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PLAINTIFF’S RESPONSE TO REQUEST FOR PRODUCTION – case 6

PLAINTIFF’S RESPONSE TO REQUEST FOR PRODUCTION

IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR

BROWARD COUNTY, FLORIDA

CASE NO. XX

MARY GARCIA,

 

Plaintiff,

 

vs.

 

SMITH INC.,

 

Defendant.

________________________________I

 

PLAINTIFF’S RESPONSE TO REQUEST FOR PRODUCTION

The Plaintiff, MARY GARCIA, by and through the undersigned counsel hereby files this, Response to Request for Production propounded by the Defendant, SMITH INC., on XX, 20__.

  1. A properly executed Authorization for obtaining true and correct copy of his Federal Income Tax Returns for the years XX, when filed (said Authorization is attached to the Plaintiff’s copy of this Request for Production).

To be provided. Will provide upon receipt.

  1. a. Withholding statements to date for the years XX when received.

Not in Plaintiff’s possession, to be provided.

  1. Photographs and/or films in the possession, custody or control of the Plaintiff, his agents, servants or attorneys, showing the scene of the accident or

incident and the damage or injury to the objects/vehicles, and/or persons involved.

Six photographs of the scene of the incident provided.

  1. Copies of all medical bills, nursing bills, drug bills, and all other bills

supporting Plaintiff’s claim for damages herein, together with all existing medical,

dental and hospital records and reports of Plaintiff’s condition or ill health, if any, claimed to be related to the incident which is the subject matter of this cause.

The following medical bills are provided:

  1. XX

The following medical records are provided:

  1. XX
  2. Estimates of repair and/or paid repair bills for the Plaintiff’s personal property, if any.

None.

  1. All business records, pay receipts and other memoranda in the possession, custody or control of the Plaintiff, including gross income from self-employment, salary, commissions, bonuses, overages, credits and reimbursements for the business expenses from the beginning of the current calendar year to thirty (30) days prior to the time of trial.

Copies of checks from XX provided from XX

  1. “Statements”, within the meaning and definitions in Rule 1 .280 (b), Florida Rules of Civil Procedure, of the Defendant, the agents of Defendant and employees, and independent witnesses as well as to the Plaintiff, bearing on the knowledge of facts relevant and material to the claim and defenses in the instant

litigation, to be produced prior to any depositions of any said persons.

               Plaintiff has a statement from XX, dated XX. It is

work product.

  1. All of the tangible things within the possession, custody, or control of the Plaintiff herein upon which the claims and defenses herein are based, and specifically, but not limited to, writings, drawings, graphs, charts, photographs, movies, slides, film, video tape, phonograph records and other recording devices, instruments, equipment, real and personal property, objects, goods and/or vehicles or operations which are the subjects of the claims and defenses herein, so that same may be inspected, copied, tested, measured, surveyed, and photographed, pursuant to Rule 1.350, Florida Rules of Civil Procedure.

 Provided in the answer to number 2.

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

Undetermined at this time.

  1. Traffic or other Court transcripts involved the subject matter of the instant litigation.

 None.

  1. All documents and items specified in your Answers to interrogatories as coming within Rule 1 .350 (c), Florida Rules of Civil Procedure, exercising the option to produce records in lieu of summary based on said records and reports.

 

Provided.

  1. All statements obtained by you, or your attorneys, of the Defendant, the agents, servants and employees of Defendant, either recorded or written, at the time of or subsequent to the subject accident or incident.

None of the Defendant.

  1. Copies of any agreements entered into by you or on your behalf with any other Defendant, person, firm, or corporation whom you contend may have some liability exposure for the subject accident or incident.

None.

CERTIFICATE OF SERVICE

IT IS HEREBY CERTIFIED that on the ____day of XX, 20__, a true and correct copy of the foregoing has been (X)faxed (X)Mailed to: XX

Law Office of Alan D. Sackrin

2100 E. Hallandale Beach Blvd.Suite 200

Hallandale Beach, FL 33009

 

By:____________________________

ALAN D. SACKRIN, ESQ.

 

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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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