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Filing # 118079818 E-Filed 12/11/2020 02:36:04 PM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
CARL LOUIS, CASE NO.: CACE20016958 (14)
Plaintiff,
vs.
DAWN ADILI AND STATE FARM
MUTUAL AUTOMOBILE INSURANCE
COMPANY,
Defendants.
/
DEFENDANT’S, STATE FARM, RESPONSE TO PLAINTIFF’S
REQUEST FOR PRODUCTION
COMES NOW the Defendant, STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY (hereinafter “Defendant”), by and through their undersigned
attorneys, files their Response to the Plaintiff's, CARL LOUIS (hereinafter “Plaintiff”), Request
for Production served with the Summons and Complaint, and states as follows:
1. All insurance policies that would inure to the benefit of the Plaintiff herein,
together with any declaration of coverage page and sworn statement of a corporate officer of
Defendant attesting to the coverage and authenticity of the policy as required by Florida Statutes.
A copy of the disclosure letter has been requested and will be furnished upon receipt.
2. Copies of any and all forms, correspondence, or reports received by you or any
agents on your behalf concerning the Plaintiff's medical condition from anyone.
The Defendant objects to this Request as violating the work-product privilege of this
Defendant. However, without waiving said objection, the Defendant will provide
complete copies of any subpoenaed records in accordance with Florida Rules of
Civil Procedure.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/11/2020 02:36:04 PM.****CASE NO.: CACE20016958 (14)
3. All correspondence, forms, notations, memoranda or information transmitted by
you in any form whatsoever to any physician’s office or health care provider’s office concerning
the Plaintiff’s physical and/or mental condition.
None.
4. Any and all surveillance reports, claims history reports or other investigative
reports prepared by you or on your behalf with regard to the Plaintiff.
The Defendant objects to this Request as violating the work-product privilege of this
Defendant. Any surveillance report which the Defendant intends to utilize at time of
trial will be disclosed pursuant to the Trial Order. However, without waiving said
objection, none at the present time.
5. Any and all surveillance films or laser copies of any and all photographs (made at
the Plaintiff's expense) taken by you or anyone on your behalf of the Plaintiff.
The Defendant objects to this Request as violating the work-product privilege of this
Defendant. Any videotapes, films or photographs which the Defendant intends to
utilize at time of trial will be disclosed pursuant to the Trial Order. However,
without waiving said objection, none at the present time.
6. Up-to-date PIP payout sheet on the Plaintiff.
None.
7. Any and all statements taken by the Defendant of any witnesses with regard to
any fact relevant to any fact in this case, such as were taken prior to the filing of suit in this
matter.
The Defendant objects to this Request as violating the work-product privilege of this
Defendant. However, without waiving said objection, none.
8. Any and all photographs of any of the vehicles involved in the crash that is the
subject of this lawsuit.
None.CASE NO.: CACE20016958 (14)
9. Any and all estimates of repair or statements concerning the nature and extent of
damage to any of the vehicles involved in the accident.
None.
10. Any and all writings, memorandums, notes or other materials reflecting
examination by the Defendant of any of the vehicles involved in the accident.
None.
11. Any and all records reflecting the towing of any vehicles involved in the accident
from the scene of the accident.
None.
12. Any and all statements given by, or taken of the Plaintiff.
No Recorded Statement.
13. Any and all medical records pertaining to the Plaintiff other than those provided
to Defendant by Plaintiff's counsel.
The Defendant objects to this Request as violating the work-product privilege of this
Defendant. However, without waiving said objection, the Defendant will provide
complete copies of any subpoenaed records in accordance with Florida Rules of
Civil Procedure.
14. Any and all written or electronic communication between you and any vendor
and/or manufacturer of the “EDR” (event data recorder), or “SDM” (sensing and diagnostic
module) that was equipped in the subject vehicle that is alleged to have been involved in the
incident, pertaining to the equipment in that vehicle, from the date of purchase to the current date.
None.
I HEREBY CERTIFY that on December 11, 2020, the foregoing was electronically filed
with the Florida Courts E-Filing Portal and that as a registered participant of the Portal I have
effectuated service through the Portal in compliance with Rule 2.516, Fla. R. Jud. Admin., on
David D. Hernandez, Esq., pleadings@kirwanspellacy.com, Kirwan Spellacy & Danner, P.A.,CASE NO.: CACE20016958 (14)
200 South Andrews Ave., 8th Floor, Fort Lauderdale, FL 33301 and Joseph N. Nusbaum, Esq.,
joe@lawbni.com, Brottman Nusbaum & Ibrahim, 137 W. Royal Palm Road, Boca Raton, FL
33432.
NICHOLAS J. RYAN & ASSOCIATES
110 S. E. 6th Street, Suite 2100
Fort Lauderdale, FL 33301
Telephone: (954) 627-9401
E-mail for service (FL R. Jud. Admin. 2.516):
flor.law-lisabaligian.294019@statefarm.com
Lisa J. Baligian, Esq.
