On January 16, 1973 a
Party Discovery
was filed
involving a dispute between
Olivia Charney,
and
Scott Lilley,
for OTHER NEGLIGENCE
in the District Court of Palm Beach County.
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Filing # 140146350 E-Filed 12/10/2021 03:25:50 PM
IN THE CIRCUIT COURT OF THE 154
JUDICIAL CIRCUIT, IN AND FOR
PALM BEACH COUNTY, FLORIDA
CASE NO: 502020CA009842XXXXMBAA
OLIVIA CHARNEY,
Plaintiff,
v.
SCOTT LILLEY,
Defendant.
/
DEFENDANT’S REQUEST FOR PRODUCTION OF ELECTRONIC MEDIA TO PLAINTIFF
COMES NOW, the Defendant, SCOTT LILLEY, by and through undersigned counsel, and
pursuant to the Florida Rules of Civil Procedure, requests the PLAINTIFF, OLIVIA CHARNEY,
to produce the following for inspection and/or copying, at the offices of KELLER, KELLER,
CARACUZZO, COX & BELLUCCIO:
1. For each social networking account listed in response to the Electronic Media
Interrogatories, please provide copies or screenshots of all photographs associated with that
account that depict the Plaintiff, during the two years prior to the date of the incident that
is the subject of this lawsuit. See Nucci v. Target Corp. 162 So.3d 146 (Fla 4" DCA
2015).
2. For each social networking account listed in response to the Electronic Media
Interrogatories, please provide copies or screenshots of all photographs associated with that
account that depict the Plaintiff, from the date of the incident that is the subject of this
lawsuit to the present. See Nucci v. Target Corp. 162 So3d 146 (Fla. 4" DCA 2015).
“** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 12/10/2021 03:25:50 PM ***I HEREBY CERTIFY that a true copy of the foregoing has been furnished by email
service this 10" day of December, 2021, to Jason D. Weisser, Esquire, Schuler, Halvorson,
Weisser, Zoeller & Overbeck, PA, jweisser@shw-law.com; michele@shw-law.com and
rehew@shw-law.com.
Keller, Keller, Caracuzzo, Cox & Belluccio
Attorneys for Defendant
224 Datura Street, Suite 1205
West Palm Beach, FL 33401
Telephone: 561-655-3133
Fax No: 561-655-3676
Email: je¢@kkecb.com
Secondary: kcarlsen@kkecb.com
By: __/e/ fonathan Ut. (ox.
Jonathan M. Cox
FL Bar No: 0152307
Document Filed Date
January 15, 2052
Case Filing Date
January 16, 1973
Category
OTHER NEGLIGENCE
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Filing # 140146350 E-Filed 12/10/2021 03:25:50 PM IN THE CIRCUIT COURT OF THE 154 JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 502020CA009842XXXXMBAA OLIVIA CHARNEY, Plaintiff, v. SCOTT LILLEY, Defendant. / DEFENDANT’S REQUEST FOR PRODUCTION OF ELECTRONIC MEDIA TO PLAINTIFF COMES NOW, the Defendant, SCOTT LILLEY, by and through undersigned counsel, and pursuant to the Florida Rules of Civil Procedure, requests the PLAINTIFF, OLIVIA CHARNEY, to produce the following for inspection and/or copying, at the offices of KELLER, KELLER, CARACUZZO, COX & BELLUCCIO: 1. For each social networking account listed in response to the Electronic Media Interrogatories, please provide copies or screenshots of all photographs associated with that account that depict the Plaintiff, during the two years prior to the date of the incident that is the subject of this lawsuit. See Nucci v. Target Corp. 162 So.3d 146 (Fla 4" DCA 2015). 2. For each social networking account listed in response to the Electronic Media Interrogatories, please provide copies or screenshots of all photographs associated with that account that depict the Plaintiff, from the date of the incident that is the subject of this lawsuit to the present. See Nucci v. Target Corp. 162 So3d 146 (Fla. 4" DCA 2015). “** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 12/10/2021 03:25:50 PM ***I HEREBY CERTIFY that a true copy of the foregoing has been furnished by email service this 10" day of December, 2021, to Jason D. Weisser, Esquire, Schuler, Halvorson, Weisser, Zoeller & Overbeck, PA, jweisser@shw-law.com; michele@shw-law.com and rehew@shw-law.com. Keller, Keller, Caracuzzo, Cox & Belluccio Attorneys for Defendant 224 Datura Street, Suite 1205 West Palm Beach, FL 33401 Telephone: 561-655-3133 Fax No: 561-655-3676 Email: je¢@kkecb.com Secondary: kcarlsen@kkecb.com By: __/e/ fonathan Ut. (ox. Jonathan M. Cox FL Bar No: 0152307