How then are we to obtain this documentation? Nicolas Yoda 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 incident or any person or physical object which relate in any way to the circumstances of the incident. P. 1.350(b). The authorities cited in this At A Glance Guide are current as of the publication date. Web(Date of Release to Production: 03/09/23) Skip to main content [email protected] | PHONE (800) 649-1362; Main navigation Request Info. HUnS1F5 !Db@Iig|_37r[MG6yTW 5t; ]7]QGp 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. On June 11, 2014, Plaintiffs served Defendant with Plaintiffs Third Request for Production of Documents (the Request). 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. Fla. R. Civ. Please produce any medical or employment records you have obtained relating to the Plaintiff. 6. 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. Jaime Suarez. Any and all land records, contracts, documents or the like reflecting the persons or. 287555) [email protected] . Casetext, Inc. and Casetext are not a law firm and do not provide legal advice. Please produce all documents which relate to or evidence your authority/permission, or lack thereof, to operate the vehicle which you were driving at the time of the collision. 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. %%EOF WebUS Legal Forms Request for Production of Documents - Personal Injury Documents Court Form The Forms Professionals Trust! For authorities updated in real time, please see the SmartRules Guide for the litigation document you are drafting. Web(a) Request; Scope. All expert reports from any experts who will testify at trial. Our goal is to help people in the best way possible. Subdivision (a) is amended to address the production of electronically stored information. (regarding mediation) or Code of Civil Procedure section 2034.010 et seq. WebWhen you need Discovery Request Sample, don't accept anything less than the USlegal brand. The request shall specify a reasonable time and place and manner of making the inspection or performing the acts. WebThe Eugene Police Department has a full-time Public Information Coordinator opportunity. Procedural Law v. Substantive Law What Is The Differance? "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 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 Please produce any and all reports from any accident investigators or reconstruction experts or engineers. 13. Use this At A Glance Guide to learn theFlorida Rules of Civil Procedure applicable to amended answer inFlorida Circuit Courts. Please produce any and all documents which evince, contain or relate to any statements made by Plaintiff or any other person or any communication by any person at the scene of the store in question. 21. In such cases, the, FLSA (Fair Labor Standard Act) offer collective action lawsuits against employers that violated the minimum wage and overtime wage standard. Fla. R. Civ. 2d 217 (Fla. 1969). (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. P. 1.280(e). endstream endobj 63 0 obj <>stream 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. 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 Webflorida rules of civil procedure 1 . 2. Request for Production in Virginia Circuit Court At A Glance, Response to Requests for Production in Florida Circuit Court At A Glance, Alex Murdaugh Found Guilty On All Charges, International Shoe The Case That Keeps on Giving, Motions An Overview for Civil Litigation. The federal rules incorporate the concept of initial disclosures, which require a party to produce discovery even without a formal request. P. 1.350 (b). Instructions (a) Unless otherwise indicated, this Request for Documents concerns and relates to the automobile collision which is described in Plaintiffs Complaint. Fla. R. Civ. 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. 9. These forms are to be used for production of documents under rule 1.351. 77 0 obj <>stream Copies of Income Tax Returns for the past three (3) years. Please produce any and all books, documents or other tangible items relating to the incident described in Plaintiffs Complaint or any of Plaintiffs claims or your defenses in this action. Contact us today for a free consultation. The party serving the request for production may move for an order compelling production under Rule 1.380. Web requests for production of documents or to inspect any tangible thing; Subsections (1) and (2) of new Section (G) was derived from Southern District of Florida Local Rule 26-1(e)(2) regarding privilege logs including the exclusion of communications between counsel after the filing of the litigation. What Constitutes a Breach of Contract in Florida? 