OBJECTION - TO PLTFS 5TH REQUEST TO PRODUCE Filed by DEFENDANT OAKWOOD CENTER OF THE PALM BEACHES INC

On December 30, 2005 an other negligence case was filed by Adele Smith, Ralph C Smith, and Ralph Smith, represented by William W Price, against Oakwood Center Of The Palm Beaches Inc, represented by Barbara W Sonneborn, and Michael S Smith, in the jurisdiction of Palm Beach County.

                        
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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502005CA012194XXXXMB AA RALPH C. SMITH, SR., and ADELE SMITH as Co-Personal Representatives of the Estate of RALPH C. SMITH, JR., deceased, and RALPH C. SMITH, SR., and ADELE SMITH, Individually, Plaintiffs, vs. OAKWOOD CENTER OF THE PALM BEACHES, INC., a Florida Corporation, Defendant / DEFENDANT, OAKWOOD CENTER OF THE PALM BEACHES, INC. OBJECTIONS TO PLAINTIFFS’ FIFTH REQUEST TO PRODUCE COMES NOW the Defendant, OAKWOOD CENTER OF PALM BEACHES, INC. by and through its undersigned counsel, and objects to Plaintiffs’ Fifth Request to Produce served on June 13, 2008, and states as follows: 3. Objection: irrelevant, immaterial, and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving the foregoing objection, timesheets for the date of the incident which forms the basis of Plaintiff's complaint are being retrieved and will be produced upon receip…

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