Request For Production Defendants Fourth Request

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IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR

COLLIER COUNTY, FLORIDA CIVIL ACTION.
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ELLIS HANSON and VELTA HANSON, i 2a
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Plaintiffs, we RHerreR
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v. Case No. 09-6515-CA 2 2
ALMA TETI, 3 2
Defendant.

PLAINTIFFS’, ELLIS HANSON AND VELTA HANSON,
RESPONSE TO DEFENDANT’S THIRD REQUEST FOR PRODUCTION
Plaintiffs, Ellis Hanson and Velta Hanson (collectively the “Hansons”), pursuant
to Rule 1.350, Florida Rules of Civil Procedure, respond to the Third Request for
Production filed by Defendant, as follows:
GENERAL RESPONSE
To the extent that each specific response below indicates that documents will be
produced pursuant to this Response: (a) such production of documents shall exclude any
documents that are subject to the attorney/client privilege, the accountant/client privilege,
the attorney/work product privilege or protection, or confidential records, trade secrets,
proprietary or any other documents that are otherwise privileged under law; and (b…