On May 12, 2008 a
Response to Request to Produce 7902769 Comments: Response to Request to Produce
was filed
involving a dispute between
Sandra Alicea,
and
George Chater,
for CA - Auto Negligence
in the District Court of Orange County.
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IN THE CIRCUIT COURT OF THE NINTH JUDICIAL
CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA
CIVIL DIVISION
CASE NO.: 2008-CA-010981-O
SANDRA ALICEA,
Plaintiff,
Lydia Gardner
vs.
GEORGE CHATER,
2009 Sep 25 05:57 PM
Defendant.
_______________________________/
DEFENDANT, GEORGE CHATER’S, RESPONSE TO
PLAINTIFF’S REQUEST FOR PRODUCTION
Defendant, GEORGE CHATER, by and through the undersigned counsel, hereby files
eFiled in the Office of Clerk of Court, Orange County Florida
this Response to Plaintiff’s Request to Produce. The following numbered responses correspond
to the numbered Request to Produce.
1. Objection, work product privilege. Without waiving said objection, none.
2. Objection, work product privilege. Without waiving said objection, none.
3. None.
4. None.
5. None.
6. Attached.
7. Objection, relevance. Defendant is not alleging mechanical failure caused this accident.
8. Attached.
9. Objection, work product. Due to the overly broad nature of the request, Defendant is
unable to formulate a privilege log.
10. None.
11. Objection, work product.
12. None.
13. None in possession of the Defendant.
14. Only those provided by Plaintiff’s counsel.
15. None.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY, that on September 25, 2009, I electronically filed the foregoing
with the Clerk of Courts by using the ECF system, which will send a notice of electronic filing to
the following: HARRAN E. UDELL, ESQ., Attorneys for Plaintiff, P.O. Box 4979, 20 N.
th
Orange Ave., 9 Floor, Orlando, FL 32802-4979.
_/S/ Leslie A. Moore_____________
LESLIE A. MOORE, ESQ.
Florida Bar No.: 0581283
Law Offices of Terryl Blackmon Walker
1030 West Canton Avenue, Suite 110
Winter Park, Florida 32789
(407) 975-5820 / Fax: (407) 647-0152
Attorney for Defendant
Document Filed Date
September 25, 2009
Case Filing Date
May 12, 2008
Category
CA - Auto Negligence
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IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CIVIL DIVISION CASE NO.: 2008-CA-010981-O SANDRA ALICEA, Plaintiff, Lydia Gardner vs. GEORGE CHATER, 2009 Sep 25 05:57 PM Defendant. _______________________________/ DEFENDANT, GEORGE CHATER’S, RESPONSE TO PLAINTIFF’S REQUEST FOR PRODUCTION Defendant, GEORGE CHATER, by and through the undersigned counsel, hereby files eFiled in the Office of Clerk of Court, Orange County Florida this Response to Plaintiff’s Request to Produce. The following numbered responses correspond to the numbered Request to Produce. 1. Objection, work product privilege. Without waiving said objection, none. 2. Objection, work product privilege. Without waiving said objection, none. 3. None. 4. None. 5. None. 6. Attached. 7. Objection, relevance. Defendant is not alleging mechanical failure caused this accident. 8. Attached. 9. Objection, work product. Due to the overly broad nature of the request, Defendant is unable to formulate a privilege log. 10. None. 11. Objection, work product. 12. None. 13. None in possession of the Defendant. 14. Only those provided by Plaintiff’s counsel. 15. None. CERTIFICATE OF SERVICE I HEREBY CERTIFY, that on September 25, 2009, I electronically filed the foregoing with the Clerk of Courts by using the ECF system, which will send a notice of electronic filing to the following: HARRAN E. UDELL, ESQ., Attorneys for Plaintiff, P.O. Box 4979, 20 N. th Orange Ave., 9 Floor, Orlando, FL 32802-4979. _/S/ Leslie A. Moore_____________ LESLIE A. MOORE, ESQ. Florida Bar No.: 0581283 Law Offices of Terryl Blackmon Walker 1030 West Canton Avenue, Suite 110 Winter Park, Florida 32789 (407) 975-5820 / Fax: (407) 647-0152 Attorney for Defendant