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 # 67099691 E-Filed 01/26/2018 02:06:44 PM
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:
WAL-MART STORES, INC., a foreign
corporation,
Defendant.
/
MOTION TO COMPEL RESPONSE TO
PLAINTIFF'S REQUEST FOR PRODUCTION #8
COMES NOW the Plaintiff, NILDA RUSCALLEDA, by and through undersigned
counsel and hereby moves this Honorable Court to compel the Defendant to produce response to
Plaintiff's Request For Production #8 served with Summons and Complaint as follows:
1. On or about June 30, 2017, the Plaintiff propounded Request for Production on
the Defendant.
2. On or about September 6, 2017, the Defendant filed its response to Plaintiff's
Request for Production.
3. Defendant did not respond to Request for Production #8 and it prevents the
Plaintiff from properly preparing her case for trial.
4, Further, the Plaintiff is unable to obtain the equivalent information from any other
source without hardship.WHEREFORE, the Plaintiff requests this Honorable Court to grant her Motion to
Compel and order the Defendant to provide response to Request for Production #8.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via
U.S. Mail on this 2 - day of January, 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
\4%
Document Filed Date
January 26, 2018
Case Filing Date
June 21, 2017
Category
Comm Premises Liability
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Filing # 67099691 E-Filed 01/26/2018 02:06:44 PM 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: WAL-MART STORES, INC., a foreign corporation, Defendant. / MOTION TO COMPEL RESPONSE TO PLAINTIFF'S REQUEST FOR PRODUCTION #8 COMES NOW the Plaintiff, NILDA RUSCALLEDA, by and through undersigned counsel and hereby moves this Honorable Court to compel the Defendant to produce response to Plaintiff's Request For Production #8 served with Summons and Complaint as follows: 1. On or about June 30, 2017, the Plaintiff propounded Request for Production on the Defendant. 2. On or about September 6, 2017, the Defendant filed its response to Plaintiff's Request for Production. 3. Defendant did not respond to Request for Production #8 and it prevents the Plaintiff from properly preparing her case for trial. 4, Further, the Plaintiff is unable to obtain the equivalent information from any other source without hardship.WHEREFORE, the Plaintiff requests this Honorable Court to grant her Motion to Compel and order the Defendant to provide response to Request for Production #8. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via U.S. Mail on this 2 - day of January, 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 \4%