7. 3W|o7=c~s1c96n!gL`nj{`f;og6fCI2a{>m'UdR'\Le0i hOH1109_K & P_83kyO3'mbEfk))D(2x4UO?.BvgW.X P. 1.350). FLSA Class Actions For Unpaid Wages And Overtime, Are They Worth It? 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. entities owning the property where the plaintiff was injured, as described in the Complaint. The producing party either must produce the documents or items specified as they are kept in the regular course of business, or must identify them to correspond to the categories in the request. Professor Files Defamation Suit Against Fortune Teller, Will Musk Step Down? 2d 82 (Fla. 3d DCA 1966) ; and Miami v. Florida Public Service Commission , 226 So. 10. (regarding expert witnesses). |]!NHYjc+)TH&WmWOMZAQnJk IfK.iQD6c_&"2ufCyZ&@WHGm Y4E~`eQ *'R:tT|5V=JtA!i5;N}Hjxe4qK1nm(9<4g3%G} The Request contained 6 requests that sought production of documents related to Often, these ladders are supplied by employers or homeowners in a faulty condition. After Rule 26 Meeting. If a foreign subpoena is sent, the Clerk must make sure that the information within the foreign subpoena is reflected verbatim within the Florida subpoena. Procedural Law v. Substantive Law What Is The Differance? Instructions to the Asking Party (a) These interrogatories are designed for optional use by Web3. 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. The Items are: 1. See Seventeenth Circuit Court SmartRules Capsule SUBPOENA. 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 Massey & Duffy, P LLC 855 E. Univ. &6qME[v py1p|Wj];0&YI+b+]L3aG0S8 )\ab 72XCl`cXg-jlcP(jj/pda8E^FI;g#(OvlfF0N:e6Yt &iU*]+fqcPQnHW\t4U`$sx(d(#6#7sn_i6oSB}(-C~r5C}W4X!l>Dl[tkD@C{"+b[V;/rA-z`;jG!j lp=.>"[? 0aeY }!do7@\>LwO9 QOHljivP$T-W,n[ Bc,4p[OQO&/^\BT{uG>@)Ue($tuJ!wt ni"te&mFU+1l.Mouf|_zUUW-{H#2C,4`GfFZOTD1Q=qrWS%9iEWE+I[ql$4]%IKF~NW?5_=9uw HE` _@@ Pursuant to FRCP Rule 34(b)(2)(E), Defendant requests that when Plaintiff does 2011 Amendment. 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 P. 1.280(b)(5). WebFirst Co Product RegistrationIf you do not have that information then you can contact customer care to request a registration code be created for you. Fla. R. Civ. P. 1.350(b). Requests for Production United States District Court Southern District of Florida. The party serving the request for production may move for an order compelling production under Rule 1.380. bcjR/M. Request For Production of Documents In-Aid-of-Execution: Another discovery method available to creditors, pursuant to Florida Rules of Procedure 1.350(a), is to request the production of documents. WebPlaintiff request for production of documents sample breach. {HX6CI"hVV. Copy costs will not be paid without prior written approval. Early in the case, a party must: The authorities cited in this At A Glance Guide are current as of the publication date. 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 0 Ave. Gainesville, FL 32601 Phone: 325-505-8900 [emailprotected], Cares Act & Eviction Moratorium On March 27, 2020, the Cares Act came into being. 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. 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. For more detailed information, please see the SmartRules Request for Production guides for the court where your action is pending. Apply today for an opportunity to join the proud lega 8. 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. Use this At A Glance Guide to learn theFlorida Rules of Civil Procedure applicable to amended answer inFlorida Circuit Courts. 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. hbbd``b`J@1`ug&Fs YF_ WebRequests for production of documents and responses may be made on the record at depositions but usually should be confirmed in writing to avoid uncertainty. Please produce any and all documents or other written material which you contend evidence, support or refute any fact or circumstance relating to your defenses or claims in this action. Fla. R. Civ. Copy of marriage certificate if a derivative claim is P. 1.350(b). Plaintiffs Third Request for Production (the Motion), and in support thereof states as follows: 1. February 8, 2022 interrogatories; requests for production; requests for admissions. The production of nonprivileged materials should no- t be delayed while a party is 1 0 obj Our. <>/ExtGState<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> One Form Dated: June 20, 2016 /s/ Michael Massey Counsel for Plaintiff Designated Email: [emailprotected] Fla. Bar No. Zzuo3 Please produce a copy of all transcripts containing the testimony of any party or witness pertaining to the incident. 