Party Discovery: Wilner Jean, et al Plaintiff vs. School Board of Broward County Defendant

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                                Filing #   134320405 E-Filed 09/09/2021 08:08:04 PM




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

           WILNER         JEAN,                                CASE NO.: CACE-21-003837
           as   Natural Parent/Legal Guardian of
           GHISLAINE JEAN, a          minor,

                       Plaintiff.


           V




           SCHOOL BOARD OF BROWARD                 COUNTY,

                       Defendant.
                                                           i

                                    PLAINTIFF'S NOTICE OF FILING RESPONSES TO
                                     DEFENDANT'S REQUEST FOR PRODUCTION


                       Plaintiff, WILNER JEAN, as Natural Parent/Legal Guardian of GHISLAINE JEAN, a

           minor, by and through undersigned counsel, files this Notice    of Filing   Responses to Defendant's,

           SCHOOL BOARD OF BROWARD COUNTY, Request for Production dated June 3, 2021.


                                               CERTIFICATE OF SERVICE


                       I HEREBY CERTIFY that a true copy of the   foregoing has been     filed with the Clerk of
           Court and furnished via Clerk's Electronic Service to all counsel ofrecord, this 9TH     day of
           SEPTEMBER 2021.


                                                         MILLER & JACOBS
                                                         Attorneys for Plaintiffs
                                                         1600 South Federal Highway, Suite       #1101
                                                         Pompano Beach, FL 33062
                                                         Telephone:     (954) 784-2277
                                                         Facsimile:     (954) 784-5577
                                                         Email:


                                                         BY:      ROG S.   9UM 4
                                                                  RICK S.   JACOBS, ESQUIRE
                                                                  Florida Bar No: 0057738




                ***
                      FILED: BROWARD   COUNTY, FL BRENDA D. FORMAN, CLERK 09/09/2021 08:08:04 PM.****
PLAINTIFF'S RESPONSE TO DEFENDANT'S REQUEST FOR PRODUCTION


      1.    All documentsin Plaintiff' s   possession attached hereto.

      2.    None in Plaintiff's possession.


      3.    All documentsin Plaintiff' s   possession attached hereto.

      4.    None in Plaintiff's possession.


      5.    All documentsin Plaintiff's possession attached hereto.


      6.    All documentsin Plaintiff's possession attached hereto.


      7.    None in Plaintiff's possession.


      8.    None in Plaintiff's possession.


      9.    None in Plaintiff's possession.


      10.   None in Plaintiff's possession.


      11.   None in Plaintiff's possession.


      12.   None in Plaintiff's possession.


      13.   None in Plaintiff's possession.


      14.   None in Plaintiff's possession.


      15.   All documentsin Plaintiff's possession attached hereto.


      16.   None in Plaintiff's possession.


      17.   None in Plaintiff's possession.


      18.   None in Plaintiff's possession.


      19.   None in Plaintiff's possession.


      20.   None in Plaintiff's possession.


      21.   All documentsin Plaintiff's possession attached hereto.


      22.   None in Plaintiff's possession.
23.   None in Plaintiff's possession.


24.   None in Plaintiff's possession.


25.   None in Plaintiff's possession.


26.   None in Plaintiff's possession.


27.   None in Plaintiff's possession.


28.   None in Plaintiff's possession.


29.   To be determined   as   Discovery is still ongoing.

30.   This informationhas been     provided to   Defendant via the   filing of the
      subject Complaint for Damages.

31.   None in Plaintiff's possession.


32.   None in Plaintiff's possession.