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 # 58072535 E-Filed 06/21/2017 03:04:54 PM
IN THE CIRCUIT COURT OF THE 117
JUDICIAL CIRCUIT IN AND FOR MIAMI-
DADE COUNTY, FLORIDA
NILDA RUSCALLEDA, GENERAL JURISDICTION DIVISION
Plaintiff Case No:
Vs, Florida Bar No: 0008486
WAL-MART STORES, INC., a foreign
corporation,
Defendant
/
REQUEST FOR PRODUCTION
COMES NOW the Plaintiff, NILDA RUSCALLEDA, by and through undersigned
counsel and pursuant to the applicable Florida Rules of Civil Procedure and requests the
Defendant, WAL-MART STORES,INC., a foreign corporation, to produce the following for
inspection and/or copying within the time prescribed by said Rule at the below-named offices:
1. Incident reports and/or accident reports which were prepared by the Defendant
and/or any other person, firm, or entity in the regular course of business.
2. Any and all statements of the Plaintiff revealing knowledge of facts relevant and
material to the claims and defenses in the instant litigation.
3. Any and all photographs, movies, charts and other documentary evidence of the
scene and/or parties involved in or pertaining to the subject accident, occurrences or issues
involved in this cause.
4. Any and all insurance policies providing benefits or coverage to the Defendant for
any claimed injury or damage from the subject accident or occurrence.
5. Any and all photographs and/or movies of the Plaintiffs resulting from
surveillance and/or investigation of the Plaintiffs.6. Any and all maintenance or lease agreements for the subject premises in existence
on the date of the subject incident that relate to cleaning the subject floors.
7, Any and all documents which reflect written or oral complaints received by you
for the subject premises within the five (5) year period prior to the date of accident regarding slip
and fall accidents within the subject store,
8. Policy and procedural manuals for the subject premises regarding:
a, Inspection, cleaning and maintenance of the premises, including its floor.
b. What to do when a customer is injored on the premises.
c Keeping the premises clean and safe for customers,
d Accident and injury prevention inside the store,
9. Any and all videotapes of the subject accident.
As grounds for the foregoing Request, the Plaintiff is unable without undue hardship, to
obtain the substantial equivalent of same by other means,
WE HEREBY CERTIFY that a true and correct copy of the foregoing was served along
with the Summons and Complaint in the above captioned cause.
FRIEDLAND LAW GROUP
Attorneys for Plaintiff’
1430 South Dixie Highway, Suite 305
Coral Gables, Florida 331 46
Tel: (305) 661-2008
Fax: (305) 66
on
Document Filed Date
June 21, 2017
Case Filing Date
June 21, 2017
Category
Comm Premises Liability
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Filing # 58072535 E-Filed 06/21/2017 03:04:54 PM IN THE CIRCUIT COURT OF THE 117 JUDICIAL CIRCUIT IN AND FOR MIAMI- DADE COUNTY, FLORIDA NILDA RUSCALLEDA, GENERAL JURISDICTION DIVISION Plaintiff Case No: Vs, Florida Bar No: 0008486 WAL-MART STORES, INC., a foreign corporation, Defendant / REQUEST FOR PRODUCTION COMES NOW the Plaintiff, NILDA RUSCALLEDA, by and through undersigned counsel and pursuant to the applicable Florida Rules of Civil Procedure and requests the Defendant, WAL-MART STORES,INC., a foreign corporation, to produce the following for inspection and/or copying within the time prescribed by said Rule at the below-named offices: 1. Incident reports and/or accident reports which were prepared by the Defendant and/or any other person, firm, or entity in the regular course of business. 2. Any and all statements of the Plaintiff revealing knowledge of facts relevant and material to the claims and defenses in the instant litigation. 3. Any and all photographs, movies, charts and other documentary evidence of the scene and/or parties involved in or pertaining to the subject accident, occurrences or issues involved in this cause. 4. Any and all insurance policies providing benefits or coverage to the Defendant for any claimed injury or damage from the subject accident or occurrence. 5. Any and all photographs and/or movies of the Plaintiffs resulting from surveillance and/or investigation of the Plaintiffs.6. Any and all maintenance or lease agreements for the subject premises in existence on the date of the subject incident that relate to cleaning the subject floors. 7, Any and all documents which reflect written or oral complaints received by you for the subject premises within the five (5) year period prior to the date of accident regarding slip and fall accidents within the subject store, 8. Policy and procedural manuals for the subject premises regarding: a, Inspection, cleaning and maintenance of the premises, including its floor. b. What to do when a customer is injored on the premises. c Keeping the premises clean and safe for customers, d Accident and injury prevention inside the store, 9. Any and all videotapes of the subject accident. As grounds for the foregoing Request, the Plaintiff is unable without undue hardship, to obtain the substantial equivalent of same by other means, WE HEREBY CERTIFY that a true and correct copy of the foregoing was served along with the Summons and Complaint in the above captioned cause. FRIEDLAND LAW GROUP Attorneys for Plaintiff’ 1430 South Dixie Highway, Suite 305 Coral Gables, Florida 331 46 Tel: (305) 661-2008 Fax: (305) 66 on