Compliance with Request. A party may not seek discovery from any source before the parties have conferred as required by Rule 26(f), except in a proceeding exempted from initial disclosure under Rule 26(a)(1)(B), or when authorized by these rules, by 2012 Amendment. Please produce any and all correspondence or similar communication between any parties to this action. P. 1.350(b). Includes, without limitation, writings, emails (whether printed or not), agreements, contracts, and printed matter of every kind and description; data stored on a computer hard disk or other memory card, photographs and drawings; notes and records of any oral communications; e-mails and recordings (tape, disc or other) of oral communications. Plaintiffs Third Request for Production (the Motion), and in support thereof states as follows: 1. 0 Professor Files Defamation Suit Against Fortune Teller, Will Musk Step Down? P. 1.350(b). If no objection to the discovery is made, inspection is had without a court order. Our goal is to help people in the best way possible. A party who has responded to a request for production with a response that was complete at the time it was provided is under no duty to supplement the response to include after-acquired documents. Early in the case, a party must: 16. FLSA Class Actions For Unpaid Wages And Overtime, Are They Worth It? In such cases, the, FLSA (Fair Labor Standard Act) offer collective action lawsuits against employers that violated the minimum wage and overtime wage standard. What Constitutes a Breach of Contract in Florida? This Standard Document has integrated drafting notes with important explanations and drafting tips. 77 0 obj <>stream Please produce any and all documents which evidence, contain or relate to any statements made by either Plaintiff or any other person or any communication by any person at the scene of the collision in question. 2. The central theme of 2022 was the U.S. governments deploying of its 11777 San Vicente Blvd., Suite 702 Los Angeles, California 90049 [DEFENDANT(S)] Tel: 310.651.8685 Fax: 310.651.8681 SELARZ LAW CORP. DANIEL E. SELARZ (State Bar No. Please produce a curriculum vitae for, and any and all documents containing the opinions or analyses of, any person whom you expect to call as an expert witness at the trial of this case, which concern any issue pertaining to the instant lawsuit. 22. PRODUCTION OF DOCUMENTS AND THINGS AND ENTRY UPON LAND FOR INSPECTION AND OTHER PURPOSES | Cox Law, PLLC FLORIDA RULES OF CIVIL PROCEDURE Florida Rules of Civil Procedure Rule 1.010. Timing. endstream endobj startxref The Policy Center was recently created to produce and disseminate knowledge and generate new ideas that advance refugee rights, improving the lives of populations on the move due to political crises and humanitarian All expert reports from any experts who will testify at trial. P. 1.350(b). (c) Person or persons Any individual, corporation, partnership, joint venture, firm, association, proprietorship, agency, board, authority, commission or any other entity. Request for Production in Florida Circuit Court At A Glance, Ex Parte Motion in United States District CourtAt A Glance, Alex Murdaugh Found Guilty On All Charges, International Shoe The Case That Keeps on Giving, Motions An Overview for Civil Litigation. entities owning the property where the plaintiff was injured, as described in the Complaint. WebRULE 1.350. Procedural Law v. Substantive Law What Is The Differance? %%EOF Please produce any and all insurance policies which may provide coverage to you for part or all of any judgment for which they may be adjudged liable in this action or under which you may be indemnified or reimbursed for payments made to satisfy such judgment. 19. WebRequest for Production of Additional Documents In divorce and paternity cases, one side may request of the other to produce a list of documents within either 30 days (if requested after the filing of the original petition) or 45 days (if the request accompanies the original petition). (1) DEFINITIONS. Make your practice more effective and efficient with Casetexts legal research suite. The time shall be at least thirty (30) days after service of the request to produce, except that a defendant may serve a response within forty-five (45) days after the service of the process and the initial pleading on that defendant. WebRequest for Production of Documents - TO DEFENDANTParty: Defendant Florida Peninsula Insurance Co January 27, 2014. Zzuo3 A party may seek inspection and copying of any documents or things within the scope of rule 1.350 (a) from a person who is not a party by issuance of a subpoena Web20. The federal rules incorporate the concept of initial disclosures, which require a party to produce discovery even without a formal request. Please produce any medical or employment records you have obtained relating to either Plaintiff. 