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Filing # 110883880 E-Filed 07/28/2020 10:11:27 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,
v.
CITY OF LYNN HAVEN, and
LEONARD FRANCIS HINSON,
individually,
Defendants.
/
PLAINTIFF’S RESPONSE TO
DEFENDANT CITY’S SECOND REQ’ T FOR PRODUCTION
Plaintiff, SHAE KRISTINE MURDOCK, by and through her undersigned counsel,
responds 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:
Plaintiff objects to the extent that this request overly broad, seek records that are irrelevant, are
not reasonably calculated to lead to the discovery of admissible evidence in this case, seek
confidential financial and other personal identifying information about Plaintiff that has no
bearing whatsoever on any of the issues in this case as between Defendant and Plaintiff.
Additionally, the information sought is a fishing expedition not geared to obtain documents that
would be admissible at trial and are designed to harass, embarrass, annoy, and oppress Plaintiff.
Rather than laser focusing on the discrete issues in this case; namely, whether Defendant is liable
for false imprisonment/arrest and, if so, what is the nature of Plaintiff's damages, Defendant is
instead trying to cast as wide a net as possible in discovery to annoy and harass Plaintiff.
2. All business tax returns from 2016 to present.
RESPONSE:
Plaintiff objects to the extent that this request overly broad, seek records that are irrelevant, are
not reasonably calculated to lead to the discovery of admissible evidence in this case, seek
confidential financial and other personal identifying information about Plaintiff that has no
bearing whatsoever on any of the issues in this case as between Defendant and Plaintiff.Additionally, the information sought is a fishing expedition not geared to obtain documents that
would be admissible at trial and are designed to harass, embarrass, annoy, and oppress Plaintiff.
Rather than laser focusing on the discrete issues in this case; namely, whether Defendant is liable
for false imprisonment/arrest and, if so, what is the nature of Plaintiff's damages, Defendant is
instead trying to cast as wide a net as possible in discovery to annoy and harass Plaintiff.
3. All permits or licenses issued to Plaintiff by the City of Lynn Haven, Florida.
RESPONSE:
Plaintiff objects to the extent that this request overly broad, seek records that are irrelevant, are
not reasonably calculated to lead to the discovery of admissible evidence in this case, seek
confidential financial and other personal identifying information about Plaintiff that has no
bearing whatsoever on any of the issues in this case as between Defendant and Plaintiff.
Additionally, the information sought is a fishing expedition not geared to obtain documents that
would be admissible at trial and are designed to harass, embarrass, annoy, and oppress Plaintiff.
Rather than laser focusing on the discrete issues in this case; namely, whether Defendant is liable
for false imprisonment/arrest and, if so, what is the nature of Plaintiff's damages, Defendant is
instead trying to cast as wide a net as possible in discovery to annoy and harass Plaintiff.
4. All permits or licenses issued to Plaintiff by Bay County, Florida.
RESPONSE:
Plaintiff objects to the extent that this request overly broad, seek records that are irrelevant, are
not reasonably calculated to lead to the discovery of admissible evidence in this case, seck
confidential financial and other personal identifying information about Plaintiff that has no
bearing whatsoever on any of the issues in this case as between Defendant and Plaintiff.
Additionally, the information sought is a fishing expedition not geared to obtain documents that
would be admissible at trial and are designed to harass, embarrass, annoy, and oppress Plaintiff.
Rather than laser focusing on the discrete issues in this case; namely, whether Defendant is liable
for false imprisonment/arrest and, if so, what is the nature of Plaintiff's damages, Defendant is
instead trying to cast as wide a net as possible in discovery to annoy and harass Plaintiff.
5. All permits or licenses issued to Plaintiff by the State of Florida.
RESPONSE:
Plaintiff objects to the extent that this request overly broad, seek records that are irrelevant, are
not reasonably calculated to lead to the discovery of admissible evidence in this case, seek
confidential financial and other personal identifying information about Plaintiff that has no
bearing whatsoever on any of the issues in this case as between Defendant and Plaintiff.
