Discovery Response language
Name
c/o of Cole, Scott & Kissane, P.A.
9150 S Dadeland Boulevard Suite 1400
Miami, Florida 33156
The information provided in these responses was derived from a variety of sources and individuals
within insured business, its Claims administrator, Corporate Claims Services and its attorneys. Unless
specifically indicated, these responses are not based on upon the personal knowledge of the insured.
None in Defendant’s possession, custody or control.
Objection, work product; as it pertains to …
Unknown at this time. Defendant reserves the right to supplement this response as discovery
continues.
All affirmative defenses are based upon facts alleged in the Complaint as well as Florida statutes and
common law and are self-explanatory as written. Defendant defers to its attorneys to establish and
support the remaining affirmative defenses as additional facts are elicited throughout the course of
discovery.
Defendant shall comply with the Trial Order as it pertains to expert disclosure.