On December 04, 2019 a
Party Discovery
was filed
involving a dispute between
Murdock, Shae Kristine,
and
Hinson, Leonard Francis,
Lynn Haven Police Department,
for DISCRIMINATION EMPLOYMENT/OTHER
in the District Court of Bay County.
Preview
Filing # 116187495 E-Filed 11/05/2020 09:53:39 AM
IN THE CIRCUIT COURT OF THE
FOURTEENTH JUDICIAL CIRCUIT,
IN AND FOR BAY COUNTY, FLORIDA
SHAE KRISTINE MURDOCK, CASE NO.: 19-CA-4417
FLA BAR NO.: 0739685
Plaintiff,
ve
CITY OF LYNN HAVEN, and
LEONARD FRANCIS HINSON,
individually,
Defendants.
/
PLAINTIFF’S SUPPLEMENTAL RESPONSE TO
DEFENDANT CITY’S SECOND REQUEST FOR PRODUCTION
Plaintiff, SHAE KRISTINE MURDOCK, by and through her undersigned counsel,
supplements his response to Defendant City’s Second Request for Production of Documents as
follows:
1. All bank statements reflecting income, credits and debits from January 1, 2016 to present.
RESPONSE: Please see attached.
2. All business tax returns from 2016 to present.
RESPONSE: Please see attached.
3. All permits or licenses issued to Plaintiff by the City of Lynn Haven, Florida.
RESPONSE: There are no documents responsive to this request in Plaintiff's possession,
custody, or control.
4, All permits or licenses issued to Plaintiff by Bay County, Florida.
RESPONSE: There are no documents responsive to this request in Plaintiffs possession,
custody, or control.
5. All permits or licenses issued to Plaintiff by the State of Florida.RESPONSE: Please see attached.
6. All certificates showing successful completion of cosmetology school.
RESPONSE: Please see response number 5.
Respectfully submitted,
/s/ Marie A. Mattox
Marie A. Mattox [FBN 0739685]
MARIE A. MATTOX, P. A.
203 North Gadsden Street
Tallahassee, FL 32301
Telephone: (850) 383-4800
Facsimile: (850) 383-4801
marie@mattoxlaw.com
susan@mattoxlaw.com
ATTORNEYS FOR PLAINTIFF
CERTIFICATE OF SERVICE
1 HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon
all counsel of record through the e-portal and electronic communication this 5" day of November
2020.
/s/ Marie A. Mattox
Marie A. Mattox
Document Filed Date
November 05, 2020
Case Filing Date
December 04, 2019
Category
DISCRIMINATION EMPLOYMENT/OTHER
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing # 116187495 E-Filed 11/05/2020 09:53:39 AM IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT, IN AND FOR BAY COUNTY, FLORIDA SHAE KRISTINE MURDOCK, CASE NO.: 19-CA-4417 FLA BAR NO.: 0739685 Plaintiff, ve CITY OF LYNN HAVEN, and LEONARD FRANCIS HINSON, individually, Defendants. / PLAINTIFF’S SUPPLEMENTAL RESPONSE TO DEFENDANT CITY’S SECOND REQUEST FOR PRODUCTION Plaintiff, SHAE KRISTINE MURDOCK, by and through her undersigned counsel, supplements his response to Defendant City’s Second Request for Production of Documents as follows: 1. All bank statements reflecting income, credits and debits from January 1, 2016 to present. RESPONSE: Please see attached. 2. All business tax returns from 2016 to present. RESPONSE: Please see attached. 3. All permits or licenses issued to Plaintiff by the City of Lynn Haven, Florida. RESPONSE: There are no documents responsive to this request in Plaintiff's possession, custody, or control. 4, All permits or licenses issued to Plaintiff by Bay County, Florida. RESPONSE: There are no documents responsive to this request in Plaintiffs possession, custody, or control. 5. All permits or licenses issued to Plaintiff by the State of Florida.RESPONSE: Please see attached. 6. All certificates showing successful completion of cosmetology school. RESPONSE: Please see response number 5. Respectfully submitted, /s/ Marie A. Mattox Marie A. Mattox [FBN 0739685] MARIE A. MATTOX, P. A. 203 North Gadsden Street Tallahassee, FL 32301 Telephone: (850) 383-4800 Facsimile: (850) 383-4801 marie@mattoxlaw.com susan@mattoxlaw.com ATTORNEYS FOR PLAINTIFF CERTIFICATE OF SERVICE 1 HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon all counsel of record through the e-portal and electronic communication this 5" day of November 2020. /s/ Marie A. Mattox Marie A. Mattox