On October 15, 2019 a
Response to Request to Produce
was filed
involving a dispute between
Smith, Lueretta,
and
Winn- Dixie Stores, Inc,
for Neg - Premises Liability Commercial
in the District Court of Broward County.
Preview
Filing # 102971455 E-Filed 02/07/2020 05:28:10 PM
IN THE CIRCUIT COURT OF THE
17" JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
CASE NO: CACE 19-021319
Lueretta Smith, individually,
VS.
Plaintiff,
Winn-Dixie Stores, Inc., a Florida corporation,
Defendant.
/
PLAINTIFF’S RESPONSE TO REQUEST TO PRODUCE
Plaintiff, through undersigned counsel, for her response to Request to Produce, states:
1.
2.
10.
11.
None.
None.
. Attached.
Attached.
. Attached.
Objection as to the use of the word “expert” as Plaintiff has not determined what experts
will be used at trial. Without waiving, attached are medical records from Plaintiff's treating
providers.
. Attached.
None.
None
Attached.
Objection; work product privilege. Plaintiff took photographs of the area of the incident
after the date of loss in anticipation of litigation.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/07/2020 05:28:10 PM.****12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
Objection; overbroad.
None.
None.
Objection; work product privilege. Plaintiff took photographs of the area of the incident
after the date of loss in anticipation of litigation.
None.
None.
None.
None.
Attached.
Objection; overbroad.
Attached.
Attached.
None at present.
Objection; overbroad.
Objection; improper request, without waiving, none.
Objection; overbroad.
Objection; overbroad.
Attached.
Objection; overbroad.
None.
Objection; work product privilege. Plaintiff took photographs of the area of the incident
after the date of loss in anticipation of litigation.CERTIFICATE OF SERVICE
I certify that a copy hereof has been furnished via email to Paul J. Gamm, Esq., at
pgamm@hinshawlaw.com and kcardenas@hinshawlaw.com on February 7, 2020.
The Law Offices of Justin G. Morgan, P.A.
2500 Weston Road, Suite 211
Weston, Florida 33331
Tel: (954) 217-1016
Fax: (954) 217-1019
pleadings@justginmorganlaw.com
/s/Susan Guller
SUSAN GULLER, ESQ.
FBN: 385859
Document Filed Date
February 07, 2020
Case Filing Date
October 15, 2019
Category
Neg - Premises Liability Commercial
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Filing # 102971455 E-Filed 02/07/2020 05:28:10 PM IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO: CACE 19-021319 Lueretta Smith, individually, VS. Plaintiff, Winn-Dixie Stores, Inc., a Florida corporation, Defendant. / PLAINTIFF’S RESPONSE TO REQUEST TO PRODUCE Plaintiff, through undersigned counsel, for her response to Request to Produce, states: 1. 2. 10. 11. None. None. . Attached. Attached. . Attached. Objection as to the use of the word “expert” as Plaintiff has not determined what experts will be used at trial. Without waiving, attached are medical records from Plaintiff's treating providers. . Attached. None. None Attached. Objection; work product privilege. Plaintiff took photographs of the area of the incident after the date of loss in anticipation of litigation. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/07/2020 05:28:10 PM.****12. 13. 14. 15. 16. 17. 18. 19. 20. 21. 22. 23. 24. 25. 26. 27. 28. 29. 30. 31. 32. Objection; overbroad. None. None. Objection; work product privilege. Plaintiff took photographs of the area of the incident after the date of loss in anticipation of litigation. None. None. None. None. Attached. Objection; overbroad. Attached. Attached. None at present. Objection; overbroad. Objection; improper request, without waiving, none. Objection; overbroad. Objection; overbroad. Attached. Objection; overbroad. None. Objection; work product privilege. Plaintiff took photographs of the area of the incident after the date of loss in anticipation of litigation.CERTIFICATE OF SERVICE I certify that a copy hereof has been furnished via email to Paul J. Gamm, Esq., at pgamm@hinshawlaw.com and kcardenas@hinshawlaw.com on February 7, 2020. The Law Offices of Justin G. Morgan, P.A. 2500 Weston Road, Suite 211 Weston, Florida 33331 Tel: (954) 217-1016 Fax: (954) 217-1019 pleadings@justginmorganlaw.com /s/Susan Guller SUSAN GULLER, ESQ. FBN: 385859