On May 13, 2011 a
Party Discovery
was filed
involving a dispute between
Sandra Wells,
and
Chln Inc,
in the District Court of Manatee County.
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IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT
IN AND FOR MANATEE COUNTY, FLORIDA
CIVIL DIVISION
SANDRA WELLS,
Plaintiff,
vs. CASE NO.: 2011-CA-3102
~
CHLN, INC., dba = 2
CHART HOUSE RESTAURANT, = Oo
BS
Defendant. So 2S
/ 2 32
2 28
PLAINTIFEF’S FRCP 1.351(e) REQUEST FOR COPIES Sg no &
Ea
The Plaintiff, SANDRA WELLS, by and through the undersigned attomesé, files this
Request for Copies of those documents produced pursuant to Defendant, CHLN, INC., dba
CHART HOUSE RESTAURANT’S Notice of Production from Non-Party with Certificate of
Service dated July 13, 2011.
Thomas Rubino, DDS & Lindsay Eastman, DDS
Chambers Medical Group
Harold Chistolen, DMD
North River Dental Group, PA
Plaintiff agrees to pay reasonable costs of preparing the copies ($0.25/page black
and white copies; $1.00/page color copies; and postage) upon presentation of the same and
does request legible copies of all records obtained in response to their Notice of Production
eoccee
within 10 days after said documents or things have been furnished to the Defendant and failing
that, would hereby object to the use thereof by the Defendant at trial, and would further reserve
the right to move to compel, or for sanctions, or for an Order in Limine, restricting the use
thereof. Additionally, if said copies are not provided to counsel for the Plaintiff at least seven (7)
days before Plaintiff's scheduled deposition, the deposition will be scheduled for a later date.
Plaintiff requests to be contacted for approval of copying charges should the charges
exceed $100.00.
This request is made pursuant to Rule 1.351(d), Florida Rules of Civil Procedure.CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been provided
via U.S. Mail and/or Facsimile Transmission to Terra Wilhelm, Esquire, Hightower & Partners,
Bank of America Tower 200 Central Avenue, Suite 450, St. Petersburg, FL 33701 on this
Aah, of July, 2011.
ABRAHAMQON & UITERWYK
900 W. Platt
TOMAS L. GACIO, ESQUIRE
Florida Bar Number: 0845612
Document Filed Date
July 20, 2011
Case Filing Date
May 13, 2011
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IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR MANATEE COUNTY, FLORIDA CIVIL DIVISION SANDRA WELLS, Plaintiff, vs. CASE NO.: 2011-CA-3102 ~ CHLN, INC., dba = 2 CHART HOUSE RESTAURANT, = Oo BS Defendant. So 2S / 2 32 2 28 PLAINTIFEF’S FRCP 1.351(e) REQUEST FOR COPIES Sg no & Ea The Plaintiff, SANDRA WELLS, by and through the undersigned attomesé, files this Request for Copies of those documents produced pursuant to Defendant, CHLN, INC., dba CHART HOUSE RESTAURANT’S Notice of Production from Non-Party with Certificate of Service dated July 13, 2011. Thomas Rubino, DDS & Lindsay Eastman, DDS Chambers Medical Group Harold Chistolen, DMD North River Dental Group, PA Plaintiff agrees to pay reasonable costs of preparing the copies ($0.25/page black and white copies; $1.00/page color copies; and postage) upon presentation of the same and does request legible copies of all records obtained in response to their Notice of Production eoccee within 10 days after said documents or things have been furnished to the Defendant and failing that, would hereby object to the use thereof by the Defendant at trial, and would further reserve the right to move to compel, or for sanctions, or for an Order in Limine, restricting the use thereof. Additionally, if said copies are not provided to counsel for the Plaintiff at least seven (7) days before Plaintiff's scheduled deposition, the deposition will be scheduled for a later date. Plaintiff requests to be contacted for approval of copying charges should the charges exceed $100.00. This request is made pursuant to Rule 1.351(d), Florida Rules of Civil Procedure.CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been provided via U.S. Mail and/or Facsimile Transmission to Terra Wilhelm, Esquire, Hightower & Partners, Bank of America Tower 200 Central Avenue, Suite 450, St. Petersburg, FL 33701 on this Aah, of July, 2011. ABRAHAMQON & UITERWYK 900 W. Platt TOMAS L. GACIO, ESQUIRE Florida Bar Number: 0845612