RESPONSE TO REQ TO PRODUCE - DEFENDANT'S RESPONSES TO PLAINTIFF'S REQUESTS FOR PRODUCTION

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                          Filing # 130030376 E-Filed 07/02/2021 11:45:33 PM

IN THE CIRCUIT COURT OF THE 15!H
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA

FRANCIS ALOYISUS MCMAHON CASE NO: 2020-CA-010915-XXXX- MB

Plaintiff,

vs.

BMW of NORTH AMERICA, LLC.,
Defendant.
/
DEFENDANT’S RESPONSES TO PLAINTIFF’S REQUESTS FOR PRODUCTION

Defendant, BMW of North America, LLC, (“BMW NA”), by and through the undersigned
counsel and pursuant to Rule 1.350 ef seq., Florida Rules of Civil Procedure, hereby responds to
Plaintiff’s Request for Production and states the following:

GENERAL STATEMENTS

1. The fact that BMW NA has responded to a particular demand shall not be
interpreted as implying that BMW NA acknowledges the appropriateness of that demand. To the
extent that information, documents, and/or other materials are provided in response to these
demands, BMW NA specifically reserves the right to challenge or object on any grounds to the
admissibility, competency, materiality, relevancy or truth or accura…