On December 04, 2019 a
Party Notice
was filed
involving a dispute between
Odom, Patsy J,
and
Tower Hilll Signature Insurance Company,
for INSURANCE CLAIM
in the District Court of Bay County.
Preview
Filing # 115651171 E-Filed 10/27/2020 09:55:59 AM
IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT
IN AND FOR BAY COUNTY, FLORIDA
PATSY J. ODOM,
Plaintiff,
v. Case No.: 19-004405 CA.
TOWER HILL SIGNATURE INSURANCE
COMPANY, a Florida insurance corporation,
Defendant.
/
DEFENDANT’S NOTICE OF OBJECTION TO
PLAINTIFF’S NOTICE OF PRODUCTION FROM NON-PARTY
Defendant, TOWER HILL SIGNATURE INSURANCE COMPANY (“Tower Hill”), by
and through the undersigned counsel and pursuant to Rule 1.351, Florida Rules of Civil
Procedure, hereby objects to Plaintiff's Notice of Production from Non-Party and Subpoena
Duces Tecum Without Deposition dated October 14, 2020, attached as “Exhibit A”, directed to:
Todd Alford,
Arcadia ICR, LLC
3355 Addison Drive
Pensacola, Florida
Defendant objects on the grounds that the subpoena to Arcadia ICR, LLC has been
withdrawn as an expert witness for purposes of trial and accordingly, any file materials are
protected from disclosure by the work product doctrine and Florida law. Additionally, the
subpoena is overly broad, not reasonably calculated to lead to the discovery of admissible
evidence, exceeds the scope of permissible discovery under Florida law and the Florida Rules of
Civil Procedure, and seeks documentation protected from disclosure by the work product
doctrine and Florida law.
Page 1 of 24/ Nicole M. Fluet
NICOLE M. FLUET, Fla. Bar No. 91077
nfluct@gallowaylawfirm.com
SARAH K. CULLETON, Fla. Bar No. 1015231
sculleton@gallowaylawfirm.com
Galloway, Johnson, Tompkins, Burr & Smith, PLC
400 N. Ashley Drive, Suite 1000
Tampa, Florida 33602
(813) 977-1200
(813) 977-1288 (facsimile)
tampaservice@gallowaylawfirm.com
Counsel for Defendant, Tower Hill Signature
Insurance Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to
the following via the Florida Courts E-Filing Portal and/or electronic mail delivery this 26" day
of October, 2020:
Clark Hamilton, Jr., Esq.
Tyler & Hamilton, P.A.
4741 Atlantic Boulevard, Suite A
Jacksonville, FL 32207
Telephone: 904-398-9999
Facsimile: 904-398-0806
courtdocs@floridainsurancelawyers.com
tandhpa@bellsouth.net
Counsel for Plaintiff
Jay Manuel, Esq.
Manuel & Thompson, P.A.
120 Richard Jackson Boulevard, Suite 200
Panama City, Florida 325407
Phone: 850-785-5555
Fax: 850-785-0133
jay@manuelthompson.com
velinda@manuelthompson.com
tim@manuelthompson.com
Counsel for Plaintiff
[o] Nicale M. Fluct
NICOLE M. FLUET
SARAH K. CULLETON
Page 2 of 2
Document Filed Date
October 27, 2020
Case Filing Date
December 04, 2019
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Filing # 115651171 E-Filed 10/27/2020 09:55:59 AM IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA PATSY J. ODOM, Plaintiff, v. Case No.: 19-004405 CA. TOWER HILL SIGNATURE INSURANCE COMPANY, a Florida insurance corporation, Defendant. / DEFENDANT’S NOTICE OF OBJECTION TO PLAINTIFF’S NOTICE OF PRODUCTION FROM NON-PARTY Defendant, TOWER HILL SIGNATURE INSURANCE COMPANY (“Tower Hill”), by and through the undersigned counsel and pursuant to Rule 1.351, Florida Rules of Civil Procedure, hereby objects to Plaintiff's Notice of Production from Non-Party and Subpoena Duces Tecum Without Deposition dated October 14, 2020, attached as “Exhibit A”, directed to: Todd Alford, Arcadia ICR, LLC 3355 Addison Drive Pensacola, Florida Defendant objects on the grounds that the subpoena to Arcadia ICR, LLC has been withdrawn as an expert witness for purposes of trial and accordingly, any file materials are protected from disclosure by the work product doctrine and Florida law. Additionally, the subpoena is overly broad, not reasonably calculated to lead to the discovery of admissible evidence, exceeds the scope of permissible discovery under Florida law and the Florida Rules of Civil Procedure, and seeks documentation protected from disclosure by the work product doctrine and Florida law. Page 1 of 24/ Nicole M. Fluet NICOLE M. FLUET, Fla. Bar No. 91077 nfluct@gallowaylawfirm.com SARAH K. CULLETON, Fla. Bar No. 1015231 sculleton@gallowaylawfirm.com Galloway, Johnson, Tompkins, Burr & Smith, PLC 400 N. Ashley Drive, Suite 1000 Tampa, Florida 33602 (813) 977-1200 (813) 977-1288 (facsimile) tampaservice@gallowaylawfirm.com Counsel for Defendant, Tower Hill Signature Insurance Company CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to the following via the Florida Courts E-Filing Portal and/or electronic mail delivery this 26" day of October, 2020: Clark Hamilton, Jr., Esq. Tyler & Hamilton, P.A. 4741 Atlantic Boulevard, Suite A Jacksonville, FL 32207 Telephone: 904-398-9999 Facsimile: 904-398-0806 courtdocs@floridainsurancelawyers.com tandhpa@bellsouth.net Counsel for Plaintiff Jay Manuel, Esq. Manuel & Thompson, P.A. 120 Richard Jackson Boulevard, Suite 200 Panama City, Florida 325407 Phone: 850-785-5555 Fax: 850-785-0133 jay@manuelthompson.com velinda@manuelthompson.com tim@manuelthompson.com Counsel for Plaintiff [o] Nicale M. Fluct NICOLE M. FLUET SARAH K. CULLETON Page 2 of 2