RESPONSE TO: - PLTFS AMENDED REQUEST FOR PRODUCTION OF DOCUMENTS Filed by DEFENDANT MIDTOWN IMAGING LLC

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                          IN THE CIRCUIT COURT OF THE FIFTEENTH
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA

CASE NO.: 05-2008-CA-002138-XXXX-MB

TERESA MARIA CORTINAS, M.D., P.A. A DP

 

Plaintiff,

vs. rm
ADVANCED IMAGING ASSOCIATES, LLC, a
MIDTOWN IMAGING, LLC, ROBERT D.

BURKE, M.D., P.L., and ROBERT D. BURKE,

 

82:1 Hd Ol Udi eo

 

Defendants.
/

 

DEFENDANT MIDTOWN IMAGINING, LLC’S RESPONSE TO PLAINTIFF’S

AMENDED REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANTS

Defendant, Midtown Imaging, LLC (“MTI”), by and through undersigned counsel and
pursuant to Florida Rule of Civil Procedure 1.350, hereby respond to Plaintiff's Amended
Request for Production of Documents to Defendants.

GENERAL OBJECTIONS

 

(a) Defendant objects to any definitions or instructions that impose requirements
beyond those set forth in the applicable Florida Rules of Civil Procedure or Local
Rules.

(b) Defendant objects to any request that calls for a response that infringes upon the
attorney-client, accountant-cl…