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 NUMBER: XX
MELISSA THOMPSON,
Plaintiffs,
vs.
CVS PHARMACY, INC.,
Defendant.
__________________________________/
PLAINTIFF’S RESPONSE TO DEFENDANT’S REQUEST TO PRODUCE
Plaintiff, MELISSA THOMPSON by and through the undersigned counsel, hereby files her respond to Defendant=s, CVS PHARMACY, INC., Request to Produce, dated XX, 20__.
- The documents that support allegations of Defendant’s negligence are in Defendant’s statement that was provided by Defendant in response to Plaintiff’s request for production and an eye witness statement by a passenger.
- Copies of passenger ticket and medical records are provided. A statement from an eye-witness is attorney/client privilege and work-product.
- No photographs, video-tapes known.
- XX
CERTIFICATE OF SERVICE
IT IS HEREBY CERTIFIED that on this ____ day of XX, 20__, a true and correct copy of the foregoing was 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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