Response to Request for Production - Due Date: Complete Date: - ROSA RODRIGUEZ VS THE TJX COMPANIES, INC.

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On January 4, 2016 a comm premises liability case was filed by Rodriguez, Rosa, represented by Medina, Monica A., against Lifetime Brands Inc, and The Tjx Companies, Inc., represented by Ben Esco, and Redlich, Rey, in the jurisdiction of Miami-Dade County. Judge Elisabeth M. Espinosa presiding.

                        
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                          Filing # 42785728 E-Filed 06/15/2016 03:00:57 PM

IN THE CIRCUIT COURT OF THE 11"
JUDICIAL CIRCUIT IN AND FOR MIAMI-
DADE COUNTY, FLORIDA
CIRCUIT CIVIL DIVISION
CASE NO. 16-000016 CA 24

ROSA RODRIGUEZ,

Plaintiff,
VS.
THE TJX COMPANIES, INC.,

Defendant.

PLAINTIFF'S RESPONSE TO DEFENDANT'S REQUEST FOR PRODUCTION
The Plaintiff, ROSA RODRIGUEZZ, by and through undersigned counsel and pursuant
to the applicable Florida Rules of Civil Procedure, files her response to Defendant, THE TJX

COMPANIES, INC’s Request for Production served on April 22, 2016 and states as follows:

1, None,

2. None in Plaintiff's possession.

3. Said documents include Plaintiff's medical records and bills. Discovery is ongoing.
4. Objection, there is no claim for lost wages.

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Objection, there is no claim for lost wages.

6 Attached are the medical bills from Florida Health Clinic and Oasis Medical Center.

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Attached are the medical bills from Florida Health Clinic and Oasis Medical Center.

8. Attached a…