Request for Production - Party: Defendant Baptiste, Emmanuel Defendant Charles, Joseph Michael

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                          Filing # 115654454 E-Filed 10/27/2020 10:22:55 AM

IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA

DEBORAH ANN WALTERS, CASE NO.: CACE20016603 (13)

Plaintiff,
vs.

EMMANUEL BAPTISTE AND JOSEPH
MICHAEL CHARLES,

Defendants.
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DEFENDANTS' REQUEST FOR PRODUCTION TO THE PLAINTIFF
Please provide films and/or records on CD

 

COMES NOW, the Defendants, EMMANUEL BAPTISTE and JOSEPH M. CHARLES
(hereinafter “Defendants”), by and through their undersigned counsel pursuant to Florida Rules
of Civil Procedure 1.350, hereby requests the Plaintiff, DEBORAH A. WALTERS (hereinafter
“Plaintiff’), to produce to the undersigned attorneys within thirty (30) days from the date hereof,
the following items on the grounds that the items requested contain or constitute material and
relevant evidence to this cause and are unavailable to the Defendants, and without which the
Defendants cannot adequately and properly prepare this case:

1. A complete copy of the Pl…