Additionally, the information sought is a fishing expedition not geared to obtain documents that
would be admissible at trial and are designed to harass, embarrass, annoy, and oppress Plaintiff.
Rather than laser focusing on the discrete issues in this case; namely, whether Defendant is liable
for false imprisonment/arrest and, if so, what is the nature of Plaintiff's damages, Defendant isinstead trying to cast as wide a net as possible in discovery to annoy and harass Plaintiff.
6. All certificates showing successful completion of cosmetology school.
RESPONSE:
Plaintiff objects to the extent that this request overly broad, seek records that are irrelevant, are
not reasonably calculated to lead to the discovery of admissible evidence in this case, seek
confidential financial and other personal identifying information about Plaintiff that has no
bearing whatsoever on any of the issues in this case as between Defendant and Plaintiff.
Additionally, the information sought is a fishing expedition not geared to obtain documents that
would be admissible at trial and are designed to harass, embarrass, annoy, and oppress Plaintiff.
Rather than laser focusing on the discrete issues in this case; namely, whether Defendant is liable
for false imprisonment/arrest and, if so, what is the nature of Plaintiff's damages, Defendant is
instead trying to cast as wide a net as possible in discovery to annoy and harass Plaintiff.
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 PLAINTIFFCERTIFICATE OF SERVICE
I 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 28" day of July
2020 to the attorneys listed below:
Kayla E. Platt Rady
J. David Marsey
dmarsey@rumberger.com
docketingorlando@rumberger.com
krady@rumberger.com
kradysecy@rumberger.com
RUMBERGER, KIRK,
& CALDWELL, P.A.
101 North Monroe Street, Suite 120
Tallahassee, FL 32301
Attorneys for Defendant,
City of Lynn Haven
Jeffrey S. Carter
jeff@jeffearterpa.com
service@jeffcarterpa.com
JEFF CARTER, P.A.
P.O. Box 228
Panama City, FL 32402
Attorney for Defendant,
Leonard Francis Hinson
/s/ Marie A. Mattox
Marie A. Mattox
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Filing # 110883880 E-Filed 07/28/2020 10:11:27 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, v. CITY OF LYNN HAVEN, and LEONARD FRANCIS HINSON, individually, Defendants. / PLAINTIFF’S RESPONSE TO DEFENDANT CITY’S SECOND REQ’ T FOR PRODUCTION Plaintiff, SHAE KRISTINE MURDOCK, by and through her undersigned counsel, responds 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: Plaintiff objects to the extent that this request overly broad, seek records that are irrelevant, are not reasonably calculated to lead to the discovery of admissible evidence in this case, seek confidential financial and other personal identifying information about Plaintiff that has no bearing whatsoever on any of the issues in this case as between Defendant and Plaintiff. Additionally, the information sought is a fishing expedition not geared to obtain documents that would be admissible at trial and are designed to harass, embarrass, annoy, and oppress Plaintiff. Rather than laser focusing on the discrete issues in this case; namely, whether Defendant is liable for false imprisonment/arrest and, if so, what is the nature of Plaintiff's damages, Defendant is instead trying to cast as wide a net as possible in discovery to annoy and harass Plaintiff. 2. All business tax returns from 2016 to present. RESPONSE: Plaintiff objects to the extent that this request overly broad, seek records that are irrelevant, are not reasonably calculated to lead to the discovery of admissible evidence in this case, seek confidential financial and other personal identifying information about Plaintiff that has no bearing whatsoever on any of the issues in this case as between Defendant and Plaintiff.Additionally, the information sought is a fishing expedition not geared to obtain documents that would be admissible at trial and are designed to harass, embarrass, annoy, and oppress Plaintiff. Rather than laser focusing on the discrete issues in this case; namely, whether Defendant is liable for false imprisonment/arrest and, if so, what is the nature of Plaintiff's damages, Defendant is instead trying to cast as wide a net as possible in discovery to annoy and harass Plaintiff. 