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Filing # 106095993 E-Filed 04/09/2020 06:01:38 PM
IN THE CIRCUIT COURT IN AND FOR BAY COUNTY, FLORIDA
NATALIE SORRENTO,
Plaintiff,
v. Case Number: 20000243CA
ALLSTATE INSURANCE COMPANY,
Defendant.
/
DEFENDANT ALLSTATE INSURANCE COMPANY’S
REQUEST FOR PRODUCTION
Defendant, ALLSTATE INSURANCE COMPANY, by and through its undersigned
counsel and responds to Plaintiff's Request for Production as follows:
1. Every recorded statement in your possession, custody, and/or control given by
any party in this action, including notes of any interviews or discussions with any party in this
action, whether such notes pertain to recorded or unrecorded statements.
RESPONSE: Objection: This request seeks information protected from discovery
by the attorney-client privilege and/or the attorney work product doctrine, or
information subject to protection as trial preparation materials or prepared in
anticipation of litigation. However, without waiving said objections, attached are
audio recording of Plaintiff given and video recording of sworn statement given by
Plaintiff.
2. Every recorded statement in your possession, custody, and/or control pertaining in
any manner to the issues in this action, including liability and damages, not produced pursuant to
the preceding request.
RESPONSE: Objection: This request seeks information protected from discovery
by the attorney-client privilege and/or the attorney work product doctrine, or
information subject to protection as trial preparation materials or prepared in
anticipation of litigation. However, without waiving said objections, no formal
statements have been located other than those previous identified above.3. All photographs, video tapes, or other documents in your possession, custody,
and/or control depicting or portraying any Persons in this action or any property owned by any
Persons in this action, which pertain in any manner to the issues in this action.
RESPONSE: Attached are copies of photographs the vehicle driven by the Plaintiff
as described in the Complaint. See response to Request No. 1 as to videotape of
Plaintiff during her Examination Under Oath.
4, All other photographs, video tapes, or other documents in your possession,
custody, and/or control pertaining in any manner to the issues in this action, including issues of
liability or damages.
RESPONSE: Objection: This request seeks information protected from discovery
by the attorney-client privilege and/or the attorney work product doctrine, or
information subject to protection as trial preparation materials or prepared in
anticipation of litigation. However, without waiving said objections, no non-
privileged documents have been located that would be responsive to this request
other than those photographs, video tapes and other documents being produced in
response to the other various numbered Requests herein.
5. Each and every document in your possession, custody, and/or control that might
support or tend to support any and all of the Defendant’s affirmative defenses.
RESPONSE: Objection. All documents responsive to this request, if any, are work-
product and/or attorney-client related and include claim notes generated during the
processing of the claim, ISO claim searches, and documents regarding other
insurance benefits paid or available. Further, the affirmative defenses were
asserted in an abundance of caution and to avoid waiver. Discovery and
investigation of this matter are ongoing. If discovery fails to adduce sufficient facts
to support an affirmative defense, it will be dismissed by counsel for Defendant.
6. Any and all documents or other tangible or intangible things in your possession,
custody, and/or control which might be presented as evidence or as an exhibit at trial of this
action.
RESPONSE: Discovery is ongoing and trial evidence has not yet determined at this
time.7. Any document in your possession, custody, and/or control that may have been
referenced in any answers to interrogatories you may have filed in this action.
RESPONSE: Attached.
8. Any document related to the subject event.
RESPONSE: Objection. Documents responsive to this request are work-product
and/or attorney-client related and will not be produced. Non-privileged documents
such as copies of PIP log, motor vehicle accident report, and correspondence
between Plaintiff’s designated representatives and Defendant’s representatives are
produced in additional to the other documents already identified and produced
herein.
9. Any and all policies of automobile liability insurance that may provide coverage
for the damages complained of herein that DEFENDANT ALLSTATE INSURANCE
COMPANY had in force and effect on or about November 12, 2015.
RESPONSE: Attached.
10. Any and all statements provided by PLAINTIFF and/or witnesses in connection
with the subject accident in the possession and/or control of DEFENDANT ALLSTATE
INSURANCE COMPANY.
RESPONSE: See response to Request Number 1.
11. Any and all property damage appraisals and/or estimations prepared in connection
with the subject accident in the possession and/or control of DEFENDANT ALLSTATE
INSURANCE COMPANY.
RESPONSE: Attached.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to
Joseph A. Zarzaur, Jr., Esq., with Zarzaur Law, P.A., P. O. Box 12350, Pensacola, FL 32591;joe@zarzarulaw.com; service@zarzaurlaw.com, via Florida Courts E-Filing Portal, and that
copies of the referenced documents have been provided to same via electronic mail, this
day of April, 2020.
s/Jerry D. Sanders
Jerry D. Sanders
Florida Bar Number: 112798
Vernis & Bowling for Northwest Florida, P.A.
