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PLAINTIFF=S REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT – case 5

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

ROBERT JONES,

 

Plaintiff,

vs.

AMUSEMENT PARKS, LLC.,

                  

Defendant.

_____________________________________/

 

PLAINTIFF=S REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT

The Plaintiff, ROBERT JONES, by and through the undersigned attorney and request the Defendant, AMUSEMENT PARKS, LLC., to produce, pursuant to Fla.R.Civ.P. 1.350 to the Law Office of Alan D. Sackrin, the following:

  1. All and all statements of the plaintiff taken by or on behalf of the defendant or reproductions of any recorded statements of the plaintiff.
  2. Any 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 twelve hours of the occurrence of the incident.
  4. Photographs of the area where the subject incident occurred taken more than twelve hours after occurrence of the incident.
  5. Any photographs taken of the Plaintiff within twelve hours of the occurrence of the incident.
  6. Any statements of any witnesses taken by or on behalf of the defendant or reproductions of any recorded statements of any witnesses.
  7. Any insurance policy which provider’s coverage to Defendant as a result of the subject incident.
  8. Personnel file for any employee named “XX” who was working on the date of the subject incident.
  9. Any videotape or surveillance done in the ordinary course of business of the go-cart area on the date of the subject incident – XX

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