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Filing #59490061 E-Filed 07/25/2017 03:30:21 PM
7416878 IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT, IN AND FOR ORANGE
COUNTY, FLORIDA
CASE NO.: 2017 CA 004880 - O
JAMES FEASTER AND BRITTANY FEASTER,
Plaintiffs,
vs.
AMERICAN INTEGRITY INSURANCE COMPANY OF
FLORIDA,
Defendant.
SSS
T “S RESPONSE TO DEFENDANT’! RE Te
The Plaintiff, by and through the undersigned attorneys, and in response to Defendant,
American Integrity Insurance Company of Florida’s, Request to Produce, dated June 22, 2017,
states:
1 Objection. This request contemplates documents protected by work product
privilege, as it would encompass documents from consulting experts that have not been listed as
trial experts. Without waiving this objection, please see attached.
2. Objection. This request contemplates documents protected by work product
privilege, as it would encompass documents from consulting experts that have not been listed as
trial experts. Without waiving this objection, please see attached.
3 Objection. This request contemplates documents protected by work product
privilege, as it would encompass documents from consulting experts that have not been listed as
trial experts. Without waiving this objection, please see attached.
4. Objection. This request contemplates documents protected by work product
privilege, as it would encompass documents from consulting experts that have not been listed as
trial experts. Without waiving this objection, please see attached.
5 Objection. Vague. Additionally, this request contemplates documents protected by
work product privilege, as it would encompass documents from consulting experts that have not
been listed as trial experts. Without waiving this objection, please see attached.
6 Attached.
7, Objection. Vague. Additionally, this request contemplates documents protected by
work product privilege, as it would encompass documents from consulting experts that have not
been listed as trial experts. Without waiving this objection, please see attached.
8. Objection. This request contemplates documents protected by work product
privilege, as it would encompass documents from consulting experts that have not been listed as
trial experts. Without waiving this objection, please see attached.
9. Objection. This request contemplates documents protected by work product
privilege, as it would encompass documents from consulting experts that have not been listed as
trial experts. Without waiving this objection, please see attached.
10. Objection. This request contemplates documents protected by work product
privilege, as it would encompass documents from consulting experts that have not been listed as
trial experts. Without waiving this objection, please see attached.
11. None.
12. Objection. Vague. Additionally, this request contemplates documents protected by
work product privilege, as it would encompass documents from consulting experts that have not
been listed as trial experts. Without waiving this objection, please see attached.
13. None.
14, Objection. This request contemplates documents protected by work product
privilege, as it would encompass documents from consulting experts that have not been listed as
trial experts. Without waiving this objection, please see attached.
15. Objection. Overly broad. Additoinally, this request contemplates documents
protected by work product privilege, as it would encompass documents from consulting experts that
have not been listed as trial experts. Without waiving this objection, please see attached.
16 None.
17, See attached.
18. None.
19, Attached.
20 Objection. Vague. Additionally, this request contemplates documents protected by
work product privilege, as it would encompass documents from consulting experts that have not
been listed as trial experts. Without waiving this objection, please see attached.
21. Objection. This request contemplates documents protected by work product
privilege, as it would encompass documents from consulting experts that have not been listed as
trial experts. Without waiving this objection, please see attached.
22. Objection. This request contemplates documents protected by work product
privilege, as it would encompass documents from consulting experts that have not been listed as
trial experts. Without waiving this objection, please see attached.
23. Objection. This request contemplates documents protected by work product
privilege, as it would encompass documents from consulting experts that have not been listed as
trial experts. Without waiving this objection, please see attached.
24. Objection. This request contemplates documents protected by work product
privilege, as it would encompass documents from consulting experts that have not been listed as
trial experts. Without waiving this objection, please see attached,
25. N/A.
26. Objection. Overly broad. This request contemplates documents protected by work
product privilege, as it would encompass documents from consulting experts that have not been
listed as trial experts. Without waiving this objection, please see attached.
27. See attached.
28, See attached.
29. Objection. This request contemplates documents protected by work product
privilege, as it would encompass documents from consulting experts that have not been listed as
trial experts. Without waiving this objection, please see attached,
30. Objection. This request contemplates documents protected by work product
privilege, as it would encompass documents from consulting experts that have not been listed as
trial experts. Without waiving this objection, please see attached.
31. Objection. This request contemplates documents protected by work product
privilege, as it would encompass documents from consulting experts that have not been listed as
trial experts. Without waiving this objection, please see attached.
32 None.
33 None.
34, Please see attached.
35, Objection. This request contemplates documents protected by work product
privilege, as it would encompass documents from consulting experts that have not been listed as
trial experts. Without waiving this objection, please see attached.
I HEREBY CERTIFY that a true and correct copy of the regoing has been served by email
and first-class mail, postage prepaid, to: Troy J. Seibert, Esquire, Bui r Weihmuller Katz Craig LLP, 400
N. Ashley Drive, Suite 2300, Tampa, FL 33602; tseibert@ ier legal, jgionet@butler. legal;
eservice@butler.
legal on this 7 4465 of July, 2017.
i
\ }
David A. Spain, Esquire
Florida 0816175
Morgan & Morgan, P.A.
