Slip Fall Personal Injury Lawsuit - Plaintiff's Response to Defendant's Request to Production

CASE NUMBER: 07-24167 CA 03

ACCIDENT VICTIM,

Plaintiff,

vs.

WEST GARDENS VILLAGE CONDOMINIUM ASSOCIATION, INC.

and JR GONZALEZ & ASSOCIATES, INC.,

Defendants.

___________________________________________/

PLAINTIFF'S RESPONSE TO REQUEST FOR PRODUCTION

1. None.

2. None.

3. None.

4. None in our possession at this time, but will produce upon receipt.

5. Attached are all of Plaintiff's medical records in our possession.

6. Any such reports would be contained within the Plaintiff's medical records which were produced in response to No. 5.

7. Attached are all hospital records.

8. Attached are all medical bills in our possession.

9. None.

10. Undecided at this time.

11. Objection, work product, however if defendants agree to produce their photographs, plaintiff will produce the photographs they have of the accident scene, the subject premises and the plaintiff.

12. None.

13. Undecided at this time.

14. Objection, work product, however plaintiff will produce the statement of Dr. Mark Maederer if defendant agrees to produce its statements.

15. None.

16. None.

17. Objection, overbroad, and invades attorney-client and work-product privileges.

18. Attached is the plaintiff's driver's license.

19. Undecided at this time.

20. None.

21. Attached is plaintiff's Medicaid card.

WE HEREBY CERTIFY that a true and correct copy of the foregoing was mailed this 21st day of September, 2007 to: Sally Seltzer, Cooney, Mattwson, Lance, Blackburn, Richards & O'Connor, P.A.

1600 West Commercial Blvd., Suite 200, P.O. Box 14546, Ft. Lauderdale, FL 33302.

JUSTIN ZIEGLER, ESQ.

Justin Ziegler, P.L.

Co-counsel for the plaintiff

9100 S. Dadeland Boulevard

Suite 512

Miami, Fl. 33156

T: 305-403-0966

Florida Bar #: 662305

______________________________

By: JUSTIN ZIEGLER