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PLAINTIFFS’ REQUEST FOR PRODUCTION TO DEFENDANT – case 8

PLAINTIFFS’ REQUEST FOR PRODUCTION TO DEFENDANT

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

CASE NUMBER: XX

MELISSA THOMPSON,

 

Plaintiffs,

vs.

 

CVS PHARMACY, INC.,

 

Defendant.

__________________________________/

PLAINTIFFS’ REQUEST FOR PRODUCTION TO DEFENDANT

The Plaintiff, MELISSA THOMPSON, through the undersigned attorney, requests the Defendant, CVS PHARMACY, INC., to produce, pursuant to Fla. R. Civ. P. 1.350, the following:

  1. A copy of all accident/incident reports prepared by or on behalf of the Defendant which reports were required be completed pursuant to governmental entity mandates pertaining to the incident alleged in the complaint.
  2. Any accident/incident prepared by or on behalf of the Defendant pursuant to the routine procedure or protocols of the Defendant pertaining to the incident alleged in the complaint.
  3. Photographs taken by or on behalf of the Defendant at the time of or within 1 hour of the occurrence of the incident pertaining to any fact or issue in this case.
  4. Any statements of the Plaintiff taken by or on behalf of any of the Defendant or its insurer or reproductions of any recorded statements of the Plaintiff.
  5. Statements of any witnesses taken by or on behalf of the defendant or its insurer.
  6. Declaration sheet of each liability policy insuring Defendant for its potential liability to the plaintiff.
  7. Procedure or protocols in effect in 20__ pertaining to the emergency situations such as this.

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.

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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