RESPONSE TO REQUEST TO PRODUCE FILED BY PLTF VIRGINIA PHILLIPS - PHILLIPS, VIRGINIA vs DJS ROOT SCOOTER INC et al

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On January 17, 2019 an auto negligence case was filed by Phillips, Virginia, represented by Liotta, Scott Jerry, against Djs Root Scooter Inc, and Lambert, Donald, represented by Isabel, Melissa Anne, and Rywant, Michael Stanley, in the jurisdiction of Marion County. Judge ROGERS, STEVEN GLEN presiding.

                        
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Filing # 94955865 E-Filed 08/29/2019 09:52:53 AM

                                                               IN THE CIRCUIT COURT OF THE FIFTH
                                                               JUDICIAL CIRCUIT, IN AND FOR
                                                               MARION COUNTY, FLORIDA

                                                               CASE NO:     2019-CA-0142
         VIRGINIA PHILLIPS,

                Plaintiff,

         Vv.


         DONALD LAMBERT and
         DJ’s ROOT SCOOTER, INC.
         A Florida Profit Corporation,

                Defendants.




               PLAINTIFF’S RESPONSE TO DEFENDANT’S REQUEST FOR PRODUCTION

                Plaintiff, VIRGINIA PHILLIPS, by and through the undersigned counsel, hereby

         responds to Defendant, DONALD LAMBERT and DJ’s ROOT SCOOTER, INC. Request to

         Produce, as follows:

                 1       Attached. Find medical bills in possession of Plaintiff.

        …