Party Discovery: SMITH, JAMES R vs. SECURITY FIRST INSURANCE COMPANY

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                                Filing # 111530277 E-Filed 08/10/2020 01:32:27 PM

IN THE CIRCUIT COURT OF THE 14" JUDICIAL CIRCUIT
IN AND FOR BAY COUNTY, FLORIDA
CIVIL DIVISION

CASE NO.: 19004406CA
JAMES R. SMITH,

Plaintiff,
vs.

SECURITY FIRST INSURANCE
COMPANY,

Defendant.
/

PLAINTIFF’S RESPONSE TO DEFENDANT’S FIRST REQUEST FOR
PRODUCTION

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:

1. In response to Request No. 1, Plaintiff has attached any and all documents in

his possession hereto and Defendant retains documents in addition to and

beyond what Plaintiff possesses;

2. In response to Request No. 2, Plaintiff has attached any and all documents in
his possession hereto;
3. In response to Request No. 3, Plaintiff has attached any and all documents in

his possession hereto;
4. In response to Request No. 4, Plaintiff has attached any and all documents in

his possession hereto;10.

11.

In response to Request No. 5, Plaintiff has attached any and all documents in
his possession hereto;

In response to Request No. 6, Plaintiff has attached any and all documents in
his possession hereto;

In response to Request No. 7, Objection; vague, over broad, unduly
burdensome, notwithstanding, Plaintiff has attached any and all documents in
his possession hereto and Defendant retains documents in addition to and
beyond what Plaintiff possesses;

In response to Request No. 8, Objection; vague, over broad, unduly
burdensome, notwithstanding, Plaintiff has attached any and all documents in
his possession hereto and Defendant retains documents in addition to and
beyond what Plaintiff possesses;

In response to Request No. 9, Objection; vague, over broad, unduly
burdensome, notwithstanding, Plaintiff has attached any and all documents in
his possession hereto and Defendant retains documents in addition to and
beyond what Plaintiff possesses;

In response to Request No. 10, This matter is not presently set for trial and
Plaintiff has not decided what it will produce at trial at this early stage; further,
see Plaintiff's response to Interrogatory No. 6 of “Defendant’s First Set of
Interrogatories to Plaintiff” for further details regarding experts;

In response to Request No. 11, Objection; vague, over broad, unduly

burdensome, notwithstanding, Plaintiff has attached any and all documents inhis possession hereto and Defendant retains documents in addition to and
beyond what Plaintiff possesses;

12. In response to Request No. 12, Plaintiff has attached any and all documents in
his possession hereto;

13. In response to Request No. 13, Objection; vague, over broad, unduly
burdensome, notwithstanding, Plaintiff has attached any and all documents in
his possession hereto and Defendant retains documents in addition to and
beyond what Plaintiff possesses;

14. In response to Request No. 14, Objection; vague, over broad, unduly
burdensome, notwithstanding, none in Plaintiff's possession, custody, and/or
control;

15. In response to Request No. 15, Said items have been requested and will be

provided to Defendant immediately upon receipt.

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@esklegal.com, and tiffany.coleman@csklegal.com.

KANDELL, KANDELL & PETRIE
Attorneys for Plaintiffs
2665 South Bayshore Drive

 

Fla. Bar. No. 079014