On December 31, 2016 a
Response to Request for Production
was filed
involving a dispute between
Vivio, Donna,
and
E & B Alf Inc,
for Neg - Premises Liability Commercial
in the District Court of Broward County.
Preview
Filing # 56300448 E-Filed 05/11/2017 11:53:19 AM
IN THE CIRCUIT COURT OF THE 17
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO: 17-000359
DONNA VIVIO, as Personal Representatives
of the Estate of HARRIET S. MONTELIONE,
deceased,
Plaintiffs,
vs.
E & BALF, INC., d/b/a GOLDEN AGE
MANOR,
Defendant.
/
RESPONSE TO REQUEST FOR PRODUCTION
COMES NOW the Plaintiffs, by and through undersigned counsel, files this Response to
Defendant’s Request for Production dated March 24, 2017, pursuant to Florida Rules of Civil
Procedures, as follows:
1. Attached.
2. Attached.
3. See Privilege Log.
4. Attached.
*#* FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 5/11/2017 11:53:18 AM.****5. Attached.
6. Attached.
7. Objection, work product. Work product. Without waiving said objection, none in
our possession.
8. Objection, work product. Work product. Without waiving said objection, none in
our possession.
9. See Privilege Log.
10. Attached.
11. None in our possession.
12. None in our possession.
13. None in our possession.
14. None in our possession.
15. Objection, work product. Work product. Without waiving said objection, none in
our possession.
16. None in our possession.
17. i-v. None in our possession.
18. Objection, work product. Work product. Without waiving said objection, none in
our possession.
19. Objection, work product. Work product. Without waiving said objection, none in
our possession.20. Attached.
21. — Attached.
22. None in our possession.
WE HEREBY CERTIFY that a true and correct copy of the foregoing was emailed this
11th day of May, 2017 to: John D. Coleman, Esquire.
SILVERSTEIN, SILVERSTEIN &
SILVERSTEIN, P.A.
504 Aventura Corporate Center
20801 Biscayne Boulevard
Aventura, Florida 33180
Miami-Dade (305) 935-2500
Broward (954) 463-1333
Facsimile (305) 935-3214
dsilverstein@ssspa-law.com
gpatterson@ssspa-law.com
By: s/DARRYN L. SILVERSTEIN
Florida Bar #511633
Attorney for Plaintiff
Document Filed Date
May 11, 2017
Case Filing Date
December 31, 2016
Category
Neg - Premises Liability Commercial
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing # 56300448 E-Filed 05/11/2017 11:53:19 AM IN THE CIRCUIT COURT OF THE 17 JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO: 17-000359 DONNA VIVIO, as Personal Representatives of the Estate of HARRIET S. MONTELIONE, deceased, Plaintiffs, vs. E & BALF, INC., d/b/a GOLDEN AGE MANOR, Defendant. / RESPONSE TO REQUEST FOR PRODUCTION COMES NOW the Plaintiffs, by and through undersigned counsel, files this Response to Defendant’s Request for Production dated March 24, 2017, pursuant to Florida Rules of Civil Procedures, as follows: 1. Attached. 2. Attached. 3. See Privilege Log. 4. Attached. *#* FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 5/11/2017 11:53:18 AM.****5. Attached. 6. Attached. 7. Objection, work product. Work product. Without waiving said objection, none in our possession. 8. Objection, work product. Work product. Without waiving said objection, none in our possession. 9. See Privilege Log. 10. Attached. 11. None in our possession. 12. None in our possession. 13. None in our possession. 14. None in our possession. 15. Objection, work product. Work product. Without waiving said objection, none in our possession. 16. None in our possession. 17. i-v. None in our possession. 18. Objection, work product. Work product. Without waiving said objection, none in our possession. 19. Objection, work product. Work product. Without waiving said objection, none in our possession.20. Attached. 21. — Attached. 22. None in our possession. WE HEREBY CERTIFY that a true and correct copy of the foregoing was emailed this 11th day of May, 2017 to: John D. Coleman, Esquire. SILVERSTEIN, SILVERSTEIN & SILVERSTEIN, P.A. 504 Aventura Corporate Center 20801 Biscayne Boulevard Aventura, Florida 33180 Miami-Dade (305) 935-2500 Broward (954) 463-1333 Facsimile (305) 935-3214 dsilverstein@ssspa-law.com gpatterson@ssspa-law.com By: s/DARRYN L. SILVERSTEIN Florida Bar #511633 Attorney for Plaintiff