IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA
CASE NUMBER: 2007
CLIENT,
Plaintiff,
vs.
DENNY’SRESTAURANTS, LLC,
Defendant.
___________________________________________/
DRAFT OF PLANTIFF’S RESPONSE TO REQUEST FOR PRODUCTION
Plaintiff, CLIENT, hereby responds to the Defendant, DENNY’SRESTAURANTS, LLC, INC.’S Request For Production dated December __ 2007 by corresponding number as follows:
•1. Attached are Plaintiff’s medical bills in our possession.
•2. Attached are Plaintiff’s medical records in our possession.
•3. Attached are Plaintiff’s MRI reports or other diagnostic testing in our possession.
•4. Objection, work product, however if defendant agrees to produce their photographs and
video including surveillance, plaintiff will produce the photographs and/or video they have of the accident scene, the subject premises and the plaintiff.
•5. Objection overbroad, to providing tax returns for the past five years. As to tax returns for the
past three years, none in our possession, but will produce upon receipt.
•6. None
WE HEREBY CERTIFY that a true and correct copy of the foregoing was mailed this
JUSTIN ZIEGLER, ESQ.
Co-counsel for the plaintiff
9100 S. Dadeland Boulevard
Suite 908
Miami, Fl. 33156
T: 305-403-0966
F: 786-235-0793
Florida Bar #: 662305
______________________________
By: JUSTIN ZIEGLER
