On May 31, 2017 a
Party Discovery
was filed
involving a dispute between
Milagros Bengochea Valencia,
and
Moran Foods Llc,
Moran Foods Llc Save A Lot Dba,
Supervalu Stores Inc,
for 3
in the District Court of Orange County.
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Filing # 120439833 E-Filed 01/28/2021 04:19:49 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR ORANGE COUNTY, FLORIDA
MILAGROS BENGOCHEA VALENCIA,
Plaintiff, CASE NO.: 2017-CA-004935-O
vs.
SUPERVALU STORES, INC. and
MORAN FOODS LLC, d/b/a SAVE-A-LOT,
Defendants.
__________________________________/
DEFENDANT'S RESPONSES TO PLAINTIFF’S
THIRD SUPPLEMENTAL REQUEST FOR PRODUCTION
COMES NOW, the Defendant, Moran Foods, LLC, by and through its undersigned
counsel, to file its Responses to Plaintiff’s Third Supplemental Request for Production as follows:
1. Please provide the Video Evidence Worksheet filled out by then-manager, Kevin Finch
on the date of the subject incident.
RESPONSE: Objection. This request calls for the production of documents
protected by the work product doctrine.
Privilege Log: Defendant is withholding the video evidence worksheet
prepared by Kevin Finch on November 22, 2015.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to
Harold S. Velez, Esq. (Pleadings4@kpattorney.com) on this 28th day of January, 2021.
GOLDEN SCAZ GAGAIN, PLLC
Attorneys for Defendant
1135 Marbella Plaza Drive
Tampa, Florida 33619
Phone: (813) 250-3969
Fax: (813) 251-3675
E-mail:egagain@gsgfirm.com
By /s/ Edward F. Gagain, III
EDWARD F. GAGAIN, III
Florida Bar No.: 0085154
CAITLIN E. COSTA
Florida Bar No.: 0112428
Document Filed Date
January 28, 2021
Case Filing Date
May 31, 2017
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Filing # 120439833 E-Filed 01/28/2021 04:19:49 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA MILAGROS BENGOCHEA VALENCIA, Plaintiff, CASE NO.: 2017-CA-004935-O vs. SUPERVALU STORES, INC. and MORAN FOODS LLC, d/b/a SAVE-A-LOT, Defendants. __________________________________/ DEFENDANT'S RESPONSES TO PLAINTIFF’S THIRD SUPPLEMENTAL REQUEST FOR PRODUCTION COMES NOW, the Defendant, Moran Foods, LLC, by and through its undersigned counsel, to file its Responses to Plaintiff’s Third Supplemental Request for Production as follows: 1. Please provide the Video Evidence Worksheet filled out by then-manager, Kevin Finch on the date of the subject incident. RESPONSE: Objection. This request calls for the production of documents protected by the work product doctrine. Privilege Log: Defendant is withholding the video evidence worksheet prepared by Kevin Finch on November 22, 2015. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to Harold S. Velez, Esq. (Pleadings4@kpattorney.com) on this 28th day of January, 2021. GOLDEN SCAZ GAGAIN, PLLC Attorneys for Defendant 1135 Marbella Plaza Drive Tampa, Florida 33619 Phone: (813) 250-3969 Fax: (813) 251-3675 E-mail:egagain@gsgfirm.com By /s/ Edward F. Gagain, III EDWARD F. GAGAIN, III Florida Bar No.: 0085154 CAITLIN E. COSTA Florida Bar No.: 0112428