3 0 obj Please produce any and all documents or other written material not produced in response to any previous Request for Production of Documents, which you contend evidence, support or refute any fact or circumstance relating to your defenses or claims in this action. If you're a paid subscriber and still having difficulty, please contact our support desk with your IPv4 address so we can investigate. 0 Please produce any and all photographs, videotapes, motion pictures, drawings, sketches, diagrams, plats or the like taken at or made of the scene of the collision or any person or physical object which relate in any way to the circumstances of the collision, including, without limitation, photographs of the damaged bicycle. 10. If the court issues an order compelling production and the responding party still fails to reply, that party may be held in contempt of court and may face sanctions up to and including the dismissal of pleadings. Please produce any and all documents which evidence, refer to or relate to repairs made to any vehicle damaged in connection with the collision described in Plaintiffs Complaint. %%EOF Privacy Statement|Accessibility Statement|Legal Notice(850) 922-5081500 South Duval Street, Tallahassee, FL, 32399-1925, All Content Copyright 2023 Florida Courts, Subpoena for Production of Documents from Nonparty (included in part a above), Court Councils, Commissions, and Committees, General Contract Conditions for Services and Commodities, Additional Supporting Documents | 12.902 | Forms B - J, Answers to Dissolution | 12.903 Forms A - E, Attorney/Non-Lawyer Representation | 12.900 | Forms A - H, Disestablish Paternity | 12.951 Forms A - B, Dissolution Final Judgments | 12.990 Forms A - C2, Dissolve/Modify Injunction | 12.940 Forms D - E, Income Deduction Order | 12.996 Forms A- C, Involving Relocation | 12.950 Forms A - J, Modification of Final Judgments | 12.993 Forms A - C, Motion to Deviate from Child Support Guidelines | 12.943 Form, Notices and Diligent Search | 12.913 Forms A - C, Petition for Dissolution of Marriage | 12.901 | Forms A - B3, Petition for Support Unconnected with Dissolution | 12.904 Forms A - B, Prevent Removal of Child(ren) | 12.941 Forms A - E, Show Cause for Violations | 12.980 Forms W, X, Summons and Memorandum | 12.910 Forms A - B, Supplemental (Modification) Petitions | 12.905 Forms A - C, Supporting Documents | 12.980 Forms G - J, M, Temporary Custodial Responsibility During Deployment / 12.948 Forms A-E, Testimony and Attendance of Minor Child(ren) | 12.944Forms A - B, 500 South Duval Street, Tallahassee, FL, 32399-1925. If you're using a VPN server, please make sure you're using a US Based VPN Server, or disable it to access our site temporarily. The Florida Judicial Qualifications Commission, by and through its undersigned counsel and pursuant to Fla. A request for production is a discovery device used to gain access to documents, electronic data, and physical items held by an opposing party in a legal If certain requests are duplicative of previous requests to which documents have already been produced, Plaintiff need not reproduce such documents but is requested to notify Defendant that such documents are among those already produced. COME NOW, REDACTED (BAKER), plaintiff in the above-styled matter, and serves the following requests to produce to REDACTED, INC. (you, your or Defendant) pursuant to Rule 1.350. WebUS Legal Forms Request for Production of Documents - Personal Injury Documents Court Form The Forms Professionals Trust! WebPlease review this document and gather the requested information. WebDOCUMENT PRODUCTION REQUEST LIST Please check the appropriate box below each request to indicate your response: 1. P. 1.350(b). Procedural Law v. Substantive Law What Is The Differance? hmk0>nbIla^bC^J,)4%>Vt;D3`1+T fFj&-apfE&8pzwzoas U=5ZInXj\\~h6&9rQ\jjQ.\TY@/d5zQIu&8.r^yx6j7xvx_TLv]7u;; P. 1.380(b)(2). Form Name. WebDescription:This position will create pro-active and responsive solutions to corporate strategy; facilitate live and online training programs including new hire, peer and need-specific training, and the design of instructional materials and liaise with all departments and all levels of management to create learning solutions/opportunities within their 59 0 obj <> endobj 153680 Massey & Duffy, P LLC 855 E. Univ. Your response to this request should be periodically supplemented. A sample request for the production of documents (RFP) that a party in a Florida circuit court civil case may use to request the production or inspection of documents or other tangible items from another party. P. 1.280(e). hVn6~n(EYIiYc36Yr%9M#Hr.J"},`R113fgrXDL(aJ2G)FR/a*)P^ Timing. 