On April 21, 2017 a
Motion to Compel - BETTER ANSWERS FROM DEFENDANT, COMCAST CORPORATIONParty: Plaintiff Vohs, Ronald
was filed
involving a dispute between
Vohs, Ronald,
and
Comcast Corporation,
Industrial Cable Communications Services Inc,
Josimars Cleaning Services Corp,
Usa Br General Services Corp,
for Neg - Premises Liability Residential
in the District Court of Broward County.
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Filing # 72166295 E-Filed 05/15/2018 02:10:38 PM
IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT, INAND FOR
BROWARD COUNTY, FLORIDA
RONALD VOHS,
Plaintiff,
-vs- NO. CACE 17-007673
JOSIMAR'S CLEANING SERVICES
CORP.,USA BR GENERAL SERVICES
CORP., INDUSTRIAL CABLE
COMMUNICATIONS SERVICES INC.,
AND COMCAST CORPORATION,
Defendants.
/
PLAINTIFF'S MOTION TO COMPEL BETTER ANSWERS FROM DEFENDANT,
COMCAST CORPORATION
Plaintiff, RONALD VOHS, by and through the undersigned counsel, files this
Motion to Compel Better Answers from COMCAST CORPORATION and as grounds would
state:
1. The instant matter stems from an incident that occurred January 8, 2016.
2. The Plaintiff propounded Request for Production to Defendant, COMCAST
CORPORATION, contemporaneously with the Complaint.
3. The Defendant filed incomplete answers and/or objections to Plaintiff's
Request for Production on or about July 28, 2017. Plaintiff moves to compel Better
Answers and to Overrule Objections to Plaintiffs Request for Production #’s 12, 13, 14,
15, 16, 17, 18, 19, 20, 21, 22, 27, 36 and 56.
4. Such discovery is narrowly tailored and reasonably calculated to lead to
discovery of admissible evidence.
WHEREFORE, Plaintiff, RONALD VOHS, respectfully requests the Court grant
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 5/15/2018 2:10:39 PM.****Plaintiffs Motion to Compel and enter an Order requiring Defendant to provide better
answers to said discovery within ten days and for any other relief as the Court may deem
proper.
CERTIFICATE OF SERVICE
| hereby Certify that a copy of the foregoing has been filed with the E-Portal which will
send electronic service by email to: Armando P. Rubio, Esq, Fields Howell LLP
arubio@fieldshowell.com:dclarke@fieldshowell.com;smarshall@fieldshowell.com;
service@filedshowell.com; and Connolly C. McArthur, Esq, of Fudge & McArthur,
Eservice@fudgemcarthur.com;dfudge@fudgemcarthur.com;
Apopp@fudgebroadwater.com this _15"_ day of May 2018.
Yeemee Chan, Esquire
Steinger, Iscoe & Greene, P.A.
Coastal Tower
2400 E. Commercial Blvd Suite 900
Fort Lauderdale, FL 33308
(954) 491-7701
Attorney for Plaintiff
ychan@injurylawyers.com
Y eareeC han, Esquire
Yeemee Chan, Esquire
Florida Bar No.: 58355
Document Filed Date
May 15, 2018
Case Filing Date
April 21, 2017
Category
Neg - Premises Liability Residential
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Filing # 72166295 E-Filed 05/15/2018 02:10:38 PM IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT, INAND FOR BROWARD COUNTY, FLORIDA RONALD VOHS, Plaintiff, -vs- NO. CACE 17-007673 JOSIMAR'S CLEANING SERVICES CORP.,USA BR GENERAL SERVICES CORP., INDUSTRIAL CABLE COMMUNICATIONS SERVICES INC., AND COMCAST CORPORATION, Defendants. / PLAINTIFF'S MOTION TO COMPEL BETTER ANSWERS FROM DEFENDANT, COMCAST CORPORATION Plaintiff, RONALD VOHS, by and through the undersigned counsel, files this Motion to Compel Better Answers from COMCAST CORPORATION and as grounds would state: 1. The instant matter stems from an incident that occurred January 8, 2016. 2. The Plaintiff propounded Request for Production to Defendant, COMCAST CORPORATION, contemporaneously with the Complaint. 3. The Defendant filed incomplete answers and/or objections to Plaintiff's Request for Production on or about July 28, 2017. Plaintiff moves to compel Better Answers and to Overrule Objections to Plaintiffs Request for Production #’s 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 27, 36 and 56. 4. Such discovery is narrowly tailored and reasonably calculated to lead to discovery of admissible evidence. WHEREFORE, Plaintiff, RONALD VOHS, respectfully requests the Court grant *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 5/15/2018 2:10:39 PM.****Plaintiffs Motion to Compel and enter an Order requiring Defendant to provide better answers to said discovery within ten days and for any other relief as the Court may deem proper. CERTIFICATE OF SERVICE | hereby Certify that a copy of the foregoing has been filed with the E-Portal which will send electronic service by email to: Armando P. Rubio, Esq, Fields Howell LLP arubio@fieldshowell.com:dclarke@fieldshowell.com;smarshall@fieldshowell.com; service@filedshowell.com; and Connolly C. McArthur, Esq, of Fudge & McArthur, Eservice@fudgemcarthur.com;dfudge@fudgemcarthur.com; Apopp@fudgebroadwater.com this _15"_ day of May 2018. Yeemee Chan, Esquire Steinger, Iscoe & Greene, P.A. Coastal Tower 2400 E. Commercial Blvd Suite 900 Fort Lauderdale, FL 33308 (954) 491-7701 Attorney for Plaintiff ychan@injurylawyers.com Y eareeC han, Esquire Yeemee Chan, Esquire Florida Bar No.: 58355