On July 09, 100 a
Party Discovery
was filed
involving a dispute between
Furry, Denise,
and
State Farm Florida Insurance Company,
for Matters Involving Claims > 15,001 - 30,000
in the District Court of Charlotte County.
Preview
Filing # 157890028 E-Filed 09/21/2022 04:21:22 PM
IN THE COUNTY COURT OF THE
2074 JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA
CASE NO.: 21000164CC
DENISE FURRY,
Plaintiff,
VS.
STATE FARM FLORIDA
INSURANCE COMPANY,
/
DEFENDANT’S RESPONSES TO PLAINTIFF’S THIRD REQUEST FOR
PRODUCTION OF DOCUMENTS REGARDING ATTORNEY’S FEES & COSTS
COMES NOW the Defendant, STATE FARM FLORIDA INSURANCE COMPANY, by
and through its undersigned counsel and pursuant to Florida Rule of Civil Procedure 1.350, and
hereby files and serves its Responses to Plaintiff's, DENISE FURRY, PLAINTIFF’S THIRD
REQUEST FOR PRODUCTION OF DOCUMENTS REGARDING ATTORNEY’S FEES &
COSTS, as follows:
1) All documents which identify all witnesses which support, and the complete factual basis for
the Answer contained in STATE FARM FLORIDA INSURANCE COMPANY’S (“STATE
FARM”) answer to Interrogatory No. 22 of Plaintiffs’ First Set of Interrogatories regarding
Attorney’s Fees and Costs, (served on Plaintiff under Certificate of Service dated August 19, 2022)
which states as follows: “... on February 8, 2021 State Farm had determined to invoke appraisal
in this claim...”
Response: An electronic claim activity log note which is part of the claim file, and deemed as
work product.
PRIVILEGE LOG
Document(s): Claim Activity Log Notes.
Dates: From the date this claim was submitted to State Farm, to the date this
claim and lawsuit are fully and finally resolved.
Prepared By: State Farm representatives.
Privileges Asserted: Attorney-client privilege and work product privilege.
Furry vy. State Farm Fla. Ins, Co.
Case No. 21000164CC
Page 2
2) Produce all documents which show the all demands or requests for appraisal made by STATE
FARM on Plaintiff and/or her agents in this matter, and which confirm the date(s) and manner or
method each and every such demand or request for appraisal was provided or served.
Response: Objection, irrelevant, and seeks to confuse the issue on whether there is
entitlement to attorney’s fees and costs.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
via the Florida Courts E-Filing Portal and/or electronic mail this 21st day of September, 2022, to
Matthew R. Danahy, Esq., DANAHY & DUNNAVANT, P.A., 901 West Swann Avenue, Tampa,
Florida 33606 at matt@danddlaw.com; courtney@danddlaw.com; service@danddlaw.com.
GREEN, MATZNER & KELLNER, P.A.
Counsel for State Farm Florida Ins. Co.
1200 North Federal Highway, Suite 301
Boca Raton, Florida 33432
Phone: 561-347-2400
Fax: 561-955-9555
Eservice: jgreen@gaflaw.com
wnorton@gaflaw.com
estevens@gaflaw.com
hkrall@gaflaw.com
By: /s/ Walter W. Norton
JAY B. GREEN
Florida Bar No. 213268
WALTER W. NORTON
Florida Bar No. 775371
Document Filed Date
September 21, 2022
Case Filing Date
July 09, 100
Category
Matters Involving Claims > 15,001 - 30,000
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Filing # 157890028 E-Filed 09/21/2022 04:21:22 PM IN THE COUNTY COURT OF THE 2074 JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CASE NO.: 21000164CC DENISE FURRY, Plaintiff, VS. STATE FARM FLORIDA INSURANCE COMPANY, / DEFENDANT’S RESPONSES TO PLAINTIFF’S THIRD REQUEST FOR PRODUCTION OF DOCUMENTS REGARDING ATTORNEY’S FEES & COSTS COMES NOW the Defendant, STATE FARM FLORIDA INSURANCE COMPANY, by and through its undersigned counsel and pursuant to Florida Rule of Civil Procedure 1.350, and hereby files and serves its Responses to Plaintiff's, DENISE FURRY, PLAINTIFF’S THIRD REQUEST FOR PRODUCTION OF DOCUMENTS REGARDING ATTORNEY’S FEES & COSTS, as follows: 1) All documents which identify all witnesses which support, and the complete factual basis for the Answer contained in STATE FARM FLORIDA INSURANCE COMPANY’S (“STATE FARM”) answer to Interrogatory No. 22 of Plaintiffs’ First Set of Interrogatories regarding Attorney’s Fees and Costs, (served on Plaintiff under Certificate of Service dated August 19, 2022) which states as follows: “... on February 8, 2021 State Farm had determined to invoke appraisal in this claim...” Response: An electronic claim activity log note which is part of the claim file, and deemed as work product. PRIVILEGE LOG Document(s): Claim Activity Log Notes. Dates: From the date this claim was submitted to State Farm, to the date this claim and lawsuit are fully and finally resolved. Prepared By: State Farm representatives. Privileges Asserted: Attorney-client privilege and work product privilege. Furry vy. State Farm Fla. Ins, Co. Case No. 21000164CC Page 2 2) Produce all documents which show the all demands or requests for appraisal made by STATE FARM on Plaintiff and/or her agents in this matter, and which confirm the date(s) and manner or method each and every such demand or request for appraisal was provided or served. Response: Objection, irrelevant, and seeks to confuse the issue on whether there is entitlement to attorney’s fees and costs. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via the Florida Courts E-Filing Portal and/or electronic mail this 21st day of September, 2022, to Matthew R. Danahy, Esq., DANAHY & DUNNAVANT, P.A., 901 West Swann Avenue, Tampa, Florida 33606 at matt@danddlaw.com; courtney@danddlaw.com; service@danddlaw.com. GREEN, MATZNER & KELLNER, P.A. Counsel for State Farm Florida Ins. Co. 1200 North Federal Highway, Suite 301 Boca Raton, Florida 33432 Phone: 561-347-2400 Fax: 561-955-9555 Eservice: jgreen@gaflaw.com wnorton@gaflaw.com estevens@gaflaw.com hkrall@gaflaw.com By: /s/ Walter W. Norton JAY B. GREEN Florida Bar No. 213268 WALTER W. NORTON Florida Bar No. 775371