On May 19, 2017 a
Party Discovery
was filed
involving a dispute between
Janet B Robitzsch,
Kenneth Robitzsch,
and
Walt Disney Parks And Resorts Us Inc,
for CA - Premises Liability - Commercial
in the District Court of Orange County.
Preview
Filing # 56694370 E-Filed 05/19/2017 03:18:08 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR ORANGE COUNTY, FLORIDA
JANET B. ROBITZSCH, and
KENNETH ROBITZSCH,
Case No:
Plaintiffs,
v.
WALT DISNEY PARKS AND RESORTS U.S., INC.,
A Florida Corporation,
Defendant.
__________________________________________/
PLAINTIFFS’ FIRST REQUEST TO PRODUCE TO DEFENDANT
Pursuant to Florida Rule of Civil Procedure 1.350(1), Defendant, WALT DISNEY
PARKS AND RESORTS U.S., INC., is notified to produce at the office of the undersigned
attorney, within forty-five (45) days from receipt of this request, the original and all copies of
each of the following documents in the possession, custody or control of the Defendant, or
of any agent, servant, or representative of the Defendant:
1. Any and all policies of insurance issued to the Defendant which do, or may,
provide insurance coverage to said Defendant on account of the incident referred to in the
Complaint herein.
2. Any and all statements, whether written or transcribed, or notes or
memoranda thereof, made to the Defendant or anyone representing or on behalf of any
Defendant and made by the Plaintiffs herein.
3. Any and all statements, whether written or transcribed, or notes or
memoranda thereof, made to the Defendant or anyone representing or on behalf of any
Defendant, and made by any witnesses.
4. Any and all photographs, motion pictures, or drawings of the Plaintiffs herein,
PLAINTIFFS’ FIRST REQUEST TO PRODUCE TO DEFENDANT
Waters vs. Cristiani, et al.
which were made by the Defendant anyone representing or on behalf of any Defendant.
5. Any and all repair estimates of the amusement ride owned by Defendant for
damage to the ride as the result of the accident.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Plaintiffs’, JANET
B. ROBITZSCH and KENNETH ROBITZSCH, First Request to Produce to Defendant is
being officially and simultaneously served and processed on the Defendant, WALT
DISNEY PARKS AND RESORTS U.S., INC., with Summons, along with the Complaint,
Notice of Designation of Email Address, and Interrogatories on the same date.
MOODY LAW, P.A.
BY: _/s/ Christopher D. Russo________
CHRISTOPHER D. RUSSO, ESQUIRE
Florida Bar No. 0026942
575 North Broadway (33830)
Post Office Box 266
Bartow, FL 33831-0266
Telephone: 863-733-9090
Facsimile: 863-534-1001
Attorneys for Plaintiffs
E-Mail Chris@Moodylaw.com
Second E-Mail Fernanda@moodylaw.com
Page 2 of 2
Document Filed Date
May 19, 2017
Case Filing Date
May 19, 2017
Category
CA - Premises Liability - Commercial
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Filing # 56694370 E-Filed 05/19/2017 03:18:08 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA JANET B. ROBITZSCH, and KENNETH ROBITZSCH, Case No: Plaintiffs, v. WALT DISNEY PARKS AND RESORTS U.S., INC., A Florida Corporation, Defendant. __________________________________________/ PLAINTIFFS’ FIRST REQUEST TO PRODUCE TO DEFENDANT Pursuant to Florida Rule of Civil Procedure 1.350(1), Defendant, WALT DISNEY PARKS AND RESORTS U.S., INC., is notified to produce at the office of the undersigned attorney, within forty-five (45) days from receipt of this request, the original and all copies of each of the following documents in the possession, custody or control of the Defendant, or of any agent, servant, or representative of the Defendant: 1. Any and all policies of insurance issued to the Defendant which do, or may, provide insurance coverage to said Defendant on account of the incident referred to in the Complaint herein. 2. Any and all statements, whether written or transcribed, or notes or memoranda thereof, made to the Defendant or anyone representing or on behalf of any Defendant and made by the Plaintiffs herein. 3. Any and all statements, whether written or transcribed, or notes or memoranda thereof, made to the Defendant or anyone representing or on behalf of any Defendant, and made by any witnesses. 4. Any and all photographs, motion pictures, or drawings of the Plaintiffs herein, PLAINTIFFS’ FIRST REQUEST TO PRODUCE TO DEFENDANT Waters vs. Cristiani, et al. which were made by the Defendant anyone representing or on behalf of any Defendant. 5. Any and all repair estimates of the amusement ride owned by Defendant for damage to the ride as the result of the accident. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Plaintiffs’, JANET B. ROBITZSCH and KENNETH ROBITZSCH, First Request to Produce to Defendant is being officially and simultaneously served and processed on the Defendant, WALT DISNEY PARKS AND RESORTS U.S., INC., with Summons, along with the Complaint, Notice of Designation of Email Address, and Interrogatories on the same date. MOODY LAW, P.A. BY: _/s/ Christopher D. Russo________ CHRISTOPHER D. RUSSO, ESQUIRE Florida Bar No. 0026942 575 North Broadway (33830) Post Office Box 266 Bartow, FL 33831-0266 Telephone: 863-733-9090 Facsimile: 863-534-1001 Attorneys for Plaintiffs E-Mail Chris@Moodylaw.com Second E-Mail Fernanda@moodylaw.com Page 2 of 2