On August 22, 2017 a
Party Discovery
was filed
involving a dispute between
Maria De Lourdes Santiago,
and
The Boat House Orlando Llc,
for 3
in the District Court of Orange County.
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Filing # 87305793 E-Filed 04/02/2019 09:39:50 AM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR ORANGE COUNTY, STATE OF FLORIDA
CIVIL DIVISION
MARIA DE LOURDES SANTIAGO,
Plaintiff,
V. CASE NO.: 2017-CA-7719-O
THE BOAT HOUSE ORLANDO, LLC,
Defendant.
_____________________________________/
DEFENDANT’S TRIAL REQUEST TO PRODUCE TO PLAINTIFF
COMES NOW the Defendant, THE BOAT HOUSE ORLANDO, LLC, pursuant to
Florida Rules of Civil Procedure 1.350, and hereby requests the Plaintiff, MARIA DE
LOURDES SANTIAGO, to produce for inspection and/or copying by counsel for the Defendant
the following documents, said documents to be produced at the offices of Defendant’s attorneys
located at 501 E. Kennedy Boulevard, Suite 1700, Tampa, Florida 33602:
1. Copies of any and all photographs or videotapes that Plaintiff may utilize as
exhibits at the trial of this matter.
2. Copies of any and all records that Plaintiff may utilize as exhibits at the trial.
3. Copies of any and all impeachment materials that Plaintiff may use at the trial of
this matter.
4. Copies of any and all transcripts of Plaintiff’s experts’ testimony where they have
acted as an expert witness on any cause of action brought by Plaintiff’s attorneys
in the past 5 years.
5. Copies of any and all materials that Plaintiff may use at trial of this matter as
demonstrative aids, cross examination materials or exhibits.
6. Copies of any and all expert’s reports, including documents or tangible things that
such expert expects to rely upon in the giving of his expert testimony in this
matter.
7. Copies of Curriculum Vitae’s of all witnesses Plaintiff intends to call as expert
witnesses at trial.
8. If any document is withheld on any claim of privilege, or otherwise, pursuant to
current law, set forth the following:
a. the basis of the privilege claim;
b. the author of the document;
c. the date of the document;
d. the recipient or intended recipient of the document;
e. a brief description of the substance of the document;
f. all persons who received copies of the document or were shown copies of
the document, along with an identification of each such person.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and accurate copy of the above and foregoing has been
furnished by e-mail delivery to Michael B. Sanchez, Esquire (msanchez@pendaslaw.com;
agonzalez@pendaslaw.com; pleadings@pendaslaw.com), The Pendas Law Firm, 625 E.
Colonial Drive, Orlando, Florida 32803, Attorney for the Plaintiff, on April 2, 2019.
/s/ William R. Gower, III
William R. Gower, III, Esquire
Florida Bar No: 105172
BANKER LOPEZ GASSLER P.A.
501 E. Kennedy Boulevard, Suite 1700
Tampa, FL 33602
Phone No: (813) 221-1500
Fax No: (813) 222-3066
Attorneys for Defendant
service-wgower@bankerlopez.com
2
Document Filed Date
April 02, 2019
Case Filing Date
August 22, 2017
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Filing # 87305793 E-Filed 04/02/2019 09:39:50 AM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, STATE OF FLORIDA CIVIL DIVISION MARIA DE LOURDES SANTIAGO, Plaintiff, V. CASE NO.: 2017-CA-7719-O THE BOAT HOUSE ORLANDO, LLC, Defendant. _____________________________________/ DEFENDANT’S TRIAL REQUEST TO PRODUCE TO PLAINTIFF COMES NOW the Defendant, THE BOAT HOUSE ORLANDO, LLC, pursuant to Florida Rules of Civil Procedure 1.350, and hereby requests the Plaintiff, MARIA DE LOURDES SANTIAGO, to produce for inspection and/or copying by counsel for the Defendant the following documents, said documents to be produced at the offices of Defendant’s attorneys located at 501 E. Kennedy Boulevard, Suite 1700, Tampa, Florida 33602: 1. Copies of any and all photographs or videotapes that Plaintiff may utilize as exhibits at the trial of this matter. 2. Copies of any and all records that Plaintiff may utilize as exhibits at the trial. 3. Copies of any and all impeachment materials that Plaintiff may use at the trial of this matter. 4. Copies of any and all transcripts of Plaintiff’s experts’ testimony where they have acted as an expert witness on any cause of action brought by Plaintiff’s attorneys in the past 5 years. 5. Copies of any and all materials that Plaintiff may use at trial of this matter as demonstrative aids, cross examination materials or exhibits. 6. Copies of any and all expert’s reports, including documents or tangible things that such expert expects to rely upon in the giving of his expert testimony in this matter. 7. Copies of Curriculum Vitae’s of all witnesses Plaintiff intends to call as expert witnesses at trial. 8. If any document is withheld on any claim of privilege, or otherwise, pursuant to current law, set forth the following: a. the basis of the privilege claim; b. the author of the document; c. the date of the document; d. the recipient or intended recipient of the document; e. a brief description of the substance of the document; f. all persons who received copies of the document or were shown copies of the document, along with an identification of each such person. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and accurate copy of the above and foregoing has been furnished by e-mail delivery to Michael B. Sanchez, Esquire (msanchez@pendaslaw.com; agonzalez@pendaslaw.com; pleadings@pendaslaw.com), The Pendas Law Firm, 625 E. Colonial Drive, Orlando, Florida 32803, Attorney for the Plaintiff, on April 2, 2019. /s/ William R. Gower, III William R. Gower, III, Esquire Florida Bar No: 105172 BANKER LOPEZ GASSLER P.A. 501 E. Kennedy Boulevard, Suite 1700 Tampa, FL 33602 Phone No: (813) 221-1500 Fax No: (813) 222-3066 Attorneys for Defendant service-wgower@bankerlopez.com 2