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Filing # 116889193 E-Filed 11/18/2020 01:53:51 PM
IN THE CIRCUIT COURT OF THE
15TH JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
Case No.: 502020CA008922 (AD)
ERNESTINA DE ARMAS; AND MARIO
SALVADOR DE ARMAS,
Plaintiff(s),
Vv.
CHARLIE WILL MITCHELL; AND
GEICO GENERAL INSURANCE
COMPANY,
Defendant(s).
/
DEFENDANT, GEICO GENERAL INSURANCE COMPANY’S RESPONSE TO
REQUEST FOR PRODUCTION
Defendant, GEICO General Insurance Company, by and through the undersigned attorney,
file this Response to Plaintiff's Request for Production, and states as follows:
1. None within the Defendant’s care, custody, possession or control at this time.
2. None within the Defendant’s care, custody, possession or control at this time. To
the extent that the Accident Crash Report is responsive, please see attached hereto
as Exhibit “A.”
3. Attached hereto as Exhibit “B.”
4. None within the Defendant’s care, custody, possession or control at this time.
5. None within the Defendant’s care, custody, possession or control at this time.
6. None within the Defendant’s care, custody, possession or control at this time.
7. None within the Defendant’s care, custody, possession or control at this time.
*** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 11/18/2020 01:53:51 PM ***8. None within the Defendant’s care, custody, possession or control at this time.
9. None within the Defendant’s care, custody, possession or control at this time.
10. None within the Defendant’s care, custody, possession or control at this time.
11. Objection this request calls for information which is readily ascertainable to the
Plaintiff and/or already in the Plaintiff's possession or control.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY on this 18" day of November, 2020, the foregoing was filed with
the Florida Courts E-Filing Portal, which will serve this document on the following counsel of
record via Timothy Vannatta, Esq., Rubenstein Law, P.A., tim@rubensteinlaw.com; R. Timothy
Vannatta, Esq., Rubenstein Law, PA, tim@rubensteinlaw.com.
The Law Office of Jeffrey R. Hickman
/s/ Amy L. Das, Esg.
Amy L. Das, Esq.
(Employees of GEICO General Insurance Company)
Florida Bar No.: 89525
1555 Palm Beach Lakes Blvd., Ste. 1000,
West Palm Beach, FL 33401
Phone: 561-689-1479
Facsimile: (561) 242-9022
Attomey for Defendant: GEICO General
Service Email: AmDas@geico.com
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Filing # 116889193 E-Filed 11/18/2020 01:53:51 PM IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No.: 502020CA008922 (AD) ERNESTINA DE ARMAS; AND MARIO SALVADOR DE ARMAS, Plaintiff(s), Vv. CHARLIE WILL MITCHELL; AND GEICO GENERAL INSURANCE COMPANY, Defendant(s). / DEFENDANT, GEICO GENERAL INSURANCE COMPANY’S RESPONSE TO REQUEST FOR PRODUCTION Defendant, GEICO General Insurance Company, by and through the undersigned attorney, file this Response to Plaintiff's Request for Production, and states as follows: 1. None within the Defendant’s care, custody, possession or control at this time. 2. None within the Defendant’s care, custody, possession or control at this time. To the extent that the Accident Crash Report is responsive, please see attached hereto as Exhibit “A.” 3. Attached hereto as Exhibit “B.” 4. None within the Defendant’s care, custody, possession or control at this time. 5. None within the Defendant’s care, custody, possession or control at this time. 6. None within the Defendant’s care, custody, possession or control at this time. 7. None within the Defendant’s care, custody, possession or control at this time. *** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 11/18/2020 01:53:51 PM ***8. None within the Defendant’s care, custody, possession or control at this time. 9. None within the Defendant’s care, custody, possession or control at this time. 10. None within the Defendant’s care, custody, possession or control at this time. 11. Objection this request calls for information which is readily ascertainable to the Plaintiff and/or already in the Plaintiff's possession or control. CERTIFICATE OF SERVICE I HEREBY CERTIFY on this 18" day of November, 2020, the foregoing was filed with the Florida Courts E-Filing Portal, which will serve this document on the following counsel of record via Timothy Vannatta, Esq., Rubenstein Law, P.A., tim@rubensteinlaw.com; R. Timothy Vannatta, Esq., Rubenstein Law, PA, tim@rubensteinlaw.com. The Law Office of Jeffrey R. Hickman /s/ Amy L. Das, Esg. Amy L. Das, Esq. (Employees of GEICO General Insurance Company) Florida Bar No.: 89525 1555 Palm Beach Lakes Blvd., Ste. 1000, West Palm Beach, FL 33401 Phone: 561-689-1479 Facsimile: (561) 242-9022 Attomey for Defendant: GEICO General Service Email: AmDas@geico.com