PLAINTIFF=S RESPONSE TO DEFENDANT=S, REQUEST TO PRODUCE
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 RESPONSE TO
DEFENDANT=S, REQUEST TO PRODUCE
The Plaintiff, JOHN SMITH, through the undersigned counsel, respond to Defendant=s, VACATION CRUISES, Request to Produce served on or about XXXX, 2__, as follows:
- Objection, no claim for lost wages.
- Copies of the following medical records provided:
XXXX, M.D.
XXX, P.A.
- None, other than what might be included in the medical records.
- Copy of some of the expenses incurred as follows:
$XXXX
Remaining bills will be provided upon receipt.
- A copy of letters from XXXX provided.
- None, other what was received from XXXX.
- Objection as it is confidential and may lead to identity theft; however, will be provided at a deposition.
- Objection as it is confidential and may lead to identity theft; however, will be provided at a deposition.
- None in Plaintiff=s possession.
- A copy of with the list of witness provided.
- None in Plaintiff=s possession.
- See responses to #s 2 and 4.
- None.
- See response to #5.
- None.
.
- A copy of a letter dated XXXX, 20__ from XXXX provided.
- None.
- Copy of ticket booklet provided.
- Copy of the healthcare identification card provided
- None.
- Copy of photograph of tender provided.
- None.
- If Defendant provides the HIPPA compliant release form for Plaintiff’s signature, will be provided.
CERTIFICATE OF SERVICE
IT IS HEREBY CERTIFIED that on this ____ day of XXXX, 20__, a true and correct copy of the foregoing was mailed to: XXXX.
LAW OFFICE OF ALAN D. SACKRIN
Attorney for Plaintiff(s)
2100 East Hallandale Beach Blvd. /Ste. 200
Hallandale Beach, FL 33009
By______________________________
ALAN D. SACKRIN
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