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REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT- case 1

REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT

IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA

CASE NO. XXXX

RICHARD ROGERS,

 

Plaintiff,

vs.

 

SMITH ROOFING COMPANY,

 

Defendant.

__________________________/

 

REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT

The Plaintiff, RICHARD ROGERS, by and through the undersigned attorney and requests the Defendant, SMITH ROOFING COMPANY, to produce, pursuant to Fla.R.Civ.P. 1.350, to the Law Office of Alan D. Sackrin, the following:

  1. Copies of all time records which indicate the names of Defendant’s employees who were working at the XXXX as of the date of the subject incident.
  2. All contracts between the Defendant and any other party, whether XX, a subcontractor, general contractor, etc., in effect for the XX in XX as of XX, 20__.
  3. Any accident/incident report prepared by or on behalf of the Defendant which contains information concerning the facts and circumstances of the incident sued upon.
  4. All documents in effect as of XX, 20__, which Defendant utilized concerning the proper manner in which to pour tar at a construction site similar to the one where the subject incident occurred.

 

 

  1. Any statements of any witnesses taken by or on behalf of the defendant or reproductions of any recorded statements of witnesses.
  2. Any statements of the plaintiff taken by or on behalf of the defendant or reproductions of any recorded statements of the plaintiff.
  3. Photographs of the area where the subject incident occurred taken with two hours of the subject incident.
  4. Surveillance videotape of the plaintiff taken by or on behalf of the defendant at any time beginning the day after the subject incident.

information concerning the facts and circumstances of the incident sued upon.

IT IS HEREBY CERTIFIED that a true and correct copy of the foregoing has been served with the Complaint.

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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