On November 01, 2012 a
Party Discovery
was filed
involving a dispute between
Robertson Trustee, Karen J,
and
Ryan Ii, Robert P,
Ryan, Mark R,
for Circuit Civil
in the District Court of Lake County.
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Filing # 15438321 Electronically Filed 07/01/2014 12:57:28 PM
IN THE CIRCUIT COURT FOR LAKE COUNTY,
FLORIDA
Case No. 2012-CA-3843
KAREN J. ROBERTSON, Trustee of the
ROSEMARY A. RYAN REVOCABLE TRUST,
JOINED BY DIANA M. DAVENPORT,
Plaintiffs,
VS.
MARK R. RYAN and ROBERT P. RYAN, II,
Defendants.
/
DEFENDANTS’ FIRST REQUEST TO PRODUCE
DEFENDANTS, pursuant to Rule 1.350, Florida Rules of Civil Procedure, hereby request
that Plaintiffs produce the following items:
All electronic mail between Karen J. Robertson and Diana M. Davenport regarding
the probate/estate of Rosemary A. Ryan, the Rosemary A. Ryan Revocable Trust and the
home of Rosemary A. Ryan from Rosemary A. Ryan’s date of death to the present.
In support of Defendants’ First Request to Produce, it is shown that the electronic mail
being requested is believed to be in the possession, custody or control of the parties to whom this
Request is directed. The information sought is relevant to the subject matter of this action and can
be reasonably calculated to lead to the discovery of admissible evidence.
It is requested that production of the above-referenced material be made within thirty five
(35) days of the date of the Certificate of Service hereof.
Production may be made via electronic mail, U.S. Mail, hand-delivery or facsimile to the
office of Robert C. Wilkins, Jr., P-L., or Plantiffs may permit the undersigned, or someone acting
*** FILED: LAKE COUNTY, FL NEIL KELLY, CLERK. ***on behalf of the undersigned, to inspect and copy each original of the items listed above at the
office of Robert C. Wilkins, Jr., P.L., or at such other mutually convenient location.
/s/ Robert C. Wilkins, Jr.
Robert C. Wilkins, Jr., B.C.S.
Florida Bar No.: 377732
ROBERT C. WILKINS, JR., P.L.
341 N. Maitland Avenue, Suite 346
Maitland, Florida 32751
407-539-2798 (telephone)
407-539-1995 (facsimile)
Attorney for DEFENDANTS
Service@wilkins'
CLA@wilkinslegal.com
CERTIFICATE OF SERVICE
THEREBY CERTIFY that a true copy of the foregoing has been electronically filed with
the Court using the Portal as a means of service to David E. Cauthen, Esquire, attorney for
Plaintiffs, on this 1“ day of July, 2014.
/s/ Robert C. Wilkins Jr.
Robert C. Wilkins, Jr.
Document Filed Date
July 01, 2014
Case Filing Date
November 01, 2012
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Filing # 15438321 Electronically Filed 07/01/2014 12:57:28 PM IN THE CIRCUIT COURT FOR LAKE COUNTY, FLORIDA Case No. 2012-CA-3843 KAREN J. ROBERTSON, Trustee of the ROSEMARY A. RYAN REVOCABLE TRUST, JOINED BY DIANA M. DAVENPORT, Plaintiffs, VS. MARK R. RYAN and ROBERT P. RYAN, II, Defendants. / DEFENDANTS’ FIRST REQUEST TO PRODUCE DEFENDANTS, pursuant to Rule 1.350, Florida Rules of Civil Procedure, hereby request that Plaintiffs produce the following items: All electronic mail between Karen J. Robertson and Diana M. Davenport regarding the probate/estate of Rosemary A. Ryan, the Rosemary A. Ryan Revocable Trust and the home of Rosemary A. Ryan from Rosemary A. Ryan’s date of death to the present. In support of Defendants’ First Request to Produce, it is shown that the electronic mail being requested is believed to be in the possession, custody or control of the parties to whom this Request is directed. The information sought is relevant to the subject matter of this action and can be reasonably calculated to lead to the discovery of admissible evidence. It is requested that production of the above-referenced material be made within thirty five (35) days of the date of the Certificate of Service hereof. Production may be made via electronic mail, U.S. Mail, hand-delivery or facsimile to the office of Robert C. Wilkins, Jr., P-L., or Plantiffs may permit the undersigned, or someone acting *** FILED: LAKE COUNTY, FL NEIL KELLY, CLERK. ***on behalf of the undersigned, to inspect and copy each original of the items listed above at the office of Robert C. Wilkins, Jr., P.L., or at such other mutually convenient location. /s/ Robert C. Wilkins, Jr. Robert C. Wilkins, Jr., B.C.S. Florida Bar No.: 377732 ROBERT C. WILKINS, JR., P.L. 341 N. Maitland Avenue, Suite 346 Maitland, Florida 32751 407-539-2798 (telephone) 407-539-1995 (facsimile) Attorney for DEFENDANTS Service@wilkins' CLA@wilkinslegal.com CERTIFICATE OF SERVICE THEREBY CERTIFY that a true copy of the foregoing has been electronically filed with the Court using the Portal as a means of service to David E. Cauthen, Esquire, attorney for Plaintiffs, on this 1“ day of July, 2014. /s/ Robert C. Wilkins Jr. Robert C. Wilkins, Jr.