Party Discovery: HUXTABLE, BRENTLEY M vs. RESUMIL, CARLOS E

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                                Filing # 99657445 E-Filed 12/02/2019 04:08:42 PM


                                          IN THE CIRCUIT COURT OF THE NINTH JUDICIAL
                                         CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA

                                                                                                CASE NO. 2017-CA-004395-O
                                                                                                                             DIV: 35

                  BRENTLEY M. HUXTABLE,

                                             PLAINTIFF,

                  V.

                  CARLOS E. RESUMIL,

                                             DEFENDANT.

                  ______________________________/


                     DEFENDANT,           CARLOS E. RESUMIL’S RESPONSE TO REQUEST TO PRODUCE


                  COMES NOW the Defendant, CARLOS E. RESUMIL, by and through his undersigned counsel,

                  and responds to Plaintiff’s Request to Produce as follows:

                           1.       Attached is a copy of Mr. Resumil’s driver’s license.

                           2.       None.

                           3.       None.

                           4.       None.

                           5.       Attached is insurance policy.

                           6.       None.

                           7.       None.

                           8.       Objection, over broad, vague, irrelevant, and not reasonably calculated to lead to
                                    the discovery of admissible evidence and work product privilege.                Without
                                    waiving said objection, none.

                           9.       Objection, over broad, vague, irrelevant, and not reasonably calculated to lead to
                                    the discovery of admissible evidence and work product privilege.



                  TC#  17-012438
                           10.      None.

                           11.      Objection, over broad, vague, irrelevant, and not reasonably calculated to lead to
                                    the discovery of admissible evidence and work product privilege.                Without
                                    waiving said objection, none.

                           12.      Objection, over broad, vague, irrelevant, and not reasonably calculated to lead to
                                    the discovery of admissible evidence and work product privilege.                Without
                                    waiving said objection, none.

                           13.      None.


                                                         CERTIFICATE OF SERVICE

                           The   document      contains    no   confidential    or  sensitive    information     or  that  any   such
                  confidential or sensitive language has been properly protected by complying with the provisions
                  of Rule 2.420 and 2.425.       I HEREBY CERTIFY that a true and correct copy of the foregoing has
                  been furnished by electronic filing to John Allan Watson, Esquire/ Travis J. McMillen, Esquire,
                  jwatson@boginmunns.com,            storres@boginmunns.com,           bmmservice@boginmunns.com,              Bogin,
                  Munns & Munns, P.A., Gateway Center, 1000 Legion Place, Suite 1000, Orlando, FL 32801 on
                  this 2nd day of December, 2019.



                                                                        /S/ Brad Higginbotham
                                                                        BRAD HIGGINBOTHAM, ESQUIRE
                                                                        Fla. Bar No.:    658642
                                                                        Law Office of Sonya S. Wesner
                                                                        200 East Robinson Street, Suite 510
                                                                        Orlando, FL 32801
                                                                        Direct Dial:      (407) 393-9087
                                                                        Paralegal:        (407) 393-9096
                                                                        Secretary:        (407) 393-9094
                                                                        Primary E-Mail:      ORLMAIL@Nationwide.com
                                                                        Attorneys for Defendant




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