On June 21, 2017 a
Party Discovery
was filed
involving a dispute between
Ruscalleda, Nilda,
and
Wal-Mart Stores, Inc.,
for Comm Premises Liability
in the District Court of Miami-Dade County.
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Filing # 71403359 E-Filed 04/30/2018 11:32:33 AM
IN THE CIRCUIT COURT OF THE 11TH
JUDICIAL CIRCUIT COURT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
NILDA RUSCALLEDA,
GENERAL JURISDICTION DIVISION |
Plaintiff,
CASE NO.: 17-014924 CA (11)
vs.
Florida Bar No: 0008486
WAL-MART STORES, INC., a foreign
corporation,
Defendant.
/
PLAINTIFF’S RESPONSE TO DEFENDANT’S SUPPLEMENTAL
REQUEST FOR PRODUCTION
COMES NOW the Plaintiff, NILDA RUSCALLEDA, by and through undersigned
counsel files her Response to Defendant’s Supplemental Request to Produce bearing certificate
date of April 18, 2018, as follows:
1, None other than previously provided in response to initial Request for Production. |
2. Please see medical records previously provided in response to initial Request for
Production.
3. None other than previously provided in response to initial Request for Production.
4. None at this time. However, please reference Florida transitory foreign substance statute.
5. None other than depositions already taken.
6. Please see all medical records of treating doctors produced via discovery.
7. None other than previously provided in response to initial Request for Production.
8. None other than previously provided in response to initial Request for Production.
9. None other than previously provided in response to initial Request for Production.Case No.: 17-014924 CA (11)
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the above and foregoing was mailed
this (“day of April, 2018 to Samuel S. Lewis, Esq., Marlow, Adler, Abrams, Newman & Lewis,
4000 Ponce de Leon Blvd., Suite 570, Coral Gables, Fl 33146; slewis@marlowadler.com;
jrenwick@marlowadler.com.
FRIEDLAND LAW GROUP
1430 South Dixie Hwy., Suite 305
Coral Gables, Florida 33146
Tel: (305) 661-2008,
Fax: (305) 661-2001
Document Filed Date
April 30, 2018
Case Filing Date
June 21, 2017
Category
Comm Premises Liability
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Filing # 71403359 E-Filed 04/30/2018 11:32:33 AM IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA NILDA RUSCALLEDA, GENERAL JURISDICTION DIVISION | Plaintiff, CASE NO.: 17-014924 CA (11) vs. Florida Bar No: 0008486 WAL-MART STORES, INC., a foreign corporation, Defendant. / PLAINTIFF’S RESPONSE TO DEFENDANT’S SUPPLEMENTAL REQUEST FOR PRODUCTION COMES NOW the Plaintiff, NILDA RUSCALLEDA, by and through undersigned counsel files her Response to Defendant’s Supplemental Request to Produce bearing certificate date of April 18, 2018, as follows: 1, None other than previously provided in response to initial Request for Production. | 2. Please see medical records previously provided in response to initial Request for Production. 3. None other than previously provided in response to initial Request for Production. 4. None at this time. However, please reference Florida transitory foreign substance statute. 5. None other than depositions already taken. 6. Please see all medical records of treating doctors produced via discovery. 7. None other than previously provided in response to initial Request for Production. 8. None other than previously provided in response to initial Request for Production. 9. None other than previously provided in response to initial Request for Production.Case No.: 17-014924 CA (11) CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing was mailed this (“day of April, 2018 to Samuel S. Lewis, Esq., Marlow, Adler, Abrams, Newman & Lewis, 4000 Ponce de Leon Blvd., Suite 570, Coral Gables, Fl 33146; slewis@marlowadler.com; jrenwick@marlowadler.com. FRIEDLAND LAW GROUP 1430 South Dixie Hwy., Suite 305 Coral Gables, Florida 33146 Tel: (305) 661-2008, Fax: (305) 661-2001