Response to Request for Production

On October 19, 2020 a neg - premises liability residential case was filed by Moreno, Luis, and Ramos, Mary Beatrice, represented by Share, Stuart H, against Banta Properties, Inc.,, and Colonial Park Apartments, Llc, represented by Mccardle, Patrick Colin, in the jurisdiction of Broward County. Judge Frink, Keathan B. presiding.

                        
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Filing# 137619649 E-Filed 11/01/2021 11:08:37 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 20-017319 LUIS MORENO and MARY BEATRICE RAMOS, a married couple, Plaintiffs, V BANTA PROPERTIES, INC. and COLONIAL PARKAPARTMENTS, LLC, Defendants. DEFENDANT'S RESPONSES AND OBJECTIONS TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS COMES NOW, Defendant, BANTA PROPERTIES, INC., pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, hereby responds to Plaintiffs First Request for Production of Documents as follows: RESPONSES TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION 1. All video recordings in your possession obtained by surveillance or conducted by any visual observations concerning any of the activities of the plaintiff since the time of the occurrence alleged in Plaintiffs Complaint. RESPONSE: This information will be provided in accordance with the trial order, to the extent any exists. …

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