On September 30, 2021 a
Party Discovery
was filed
involving a dispute between
Wynn, Shaun,
and
Roberts, Rorie,
Swatman, Kathryn,
for Circuit Civil
in the District Court of Lake County.
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Filing # 146407618 E-Filed 03/25/2022 09:02:31 AM
IN THE CIRCUIT COURT, FIFTH
JUDICIAL CIRCUIT, IN AND FOR
LAKE COUNTY, FLORIDA
SHAUN WYNN,
Plaintiff,
Vv. CASE NO. 2021 CA 1665
KATHRYN-SWATMAN
And RORIE ROBERTS
Defendants.
PLAINTIFE’S RESPONSE TO
DEENDANT’S REQUEST FOR PRODUCTION
COMES NOV, Plaintiff, SHAUN WYNN, by and through undersigned counsel, and
hereby responds to the Defendant, RORIE ROBERTS’s, Request for Production dated January
25, 2022, as follows:
1 Plaintiff has provided to Defendant copies of all documents in his possession
responsive to Request No. 1.
2, Plaintiff has no documents in his possession responsive to Request No. 2.
3. Plaintiff has provided to Defendant copies of all medical records in his possession
responsive to Request No. 3.
4. Plaintiff has no documents in his possession responsive to Request No. 4.
5. Plaintiff has no documents in his possession responsive to Request No. 5
Plaintiff has no documents in his possession responsive to Request No. 6.
Plaintiff has no documents in his possession responsive to Request No. 7.
8 Plaintiff has no documents in his possession responsive to Request No. 8.
9. Plaintiff has provided to Defendant copies of all photographs in his possession
responsive to Request No. 9.
FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 03/25/2022 09:47:33 AM
10. Plaintiff has no documents in his possession responsive to Request No. 10.
ll. Plaintiff has no documents in his possession responsive to Request No. 11.
12. Plaintiff has provided to Defendant copies of the Incident Report in his possession
responsive to Request No. 12.
13. Plaintiff has no documents in his possession responsive to Request No. 13.
14, Plaintiff has no documents in his possession responsive to Request No. 14.
15, Plaintiff has no documents in his possession responsive to Request No. 15.
16 Plaintiff has provided to Defendant copies of all documents in his possession
responsive to Request No. 16.
17. Plaintiff has no documents in his possession responsive to Request No. 17.
18. Plaintiff has no documents in his possession responsive to Request No. 18.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
via electronic email service on this asthaay of March, 2022, to Heath Nailos, Esq., Boyette,
Cummins & Nailos, PLLC, 1635 East Highway 50, Suite 300, Clermont, FL 34711
hnailos@benlawfirm.com; lacosta@benlawfirm.com; akang@bcnlawfirm.com, attorneys for
Defendant, Rorie Roberts; and Michael Massey, Esq., Massey & Duffy, PLLC, 855 E.
University Ave., Gainesville, FL 32601, masse 3521 com attorneys for Kathryn Swatman,
Jonathan I. Rotstein, Esquire
Law Office of Rotstein & Shiffman, LLP
309 Oakridge Blvd., Suite B
Daytona Beach, FL 32118
Florida Bar No. 909580
(386) 252-5560 / (386) 238-6999. fax (mhh)
Primary: L.Bonner@rotstein-shiffman.com
Secondary 1: M.Otto@rotstein-shiffman.com
Secondary 2: T.Dallarosa@rotstein-shiffman.com
Attorney for Plaintiff
2
Document Filed Date
March 25, 2022
Case Filing Date
September 30, 2021
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Filing # 146407618 E-Filed 03/25/2022 09:02:31 AM IN THE CIRCUIT COURT, FIFTH JUDICIAL CIRCUIT, IN AND FOR LAKE COUNTY, FLORIDA SHAUN WYNN, Plaintiff, Vv. CASE NO. 2021 CA 1665 KATHRYN-SWATMAN And RORIE ROBERTS Defendants. PLAINTIFE’S RESPONSE TO DEENDANT’S REQUEST FOR PRODUCTION COMES NOV, Plaintiff, SHAUN WYNN, by and through undersigned counsel, and hereby responds to the Defendant, RORIE ROBERTS’s, Request for Production dated January 25, 2022, as follows: 1 Plaintiff has provided to Defendant copies of all documents in his possession responsive to Request No. 1. 2, Plaintiff has no documents in his possession responsive to Request No. 2. 3. Plaintiff has provided to Defendant copies of all medical records in his possession responsive to Request No. 3. 4. Plaintiff has no documents in his possession responsive to Request No. 4. 5. Plaintiff has no documents in his possession responsive to Request No. 5 Plaintiff has no documents in his possession responsive to Request No. 6. Plaintiff has no documents in his possession responsive to Request No. 7. 8 Plaintiff has no documents in his possession responsive to Request No. 8. 9. Plaintiff has provided to Defendant copies of all photographs in his possession responsive to Request No. 9. FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 03/25/2022 09:47:33 AM 10. Plaintiff has no documents in his possession responsive to Request No. 10. ll. Plaintiff has no documents in his possession responsive to Request No. 11. 12. Plaintiff has provided to Defendant copies of the Incident Report in his possession responsive to Request No. 12. 13. Plaintiff has no documents in his possession responsive to Request No. 13. 14, Plaintiff has no documents in his possession responsive to Request No. 14. 15, Plaintiff has no documents in his possession responsive to Request No. 15. 16 Plaintiff has provided to Defendant copies of all documents in his possession responsive to Request No. 16. 17. Plaintiff has no documents in his possession responsive to Request No. 17. 18. Plaintiff has no documents in his possession responsive to Request No. 18. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via electronic email service on this asthaay of March, 2022, to Heath Nailos, Esq., Boyette, Cummins & Nailos, PLLC, 1635 East Highway 50, Suite 300, Clermont, FL 34711 hnailos@benlawfirm.com; lacosta@benlawfirm.com; akang@bcnlawfirm.com, attorneys for Defendant, Rorie Roberts; and Michael Massey, Esq., Massey & Duffy, PLLC, 855 E. University Ave., Gainesville, FL 32601, masse 3521 com attorneys for Kathryn Swatman, Jonathan I. Rotstein, Esquire Law Office of Rotstein & Shiffman, LLP 309 Oakridge Blvd., Suite B Daytona Beach, FL 32118 Florida Bar No. 909580 (386) 252-5560 / (386) 238-6999. fax (mhh) Primary: L.Bonner@rotstein-shiffman.com Secondary 1: M.Otto@rotstein-shiffman.com Secondary 2: T.Dallarosa@rotstein-shiffman.com Attorney for Plaintiff 2