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Filing # 88390515 E-Filed 04/23/2019 01:50:11 PM
1932201/3
IN THE CIRCUIT COURT OF THE 19TH JUDICIAL
CIRCUIT IN AND FOR INDIAN RIVER COUNTY,
FLORIDA
CASE NO. 312019CA000232
LEAH M. HUBBARD,
Plaintiff,
v.
E. CLAYTON YATES, P.A.,
Defendant.
/
DEFENDANT, E. CLAYTON YATES P.A.’S, FIRST REQUEST TO PRODUCE TO
PLAINTIFF, LEAH M. HUBBARD
Defendant, E. CLAYTON YATES P.A., by and through its undersigned counsel
and pursuant to Rules 1.280 and 1.350 of the Florida Rules of Civil Procedure, request
that the Plaintiff, LEAH M. HUBBARD, produce to him or make available for copying
and inspection, the following within 30 days of service hereof:
1. All documents, records, invoices, bills, photos, films, videos,
correspondence, emails, and/or facsimiles which evidence, support,
establish, and/or prove the Plaintiff's claims and/or allegations in Count | of
the Complaint.
2. All documents, records, invoices, bills, photos, films, videos,
correspondence, emails, and/or facsimiles which evidence, support,
establish, and/or prove the Plaintiffs claims and/or allegations in Count II of
the Complaint.CASE NO. 312019CA000232
DEFENDANT'S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF
. All documents, records, invoices, bills, photos, films, videos,
correspondence, emails, and/or facsimiles which evidence, support,
establish, and/or prove the Plaintiff's claims and/or allegations in Count III
of the Complaint.
. All documents, records, invoices, bills, photos, films, videos,
correspondence, emails, and/or facsimiles which evidence, support,
establish, and/or prove the Plaintiffs claims and/or allegations in Count IV
of the Complaint.
. All documents, records, invoices, bills, photos, films, videos,
correspondence, emails, and/or facsimiles which evidence, support,
establish, and/or prove the Plaintiffs claims for economic damages in this
action.
. All documents, records, invoices, bills, photos, films, videos,
correspondence, emails, and/or facsimiles which evidence, support,
establish, and/or prove the Plaintiff's claims for compensatory damages in
this action.
. All documents, records, invoices, bills, photos, films, videos,
correspondence, emails, and/or facsimiles which evidence, support,
establish, and/or prove the Plaintiff's claims for infliction of emotional
distress.
. All documents, records, invoices, bills, photos, films, videos,
correspondence, emails, and/or facsimiles which evidence, support,CASE NO. 312019CA000232
DEFENDANT'S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF
establish, and/or prove the Plaintiffs claims and/or allegations in Paragraph
145 of the Complaint.
9. All documents, records, invoices, bills, photos, films, videos,
correspondence, emails, and/or facsimiles which evidence, support,
establish, and/or prove the Plaintiffs claims and/or allegations in Paragraph
146 of the Complaint.
10.All documents, records, invoices, bills, photos, films, videos,
correspondence, emails, and/or facsimiles which evidence, support,
establish, and/or prove the Plaintiffs claims and/or allegations in Paragraph
146 of the Complaint.
11.All documents, records, invoices, bills, photos, films, videos,
correspondence, emails, and/or facsimiles which evidence, support,
establish, and/or prove the Plaintiffs claims and/or allegations in Paragraph
147 of the Complaint.
12.All documents, records, invoices, bills, photos, films, videos,
correspondence, emails, and/or facsimiles which evidence, support,
establish, and/or prove the Plaintiffs claims and/or allegations in Paragraph
148 of the Complaint.
13.All documents, records, invoices, bills, photos, films, videos,
correspondence, emails, and/or facsimiles which evidence, support,
establish, and/or prove the Plaintiffs claims and/or allegations in Paragraph
149 of the Complaint.CASE NO. 312019CA000232
DEFENDANT'S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF
14.All non-privileged documents pertaining to any and all criminal convictions
for Plaintiff from January 1, 2000 to December 31, 2018.
15.All non-privileged documents pertaining to any and all criminal arrests for
Plaintiff from January 1, 2000 to December 31, 2018.
16.All non-privileged documents pertaining to any and all pleas for nolo
contendere and/or no contest in criminal cases for Plaintiff from January 1,
2000 to December 31, 2018.
17.All non-privileged documents pertaining to any and all pleas of guilty in
criminal cases for Plaintiff from January 1, 2000 to December 31, 2018.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a copy hereof has been furnished by service through
the eportal to Leah M. Hubbard, 2046 79th Avenue, Vero Beach, FL 32966, Pro Se,
Leah Hubbard, leahhubbard0706@gmail.com, on this _23rd_ day of April_, 2019.
CONROY SIMBERG
Attorney for Defendant, E. Clayton Yates, P.A.
