On December 04, 2019 a
Party Discovery
was filed
involving a dispute between
Smith, James R,
Smith, Tessa,
and
Security First Insurance Company,
for INSURANCE CLAIM
in the District Court of Bay County.
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Filing # 111659151 E-Filed 08/12/2020 11:14:06 AM
IN THE CIRCUIT COURT OF THE 14" JUDICIAL CIRCUIT
IN AND FOR BAY COUNTY, FLORIDA
JAMES R. SMITH,
Plaintiff, CIVIL DIVISION
VS.
CASE NO.: 19004406CA
SECURITY FIRST INSURANCE
COMPANY,
Defendant.
/
PLAINTIFF’S AMENDED RESP* IE TO DEFENDANT’S FIRST REQUEST FOR
PRODUCTION NO. 15
Plaintiff, JAMES R. SMITH, by and through the undersigned counsel and pursuant
to the applicable Florida Rules of Civil Procedure, hereby file and respond to the Request for
Production filed by Defendant, SECURITY FIRST INSURANCE COMPANY, as follows:
15. In response to Request No. 15, Attached hereto.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was
furnished by Eservice on of August, 2020, to: Katherine Moran, Esq., and
Paydon R. Broeder, Esq., at: Katherine.moran@csklegal.com,
paydon.broeder@ecsklegal.com, and tiffany.coleman@csklegal.com.
KANDELL, KANDELL & PETRIE
Attorneys for Plaintiffs
utir Bayshore Drive
dza, Suite 601
Fla} Bar. No. 079014
Document Filed Date
August 12, 2020
Case Filing Date
December 04, 2019
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Filing # 111659151 E-Filed 08/12/2020 11:14:06 AM IN THE CIRCUIT COURT OF THE 14" JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA JAMES R. SMITH, Plaintiff, CIVIL DIVISION VS. CASE NO.: 19004406CA SECURITY FIRST INSURANCE COMPANY, Defendant. / PLAINTIFF’S AMENDED RESP* IE TO DEFENDANT’S FIRST REQUEST FOR PRODUCTION NO. 15 Plaintiff, JAMES R. SMITH, by and through the undersigned counsel and pursuant to the applicable Florida Rules of Civil Procedure, hereby file and respond to the Request for Production filed by Defendant, SECURITY FIRST INSURANCE COMPANY, as follows: 15. In response to Request No. 15, Attached hereto. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by Eservice on of August, 2020, to: Katherine Moran, Esq., and Paydon R. Broeder, Esq., at: Katherine.moran@csklegal.com, paydon.broeder@ecsklegal.com, and tiffany.coleman@csklegal.com. KANDELL, KANDELL & PETRIE Attorneys for Plaintiffs utir Bayshore Drive dza, Suite 601 Fla} Bar. No. 079014