On August 31, 2017 a
Party Discovery
was filed
involving a dispute between
Khermes Torres,
and
Progressive Select Insurance Company,
for CA - Breach of Agreement/Contract
in the District Court of Orange County.
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Filing # 64681183 E-Filed 11/28/2017 04:00:17 PM
IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT, IN AND FOR
ORANGE COUNTY, FLORIDA
KHERMES TORRES,
Plaintiff,
vs.
CASE NO: 2017-CA-8065
PROGRESSIVE SELECT INSURANCE CIVIL DIVISION
COMPANY,
Defendant.
___________________________________/
DEFENDANT'S RESPONSES TO PLAINTIFF'S REQUEST FOR PRODUCTION
Defendant, PROGRESSIVE SELECT INSURANCE COMPANY, by and through the
undersigned attorney, files Defendant's Responses to Plaintiff's Request for Production, and would
state as follows:
1. Previously provided.
2. Objection, overbroad, unduly burdensome, claim file privilege, plaintiff is not
entitled to Defendant’s claim file, work product privilege, confidential company information.
3. All statements are attached.
4. All estimates in Defendant’s possession are attached.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been
furnished via E-Mail on November 28, 2017 to David A. Spain, Esquire, Morgan & Morgan,
Attorney for Plaintiff, Khermes Torres, DSpain@forthepeople.com, (407) 420-1414/(407) 423-
7928 (F).
Case No: 2017-CA-8065
Law Office of Terryl Blackmon Walker
Attorneys for Defendant
901 N. Lake Destiny Rd., Suite 105
Maitland, FL 32751
(407) 618-8663 (Asst.)/(407) 618-8850 (Direct)
Fax: (866) 516-8617
SERVICE DESIGNATIONS:
Primary: OrlandoHC@Progressive.com
Secondary: Ereardo1@Progressive.com
By:
EMILY J. REARDON, ESQUIRE
Florida Bar No. 59435
“Salaried Employees of Progressive Casualty Insurance Company”
Document Filed Date
November 28, 2017
Case Filing Date
August 31, 2017
Category
CA - Breach of Agreement/Contract
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Filing # 64681183 E-Filed 11/28/2017 04:00:17 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR ORANGE COUNTY, FLORIDA KHERMES TORRES, Plaintiff, vs. CASE NO: 2017-CA-8065 PROGRESSIVE SELECT INSURANCE CIVIL DIVISION COMPANY, Defendant. ___________________________________/ DEFENDANT'S RESPONSES TO PLAINTIFF'S REQUEST FOR PRODUCTION Defendant, PROGRESSIVE SELECT INSURANCE COMPANY, by and through the undersigned attorney, files Defendant's Responses to Plaintiff's Request for Production, and would state as follows: 1. Previously provided. 2. Objection, overbroad, unduly burdensome, claim file privilege, plaintiff is not entitled to Defendant’s claim file, work product privilege, confidential company information. 3. All statements are attached. 4. All estimates in Defendant’s possession are attached. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been furnished via E-Mail on November 28, 2017 to David A. Spain, Esquire, Morgan & Morgan, Attorney for Plaintiff, Khermes Torres, DSpain@forthepeople.com, (407) 420-1414/(407) 423- 7928 (F). Case No: 2017-CA-8065 Law Office of Terryl Blackmon Walker Attorneys for Defendant 901 N. Lake Destiny Rd., Suite 105 Maitland, FL 32751 (407) 618-8663 (Asst.)/(407) 618-8850 (Direct) Fax: (866) 516-8617 SERVICE DESIGNATIONS: Primary: OrlandoHC@Progressive.com Secondary: Ereardo1@Progressive.com By: EMILY J. REARDON, ESQUIRE Florida Bar No. 59435 “Salaried Employees of Progressive Casualty Insurance Company”