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Filing # 118455916 E-Filed 12/18/2020 12:25:24 PM
IN THE CIRCUIT COURT OF THE14”™
JUDICIAL CIRCUIT IN AND
FOR BAY COUNTY, FLORIDA
CASE NO.: 19004412CA
JAMIE AND JENNIFER CARR,
Plaintiffs,
v.
GULFSTREAM PROPERTY & CASUALTY
INSURANCE COMPANY
Defendant.
/
PLAINTIFFS’ MOTION TO COMPEL DEFENDANT’S VERIFIED RESPONSES TO
INTERROGATORIES AND FOR SANCTIONS
COME NOW the Plaintiffs, JAMIE AND JENNIFER CARR, by and through their
undersigned counsel, hereby moves this Honorable Court for an entry of an Order compelling
Defendant, GULFSTREAM PROPERTY & CASUALTY INSURANCE COMPANY, to comply
with outstanding discovery requests in this cause within ten (10) days and for Sanctions, as grounds
therefore, state as follows:
1. Plaintiffs propounded their First set of Interrogatories upon Defendant on
December 26, 2019.
2. To date, Defendant has not filed verified responses to Plaintiffs’ First set of
Interrogatories.
3. Undersigned counsel notified counsel for Defendant on October 22 and November
17, 2020, by email correspondence of the failure to respond, and attempted, in good faith, to secure
the requested discovery to no avail. See attached email correspondence marked as Exhibit “A”.
4. That Plaintiffs are prejudiced in the preparation of this case by Defendant’s failure toPage 2 of 2
comply with this discovery.
WHEREFORE, Plaintiffs, JAMIE AND JENNIFER CARR, respectfully request
that this Honorable Court (1) enter an Order compelling the Defendant, GULFSTREAM
PROPERTY & CASUALTY INSURANCE COMPANY, to file verified responses to Plaintiffs’
First Set of Interrogatories within ten (10) days, (2) enter an Order sanctioning Defendant,
GULFSTREAM PROPERTY & CASUALTY INSURANCE COMPANY pursuant to Rule
1.380(2); and (3) any and all relief that this Honorable Court may deem just and proper.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served on
this 18th day of December, 2020, via the Florida E-Filing Portal to: Kathy J. Maus, Esq., Butler
Weihmuller Katz Craig LLP, 400 North Ashley Drive, Suite 2300, Tampa, FL 33602,
kmaus@butler. legal.
GED LAWYERS, LLP
Attorneys for the Plaintiff
7171 North Federal Highway
Boca Raton, FL 33487
Telephone: (561) 995-1966
Facsimile: (561) 241-0812
Primary Email: pdlitlaw@gedlawyers.com
Secondary Email: bgoetsch@gedlawyers.com
BY: /s/Scott M. Rosso
SCOTT M. ROSSO, ESQ.
Florida Bar No.: 505757
DAVID R. SHAHEEN, ESQ.
Florida Bar No.: 0117947Beliana Goetsch
From: Beliana Goetsch
Sent: Thursday, October 22, 2020 4:55 PM
To: Rick Parker; Andreka Ruddock-Pinnock
Ce: Scott Rosso; David Shaheen
Subject: RE: CARR, JAMIE AND JENNIFER VS. GULFSTREAM PROPERTY AND CASUALTY
INSURANCE COMPANY:
Good Afternoon Mr. Parker,
Please advise as to when we can expect verified responses to interrogatories.
EXHIBIT
Thank you,
A
Beliana Goetsch
Paralegal
GED LAWYERS, LLP
7171 North Federal Highway
Boca Raton, FL 33487
O: 561.995.1966
D: 561.910.8251
F: 561.241.0812
www.gediawyers.com
GED LAWYERS, u»
ATTORNEYS AT Law
From: Rick Parker
Sent: Thursday, October 22, 2020 4:39 PM
To: Andreka Ruddock-Pinnock ; Beliana Goetsch
Subject: RE: CARR, JAMIE AND JENNIFER VS. GULFSTREAM PROPERTY AND CASUALTY INSURANCE COMPANY:
CAUTION: This email originated from outside of the organization. Exercise caution when clicking on links or
opening attachments even if you recognize the sender.
| have no idea who he is. Someone on your side must have spoken to Jeremy Rettig to find out the guy’s last
name. | would suggest following up with him.
Rick Parker
Partner
Butler Weihmuller Katz Craig LLP
From: Andreka Ruddock-Pinnock
Sent: Thursday, October 22, 2020 4:25 PM
To: 'Beliana Goetsch' Beliana Goetsch
From: Beliana Goetsch
Sent: Tuesday, November 17, 2020 12:03 PM
To: Andreka Ruddock-Pinnock
Ce: Rick Parker
Subject: RE: CARR, JAMIE AND JENNIFER VS. GULFSTREAM PROPERTY AND CASUALTY
INSURANCE COMPANY:
Hi Andreka,
Sorry about that! Please disregard for now.
Please advise as to when we can expect verified responses to interrogatories.
Thank you!
Beliana Goetsch
Paralegal
GED LAWYERS, LLP
7171 North Federal Highway
Boca Raton, FL 33487
O: 561.995.1966
D: 561.910.8251
F: 561.241.0812
www.gedlawyers.com
GED LAWYERS, u»
ATTORNEYS AT Law
From: Andreka Ruddock-Pinnock
Sent: Tuesday, November 17, 2020 11:48 AM
To: Beliana Goetsch
Ce: Rick Parker
Subject: RE: CARR, JAMIE AND JENNIFER VS. GULFSTREAM PROPERTY AND CASUALTY INSURANCE COMPANY:
CAUTION: This email originated from outside of the organization. Exercise caution when clicking on links or
opening attachments even if you recognize the sender.