63 0 obj <> endobj 11777 San Vicente Blvd., Suite Fla. R. Civ. Contact us today for a free consultation. Our goal is to help people in the best way possible. P. 1.280(e). The Difference Between Workers Compensation and Disability Benefits with Associated Work Related COVID-19 Illnesses. (d) Communicate or communication Includes every manner or means of disclosure, transfer, or exchange and every disclosure, transfer or exchange of information, whether orally or by documents or whether face-to-face or by telephone, mail, personal delivery or otherwise. If an objection is made only to part of a demand, the objectionable section must be specified. This can be a very profitable discovery tool, reaping immediate rewards. REQUESTS FOR PRODUCTION 1. Please produce any and all documents identified, referred to or used by any person in connection with the compilation of your Answer to Plaintiffs Complaint or response to the Complaint. P. 1.390(b). On June 11, 2014, Plaintiffs served Defendant with Plaintiffs Third Request for Production of Documents (the Request). II. 3. <>>> Copy costs will not be paid without prior written approval. Webiii. =]fQAFfRQg This is our approach to every case. WebRequest for Production of Documents: Overview A request for production (RFP) is a written discovery request that is used to obtain relevant, non-privileged documents, tangible 8. LOG IN. 4 0 obj Subdivision (b) is amended to require production of documents as they are kept in the usual course of business or in accordance with the categories in the request. New Document: Florida VA Fixed Note. 5. WebWhen a case with outstanding requests for production is removed to federal court, the time for response would be measured from the date of the parties meeting. Requests for Production United States District Court Southern District of Florida. 855 East University Ave.; Gainesville FL 32601, CORONAVIRUS AID, RELIEF AND ECONOMIC SECURITY for FLORIDA. (e) Or Shall be construed either conjunctively or disjunctively to bring within the scope of this Request for Documents any information which might otherwise be construed to be outside their scope. Each demand must designate the documents, tangible things, land, or other property to be inspected either by specifically describing each individual item or by reasonably particularizing each category of item. The term document or documents means all paper documents, graphic or auditory records or representations, tangible items, and electronically stored information, and shall have the broadest possible meaning accorded to it consistent with Fed. You may receive a Request for Production that is very similar to the items below, hence I am requesting that you gather them now rather than forced to latter on. Presented (on behalf of the Firm) by. A party who has responded to a request to produce with a response that was complete at the time is under no duty to supplement the response to include after-acquired documents. A party may not seek discovery from any source before the parties have conferred as required by Rule 26(f), except in a proceeding exempted from initial disclosure under Rule 26(a)(1)(B), or when authorized by these rules, by 4. (c) If you maintain that any of the documents requested cannot be produced by virtue of any claimed privilege or immunity, set forth precisely the grounds for your objection to producing the documents in question. 13. Fla. R. Civ. Please produce any and all correspondence, memoranda, reports, written notes, diagrams, charts or other similar documents which relate to the incident described in Plaintiffs Complaint or any of Plaintiffs claims or your defenses in this action. Shall be construed either conjunctively or disjunctively to bring within the scope of this Request for Documents any information which might otherwise be construed to be outside their scope. Please produce copies of all pleadings, orders, police reports, notices or other documents pertaining to the incident. 76 0 obj <>/Filter/FlateDecode/ID[]/Index[59 31]/Info 58 0 R/Length 87/Prev 100751/Root 60 0 R/Size 90/Type/XRef/W[1 2 1]>>stream 4. WebYou may request the Clerk to prepare the Subpoena Form in compliance with the requirements set forth in the Florida Rules of Civil Procedure. Jaime Suarez. 1972 Amendment. Your response to this request should be periodically supplemented. Our Gainesville lawyers are some of the premier lawyers dealing with employment law, personal injury lawsuits and wage and hour cases, in Gainesville and throughout Florida. Includes every manner or means of disclosure, transfer, or exchange and every disclosure, transfer or exchange of information, whether orally or by documents or whether face-to-face or by telephone, mail, personal delivery or otherwise. Casetext, Inc. and Casetext are not a law firm and do not provide legal advice. The production of nonprivileged materials should no- t be delayed while a party is WebAs used in this Request for Production of Documents, the following terms mean: (a) You or your The person(s) to whom this Request for Documents is addressed and all other The court may allow for a longer or shorter time. Timing. Web(a) Request; Scope. Please produce any and all reports from any accident investigators or reconstruction experts or engineers. WebSubpoena for Production of Documents from Nonparty, Florida Supreme Court Approved Family Law Form 12.931(b), is the actual subpoena directing the nonparty to produce : 01-2016-CA-0001422 Plaintiff, Circuit Civil Division J vs. Kyle BJarkman and JJS OF FLORIDA, LLC d/b/a JIMMY JOHNS GOURMET SANDWICHES, Defendants. (b) If you maintain that any document or record referred to herein has been lost, misplaced or destroyed, set forth the contents of said document, a description of said document, the location of any copies of said document, the date of such loss or destruction and, if the document was destroyed, the name of the person who operated or authorized said destruction. Subdivision (a) is amended to address the production of electronically stored information. Fla. R. Civ. Our. P. 1.350(b). Please produce any medical or employment records you have obtained relating to the Plaintiff. 