RESPONSE TO REQ TO PRODUCE - PLAINTIFF'S SUPPLEMENTAL RESPONSE TO DEFENDANT'S REQUEST FOR PRODUCTION

On April 15, 2021 a premises liability commercial case was filed by Monique Walker, represented by Donald Raymond Smith, against Walmart Inc, and Wal-Mart Stores East Lp, represented by Andrew Palma, Jerry Dean Hamilton, Stephanie H Vo, Suzette L Russomanno, and William H Edwards, in the jurisdiction of Palm Beach County. Judge G. Joseph Curley presiding.

                        
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Filing # 134033654 E-Filed 09/03/2021 02:42:12 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA MONIQUE WALKER, individually, Plaintiff, Vv. WAL-MART STORES EAST, LP, a foreign limited partnership, Defendant. / PLAINTIFF’S SUPPLE DEF ANT’S RE TAL RESPONSE TO FOR PRODUCTION COMES NOW, the Plaintiff, MONIQUE WALKER (hereinafter “Plaintiff’), by and through the undersigned counsel, and hereby files this Supplemental Response to Defendant’s Request for Production, as follows: RESPONSE 1. As to Request #4: (medical records, etc., from each health care professional where Plaintiff's treated for injuries for which Plaintiff seeks damages in this Action): Attached — Central Palm Beach Surgery Center and Spine & Orthopedic Specialists medical records in Plaintiff's possession. 2. As to Request #6: (any and all documentation that is or relates to any expenses incurred by reason of any and all injuries sustained as a result o…

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