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PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT- case 4

PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT

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

CASE NO. XX

JENNIFER JAMES,

 

Plaintiff,

vs.

 

TARGET CORPORATION,

 

Defendant.

_______________________________/

PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT

The Plaintiff, JENNIFER JAMES, by and through the undersigned attorney and requests the Defendant, TARGET CORPORATION, to produce, pursuant to Fla.R.Civ.P. 1.350 to the Law Office of Alan D. Sackrin, the following:

  1. All statements of the plaintiff taken by or on behalf of the defendant or reproductions of any recorded statements of the plaintiff.
  2. Accident/incident report prepared by or on behalf of the defendant concerning the subject incident.
  3. Photographs of the area where the subject incident occurred taken within one hour of the occurrence of the incident.
  4. Photographs of the area where the subject incident occurred taken more than one hour after occurrence of the incident.
  5. In-store surveillance video showing the area of the incident shortly before, during and after the incident occurred.
  6. Any statements of any witnesses taken by or on behalf of the defendant or reproductions of any recorded statements of the plaintiff.
  7. Any photographs which depict any foreign or transitory substance on the floor in the area where plaintiff fell.
  8. Defendant’s policies and procedures manual in effect on the date of the subject incident pertaining to issues such as maintenance of defendant’s floors, guarding against slip and fall incidents, etc.

IT IS HEREBY CERTIFIED that a true and correct copy of the foregoing has been served together 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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