Request For Production Of Documents
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1 Home Slip and Fall - Pleadings Main Index - Request For Documents Request For Production Of Documents IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: 13-01xxxx B.O.G. Plaintiff, vs. MILESTONE PROPERTIES INC. and, DUFFY'S DINER, INC. D/B/A DUFFY'S DINER, Defendants. / PLAINTIFF S REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT The Plaintiff, B.O.G., by and through the undersigned attorney and requests the Defendant, MILESTONE PROPERTIES INC., to produce, pursuant to Fla.R.Civ.P to the Law Office of Alan D. Sackrin, the following: 1. All statements of the plaintiff taken by or on behalf of the defendant(s) or reproductions of any recorded statements of the plaintiff. 2. Accident/incident report prepared by or on behalf of the defendant concerning the subject incident. 3. Photographs of the area where the subject incident occurred taken within one hour of the occurrence of the incident. 4. Photographs of the area where the subject incident occurred taken more than one hour after occurrence of the incident. 5. Any surveillance video showing the area of the incident shortly before, during and after the incident occurred. 6. Any statements of any witnesses taken by or on behalf of the defendant or reproductions of 1 / 5
2 any recorded statements of the plaintiff. 7. Any photographs which depict any foreign or transitory substance on the floor in the are where plaintiff fell. 8. Defendant s policies and procedures manual in effect on the date of the subject incident pertaining to issues such as maintenance of defendants= pathways guarding against slip and fall incidents, etc. 9. Lease in effect between Defendants as of December 15, Lease in effect between Duffy s and any other person(s) or entity as of December 15, IT IS HEREBY CERTIFIED that a true and correct copy of the foregoing has been served together with the complaint. LAW OFFICE OF ALAN D. SACKRIN Attorney for Plaintiff 2100 East Hallandale Beach Blvd. Suite 200 Hallandale Beach, FL Telephone: (954) Facsimile: (954) By ALAN D. SACKRIN Florida Bar No /kb This is a sample lawsuit related to a specific set of facts and circumstances and should not be used or relied upon if you have been in a slip and fall accident. We recommend and urge you to consult with an experienced slip and fall lawyer for professional advice as each case is unique. Quick Slip And Fall Facts: 2 / 5
3 Slip and falls are the second leading cause of injuries and deaths after car accidents. Every hour an older adult dies as a result of a fall. The most common injuries resulting from slip and falls include, herniated disc, head injury and/or a knee injury. Learn more from Alan Sackrin, an expert slip and fall lawyer. Want to Know More? Since 1982, Alan Sackrin has represented clients throughout Florida in recovering monetary damages for slip & fall, trip & fall, and other premises liability injuries. Alan is a Board Certified Civil Trial Expert that strives to maximize the amount of compensation his clients' receive for their claim. Alan brings a high-level of skill and knowledge to his slip and fall cases and he offers a free initial consultation. See: Sample Case Verdicts and Settlements 3 / 5
4 Related Slip and Fall Topics Please feel free to read our other slip and fall (trip and fall) related articles and fact sheets, including: - 6 Environmental factors that can cause slip and fall accidents - 4 Factors that determine the types of injuries from a slip and fall - Slip and Falls in Hotels and Motels - Slippery Conditions in Restaurants - Condominium and HOA Slip and Fall Injuries - Nursing Home Slip and Fall - Slip and Fall Case Checklist - Sample Slip and Fall Lawsuit Do You Have a Question? Please fill out the Talk With An Attorney form above to ask a question or you can call Alan Sackrin at He promises to get back to you promptly. Ask now. 4 / 5
5 Learn More: See Our Slip and Fall Resource Page 5 / 5
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