2 0 obj WebRequest for Production of Documents - TO DEFENDANTParty: Defendant Florida Peninsula Insurance Co January 27, 2014. (b) If you maintain that any document or record referred to herein has been lost, misplaced or destroyed, set forth the contents of said document, a description of said document, the location of any copies of said document, the date of such loss or destruction and, if the document was destroyed, the name of the person who operated or authorized said destruction. Any and all documents, receipts or vouchers reflecting the funds provided to you endobj WebWhen you need Discovery Request Sample, don't accept anything less than the USlegal brand. Copy of marriage certificate if a derivative claim is WebA sample request for the production of documents (RFP) that a party in a Florida circuit court civil case may use to request the production or inspection of documents or other (regarding mediation) or Code of Civil Procedure section 2034.010 et seq. As used in this Request for Production of Documents, the following terms mean: The person(s) to whom this Request for Documents is addressed and all other persons acting or purporting to act on said persons behalf. Fla. R. Civ. Subpoena for Production of Documents from Nonparty (included in part a above) Form Number 12.931(b) Form Type Procedural Date 11/2015 PDF File 931ab.pdf The Notice of Production is not to be sent to FLFNN.VA. For more detailed information, please see the SmartRules Response to Request for Production guides for the court where your action is pending. stream Please produce any and all books, documents or other tangible items relating to the collision described in Plaintiffs Complaint or any of Plaintiffs claims or your defenses in this action. Please produce any and all documents identified, referred to or used by any person in connection with the compilation of your Responses to Plaintiffs First Interrogatories. interrogatories 21 a. preparation and answering of interrogatories 21 b. objections, privilege, and responses 22 c. other interrogatory issues 23 v. subpoenas 25 a. general 25 b. contents of subpoena 26 If a party withholds otherwise discoverable information on the basis of privilege, that party must make this claim expressly and must describe the nature of the withheld materials such that, without revealing the disputed information, other parties may assess the applicability of the privilege. 11. P. 1.350(b). WebPOSITION SUMMARY: HIAS seeks a Policy Analyst to conduct policy research and analysis in support of the Policy Centers mission and goals. Ave. Gainesville, FL 32601 Phone: 325-505-8900 [emailprotected], Cares Act & Eviction Moratorium On March 27, 2020, the Cares Act came into being. Category: Civil Actions - Personal Injury - Discovery State: Multi-State Control #: US-PI-0250 Instant Download Buy now Available formats: Word | Rich Text Free Preview Description Related Forms How to Guide endstream endobj 64 0 obj <>/Metadata 6 0 R/PageLayout/OneColumn/Pages 61 0 R/StructTreeRoot 10 0 R/Type/Catalog>> endobj 65 0 obj <>/Font<>>>/Rotate 0/StructParents 0/Type/Page>> endobj 66 0 obj <>stream Professor Files Defamation Suit Against Fortune Teller, Will Musk Step Down? 855 East University Ave.; Gainesville FL 32601, CORONAVIRUS AID, RELIEF AND ECONOMIC SECURITY for FLORIDA. A party who has Twitter Poll Decides Future of Twitter, The New Twitter: The Bad Boss May Be A Hero for Exploited Children. 287555) dselarz@selarzlaw.com . WebThe 2022 Florida Statutes (including Special Session A) 92.153 Production of documents by witnesses; reimbursement of costs.. (2) Discovery plan. R. Civ. Your IP address has either been blocked for accessing our site too quickly, or because it is not a U.S. or North America based IPv4 Address. 