AMENDED - OBJECTION TO PLTF'S FIFITH REQUEST TO PRODUCE Filed by ATTORNEY BARBARA W SONNEBORN

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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

  

60s Hd €2 TAC 6002

DEFENDANT, OAKWOOD CENTER OF THE PALM BEACHES,
INC. AMENDED OBJECTIONS TO PLAINTIFFS’ FIFTH REQUEST TO

PRODUCE
(amendment to privilege log only)

COMES NOW the Defendant, OAKWOOD CENTER OF PALM

BEACHES, INC. by and through its undersigned counsel, and serves its

amended objections 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 wh…