On August 31, 2017 a
Party Discovery
was filed
involving a dispute between
Jordan Mcqueen,
and
Af Motors Llc,
Jeffrey Sens,
for CA - Auto Negligence
in the District Court of Orange County.
Preview
Filing #66053831 E-Filed 01/03/2018 03:34:31 PM
IN THE NINTH JUDICIAL CIRCUIT COURT IN AND FOR ORANGE
COUNTY, FLORIDA
CASE NO: 2017-CA-008097-O
JORDAN MCQUEEN,
Plaintiff,
VS.
JEFFREY SENS AND AF MOTORS
L.L.C.,
Defendants.
/
PLAINTIFF'S RESPONSE TO DEFENDANT'S REQUEST FOR PRODUCTION
COMES NOW the Plaintiff, JORDAN MCQUEEN, by and through the undersigned
attorneys, and in response to the Defendants’, JEFFREY SENS AND AF MOTORS L.L.C.,
Request For Production served on or about December 4, 2017, and states as follows:
1 Copies of Plaintiffs medical records and billing have been furnished to the Defense on the
date of this certificate of service.
Objection: Irrelevant, unduly burdensome and not likely to lead to the discovery of
admissible evidence as Plaintiff is not asserting a past and/or future wage loss claim.
None.
None in Plaintiffs possession, custody or control.
Objection: Work-product and attorney-client privileged. Notwithstanding said objection,
none.
None.
None in Plaintiffs possession, custody or control.
Objection: Irrelevant, unduly burdensome and not likely to lead to the discovery
of admissible evidence as Plaintiff is not asserting a past and/or future wage loss claim.
A copy of Plaintiffs auto insurance policy with National General has been furnished to the
Defense on the date of this certificate of service.
10. A copy of the subject accident report has been furnished to the Defense on the date of this
certificate of service.
1 None.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on _| | 42 Or’ , | clectronically filed the foregoing
with the Clerk of the Courts by using the Florida Courts e-Filing Portal. I further certify that
Pursuant to Rule 2.516(b)(1) I forwarded the foregoing this same day via Email to: C.
Christopher Killer, Esquire, [ primary: OrlandoLegalMail@libertymutual.com; secondary:
chris.killer@libertymutual.com] Law Offices of J. Christopher Norris, 201 E. Pine Street, Suite
875, Orlando, FL 32801.
A
Co
‘Gregor, Berry, Esquire
Sa
FBN 104895
Morgan & Morgan, P.A.
20 N. Orange Avenue
Suite 1600
Orlando, FL 32801
Telephone: (407) 420-1414
Facsimile: (407) 867-4789
Primary email: GBerry@forthepeople.com
Secondary email: apratt@forthepeople.com;
mserrano@forthepeople.com
Attorneys for Plaintiff
Document Filed Date
January 03, 2018
Case Filing Date
August 31, 2017
Category
CA - Auto Negligence
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Filing #66053831 E-Filed 01/03/2018 03:34:31 PM IN THE NINTH JUDICIAL CIRCUIT COURT IN AND FOR ORANGE COUNTY, FLORIDA CASE NO: 2017-CA-008097-O JORDAN MCQUEEN, Plaintiff, VS. JEFFREY SENS AND AF MOTORS L.L.C., Defendants. / PLAINTIFF'S RESPONSE TO DEFENDANT'S REQUEST FOR PRODUCTION COMES NOW the Plaintiff, JORDAN MCQUEEN, by and through the undersigned attorneys, and in response to the Defendants’, JEFFREY SENS AND AF MOTORS L.L.C., Request For Production served on or about December 4, 2017, and states as follows: 1 Copies of Plaintiffs medical records and billing have been furnished to the Defense on the date of this certificate of service. Objection: Irrelevant, unduly burdensome and not likely to lead to the discovery of admissible evidence as Plaintiff is not asserting a past and/or future wage loss claim. None. None in Plaintiffs possession, custody or control. Objection: Work-product and attorney-client privileged. Notwithstanding said objection, none. None. None in Plaintiffs possession, custody or control. Objection: Irrelevant, unduly burdensome and not likely to lead to the discovery of admissible evidence as Plaintiff is not asserting a past and/or future wage loss claim. A copy of Plaintiffs auto insurance policy with National General has been furnished to the Defense on the date of this certificate of service. 10. A copy of the subject accident report has been furnished to the Defense on the date of this certificate of service. 1 None. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on _| | 42 Or’ , | clectronically filed the foregoing with the Clerk of the Courts by using the Florida Courts e-Filing Portal. I further certify that Pursuant to Rule 2.516(b)(1) I forwarded the foregoing this same day via Email to: C. Christopher Killer, Esquire, [ primary: OrlandoLegalMail@libertymutual.com; secondary: chris.killer@libertymutual.com] Law Offices of J. Christopher Norris, 201 E. Pine Street, Suite 875, Orlando, FL 32801. A Co ‘Gregor, Berry, Esquire Sa FBN 104895 Morgan & Morgan, P.A. 20 N. Orange Avenue Suite 1600 Orlando, FL 32801 Telephone: (407) 420-1414 Facsimile: (407) 867-4789 Primary email: GBerry@forthepeople.com Secondary email: apratt@forthepeople.com; mserrano@forthepeople.com Attorneys for Plaintiff