none. 21. Objection on grounds of work product, however, without waiving the objection, none. 2 CASE NO. 2015-CA-000590-O I HEREBY CERTIFY that on the 10th day of April , 2015, a copy of the foregoing Defendant(s) Response to Request for Production has been furnished by E-mail to: Attorney for Plaintiff Louis A. DeFreitas, Jr., Esquire Morgan & Morgan, P.A. 198 Broadway Ave Kissimmee, FL 34741 407-452-6990 LDeFreitas@forthepeople.com LAW OFFICES OF SUZANNE F. VILLA 390 North Orange Avenue, Suite 1550 Orlando, FL 32801-1675 Telephone: (407) 236-0551 Toll Free: (877) 536-5404 ext 2360551 Attorney Direct: (407) 236-0553 Fax: (877) 437-1334 By: MICHELLE GERJEL FL Bar No. 0838772 Attorney for Defendant(s) ALLSTATE PROPERTY & CASUALTY INSURANCE COMPANY PRINCIPAL E-MAIL ADDRESS: ORLANDOLEGAL@ALLSTATE.COM Personal E-mail Address (NOT for Service of Pleadings and Documents): Michelle.Gerjel@Allstate.com 3