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Request For Production Of Documents
IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
CASE NO.: 13-01xxxx
B.O.G.
Plaintiff,
vs.
MILESTONE PROPERTIES INC. and,
DUFFY’S DINER, INC. D/B/A DUFFY’S DINER,
Defendants.
__________________________________/
PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT
The Plaintiff, B.O.G., by and through the undersigned attorney and requests the Defendant, MILESTONE PROPERTIES INC., to produce, pursuant to Fla.R.Civ.P. 1.350 to the Law Office of Alan D. Sackrin, the following:
1. All statements of the plaintiff taken by or on behalf of the defendant(s) or reproductions of any recorded statements of the plaintiff.
2. Accident/incident report prepared by or on behalf of the defendant concerning the subject incident.
3. Photographs of the area where the subject incident occurred taken within one hour of the occurrence of the incident.
4. Photographs of the area where the subject incident occurred taken more than one hour after occurrence of the incident.
5. Any surveillance video showing the area of the incident shortly before, during and after the incident occurred.
6. Any statements of any witnesses taken by or on behalf of the defendant or reproductions of any recorded statements of the plaintiff.
7. Any photographs which depict any foreign or transitory substance on the floor in the are where plaintiff fell.
8. Defendant’s policies and procedures manual in effect on the date of the subject incident pertaining to issues such as maintenance of defendants= pathways guarding against slip and fall incidents, etc.
9. Lease in effect between Defendants as of December 15, 2001.
10. Lease in effect between Duffy’s and any other person(s) or entity as of December 15, 2001.
IT IS HEREBY CERTIFIED that a true and correct copy of the foregoing has been served together with the complaint.
LAW OFFICE OF ALAN D. SACKRIN
Attorney for Plaintiff
2100 East Hallandale Beach Blvd.
Suite 200
Hallandale Beach, FL 33009
Telephone: (954) 455-0800
Facsimile: (954) 455-9649
By__________________________
ALAN D. SACKRIN
Florida Bar No. 349070
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This is a sample lawsuit related to a specific set of facts and circumstances and should not be used or relied upon if you have been in a slip and fall accident. We recommend and urge you to consult with an experienced slip and fall lawyer for professional advice as each case is unique.
Quick Slip And Fall Facts:
Slip and falls are the second leading cause of injuries and deaths after car accidents. Every hour an older adult dies as a result of a fall. The most common injuries resulting from slip and falls include, herniated disc, head injury and/or a knee injury. Learn more from Alan Sackrin, an expert slip and fall lawyer.
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Please feel free to read our other slip and fall (trip and fall) related articles and fact sheets, including:
- 6 Environmental factors that can cause slip and fall accidents
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- Slip and Fall Case Checklist
- Sample Slip and Fall Lawsuit
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