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PLAINTIFF’S RESPONSE TO DEFENDANT’S REQUEST TO PRODUCE – case 8

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__.

  1. 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.
  2. Copies of passenger ticket and medical records are provided. A statement from an eye-witness is attorney/client privilege and work-product. 
  3. No photographs, video-tapes known.
  4. 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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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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