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PLAINTIFF=S REQUEST FOR PRODUCTION TO DEFENDANT- case 2

PLAINTIFF=S REQUEST FOR PRODUCTION TO DEFENDANT

IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA

CASE NO: XXXX

JOHN SMITH,

Plaintiff,

vs.

 

VACATION CRUISES,

Defendant.

__________________________________/

PLAINTIFF=S REQUEST FOR PRODUCTION TO DEFENDANT

The Plaintiff, JOHN SMITH, through the undersigned attorney, requests the Defendant, VACATION CRUISES, to produce, pursuant to Fla. R. Civ. P. 1.350, the following:

  1. A copy of any and all statements of the Plaintiff taken by or on behalf of the Defendant(s) or reproductions of any recorded statements of the Plaintiff.
  2. A copy of any accident/incident report prepared by or on behalf of the Defendant in the ordinary course of business which report contains information concerning the facts and circumstances of the incident.
  3. Any document pertaining to the alleged incident which Plaintiff wrote in whole or in part or which Plaintiff signed
  4. Photographs of the area where the subject incident occurred taken within three hours of the occurrence of the incident.
  5. Any photographs taken of the Plaintiff by or on behalf of the Defendant.
  6. Copies of any of Defendant=s rules or protocols for the year 20__ pertaining the operation of tenders and the training for the worker operating the tenders.
  7. Statements of any witnesses taken by or on behalf of the Defendant or reproductions of any recorded statements of any witness.
  8. A copy of any surveillance from the date of the incident which shows either the subject incident, any tender utilized and/or the weather and sea conditions as the day of the incident.
  9. Copies of any documents which evidence the procedures in effect for use and/or operation of tenders by Defendant=s employees effective on XXXX, 20__.
  10. All documents that reflect the weather conditions existing at or near XX on XXXX, 20__, including the wind conditions and direction.
  11. All documents, including advisories, which detail the sea conditions at the XXXX on XXXX, 20__.
  12. All documents, including any manuals, utilized by Defendant which identify the criteria for suspending tender service in effect on XXXX, 20__.
  13. All documents evidencing any internal investigation conducted by the Defendant in the ordinary course of its business pertaining to the subject incident or required to be made by any governing authority.
  14. Any documents which indicate any disciplinary action taken against any employee or agent of the Defendant concerning actions in connect with the subject incident.

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

Attorneys for Plaintiff

2100 East Hallandale Beach Blvd. /Ste 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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