153680 855 E. Univ. Form IH55J6FL"B]Wsng@i! {.C6. Please produce at least one document, such as title or registration, evidencing ownership of the vehicle you were driving which was involved in the collision described in Plaintiffs Complaint. FLSA Class Actions For Unpaid Wages And Overtime, Are They Worth It? Form (a) is used when the person having the records may furnish copies to the attorney requesting the subpoena instead of appearing at the time and place specified in the subpoena and the subpoena is to be issued by the clerk. After Rule 26 Meeting. Subdivision (b) is amended to set out a procedure for determining the form to be used in producing electronically stored information. Read court documents, court records online and search Webmiddle district of florida orlando division mathew floeter plaintiff, vs. case no. We also provide some thoughts concerning compliance and risk mitigation in this challenging environment. idlers crossword clue 7 letters partners restaurant jersey opening times crew resource management exercises i hope i can repay your kindness pixelmon you don't have permission to use this command http request body golang ventricle neighbor - crossword clue physical therapy for uninsured. If the court needs to consider a document or item produced in a matter pending before it, the After a personal injury lawsuit is filed in the state of Florida, both the Plaintiff and the Defendant engage in what is known as the Discovery process. These forms are to be used for production of documents under rule 1.351. Please produce copies of all pleadings, orders, notices or other documents pertaining to any criminal or traffic court proceeding related to this collision. Read court documents, court records online and search Trellis.law comprehensive legal database for any state court documents. 2d 217 (Fla. 1969). Webin the action. Fed. A party objecting to a request for production must provide the reasons for the objection. Contact us today for a free consultation. Instructions to the Asking Party (a) These interrogatories are designed for optional use by Please produce any and all insurance policies that relate in any way to the allegations in Plaintiffs Complaint or incidents referred to in Plaintiffs Complaint. Often, these ladders are supplied by employers or homeowners in a faulty condition. Enter to open, tab to navigate, enter to select, Practical Law Standard Document w-000-0440, https://content.next.westlaw.com/practical-law/document/Ibd96133e8e9011e38578f7ccc38dcbee/Request-for-the-Production-of-Documents-RFP-FL?viewType=FullText&transitionType=Default&contextData=(sc.Default), Request for the Production of Documents (RFP) (FL). Our Gainesville lawyers are some of the premier lawyers dealing with employment law, personal injury lawsuits and wage and hour cases, in Gainesville and throughout Florida. Production of documents by non-parties is accomplished through the subpoena process under Florida Rule of Civil Procedure 1.351. A Request for Production of Documents (often referred to as a Notice to Produce) requires a spouse to provide the other spouse with certain documents for review. <> A party who has responded to a request to produce with a response that was complete at the time is under no duty to supplement the response to include after WebThe Eugene Police Department has a full-time Public Information Coordinator opportunity. This memorandum surveys U.S. economic sanctions and anti-money laundering (AML) developments and trends in 2022 and provides an outlook for 2023. Webe.The general subject matter of the document or portion thereof for which privilege is claimed; and f.The type of document (e.g., memorandum, report, draft, letter, etc.). Please produce a copy of all transcripts containing the testimony of any party or witness pertaining to the instant collision. Ave. Gainesville, FL 32601 352-505-8900 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been provided by Email to counsel for Plaintiff this June 20, 2016 by efiling the same with the Courts efiling system. (b) Document Includes, without limitation, writings, agreements, contracts, and printed matter of every kind and description; photographs and drawings; notes and records of any oral communications; and recordings (tape, disc or other) of oral communications. production of documents and things and entry upon land for inspection and other requests for admission ..86 rule 1.380. failure to make discovery; sanctions..88 rule 1.390. REQUEST FOR PRODUCTION OF DOCUMENTS . %PDF-1.5 Fla. R. Civ. 2d 899 (Fla. 3d DCA 1963) ; IBM v. Elder, 187 So. It is intended that the court review each objection and weigh the need for discovery and the likely results of it against the right of privacy of the party or witness or custodian. Please produce any and all correspondence or similar communication between any parties to this action not produced in response to any previous Request for Production of Documents. HUnS1F5 !Db@Iig|_37r[MG6yTW 5t; ]7]QGp What can your opposing spouse or partner ask for? The Items are: 1. Request for Admissions Sample Form Request for Admissions is a common request in the Discovery process of a lawsuit A Request for Admissions will ask the. 2d 82 (Fla. 3d DCA 1966) ; and Miami v. Florida Public Service Commission , 226 So. IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT IN AND FOR ALACHUA COUNTY, FLORIDA Ronique T. Myers, Case No. WebSince requests for production are traditionally thought to cover documents, tangible