On December 31, 2007 a
Party Discovery
was filed
involving a dispute between
James Kehoe,
Rene Kehoe,
and
Blue Streak Inc Dba Royal Gymnastics Center,
for OTHER NEGLIGENCE
in the District Court of Palm Beach County.
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IN THE CIRCUIT COURT OF THE
15™ JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY,
FLORIDA
AND AS PARENTS AND NATURAL
GUARDIANS OF KAYLA KEHOE, aminor, CASE NO. 50 2007 CA 024428 XXXXMB
JAMES AND RENE KEHOE, individually, GENERAL JURISDICTION DIVISION ,
Plaintiffs,
vs.
BLUE STREAK, INC., d/b/a ROYAL
GYMNASTICS CENTER
Defendant.
PLAINTIFF'S SUPPLEMENTAL RESPONSES TO DEFENDAN’
STRE. INC.’S FIRST REQUEST FOR PRODUCTIO.
1. Objection. Overbroad, unduly burdensome and not reasonably calculated
to lead to the discovery of admissible evidence. Without waiving this objection,
however, none in Plaintiff's possession, custody or control.
SUPPLEMENTAL RESPONSE:
Plaintiff's parents have filed tax returns, but they don’t have them in their
possession, custody or control. Moreover, the tax returns are not relevant to this
action, as neither Plaintiff is making a lost wage claim.
2. To the extent that Plaintiff has such records in her possession, custody or
control, see attached.
3. To the extent that Plaintiff has such records in her possession, custody or
control, see attached.
4. To the extent that Plaintiff has such records in her possession, custody or
control, see attached.
5. None in Plaintiff’s possession, custody or control.SUPPLEMENTAL RESPONSE:
Plaintiff has not taken written or recorded statements from the defendant
or its employees.
6. Objection. Work product privilege. Without waiving this objection,
however, none.
7. None in Plaintiff's possession, custody or control.
SUPPLEMENTAL RESPONSE:
Plaintiff has health insurance through Blue Cross/Blue Shield of Alabama,
but does not have a copy of the policy.
8. None in Plaintiff's possession, custody or control. As mentioned in
answers to interrogatories, however, Blue Cross/Blue Shield has asserted a health
subrogation lien. This is the only lien about which Plaintiff has knowledge.
9. None in Plaintiffs possession, custody or control.
SUPPLEMENTAL RESPONSE:
As Plaintiff understands the request (it is confusing and unlimited in time
and scope), she does not have such documents in her possession and no such
documents exist.
10. To the extent that Plaintiff has such records in her possession, custody or
control, see attached.
11. Undersigned counsel is in the process of obtaining these documents and
will produce upon receipt.
12. Undersigned counsel is in the process of obtaining these documents and
will produce upon receipt.CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served by
US Mail on this l2day of August, 2008, to John McClure, Eighth Floor, Courthouse Tower,
44 W. Flagler Street, Miami, FL 33130.
Randy M. Weber, Esq.
Attorneys for the Plaintiff
9350 South Dixie Highway, Suite 1200
Miami, FL 3315
Tel:
Fax:
BY:
Randy M-Weber
Fla. Bar No.: 0038880
Document Filed Date
August 14, 2008
Case Filing Date
December 31, 2007
Category
OTHER NEGLIGENCE
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IN THE CIRCUIT COURT OF THE 15™ JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA AND AS PARENTS AND NATURAL GUARDIANS OF KAYLA KEHOE, aminor, CASE NO. 50 2007 CA 024428 XXXXMB JAMES AND RENE KEHOE, individually, GENERAL JURISDICTION DIVISION , Plaintiffs, vs. BLUE STREAK, INC., d/b/a ROYAL GYMNASTICS CENTER Defendant. PLAINTIFF'S SUPPLEMENTAL RESPONSES TO DEFENDAN’ STRE. INC.’S FIRST REQUEST FOR PRODUCTIO. 1. Objection. Overbroad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, however, none in Plaintiff's possession, custody or control. SUPPLEMENTAL RESPONSE: Plaintiff's parents have filed tax returns, but they don’t have them in their possession, custody or control. Moreover, the tax returns are not relevant to this action, as neither Plaintiff is making a lost wage claim. 2. To the extent that Plaintiff has such records in her possession, custody or control, see attached. 3. To the extent that Plaintiff has such records in her possession, custody or control, see attached. 4. To the extent that Plaintiff has such records in her possession, custody or control, see attached. 5. None in Plaintiff’s possession, custody or control.SUPPLEMENTAL RESPONSE: Plaintiff has not taken written or recorded statements from the defendant or its employees. 6. Objection. Work product privilege. Without waiving this objection, however, none. 7. None in Plaintiff's possession, custody or control. SUPPLEMENTAL RESPONSE: Plaintiff has health insurance through Blue Cross/Blue Shield of Alabama, but does not have a copy of the policy. 8. None in Plaintiff's possession, custody or control. As mentioned in answers to interrogatories, however, Blue Cross/Blue Shield has asserted a health subrogation lien. This is the only lien about which Plaintiff has knowledge. 9. None in Plaintiffs possession, custody or control. SUPPLEMENTAL RESPONSE: As Plaintiff understands the request (it is confusing and unlimited in time and scope), she does not have such documents in her possession and no such documents exist. 10. To the extent that Plaintiff has such records in her possession, custody or control, see attached. 11. Undersigned counsel is in the process of obtaining these documents and will produce upon receipt. 12. Undersigned counsel is in the process of obtaining these documents and will produce upon receipt.CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served by US Mail on this l2day of August, 2008, to John McClure, Eighth Floor, Courthouse Tower, 44 W. Flagler Street, Miami, FL 33130. Randy M. Weber, Esq. Attorneys for the Plaintiff 9350 South Dixie Highway, Suite 1200 Miami, FL 3315 Tel: Fax: BY: Randy M-Weber Fla. Bar No.: 0038880