On December 29, 2017 a
Party Discovery
was filed
involving a dispute between
Martin, David,
and
State Farm Mutual Automobile Insurance Company,
for AUTO NEGLIGENCE - CIRCUIT
in the District Court of Pinellas County.
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Filing # 66976698 E-Filed 01/24/2018 02:40:34 PM
IN THE COURT OF THE SIXTH JUDICIAL CIRCUIT
IN AND FOR PINELLAS COUNTY, FLORIDA
CIVIL DIVISION
DAVID MARTIN,
Plaintiff,
CASE NO.: 18-000010-CI
vs.
SECTION: 7
STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY,
Defendant.
/
NOTICE OF SERVING RESPONSE TO FIRST REQUEST TO PRODUCE
Defendant, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, by and
through the undersigned counsel, hereby gives Notice of Serving Response to First Request to
Produce served by Plaintist counsel with the Summons and Complaint on January 4, 2018, as
follows:
1. Any and all policies of insurance and indemnity agreements (including declaration
sheets) providing coverage for the subject incident.
RESPONSE: Attached.
2. Any and all written or recorded statements of the Plaintiff.
RESPONSE: None.
3. Any and allclaims, proof of loss and notices of incidents prepared. by investigators.
adjusters, claims personnel or other agents or employees of Defendant(s) from
information obtained directly from the Plaintiff regarding the subject incident.
RESPONSE: Objected to as work product.
4. Any and all written or recorded statements taken from parties or Witnesses
concerning any issue in this cause.
RESPONSE: Obj ected to as work product. Without waiving said objection, none.
5. Any and all photographs, Video recordings, graphs, charts and other documentary
evidence of the scene, parties, or vehicles involved in or pertaining to the subject
incident, occurrence or issues in this cause.
***ELECTRONICALLY FILED 01/24/2018 02:40:34 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
RESPONSE: See attached photographs of Plaintiff’ 5 vehicle. We are not in
possession of any other photographs.
Any and all surveillance tapes, Videos, movies, photography, and reports of the
Plaintiff, including, but not limited to surveillance Videotapes and photographs.
RESPONSE: Objected to as work product. However, Without waiving said
objection, surveillance has not been conducted.
Any and all repair bills or estimates concerning the damage to any vehicles involved
in the subject incident.
RESPONSE: See attached Estimate for Plajmifl’ 5 vehicle.
Any and all laser color copies of all pictures, photographs, Video tapes or recordings,
or slides of any and all vehicles involved in the subject incident.
RESPONSE: See Response No. 5.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished on
January 24, 2018, by e-mail delivery to the individuals on the attached Service List.
/s/ Paul N. Gross
J. EMORY WOOD, ESQUIRE
Florida Bar No.: 278920
PAUL N. GROSS, ESQUIRE
Florida Bar No.: 0013529
JULIAN E. WOOD, JR., ESQUIRE
Florida Bar No.: 58004
WOOD, GROSS & WOOD, PA.
1034 16th Street North, Suite A
St. Petersburg, Florida 33705-1147
(727) 823-6888; Fax: (866) 743-3808
Primary e-mail: attorneys@woodlawpa.com
Secondary e-mail: partner@woodlawpa.com
SERVICE LIST:
Jodi B. Leisure, Esquire
docservice@tcarey.com; receptionist@tcarey.com
Carey, Leisure & Neal
622 Bypass Drive, Ste. 100
Clearwater FL 33764
Attorneys for Plaintiff
Document Filed Date
January 24, 2018
Case Filing Date
December 29, 2017
Category
AUTO NEGLIGENCE - CIRCUIT
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Filing # 66976698 E-Filed 01/24/2018 02:40:34 PM IN THE COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CIVIL DIVISION DAVID MARTIN, Plaintiff, CASE NO.: 18-000010-CI vs. SECTION: 7 STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Defendant. / NOTICE OF SERVING RESPONSE TO FIRST REQUEST TO PRODUCE Defendant, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, by and through the undersigned counsel, hereby gives Notice of Serving Response to First Request to Produce served by Plaintist counsel with the Summons and Complaint on January 4, 2018, as follows: 1. Any and all policies of insurance and indemnity agreements (including declaration sheets) providing coverage for the subject incident. RESPONSE: Attached. 2. Any and all written or recorded statements of the Plaintiff. RESPONSE: None. 3. Any and allclaims, proof of loss and notices of incidents prepared. by investigators. adjusters, claims personnel or other agents or employees of Defendant(s) from information obtained directly from the Plaintiff regarding the subject incident. RESPONSE: Objected to as work product. 4. Any and all written or recorded statements taken from parties or Witnesses concerning any issue in this cause. RESPONSE: Obj ected to as work product. Without waiving said objection, none. 5. Any and all photographs, Video recordings, graphs, charts and other documentary evidence of the scene, parties, or vehicles involved in or pertaining to the subject incident, occurrence or issues in this cause. ***ELECTRONICALLY FILED 01/24/2018 02:40:34 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** RESPONSE: See attached photographs of Plaintiff’ 5 vehicle. We are not in possession of any other photographs. Any and all surveillance tapes, Videos, movies, photography, and reports of the Plaintiff, including, but not limited to surveillance Videotapes and photographs. RESPONSE: Objected to as work product. However, Without waiving said objection, surveillance has not been conducted. Any and all repair bills or estimates concerning the damage to any vehicles involved in the subject incident. RESPONSE: See attached Estimate for Plajmifl’ 5 vehicle. Any and all laser color copies of all pictures, photographs, Video tapes or recordings, or slides of any and all vehicles involved in the subject incident. RESPONSE: See Response No. 5. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished on January 24, 2018, by e-mail delivery to the individuals on the attached Service List. /s/ Paul N. Gross J. EMORY WOOD, ESQUIRE Florida Bar No.: 278920 PAUL N. GROSS, ESQUIRE Florida Bar No.: 0013529 JULIAN E. WOOD, JR., ESQUIRE Florida Bar No.: 58004 WOOD, GROSS & WOOD, PA. 1034 16th Street North, Suite A St. Petersburg, Florida 33705-1147 (727) 823-6888; Fax: (866) 743-3808 Primary e-mail: attorneys@woodlawpa.com Secondary e-mail: partner@woodlawpa.com SERVICE LIST: Jodi B. Leisure, Esquire docservice@tcarey.com; receptionist@tcarey.com Carey, Leisure & Neal 622 Bypass Drive, Ste. 100 Clearwater FL 33764 Attorneys for Plaintiff