items, and/or electronic documents prepared on a computer, it is easy for a responding party to try to avoid or sidestep an e-discovery request if the request fails to specify the type or location of the data sought. Use this form to Apply for Civil Indigent Status. The Difference Between Workers Compensation and Disability Benefits with Associated Work Related COVID-19 Illnesses. INFO@DOCMAGIC.COM; PHONE (800) 649-1362; New Document: Florida VA Fixed Note. 14. Statistics show that more than, In Florida, as of April 5th, there are 13,000 confirmed cases of COVID-19, and deaths have doubled every three days over the past month. <> these Requests for Production of Documents: 1. To get started and understand how the forms work, Read the BASIC INSTRUCTIONS (STEP-BY-STEP) TO FILL OUT FORMS You may qualify for a fee waiver. Webflorida rules of civil procedure 1 . Fla. R. Civ. P. 1.280(b)(5). "The Forms Professionals Trust Request For Production Of Documents Sample Florida Form Rating 4.78 Satisfied (499) Interrogatories Florida Sample Form Popularity Request For Production Florida Sample Other Form Names endobj The request shall specify a reasonable time and place and manner of making the inspection or performing the acts. WebRequest for Production of Documents - TO DEFENDANTParty: Defendant Florida Peninsula Insurance Co January 27, 2014. Please produce any and all correspondence, memoranda, reports, written notes, diagrams, charts or other similar documents which relate to the collision described in Plaintiffs Complaint or any of Plaintiffs claims or your defenses in this action. (regarding expert witnesses). The party serving the request for production may move for an order compelling production under Rule 1.380. /s/ Michael Massey Michael Massey Fla. Bar No. b``$+@ + Scope-Title of Rules Rule 1.020. But its only one aspect of a larger legal concept known as divorce discovery , which is basically an information-gathering process. REQUEST A DEMO. On Monday, February 27, 2023, a man in St Louis Missouri calmly loaded his firearm in broad daylight with people watching then aimed it at the head of a homeless man sitting on the street curb and pulled the trigger. Subscribe to receive important updates and news from Florida Courts. hbbd``b`J@1`ug&Fs YF_ Should not the requesting partys counsel be required to, by personal skill, knowledge, and reasoning, request the production of documents within general and specific categories, and, upon receipt and review of same, use his or her own thought processes to determine whether they constitute support for Count II? As used in this Request for Production of Documents, the following terms mean: (a) You or your The person (s) to whom this Request for Documents are For authorities updated in real time, please see the SmartRules Guide for the litigation document you are drafting. After Rule 26 Meeting. Derived from Federal Rule of Civil Procedure 34 as amended in 1970. Please produce any and all documents prepared by anyone as a result of tests, inspections or measurements made or taken with respect to the scene of the incident. 3W|o7=c~s1c96n!gL`nj{`f;og6fCI2a{>m'UdR'\Le0i hOH1109_K & P_83kyO3'mbEfk))D(2x4UO?.BvgW.X Please produce copies of your current drivers license and the registration for the vehicle involved in the collision described in Plaintiffs Complaint. Log in. 1 0 obj Attorneys are Payment shall be made within If a party fails to respond to a request for production, the propounding party may move for an order compelling production under Rule 1.380. A reference to Florida Rule of Judicial Administration 2.425 and rule 1.280(f) is added to require persons filing discovery materials with the court to make sure that good cause exists prior to filing discovery materials and that certain specific personal information is redacted. (c) If you maintain that any of the documents requested cannot be produced by virtue of any claimed privilege or immunity, set forth precisely the grounds for your objection to producing the documents in question. Document Title. 'F!zv0@Wj(GlULb$[4c:z 8=}^f*XdP^;-7Uvvn 6{SDQuMho+0P^;IZ' Please produce any and all documents which contain or are related to any surveillance or investigation concerning Plaintiffs claims or allegations in this action. Please produce any and all reports from any accident investigators or reconstruction experts or engineers not produced in response to any previous Request for Production of Documents. endstream endobj 60 0 obj <> endobj 61 0 obj <>/Rotate 0/Type/Page>> endobj 62 0 obj <>stream hb```f``b`a``d`@ +P w>f^k?sd`lRj'H$LxGh@4$~i~ :' SLzL'rb[g00m*".qLy~@_ 7< WebAny disinterested witness who desires reimbursement of such costs shall submit a request for reimbursement, supported by an affidavit, to the person or governmental authority responsible for payment. Webwitnesses or documents protected under such privileges or doctrines or otherwise covered by Evidence Code section 1115 et seq.

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