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PLAINTIFF’S RESPONSE TO DEFENDANT’S REQUEST FOR PRODUCTION

PLAINTIFF’S RESPONSE TO DEFENDANT’S REQUEST FOR PRODUCTION

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 RESPONSE TO DEFENDANT’S REQUEST FOR PRODUCTION

The Plaintiff, JENNIFER JAMES, through the undersigned attorney, responds to the Request for Production served by Defendant, TARGET CORPORATION., on XX, 20__, as follows:

  1. Copies of Income Tax Returns, including all schedules, attachments and W2 forms, or a properly executed authorization for obtaining a true copy of Federal Income Tax Returns for the following years: XX.

XX

 

  1. A record of earnings for 20__ to date.

 

XX

 

  1. Photographs in the possession, custody or control of Plaintiff’s agents, servants, or attorneys, reflecting the scene of the incident and the damage or injury to vehicles/objects and/or persons involved.

 

XX

 

  1. Copies of medical records, including, but not limited to, first aid reports, paramedic reports, ambulance reports, x-rays, MRIs, topography studies, intra-articular photos, psychologist or psychiatric reports or analysis, and physicians’ diagnosis, generated from all injuries, medical treatment and/or psychological or physical therapy.

 

XX

 

  1. Copies of any and all medical records, therapist’s or psychologist’s notes from any treatment received by Plaintiff, Jennifer James, within the proceeding ten years of the incident in question.

 

XX

 

  1. All ordinances, regulations, rules, statutes, customs and practices and publications upon which your claims and counter-defense herein are made.

 

XX

 

  1. “Statements” within the meaning and definition of Fla. R. Civ. P. 1.280(b)(2) of the Defendant, and agents, employees and principals of the Defendant.

 

XX

 

  1. Birth Certificate for the Plaintiff, Jennifer James, herein.

 

XX

 

  1. Reports from any and all expert witnesses you intend to use at trial.

 

XX

 

 

  1. Documentation of automobile ownership.

 

XX

 

  1. Proof of loss of wages.

 

XX

 

  1. Copies of any and all insurance policies providing benefits or coverage to Plaintiff for any claimed injury or damage arising out of the allegations set forth in the Complaint, including any Statement of Benefits reflecting payments made.

 

XX

 

  1. All records of claims and payments made by any collateral sources of indemnity, as defined in §768.76, Florida Statute, concerning any payments made to Plaintiff by any collateral source for indemnity for injuries or other damages which are the subject of this lawsuit.

 

XX

 

 

CERTIFICATE OF SERVICE

 

IT IS HEREBY CERTIFIED that on the ____ day of XX, 20__, a true and correct copy of the foregoing was ( ) Telefaxed (X)Mailed to:  XX

 

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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