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APTVC, LLC and Gatesco, Inc., file this Response to Plaintiff's
Defendant APTVC, LLC and Defendant Gatesco, Inc.
Defendants’ Response to Plaintiff's
Motion to Compel Page
Second Request for Production, sans attachments
xhibit 5 string of attorneys’ communications and,
Exhibit 6 Original Affidavit of Gary W. Gates, Jr
Introduction and Overview
owns and manages an apartment complex known as the de
Cancun Apartments, hereinafter referred to as “the Complex Plaintiff alleges, by way of
her lawsuit, that on or about June 5, 2016 he suffered personal injuries from a falling
ceiling while residing at the Complex. At the time of Plaintiff s alleged i…
