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.
Preview
Filing # 62253133 E-Filed 10/02/2017 12:09:05 PM
IN THE CIRCUIT COURT OF THE 11TH
JUDICIAL CIRCUIT COURT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
NILDA RUSCALLEDA,
VS.
GENERAL JURISDICTION DIVISION
Plaintiff,
CASE NO.: 17-014924 CA (11)
Florida Bar No: 0008486
WAL-MART STORES, INC., a foreign
corporation,
Defendant. EK105970e2e51US
/
PLAINTIFE’S RESPONSE TO DEFENDANT’S REQUEST FOR PRODUCTION
COMES NOW the Plaintiff, NILDA RUSCALLEDA, by and through undersigned
counsel files her Response to Defendant, WAL-MART STORES, INC., Request to Produce
bearing certificate date of July 12, 2017, as follows:
. Objection, irrelevant, immaterial and will not lead to the discovery of admissible
evidence as Plaintiff is not making a loss wage claim.
. Objection, irrelevant, immaterial and will not lead to the discovery of admissible
evidence as Plaintiff is not making a loss wage claim.
. Objection, attorney/client work product privilege. Without waiving the objection,
attached are (8) photographs of the scene of the accident and Plaintiff's injuries after the
incident occurred.
. Attached are all medical records in Plaintiffs possession.
. Please see attached prior shoulder surgery films.
. Objection, overbroad, ambiguous, attorney/client work product privilege. Without
waiving the objection, none at this time after the applicable Florida Statute and case law
relevant to slip and fall cases at commercial establishments.
. Undetermined at this time as discovery still continues.
. Have requested and will provide upon receipt.Case Now $7-014924 CA (11)
9. Objection, irrelevant, immaterial and will not lead to the discovery of admissible
evidence as Plaintiff is not making a loss wage claim,
10. None in Plaintiff's possession.
11. None other than Medicaid which is attached to response to Request for Production.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the above and foregoing was mailed
this y of September, 2017 to Samuel S. Lewis, Esq., Marlow, Adler, Abrams, Newnan &
Lewis, 4000 Ponce de Leon Blvd. Suite 570, Coral Gables, Fl 33146;
slewis@marlowadler.comy jr
ick @marlowadier.com.
FRIEDLAND LAW GROUP
1430 South Dixie Hwy.
Coral Gables, Blouida 33146
Tels (305),661-2008 /
Pax: (305) 661-2001
i / : : :
BY___ iframe
Jonathan edlarid, Bad.
Document Filed Date
October 02, 2017
Case Filing Date
June 21, 2017
Category
Comm Premises Liability
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Filing # 62253133 E-Filed 10/02/2017 12:09:05 PM IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA NILDA RUSCALLEDA, VS. GENERAL JURISDICTION DIVISION Plaintiff, CASE NO.: 17-014924 CA (11) Florida Bar No: 0008486 WAL-MART STORES, INC., a foreign corporation, Defendant. EK105970e2e51US / PLAINTIFE’S RESPONSE TO DEFENDANT’S REQUEST FOR PRODUCTION COMES NOW the Plaintiff, NILDA RUSCALLEDA, by and through undersigned counsel files her Response to Defendant, WAL-MART STORES, INC., Request to Produce bearing certificate date of July 12, 2017, as follows: . Objection, irrelevant, immaterial and will not lead to the discovery of admissible evidence as Plaintiff is not making a loss wage claim. . Objection, irrelevant, immaterial and will not lead to the discovery of admissible evidence as Plaintiff is not making a loss wage claim. . Objection, attorney/client work product privilege. Without waiving the objection, attached are (8) photographs of the scene of the accident and Plaintiff's injuries after the incident occurred. . Attached are all medical records in Plaintiffs possession. . Please see attached prior shoulder surgery films. . Objection, overbroad, ambiguous, attorney/client work product privilege. Without waiving the objection, none at this time after the applicable Florida Statute and case law relevant to slip and fall cases at commercial establishments. . Undetermined at this time as discovery still continues. . Have requested and will provide upon receipt.Case Now $7-014924 CA (11) 9. Objection, irrelevant, immaterial and will not lead to the discovery of admissible evidence as Plaintiff is not making a loss wage claim, 10. None in Plaintiff's possession. 11. None other than Medicaid which is attached to response to Request for Production. CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the above and foregoing was mailed this y of September, 2017 to Samuel S. Lewis, Esq., Marlow, Adler, Abrams, Newnan & Lewis, 4000 Ponce de Leon Blvd. Suite 570, Coral Gables, Fl 33146; slewis@marlowadler.comy jr ick @marlowadier.com. FRIEDLAND LAW GROUP 1430 South Dixie Hwy. Coral Gables, Blouida 33146 Tels (305),661-2008 / Pax: (305) 661-2001 i / : : : BY___ iframe Jonathan edlarid, Bad.