1801 Centrepark Drive East, Suite 200
West Palm Beach, FL 33401
Telephone: (561) 697-8088
Facsimile: (561) 697-8664
Primary Email: eservicewpb@conroysimberg.com
Secondary Email: jrubin@conroysimberg.com
By: _/s/ Jeffrey K. Rubin
John A. Lurvey, Esquire
Florida Bar No. 570222
Jeffrey K. Rubin, Esquire
Florida Bar No. 42084
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Filing # 88390515 E-Filed 04/23/2019 01:50:11 PM 1932201/3 IN THE CIRCUIT COURT OF THE 19TH JUDICIAL CIRCUIT IN AND FOR INDIAN RIVER COUNTY, FLORIDA CASE NO. 312019CA000232 LEAH M. HUBBARD, Plaintiff, v. E. CLAYTON YATES, P.A., Defendant. / DEFENDANT, E. CLAYTON YATES P.A.’S, FIRST REQUEST TO PRODUCE TO PLAINTIFF, LEAH M. HUBBARD Defendant, E. CLAYTON YATES P.A., by and through its undersigned counsel and pursuant to Rules 1.280 and 1.350 of the Florida Rules of Civil Procedure, request that the Plaintiff, LEAH M. HUBBARD, produce to him or make available for copying and inspection, the following within 30 days of service hereof: 1. All documents, records, invoices, bills, photos, films, videos, correspondence, emails, and/or facsimiles which evidence, support, establish, and/or prove the Plaintiff's claims and/or allegations in Count | of the Complaint. 2. All documents, records, invoices, bills, photos, films, videos, correspondence, emails, and/or facsimiles which evidence, support, establish, and/or prove the Plaintiffs claims and/or allegations in Count II of the Complaint.CASE NO. 312019CA000232 DEFENDANT'S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF . All documents, records, invoices, bills, photos, films, videos, correspondence, emails, and/or facsimiles which evidence, support, establish, and/or prove the Plaintiff's claims and/or allegations in Count III of the Complaint. . All documents, records, invoices, bills, photos, films, videos, correspondence, emails, and/or facsimiles which evidence, support, establish, and/or prove the Plaintiffs claims and/or allegations in Count IV of the Complaint. . All documents, records, invoices, bills, photos, films, videos, correspondence, emails, and/or facsimiles which evidence, support, establish, and/or prove the Plaintiffs claims for economic damages in this action. . All documents, records, invoices, bills, photos, films, videos, correspondence, emails, and/or facsimiles which evidence, support, establish, and/or prove the Plaintiff's claims for compensatory damages in this action. . All documents, records, invoices, bills, photos, films, videos, correspondence, emails, and/or facsimiles which evidence, support, establish, and/or prove the Plaintiff's claims for infliction of emotional distress. . All documents, records, invoices, bills, photos, films, videos, correspondence, emails, and/or facsimiles which evidence, support,CASE NO. 312019CA000232 DEFENDANT'S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF establish, and/or prove the Plaintiffs claims and/or allegations in Paragraph 145 of the Complaint. 9. All documents, records, invoices, bills, photos, films, videos, correspondence, emails, and/or facsimiles which evidence, support, establish, and/or prove the Plaintiffs claims and/or allegations in Paragraph 146 of the Complaint. 10.All documents, records, invoices, bills, photos, films, videos, correspondence, emails, and/or facsimiles which evidence, support, establish, and/or prove the Plaintiffs claims and/or allegations in Paragraph 146 of the Complaint. 11.All documents, records, invoices, bills, photos, films, videos, correspondence, emails, and/or facsimiles which evidence, support, establish, and/or prove the Plaintiffs claims and/or allegations in Paragraph 147 of the Complaint. 12.All documents, records, invoices, bills, photos, films, videos, correspondence, emails, and/or facsimiles which evidence, support, establish, and/or prove the Plaintiffs claims and/or allegations in Paragraph 148 of the Complaint. 13.All documents, records, invoices, bills, photos, films, videos, correspondence, emails, and/or facsimiles which evidence, support, establish, and/or prove the Plaintiffs claims and/or allegations in Paragraph 149 of the Complaint.CASE NO. 312019CA000232 DEFENDANT'S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF 14.All non-privileged documents pertaining to any and all criminal convictions for Plaintiff from January 1, 2000 to December 31, 2018. 15.All non-privileged documents pertaining to any and all criminal arrests for Plaintiff from January 1, 2000 to December 31, 2018. 16.All non-privileged documents pertaining to any and all pleas for nolo contendere and/or no contest in criminal cases for Plaintiff from January 1, 2000 to December 31, 2018. 17.All non-privileged documents pertaining to any and all pleas of guilty in criminal cases for Plaintiff from January 1, 2000 to December 31, 2018. CERTIFICATE OF SERVICE | HEREBY CERTIFY that a copy hereof has been furnished by service through the eportal to Leah M. Hubbard, 2046 79th Avenue, Vero Beach, FL 32966, Pro Se, Leah Hubbard, leahhubbard0706@gmail.com, on this _23rd_ day of April_, 2019. CONROY SIMBERG Attorney for Defendant, E. Clayton Yates, P.A. 1801 Centrepark Drive East, Suite 200 West Palm Beach, FL 33401 Telephone: (561) 697-8088 Facsimile: (561) 697-8664 Primary Email: eservicewpb@conroysimberg.com Secondary Email: jrubin@conroysimberg.com By: _/s/ Jeffrey K. Rubin John A. Lurvey, Esquire Florida Bar No. 570222 Jeffrey K. Rubin, Esquire Florida Bar No. 42084