315 South Palafox Street
Pensacola, Florida 32502
Telephone: (850) 433-5461
Facsimile: (850) 432-0166
JSanders@Florida-Law.com
ikerns@Florida-Law.com
vtaylor@Florida-Law.com
Attorney for ALLSTATE INSURANCE
COMPANY
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Filing # 106095993 E-Filed 04/09/2020 06:01:38 PM IN THE CIRCUIT COURT IN AND FOR BAY COUNTY, FLORIDA NATALIE SORRENTO, Plaintiff, v. Case Number: 20000243CA ALLSTATE INSURANCE COMPANY, Defendant. / DEFENDANT ALLSTATE INSURANCE COMPANY’S REQUEST FOR PRODUCTION Defendant, ALLSTATE INSURANCE COMPANY, by and through its undersigned counsel and responds to Plaintiff's Request for Production as follows: 1. Every recorded statement in your possession, custody, and/or control given by any party in this action, including notes of any interviews or discussions with any party in this action, whether such notes pertain to recorded or unrecorded statements. RESPONSE: Objection: This request seeks information protected from discovery by the attorney-client privilege and/or the attorney work product doctrine, or information subject to protection as trial preparation materials or prepared in anticipation of litigation. However, without waiving said objections, attached are audio recording of Plaintiff given and video recording of sworn statement given by Plaintiff. 2. Every recorded statement in your possession, custody, and/or control pertaining in any manner to the issues in this action, including liability and damages, not produced pursuant to the preceding request. RESPONSE: Objection: This request seeks information protected from discovery by the attorney-client privilege and/or the attorney work product doctrine, or information subject to protection as trial preparation materials or prepared in anticipation of litigation. However, without waiving said objections, no formal statements have been located other than those previous identified above.3. All photographs, video tapes, or other documents in your possession, custody, and/or control depicting or portraying any Persons in this action or any property owned by any Persons in this action, which pertain in any manner to the issues in this action. RESPONSE: Attached are copies of photographs the vehicle driven by the Plaintiff as described in the Complaint. See response to Request No. 1 as to videotape of Plaintiff during her Examination Under Oath. 4, All other photographs, video tapes, or other documents in your possession, custody, and/or control pertaining in any manner to the issues in this action, including issues of liability or damages. RESPONSE: Objection: This request seeks information protected from discovery by the attorney-client privilege and/or the attorney work product doctrine, or information subject to protection as trial preparation materials or prepared in anticipation of litigation. However, without waiving said objections, no non- privileged documents have been located that would be responsive to this request other than those photographs, video tapes and other documents being produced in response to the other various numbered Requests herein. 5. Each and every document in your possession, custody, and/or control that might support or tend to support any and all of the Defendant’s affirmative defenses. RESPONSE: Objection. All documents responsive to this request, if any, are work- product and/or attorney-client related and include claim notes generated during the processing of the claim, ISO claim searches, and documents regarding other insurance benefits paid or available. Further, the affirmative defenses were asserted in an abundance of caution and to avoid waiver. Discovery and investigation of this matter are ongoing. If discovery fails to adduce sufficient facts to support an affirmative defense, it will be dismissed by counsel for Defendant. 6. Any and all documents or other tangible or intangible things in your possession, custody, and/or control which might be presented as evidence or as an exhibit at trial of this action. RESPONSE: Discovery is ongoing and trial evidence has not yet determined at this time.7. Any document in your possession, custody, and/or control that may have been referenced in any answers to interrogatories you may have filed in this action. RESPONSE: Attached. 8. Any document related to the subject event. RESPONSE: Objection. Documents responsive to this request are work-product and/or attorney-client related and will not be produced. Non-privileged documents such as copies of PIP log, motor vehicle accident report, and correspondence between Plaintiff’s designated representatives and Defendant’s representatives are produced in additional to the other documents already identified and produced herein. 9. Any and all policies of automobile liability insurance that may provide coverage for the damages complained of herein that DEFENDANT ALLSTATE INSURANCE COMPANY had in force and effect on or about November 12, 2015. RESPONSE: Attached. 10. Any and all statements provided by PLAINTIFF and/or witnesses in connection with the subject accident in the possession and/or control of DEFENDANT ALLSTATE INSURANCE COMPANY. RESPONSE: See response to Request Number 1. 11. Any and all property damage appraisals and/or estimations prepared in connection with the subject accident in the possession and/or control of DEFENDANT ALLSTATE INSURANCE COMPANY. RESPONSE: Attached. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to Joseph A. Zarzaur, Jr., Esq., with Zarzaur Law, P.A., P. O. Box 12350, Pensacola, FL 32591;joe@zarzarulaw.com; service@zarzaurlaw.com, via Florida Courts E-Filing Portal, and that copies of the referenced documents have been provided to same via electronic mail, this day of April, 2020. s/Jerry D. Sanders Jerry D. Sanders Florida Bar Number: 112798 Vernis & Bowling for Northwest Florida, P.A. 315 South Palafox Street Pensacola, Florida 32502 Telephone: (850) 433-5461 Facsimile: (850) 432-0166 JSanders@Florida-Law.com ikerns@Florida-Law.com vtaylor@Florida-Law.com Attorney for ALLSTATE INSURANCE COMPANY