3. All permits or licenses issued to Plaintiff by the City of Lynn Haven, Florida. RESPONSE: Plaintiff objects to the extent that this request overly broad, seek records that are irrelevant, are not reasonably calculated to lead to the discovery of admissible evidence in this case, seek confidential financial and other personal identifying information about Plaintiff that has no bearing whatsoever on any of the issues in this case as between Defendant and Plaintiff. Additionally, the information sought is a fishing expedition not geared to obtain documents that would be admissible at trial and are designed to harass, embarrass, annoy, and oppress Plaintiff. Rather than laser focusing on the discrete issues in this case; namely, whether Defendant is liable for false imprisonment/arrest and, if so, what is the nature of Plaintiff's damages, Defendant is instead trying to cast as wide a net as possible in discovery to annoy and harass Plaintiff. 4. All permits or licenses issued to Plaintiff by Bay County, Florida. RESPONSE: Plaintiff objects to the extent that this request overly broad, seek records that are irrelevant, are not reasonably calculated to lead to the discovery of admissible evidence in this case, seck confidential financial and other personal identifying information about Plaintiff that has no bearing whatsoever on any of the issues in this case as between Defendant and Plaintiff. Additionally, the information sought is a fishing expedition not geared to obtain documents that would be admissible at trial and are designed to harass, embarrass, annoy, and oppress Plaintiff. Rather than laser focusing on the discrete issues in this case; namely, whether Defendant is liable for false imprisonment/arrest and, if so, what is the nature of Plaintiff's damages, Defendant is instead trying to cast as wide a net as possible in discovery to annoy and harass Plaintiff. 5. All permits or licenses issued to Plaintiff by the State of Florida. RESPONSE: Plaintiff objects to the extent that this request overly broad, seek records that are irrelevant, are not reasonably calculated to lead to the discovery of admissible evidence in this case, seek confidential financial and other personal identifying information about Plaintiff that has no bearing whatsoever on any of the issues in this case as between Defendant and Plaintiff. Additionally, the information sought is a fishing expedition not geared to obtain documents that would be admissible at trial and are designed to harass, embarrass, annoy, and oppress Plaintiff. Rather than laser focusing on the discrete issues in this case; namely, whether Defendant is liable for false imprisonment/arrest and, if so, what is the nature of Plaintiff's damages, Defendant isinstead trying to cast as wide a net as possible in discovery to annoy and harass Plaintiff. 6. All certificates showing successful completion of cosmetology school. RESPONSE: Plaintiff objects to the extent that this request overly broad, seek records that are irrelevant, are not reasonably calculated to lead to the discovery of admissible evidence in this case, seek confidential financial and other personal identifying information about Plaintiff that has no bearing whatsoever on any of the issues in this case as between Defendant and Plaintiff. Additionally, the information sought is a fishing expedition not geared to obtain documents that would be admissible at trial and are designed to harass, embarrass, annoy, and oppress Plaintiff. Rather than laser focusing on the discrete issues in this case; namely, whether Defendant is liable for false imprisonment/arrest and, if so, what is the nature of Plaintiff's damages, Defendant is instead trying to cast as wide a net as possible in discovery to annoy and harass Plaintiff. 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 PLAINTIFFCERTIFICATE OF SERVICE I 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 28" day of July 2020 to the attorneys listed below: Kayla E. Platt Rady J. David Marsey dmarsey@rumberger.com docketingorlando@rumberger.com krady@rumberger.com kradysecy@rumberger.com RUMBERGER, KIRK, & CALDWELL, P.A. 101 North Monroe Street, Suite 120 Tallahassee, FL 32301 Attorneys for Defendant, City of Lynn Haven Jeffrey S. Carter jeff@jeffearterpa.com service@jeffcarterpa.com JEFF CARTER, P.A. P.O. Box 228 Panama City, FL 32402 Attorney for Defendant, Leonard Francis Hinson /s/ Marie A. Mattox Marie A. Mattox