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PLAINTIFF=S RESPONSE TO DEFENDANT=S, REQUEST TO PRODUCE- case 2

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:

  1. Objection, no claim for lost wages.

 

  1. Copies of the following medical records provided:

         

          XXXX, M.D.                               

          XXX, P.A.              

         

  1. None, other than what might be included in the medical records.

 

  1. Copy of some of the expenses incurred as follows:

                                        $XXXX

 

          Remaining bills will be provided upon receipt.

         

  1. A copy of letters from XXXX provided.

 

  1. None, other what was received from XXXX.

 

  1. Objection as it is confidential and may lead to identity theft; however, will be provided at a deposition.

 

  1. Objection as it is confidential and may lead to identity theft; however, will be provided at a deposition.

 

  1. None in Plaintiff=s possession.

 

  1. A copy of with the list of witness provided.

 

  1. None in Plaintiff=s possession.

 

  1. See responses to #s 2 and 4.

 

  1. None.

 

  1. See response to #5.

 

  1. None.

.

  1. A copy of a letter dated XXXX, 20__ from XXXX provided.

 

  1. None.

 

  1. Copy of ticket booklet provided.

 

  1. Copy of the healthcare identification card provided

 

  1. None.

 

  1. Copy of photograph of tender provided.

 

  1. None.

 

  1. 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

/kb

 

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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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