Response to Request for Production - Due Date: Complete Date:

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                          Filing # 52490971 E-Filed 02/14/2017 03:58:51 PM

IN THE COUNTY COURT, IN AND FOR
MIAMI-DADE COUNTY, FLORIDA

GENERAL JURISDICTION DIVISION
CASE NO: 16-31411 CA (41)

ARLEN HOUSE EAST CONDOMINIUM
ASSOCIATION INC.,

Plaintiff,
v.
AHE RESTAURANT MANAGEMENT
GROUP, LLC & ALL OTHER TENANTS
IN POSSESSION,

Defendants.
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DEFENDANT/COUNTERCLAIMANT?’S RESPONSE TO
PLAINTIFF/COUNTER-DEFENDANT'S REQUEST FOR PRODUCTION OF
DOCUMENTS

 

Defendant/Counterclaimant, AHE Restaurant Management Group, LLC & All
Other Tenants in Possession, (“Defendant”) respond to Plaintiff/Counter-Defendant’s
Request for Production of Document by Plaintiff/Counter-Defendant, Arlen House East
Condominium Association Inc. (“Plaintiff”), and state

General Objections to Each Item of the Request

 

A Defendant objects to the Requests to the extent production is sought of
attorneys’ work product, materials prepared for litigation and attorney/client privileged
documents. If and to the extent any of the Requests elicit prod…