On January 31, 2014 a
Party Discovery
was filed
involving a dispute between
Carolyn Brown,
and
Frank Leon,
Terrys Automobile Supply Inc,
Terrys Auto Supply Inc,
for AUTO NEGLIGENCE
in the District Court of Palm Beach County.
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*** FILED: PALM BEACH COUNTY, FL SHARON R BOCK. CLERK.***
Filing # 12025646 Electronically Filed 04/02/2014 10:56:05 AM
12-1201-PI-TF
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT, IN AND
FOR, PALM BEACH COUNTY, FLORIDA
CAROLYN BROWN, CASE NO. 502014CA001210XXXXMB
Plaintiff(s),
Vs.
FRANK LEON, III and
TERRY'S AUTOMOTIVE SUPPLY, INC.,
Defendant(s).
PLAINTIFF’S RESPONSE TO DEFENDANT, TERRY'S AUTOMOTIVE SUPPLY,
INC.’S, REQUEST TO PRODUCE
COMES NOW, the Plaintiff, Carolyn Brown, by and through the undersigned counsel,
files this Response to Request to Produce filed by Defendant, TERRY'S AUTOMOTIVE
SUPPLY, INC., served with the filing date of Mark Hektner, Esq., Law Office of Peter J.
Delahunty, Loggerhead Plaza North 14241 US Hwy 1, Juno Beach, FL
33408,usz.slwpb.delahunty@zurichna.com,arelis.dujon@zurichna.com, by stating:
1. Objection. Overbroad, unduly burdensome and not reasonably calculated to lead
to the discovery of admissible evidence. Without waiving said objection, attached are tax
returns for years 2009-2013.
2. See response to paragraph one above.
3. Attached.
Page 1 of 312-1201-PI-TF
4, None.
5. None.
6. Objection. Work product privilege. Without waiving said objection, None.
7. See response to paragraph three above.
8. See response to paragraph three above.
9. Objection. Documents responsive to this request are in Defendants’ possession.
10. See response to paragraph three above.
11. ‘None.
12. None.
13. Attached.
14. See response to paragraph three above.
15. Not applicable.
16. None.
17. None.
18. Objection. Vague, irrelevant and not reasonably calculated to lead to the discovery
of admissible evidence.
19. Attached.
20. See response to paragraph three above.
21. Attached.
22. None.
Page 2 of 312-1201-PI-TF
23. Attached.
I HEREBY CERTIFY that a copy of the above and foregoing has been furnished by US
Mail this Ww day of April, 2014 to: Mark Hektner, Esq., Law Office of Peter J.
Delahunty, Loggerhead Plaza North 14241 US Hwy 1, Juno Beach, FL
33408,usz.slwpb.delahunty@zurichna.com,arelis.dujon@zurichna.com.
wD La
Timothy C. Felice, Esq.
The Felice Law Group, PLLC
3030 S. Dixie Highway
Suite 8
West Palm Beach, FL 33405
(561) 444-8822 - Telephone
(561) 514-4946 - Facsimile
Primary Email — cfelice@fgwpblaw.com
Secondary Email — tfelice@fgwpblaw.com
Florida Bar # 0013199
Page 3 of 3
Document Filed Date
April 02, 2014
Case Filing Date
January 31, 2014
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*** FILED: PALM BEACH COUNTY, FL SHARON R BOCK. CLERK.*** Filing # 12025646 Electronically Filed 04/02/2014 10:56:05 AM 12-1201-PI-TF IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR, PALM BEACH COUNTY, FLORIDA CAROLYN BROWN, CASE NO. 502014CA001210XXXXMB Plaintiff(s), Vs. FRANK LEON, III and TERRY'S AUTOMOTIVE SUPPLY, INC., Defendant(s). PLAINTIFF’S RESPONSE TO DEFENDANT, TERRY'S AUTOMOTIVE SUPPLY, INC.’S, REQUEST TO PRODUCE COMES NOW, the Plaintiff, Carolyn Brown, by and through the undersigned counsel, files this Response to Request to Produce filed by Defendant, TERRY'S AUTOMOTIVE SUPPLY, INC., served with the filing date of Mark Hektner, Esq., Law Office of Peter J. Delahunty, Loggerhead Plaza North 14241 US Hwy 1, Juno Beach, FL 33408,usz.slwpb.delahunty@zurichna.com,arelis.dujon@zurichna.com, by stating: 1. Objection. Overbroad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving said objection, attached are tax returns for years 2009-2013. 2. See response to paragraph one above. 3. Attached. Page 1 of 312-1201-PI-TF 4, None. 5. None. 6. Objection. Work product privilege. Without waiving said objection, None. 7. See response to paragraph three above. 8. See response to paragraph three above. 9. Objection. Documents responsive to this request are in Defendants’ possession. 10. See response to paragraph three above. 11. ‘None. 12. None. 13. Attached. 14. See response to paragraph three above. 15. Not applicable. 16. None. 17. None. 18. Objection. Vague, irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. 19. Attached. 20. See response to paragraph three above. 21. Attached. 22. None. Page 2 of 312-1201-PI-TF 23. Attached. I HEREBY CERTIFY that a copy of the above and foregoing has been furnished by US Mail this Ww day of April, 2014 to: Mark Hektner, Esq., Law Office of Peter J. Delahunty, Loggerhead Plaza North 14241 US Hwy 1, Juno Beach, FL 33408,usz.slwpb.delahunty@zurichna.com,arelis.dujon@zurichna.com. wD La Timothy C. Felice, Esq. The Felice Law Group, PLLC 3030 S. Dixie Highway Suite 8 West Palm Beach, FL 33405 (561) 444-8822 - Telephone (561) 514-4946 - Facsimile Primary Email — cfelice@fgwpblaw.com Secondary Email — tfelice@fgwpblaw.com Florida Bar # 0013199 Page 3 of 3