20 N. Orange Avenue, 4° Floor
Post Office Box 4979
Orlando, Florida 32802-4979
Telephone:
Facsimile: (407) 245-3353
Primary email: DSpain@forthepeople.com
Attorneys for Plaintiff
Preview
Filing #59490061 E-Filed 07/25/2017 03:30:21 PM 7416878 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR ORANGE COUNTY, FLORIDA CASE NO.: 2017 CA 004880 - O JAMES FEASTER AND BRITTANY FEASTER, Plaintiffs, vs. AMERICAN INTEGRITY INSURANCE COMPANY OF FLORIDA, Defendant. SSS T “S RESPONSE TO DEFENDANT’! RE Te The Plaintiff, by and through the undersigned attorneys, and in response to Defendant, American Integrity Insurance Company of Florida’s, Request to Produce, dated June 22, 2017, states: 1 Objection. This request contemplates documents protected by work product privilege, as it would encompass documents from consulting experts that have not been listed as trial experts. Without waiving this objection, please see attached. 2. Objection. This request contemplates documents protected by work product privilege, as it would encompass documents from consulting experts that have not been listed as trial experts. Without waiving this objection, please see attached. 3 Objection. This request contemplates documents protected by work product privilege, as it would encompass documents from consulting experts that have not been listed as trial experts. Without waiving this objection, please see attached. 4. Objection. This request contemplates documents protected by work product privilege, as it would encompass documents from consulting experts that have not been listed as trial experts. Without waiving this objection, please see attached. 5 Objection. Vague. Additionally, this request contemplates documents protected by work product privilege, as it would encompass documents from consulting experts that have not been listed as trial experts. Without waiving this objection, please see attached. 6 Attached. 7, Objection. Vague. Additionally, this request contemplates documents protected by work product privilege, as it would encompass documents from consulting experts that have not been listed as trial experts. Without waiving this objection, please see attached. 8. Objection. This request contemplates documents protected by work product privilege, as it would encompass documents from consulting experts that have not been listed as trial experts. Without waiving this objection, please see attached. 9. Objection. This request contemplates documents protected by work product privilege, as it would encompass documents from consulting experts that have not been listed as trial experts. Without waiving this objection, please see attached. 10. Objection. This request contemplates documents protected by work product privilege, as it would encompass documents from consulting experts that have not been listed as trial experts. Without waiving this objection, please see attached. 11. None. 12. Objection. Vague. Additionally, this request contemplates documents protected by work product privilege, as it would encompass documents from consulting experts that have not been listed as trial experts. Without waiving this objection, please see attached. 13. None. 14, Objection. This request contemplates documents protected by work product privilege, as it would encompass documents from consulting experts that have not been listed as trial experts. Without waiving this objection, please see attached. 15. Objection. Overly broad. Additoinally, this request contemplates documents protected by work product privilege, as it would encompass documents from consulting experts that have not been listed as trial experts. Without waiving this objection, please see attached. 16 None. 17, See attached. 18. None. 19, Attached. 20 Objection. Vague. Additionally, this request contemplates documents protected by work product privilege, as it would encompass documents from consulting experts that have not been listed as trial experts. Without waiving this objection, please see attached. 21. Objection. This request contemplates documents protected by work product privilege, as it would encompass documents from consulting experts that have not been listed as trial experts. Without waiving this objection, please see attached. 22. Objection. This request contemplates documents protected by work product privilege, as it would encompass documents from consulting experts that have not been listed as trial experts. Without waiving this objection, please see attached. 23. Objection. This request contemplates documents protected by work product privilege, as it would encompass documents from consulting experts that have not been listed as trial experts. Without waiving this objection, please see attached. 24. Objection. This request contemplates documents protected by work product privilege, as it would encompass documents from consulting experts that have not been listed as trial experts. Without waiving this objection, please see attached, 25. N/A. 26. Objection. Overly broad. This request contemplates documents protected by work product privilege, as it would encompass documents from consulting experts that have not been listed as trial experts. Without waiving this objection, please see attached. 27. See attached. 28, See attached. 29. Objection. This request contemplates documents protected by work product privilege, as it would encompass documents from consulting experts that have not been listed as trial experts. Without waiving this objection, please see attached, 30. Objection. This request contemplates documents protected by work product privilege, as it would encompass documents from consulting experts that have not been listed as trial experts. Without waiving this objection, please see attached. 31. Objection. This request contemplates documents protected by work product privilege, as it would encompass documents from consulting experts that have not been listed as trial experts. Without waiving this objection, please see attached. 32 None. 33 None. 34, Please see attached. 35, Objection. This request contemplates documents protected by work product privilege, as it would encompass documents from consulting experts that have not been listed as trial experts. Without waiving this objection, please see attached. I HEREBY CERTIFY that a true and correct copy of the regoing has been served by email and first-class mail, postage prepaid, to: Troy J. Seibert, Esquire, Bui r Weihmuller Katz Craig LLP, 400 N. Ashley Drive, Suite 2300, Tampa, FL 33602; tseibert@ ier legal, jgionet@butler. legal; eservice@butler. legal on this 7 4465 of July, 2017. i \ } David A. Spain, Esquire Florida 0816175 Morgan & Morgan, P.A. 20 N. Orange Avenue, 4° Floor Post Office Box 4979 Orlando, Florida 32802-4979 Telephone: Facsimile: (407) 245-3353 Primary email: DSpain@forthepeople.com Attorneys for Plaintiff