REQUEST TO PRODUCE

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                          Filing # 145359537 E-Filed 03/09/2022 11:22:20 AM

IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT,
IN AND FOR GADSDEN COUNTY, FLORIDA

REGINA DAVIS,
Plaintiff,
vs. CASENO.: — 21000024 CAA

GADSDEN SENIOR
SERVICES, INC.,

Defendant

PLAINTIFF’S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS
PLEASE TAKE NOTICE THAT Plaintiff REGINA DAVIS (“DAVIS”), by and
through the undersigned counsel, and pursuant to Florida Rule of Civil Procedure 1.350, request
that Defendant, the GADSDEN SENIOR SERVICES, INC. (“GSS”) produce and permit
Defendant to inspect and to copy each of the following documents requested below at the offices
of Rayboun Winegardner PLLC, 1410 Piedmont Drive East, Suite 2, Tallahassee, Florida 32308,

within thirty days of service of this request.

DEFINITIONS AND INSTRUCTIONS
1. The term "you" means the GASDEN SENIOR SERVICES, INC. or its personnel
2 The terms “document” or “record” means, without limitation, any writing and any
other tangible thing in your custody, possession…