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PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS – case 6

PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS

IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA

CASE NO. XX

MARY GARCIA,

Plaintiff,

 

v.

 

SMITH INC.,

 

Defendant.

________________________________/

 

PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS

The Plaintiff, MARY GARCIA, by and through the undersigned attorney and requests the Defendant to produce to the Plaintiff, pursuant to Fla.R.Civ.P. 1.350 the following:

  1. The declaration sheet for all liability insurance policies which provide coverage to the Defendant for the subject incident.
  2. Copies of all documents, including violations, received from any governmental entity (including OSHA) pertaining to the subject incident.
  3. All documents which Defendant prepared in response to any alleged violation referred to in #2, above.
  4. All photographs taken by or on behalf of the Defendant of the area of the subject incident.
  5. The personnel files of all employees of Defendant’s employees’ or agents who placed, or caused to be placed, any grease, oil or other substance on the ladder from which Plaintiff contends he slipped.
  6. Any documents of the Defendant pertaining to the placement of oil, grease, or any other substance, on the rungs of the ladders affixed to the building at the XX prior to XX, 20__.
  7. Any statements of any witnesses taken by or on behalf of the defendant or reproductions of any recorded statements of the plaintiff.
  8. Any statements of the plaintiff taken by or on behalf of the defendant or reproductions of any recorded statements of the plaintiff.
  9. Any action/incident reports prepared by or on behalf of the defendant which report contains information concerning the facts and circumstances of the incident sued upon.

 

IT IS HEREBY CERTIFIED that a true and correct copy of the foregoing is being served with the Complaint.

LAW OFFICE OF ALAN D. SACKRIN

Attorney for Plaintiff

2100 East Hallandale Beach Blvd.

Suite 200

Hallandale Beach, Fl. 33009

 

By__________________________

ALAN D. SACKRIN

 

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The pleading above is a sample document related to a specific set of facts and circumstances and should not be used or relied upon for any personal injury matter. This document is being provided for illustrative purposes only. We recommend and urge you to consult with an experienced personal injury lawyer for professional advice as each case is unique.

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