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 # 64366943 E-Filed 11/17/2017 03:53:11 PM
IN AND FOR THE CIRCUIT COURT
OF THE 11TH JUDICIAL CIRCUIT IN
AND FOR MIAMI-DADE COUNTY,
FLORIDA
CASE NO.: 17-014924 CA (11)
NILDA RUSCALLEDA,
Plaintiff,
Vv.
WAL-MART STORES, INC. a foreign
corporation,
Defendant.
DEFENDANT'S SECOND REQUEST TO PRODUCE TO PLAINTIFF
Defendant, WALMART STORES, INC., by and through the undersigned counsel,
and pursuant to F.R.Civ.P.1.350, hereby requests the Plaintiff, NILDA RUSCALLEDA,
to produce the following for inspection and copying:
1. Any and all photographs taken by Plaintiff or in the possession of the
Plaintiff of the floor of the Defendant’s store following Plaintiff's alleged incident.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that on 17th day of November, the foregoing was
electronically filed with the Clerk of the Court by using the Florida Courts e-Filing Portal.
It is further certified that a true and correct copy of the foregoing has been furnished via
e-mail to: Jonathan R. Friedland, Esquire, Friedland Law Group, 1430 South DixieCase No.: 17-014924 CA (11)
Highway, Suite 305, Coral Gables, FL 33146; email@friedlandlawgroup.com
By:
Samuel S. Lewis
Samuel S. Lewis, Esq.
Florida Bar No.: 380261
Marlow Adler Abrams Newman & Lewis
4000 Ponce de Leon Blvd., Suite 570
Coral Gables, FL 33146
(305) 460-6520 Telephone
(305) 446-3667 Facsimile
slewis@marlowadler.com
jrenwick@marlowadler.com
Attorneys for Walmart Stores, Inc.
20f2
Document Filed Date
November 17, 2017
Case Filing Date
June 21, 2017
Category
Comm Premises Liability
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Filing # 64366943 E-Filed 11/17/2017 03:53:11 PM IN AND FOR THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NO.: 17-014924 CA (11) NILDA RUSCALLEDA, Plaintiff, Vv. WAL-MART STORES, INC. a foreign corporation, Defendant. DEFENDANT'S SECOND REQUEST TO PRODUCE TO PLAINTIFF Defendant, WALMART STORES, INC., by and through the undersigned counsel, and pursuant to F.R.Civ.P.1.350, hereby requests the Plaintiff, NILDA RUSCALLEDA, to produce the following for inspection and copying: 1. Any and all photographs taken by Plaintiff or in the possession of the Plaintiff of the floor of the Defendant’s store following Plaintiff's alleged incident. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that on 17th day of November, the foregoing was electronically filed with the Clerk of the Court by using the Florida Courts e-Filing Portal. It is further certified that a true and correct copy of the foregoing has been furnished via e-mail to: Jonathan R. Friedland, Esquire, Friedland Law Group, 1430 South DixieCase No.: 17-014924 CA (11) Highway, Suite 305, Coral Gables, FL 33146; email@friedlandlawgroup.com By: Samuel S. Lewis Samuel S. Lewis, Esq. Florida Bar No.: 380261 Marlow Adler Abrams Newman & Lewis 4000 Ponce de Leon Blvd., Suite 570 Coral Gables, FL 33146 (305) 460-6520 Telephone (305) 446-3667 Facsimile slewis@marlowadler.com jrenwick@marlowadler.com Attorneys for Walmart Stores, Inc. 20f2