On January 05, 2018 a
Request,Application
was filed
involving a dispute between
Guzman, Noralys,
and
Mohammed, Ayesha,
Tahseen, Nighat Aziz,
for Auto Negligence
in the District Court of Broward County.
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Filing # 109565634 E-Filed 06/29/2020 06:17:22 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
Case No.: CACE18000390 (25)
NORALYS GUZMAN,
Plaintiff(s),
v.
AYESHA MOHAMMED, owner, and
NIGHAT AZIZ TAHSEEN, driver,
Defendant(s).
AMENDED RESPONSE TO UPDATED TRIAL REQUEST FOR PRODUCTION
COMES NOW the Defendant, Nighat Tahseen, by and through the undersigned
attorney, files this Response to Plaintiff's Updated Trial Request for Production, and
states as follows:
As to each of the Requests, Defendant will provide those documents which
Defendant has been able to locate at this time. Defendant reserves the right to
supplement these Responses upon further investigation and discovery.
1. None.
2. None.
3. Documents will be enclosed in accompanying CD.
4. Documents will be enclosed in accompanying CD.
5. Documents will be enclosed in a second accompanying CD.
6. Documents will be enclosed in a second accompanying CD.
7. Documents will be enclosed in accompanying CD.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/29/2020 06:17:21 PM.****8. Documents expected to be used at trial have been previously
disclosed and/or are disclosed to Plaintiff herein.
9. Documents will be enclosed in accompanying CD.
10. Documents will be enclosed in accompanying CD.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished by Electronic Mail on this the 29th day of June, 2020 to the following
designated service email address(es): Berkin Aslan, Esq., Kanner & Pintaluga, P A,
Pleadings13@kpattorney.com, baslan@kpattorney.com.
The Law Office of George L. Cimballa, III
/s/ Géselle D
Giselle Defalla, Esq.
(Employees of GEICO General Insurance Company)
Florida Bar No: 127121
600 N. Pine Island Road, Suite 260
Plantation, FL 33324
Phone: 954-472-6585
Facsimile: 954-472-6586
Attorney for Defendant(s): Nighat Tahseen; Ayesha
Mohammed.
Service Email: ftlgeico@geico.com;
gdefalla@gmail.com
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Filing # 109565634 E-Filed 06/29/2020 06:17:22 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA Case No.: CACE18000390 (25) NORALYS GUZMAN, Plaintiff(s), v. AYESHA MOHAMMED, owner, and NIGHAT AZIZ TAHSEEN, driver, Defendant(s). AMENDED RESPONSE TO UPDATED TRIAL REQUEST FOR PRODUCTION COMES NOW the Defendant, Nighat Tahseen, by and through the undersigned attorney, files this Response to Plaintiff's Updated Trial Request for Production, and states as follows: As to each of the Requests, Defendant will provide those documents which Defendant has been able to locate at this time. Defendant reserves the right to supplement these Responses upon further investigation and discovery. 1. None. 2. None. 3. Documents will be enclosed in accompanying CD. 4. Documents will be enclosed in accompanying CD. 5. Documents will be enclosed in a second accompanying CD. 6. Documents will be enclosed in a second accompanying CD. 7. Documents will be enclosed in accompanying CD. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/29/2020 06:17:21 PM.****8. Documents expected to be used at trial have been previously disclosed and/or are disclosed to Plaintiff herein. 9. Documents will be enclosed in accompanying CD. 10. Documents will be enclosed in accompanying CD. CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Electronic Mail on this the 29th day of June, 2020 to the following designated service email address(es): Berkin Aslan, Esq., Kanner & Pintaluga, P A, Pleadings13@kpattorney.com, baslan@kpattorney.com. The Law Office of George L. Cimballa, III /s/ Géselle D Giselle Defalla, Esq. (Employees of GEICO General Insurance Company) Florida Bar No: 127121 600 N. Pine Island Road, Suite 260 Plantation, FL 33324 Phone: 954-472-6585 Facsimile: 954-472-6586 Attorney for Defendant(s): Nighat Tahseen; Ayesha Mohammed. Service Email: ftlgeico@geico.com; gdefalla@gmail.com