Hi Beliana,
Is this deposition still going forward? | have a hold on Rick's calendar for 12/21 at 10am. If it’s not going
forward, we would like to use this date for something else. Please let me know!
Thank you!
Preview
Filing # 118455916 E-Filed 12/18/2020 12:25:24 PM IN THE CIRCUIT COURT OF THE14”™ JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA CASE NO.: 19004412CA JAMIE AND JENNIFER CARR, Plaintiffs, v. GULFSTREAM PROPERTY & CASUALTY INSURANCE COMPANY Defendant. / PLAINTIFFS’ MOTION TO COMPEL DEFENDANT’S VERIFIED RESPONSES TO INTERROGATORIES AND FOR SANCTIONS COME NOW the Plaintiffs, JAMIE AND JENNIFER CARR, by and through their undersigned counsel, hereby moves this Honorable Court for an entry of an Order compelling Defendant, GULFSTREAM PROPERTY & CASUALTY INSURANCE COMPANY, to comply with outstanding discovery requests in this cause within ten (10) days and for Sanctions, as grounds therefore, state as follows: 1. Plaintiffs propounded their First set of Interrogatories upon Defendant on December 26, 2019. 2. To date, Defendant has not filed verified responses to Plaintiffs’ First set of Interrogatories. 3. Undersigned counsel notified counsel for Defendant on October 22 and November 17, 2020, by email correspondence of the failure to respond, and attempted, in good faith, to secure the requested discovery to no avail. See attached email correspondence marked as Exhibit “A”. 4. That Plaintiffs are prejudiced in the preparation of this case by Defendant’s failure toPage 2 of 2 comply with this discovery. WHEREFORE, Plaintiffs, JAMIE AND JENNIFER CARR, respectfully request that this Honorable Court (1) enter an Order compelling the Defendant, GULFSTREAM PROPERTY & CASUALTY INSURANCE COMPANY, to file verified responses to Plaintiffs’ First Set of Interrogatories within ten (10) days, (2) enter an Order sanctioning Defendant, GULFSTREAM PROPERTY & CASUALTY INSURANCE COMPANY pursuant to Rule 1.380(2); and (3) any and all relief that this Honorable Court may deem just and proper. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been served on this 18th day of December, 2020, via the Florida E-Filing Portal to: Kathy J. Maus, Esq., Butler Weihmuller Katz Craig LLP, 400 North Ashley Drive, Suite 2300, Tampa, FL 33602, kmaus@butler. legal. GED LAWYERS, LLP Attorneys for the Plaintiff 7171 North Federal Highway Boca Raton, FL 33487 Telephone: (561) 995-1966 Facsimile: (561) 241-0812 Primary Email: pdlitlaw@gedlawyers.com Secondary Email: bgoetsch@gedlawyers.com BY: /s/Scott M. Rosso SCOTT M. ROSSO, ESQ. Florida Bar No.: 505757 DAVID R. SHAHEEN, ESQ. Florida Bar No.: 0117947Beliana Goetsch From: Beliana Goetsch Sent: Thursday, October 22, 2020 4:55 PM To: Rick Parker; Andreka Ruddock-Pinnock Ce: Scott Rosso; David Shaheen Subject: RE: CARR, JAMIE AND JENNIFER VS. GULFSTREAM PROPERTY AND CASUALTY INSURANCE COMPANY: Good Afternoon Mr. Parker, Please advise as to when we can expect verified responses to interrogatories. EXHIBIT Thank you, A Beliana Goetsch Paralegal GED LAWYERS, LLP 7171 North Federal Highway Boca Raton, FL 33487 O: 561.995.1966 D: 561.910.8251 F: 561.241.0812 www.gediawyers.com GED LAWYERS, u» ATTORNEYS AT Law From: Rick Parker Sent: Thursday, October 22, 2020 4:39 PM To: Andreka Ruddock-Pinnock ; Beliana Goetsch Subject: RE: CARR, JAMIE AND JENNIFER VS. GULFSTREAM PROPERTY AND CASUALTY INSURANCE COMPANY: CAUTION: This email originated from outside of the organization. Exercise caution when clicking on links or opening attachments even if you recognize the sender. | have no idea who he is. Someone on your side must have spoken to Jeremy Rettig to find out the guy’s last name. | would suggest following up with him. Rick Parker Partner Butler Weihmuller Katz Craig LLP From: Andreka Ruddock-Pinnock Sent: Thursday, October 22, 2020 4:25 PM To: 'Beliana Goetsch' Beliana Goetsch From: Beliana Goetsch Sent: Tuesday, November 17, 2020 12:03 PM To: Andreka Ruddock-Pinnock Ce: Rick Parker Subject: RE: CARR, JAMIE AND JENNIFER VS. GULFSTREAM PROPERTY AND CASUALTY INSURANCE COMPANY: Hi Andreka, Sorry about that! Please disregard for now. Please advise as to when we can expect verified responses to interrogatories. Thank you! Beliana Goetsch Paralegal GED LAWYERS, LLP 7171 North Federal Highway Boca Raton, FL 33487 O: 561.995.1966 D: 561.910.8251 F: 561.241.0812 www.gedlawyers.com GED LAWYERS, u» ATTORNEYS AT Law From: Andreka Ruddock-Pinnock Sent: Tuesday, November 17, 2020 11:48 AM To: Beliana Goetsch Ce: Rick Parker Subject: RE: CARR, JAMIE AND JENNIFER VS. GULFSTREAM PROPERTY AND CASUALTY INSURANCE COMPANY: CAUTION: This email originated from outside of the organization. Exercise caution when clicking on links or opening attachments even if you recognize the sender. Hi Beliana, Is this deposition still going forward? | have a hold on Rick's calendar for 12/21 at 10am. If it’s not going forward, we would like to use this date for something else. Please let me know! Thank you!