PLANTIFF JULIA LEE’S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT GRAND OCEAN RESORT
DEFINITIONS AND INSTRUCTIONS
1. As used in these requests, the following terms are to be interpreted in accordance with these definitions:
a. The term "person" includes any individual, joint stock company, unincorporated association or society, municipal or other corporation, state, which agencies or political subdivisions, and court, or any other governmental entity.
b. The terms "you" or "your" include the persons to whom these requests are addressed, and all that person's agents, representatives or attorneys.
c. In accordance, the terms, "document" or "documents" includes all writings, drawings, graphs, charts, photographs, recordings, and any other data …show more content…
All agreements documents, and reports (either electronic or written) that relate to the corporate hotel company Grand Ocean Resort.
2. All written reports of each person whom you expect to call as an expert witness at trial.
3. The most recent resume of each specialist whom you expect to call as an expert witness at trial.
4. All books, calendars, diaries, day timers, computer generated case management soft ware information, or other similar compilations maintained for business or professional reasons from February 2013 until the present which contain any and all references to the legal representation of the Plaintiff.
5. All statements and communications of any and all witnesses including any and all statements of Plaintiff(s) and Defendant(s), including taped recordings, whether transcribed or not, as well as all written statements.
6. Any and all documents of any nature whatsoever which refer in any way to the alleged accident described in Plaintiff(s) Complaint and/or the facts or circumstances leading up to and following said alleged accident.
7. Any and all documents and communications containing the name and home and business addresses of all individuals contacted as potential
DEFINITIONS AND INSTRUCTIONS
1. As used in these requests, the following terms are to be interpreted in accordance with these definitions:
a. The term "person" includes any individual, joint stock company, unincorporated association or society, municipal or other corporation, state, which agencies or political subdivisions, and court, or any other governmental entity.
b. The terms "you" or "your" include the persons to whom these requests are addressed, and all that person's agents, representatives or attorneys.
c. In accordance, the terms, "document" or "documents" includes all writings, drawings, graphs, charts, photographs, recordings, and any other data …show more content…
All agreements documents, and reports (either electronic or written) that relate to the corporate hotel company Grand Ocean Resort.
2. All written reports of each person whom you expect to call as an expert witness at trial.
3. The most recent resume of each specialist whom you expect to call as an expert witness at trial.
4. All books, calendars, diaries, day timers, computer generated case management soft ware information, or other similar compilations maintained for business or professional reasons from February 2013 until the present which contain any and all references to the legal representation of the Plaintiff.
5. All statements and communications of any and all witnesses including any and all statements of Plaintiff(s) and Defendant(s), including taped recordings, whether transcribed or not, as well as all written statements.
6. Any and all documents of any nature whatsoever which refer in any way to the alleged accident described in Plaintiff(s) Complaint and/or the facts or circumstances leading up to and following said alleged accident.
7. Any and all documents and communications containing the name and home and business addresses of all individuals contacted as potential