UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF FLORIDA

TALLAHASSEE DIVISION

JAMI CLAIRE, KATHRYN LANE,

and AHMIR MURPHY, 

Plaintiffs, 

v. CASE NO.: 4:20-cv-00020-MW-MAF 

FLORIDA DEPARTMENT OF 

MANAGEMENT SERVICES, et al., 

Defendants. 

__________________________________________/ 

FLORIDA DEPARTMENT OF CORRECTIONS’ AND SECRETARY 

MARK INCH’S RULE 26(A)(1) DISCLOSURES

Defendants, MARK INCH, in his official capacity as Secretary of the Florida 

Department of Corrections and the FLORIDA DEPARTMENT OF 

CORRECTIONS (“FDC” or “Department”) (collectively, “FDC Defendants”), by 

and through undersigned counsel, and in compliance with this Court’s Scheduling 

Order, make the following disclosures to Plaintiffs, pursuant to Rule 26(a)(1), Fed. 

R. Civ. P.:

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Introductory Statement

FDC Defendants’ disclosures are based upon information and documents 

known to them at this time. FDC Defendants reserve the right to amend these 

disclosures in accordance with subsequently discovered facts, information, and 

documents. FDC Defendants further reserve the right to object in all subsequent 

proceedings to the use of this information and documents identified below, and 

further states that some or all of the information and documents referenced herein, 

or produced at a later time, may be subject to various objections, protective orders, 

and/or discovery motions and/or motions in limine. FDC Defendants further note 

that this information is set forth in these disclosures may include hearsay and other 

forms of information that are unreliable, irrelevant, or otherwise inadmissible as 

evidence. Therefore, FDC Defendants reserve all objections relating to the 

admissibility of evidence sought or produced herein now or hereafter. Additionally, 

the description of the issues and subject areas known by the individuals listed herein 

is not meant to include the complete foundation of all facts known by such 

individuals.

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Disclosures

A. The name and, if known, the address of each individual likely to have 

discoverable information that the Defendant may use to support its 

defenses, unless solely for impeachment:

1. Ahmir Murphy (Plaintiff)

c/o Plaintiff’s counsel 

One Plaintiff who has the ultimate burden of proving that the FDC 

Defendants committed some unlawful act or some act prohibited by 

existing law. Has knowledge of having one or more medical 

condition(s) which underlie efforts to obtain insurance coverage for 

specific, requested medical procedure(s). May have knowledge that the 

FDC Defendants lacks the ability or legal authority to provide such 

insurance coverage. 

2. Gregory Alan Tracine, II,

Correctional Officer Colonel 

Florida Department of Corrections

c/o Defendant’s Counsel

Has general knowledge of Plaintiff Murphy’s job performance, job 

duties, compensation, and benefits eligibility. Has general knowledge 

of Plaintiff Murphy’s efforts to seek insurance coverage for the medical 

procedure which is the subject of her claim as well as Plaintiff’s request 

for reasonable accommodation in the workplace. 

3. Peter A. Heron, 

Assistant Warden

Florida Department of Corrections

c/o Defendant’s Counsel

Has general knowledge of Plaintiff Murphy’s job performance, job 

duties, compensation, and benefits eligibility. Has general knowledge 

of Plaintiff Murphy’s efforts to seek insurance coverage for the medical 

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procedure which is the subject of her claim as well as Plaintiff’s request 

for reasonable accommodation in the workplace. 

4. David Arthmann, 

Director, Human Resources

Florida Department of Corrections.

Has general knowledge as to human resource and employee benefits 

issues, including the “State Health Insurance Plan”. 

5. Jonathon Satter, 

Secretary

Florida Department of Management Services

c/o Co-Defendant’s Counsel

Has knowledge of the establishment and administration of the “State 

Insurance Plan” including the procurement of insurance vendors 

providing coverage under the plan. 

B. A description by category of all documents, data compilations, and 

tangible things that are in the possession, custody or control of the 

Defendant that may be used to support its defenses, unless solely for 

impeachment:

Plaintiff Murphy’s Personnel File.

Plaintiff Murphy’s correspondence with FDC Defendant Employees.

FDC Employee correspondence with Co-Defendant DMS and documents 

provided to FDC Defendant by Co-Defendant DMS.

AvMed Health Insurance Plan documents.

Correspondence between AvMed and FDC Defendant. 

C. A computation of any category of damages claimed by the disclosing 

party, making available for inspection and copying as under Rule 34 the 

documents or other evidentiary material, not privileged or protected 

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from disclosure, on which such computation is based, including materials 

bearing on the nature and extent of injury suffered.

To the extent Fed. R. Civ. P. 26(a)(1), requires attorney’s fees and costs sought 

by FDC Defendants be disclosed, then, and in, that event, FDC Defendants

would state that they have been required to expend attorneys’ fees and costs 

as a result of defending this action, for which FDC Defendants may be 

entitled. 

D. Insurance Agreement

FDC Defendants are provided insurance coverage pursuant to Chapter 284, 

Florida Statutes. 

Dated this 4th day of June, 2020.

Respectfully submitted,

s/ Mark K. Logan .

MARK K. LOGAN

Florida Bar No. 0494208

E-mail: mlogan@sniffenlaw.com

JEFFREY D. SLANKER

Florida Bar No. 100391

E-mail: jslanker@sniffenlaw.com

MICHAEL P. SPELLMAN

Florida Bar No. 937975

E-mail: mspellman@sniffenlaw.com

SNIFFEN & SPELLMAN, P.A.

123 North Monroe Street

Tallahassee, Florida 32301

Telephone: (850) 205-1996

Facsimile: (850) 205-3004

ATTORNEYS FOR FDC DEFENDANTS

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 4th day of June, 2020, a true copy of the 

foregoing was electronically filed in the U.S. District Court, Northern District of 

Florida, using the CM/ECF system which will send a notice of filing to all counsel 

of record. 

/s/ Mark K. Logan

MARK K. LOGAN 

 

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