Florida Bar No.: 956181
Attorney for Defendant, State Farm Mutual
Automobile Insurance Company
Attomeys and Staff of Nicholas J. Ryan & Associates are Employees
of the Law Department of State Farm Mutual Automobile Insurance
Company
Preview
Filing # 118079818 E-Filed 12/11/2020 02:36:04 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CARL LOUIS, CASE NO.: CACE20016958 (14) Plaintiff, vs. DAWN ADILI AND STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Defendants. / DEFENDANT’S, STATE FARM, RESPONSE TO PLAINTIFF’S REQUEST FOR PRODUCTION COMES NOW the Defendant, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY (hereinafter “Defendant”), by and through their undersigned attorneys, files their Response to the Plaintiff's, CARL LOUIS (hereinafter “Plaintiff”), Request for Production served with the Summons and Complaint, and states as follows: 1. All insurance policies that would inure to the benefit of the Plaintiff herein, together with any declaration of coverage page and sworn statement of a corporate officer of Defendant attesting to the coverage and authenticity of the policy as required by Florida Statutes. A copy of the disclosure letter has been requested and will be furnished upon receipt. 2. Copies of any and all forms, correspondence, or reports received by you or any agents on your behalf concerning the Plaintiff's medical condition from anyone. The Defendant objects to this Request as violating the work-product privilege of this Defendant. However, without waiving said objection, the Defendant will provide complete copies of any subpoenaed records in accordance with Florida Rules of Civil Procedure. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/11/2020 02:36:04 PM.****CASE NO.: CACE20016958 (14) 3. All correspondence, forms, notations, memoranda or information transmitted by you in any form whatsoever to any physician’s office or health care provider’s office concerning the Plaintiff’s physical and/or mental condition. None. 4. Any and all surveillance reports, claims history reports or other investigative reports prepared by you or on your behalf with regard to the Plaintiff. The Defendant objects to this Request as violating the work-product privilege of this Defendant. Any surveillance report which the Defendant intends to utilize at time of trial will be disclosed pursuant to the Trial Order. However, without waiving said objection, none at the present time. 5. Any and all surveillance films or laser copies of any and all photographs (made at the Plaintiff's expense) taken by you or anyone on your behalf of the Plaintiff. The Defendant objects to this Request as violating the work-product privilege of this Defendant. Any videotapes, films or photographs which the Defendant intends to utilize at time of trial will be disclosed pursuant to the Trial Order. However, without waiving said objection, none at the present time. 6. Up-to-date PIP payout sheet on the Plaintiff. None. 7. Any and all statements taken by the Defendant of any witnesses with regard to any fact relevant to any fact in this case, such as were taken prior to the filing of suit in this matter. The Defendant objects to this Request as violating the work-product privilege of this Defendant. However, without waiving said objection, none. 8. Any and all photographs of any of the vehicles involved in the crash that is the subject of this lawsuit. None.CASE NO.: CACE20016958 (14) 9. Any and all estimates of repair or statements concerning the nature and extent of damage to any of the vehicles involved in the accident. None. 10. Any and all writings, memorandums, notes or other materials reflecting examination by the Defendant of any of the vehicles involved in the accident. None. 11. Any and all records reflecting the towing of any vehicles involved in the accident from the scene of the accident. None. 12. Any and all statements given by, or taken of the Plaintiff. No Recorded Statement. 13. Any and all medical records pertaining to the Plaintiff other than those provided to Defendant by Plaintiff's counsel. The Defendant objects to this Request as violating the work-product privilege of this Defendant. However, without waiving said objection, the Defendant will provide complete copies of any subpoenaed records in accordance with Florida Rules of Civil Procedure. 14. Any and all written or electronic communication between you and any vendor and/or manufacturer of the “EDR” (event data recorder), or “SDM” (sensing and diagnostic module) that was equipped in the subject vehicle that is alleged to have been involved in the incident, pertaining to the equipment in that vehicle, from the date of purchase to the current date. None. I HEREBY CERTIFY that on December 11, 2020, the foregoing was electronically filed with the Florida Courts E-Filing Portal and that as a registered participant of the Portal I have effectuated service through the Portal in compliance with Rule 2.516, Fla. R. Jud. Admin., on David D. Hernandez, Esq., pleadings@kirwanspellacy.com, Kirwan Spellacy & Danner, P.A.,CASE NO.: CACE20016958 (14) 200 South Andrews Ave., 8th Floor, Fort Lauderdale, FL 33301 and Joseph N. Nusbaum, Esq., joe@lawbni.com, Brottman Nusbaum & Ibrahim, 137 W. Royal Palm Road, Boca Raton, FL 33432. NICHOLAS J. RYAN & ASSOCIATES 110 S. E. 6th Street, Suite 2100 Fort Lauderdale, FL 33301 Telephone: (954) 627-9401 E-mail for service (FL R. Jud. Admin. 2.516): flor.law-lisabaligian.294019@statefarm.com Lisa J. Baligian, Esq. Florida Bar No.: 956181 Attorney for Defendant, State Farm Mutual Automobile Insurance Company Attomeys and Staff of Nicholas J. Ryan & Associates are Employees of the Law Department of State Farm Mutual Automobile Insurance Company