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. %PDF-1.5 WebEach request for the production of documents must, with reasonable particularity, identify or describe the documents to be produced, either by individual item or by category, with sufficient specificity to enable the responding party to respond consistent with the requirements of this part. Plaintiff requests that the following documents be produced at the law offices of the undersigned within 30 days. This Standard Document has integrated drafting notes with important explanations and drafting tips. W e0 K` LOG IN. This can be a very profitable discovery tool, reaping immediate rewards. 855 East University Ave.; Gainesville FL 32601, CORONAVIRUS AID, RELIEF AND ECONOMIC SECURITY for FLORIDA. Twitter Poll Decides Future of Twitter, The New Twitter: The Bad Boss May Be A Hero for Exploited Children. 1980 Amendment. FLFNN.VA. (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. WebArizona (/ r z o n / ARR-ih-ZOH-n; Navajo: Hoozdo Hahoodzo [hozto hahotso]; O'odham: Al onak [ai nak]) is a state in the Southwestern United States.It is the 6th-largest and the 14th-most-populous of the 50 states. 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 Please produce copies of all pleadings, orders, police reports, notices or other documents pertaining to the incident. 855 East University Ave.; Gainesville FL 32601, CORONAVIRUS AID, RELIEF AND ECONOMIC SECURITY for FLORIDA. IH55J6FL"B]Wsng@i! {.C6. Accessible | Fair | Effective | Responsive | Accountable. [email protected]; PHONE (800) 649-1362; New Document: Florida VA Fixed Note. Rule 1.350 - PRODUCTION OF DOCUMENTS AND THINGS AND ENTRY UPON LAND FOR INSPECTION AND OTHER PURPOSES, Rule 1.351 - PRODUCTION OF DOCUMENTS AND THINGS WITHOUT DEPOSITION. Webmiddle district of florida orlando division mathew floeter plaintiff, vs. case no. Any and all documents, receipts or vouchers reflecting the funds provided to you 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 Any party may request any other party (1) to produce and permit the party making the request, or someone acting in the requesting party's behalf, to inspect and copy any designated documents, including electronically stored information, writings, 16. Privacy and Court Records Rule 1.030. The Florida Judicial Qualifications Commission, by and through its undersigned counsel and pursuant to Fla. Production of documents by non-parties is accomplished through the subpoena process under Florida Rule of Civil Procedure 1.351. 2d 899 (Fla. 3d DCA 1963) ; IBM v. Elder, 187 So. P. 1.350(b). / PLAINTIFFS FIRST REQUEST FOR PRODUCTION OF DOCUMENTS AND NOTICE TO PRODUCE TO DEFENDANTS COME NOW, Plaintiff in the above-styled action, and hereby requests both Defendants KYLE BJARKMAN and JJS OF FLORIDA, LLC d/b/a JIMMY JOHNS GOURMET SANDWICHES produce and permit Plaintiff, or someone acting on their behalf, to inspect and copy the following designated documents. 5. Read court documents, court records online and search 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. 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. (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. Personal Injury. 59 0 obj <> endobj Any individual, corporation, partnership, joint venture, firm, association, proprietorship, agency, board, authority, commission or any other entity. After Rule 26 Meeting. 11. 4 0 obj Please produce any and all correspondence or similar communication between any parties to this action. 1972 Amendment. WebRequest for Production of Documents - TO DEFENDANTParty: Defendant Florida Peninsula Insurance Co January 27, 2014. 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 %PDF-1.4 % hb````qbL, /07`/ 3@1c +. 2012 Amendment. 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 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. Contact us today for a free consultation. Web20. Compliance with Request. 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. 89 0 obj <>stream 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? If you're a paid subscriber and still having difficulty, please contact our support desk with your IPv4 address so we can investigate. endstream endobj startxref 12. 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. Requests for Production United States District Court Southern District of Florida. Document Title. 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. P. 1.380(b)(2). The new rule eliminates the good cause requirement of the former rule, changes the time for making the request and responding to it, and changes the procedure for the response. P. 1.280(e). Read court documents, court records online and search Trellis.law comprehensive legal database for any state court documents. Webwitnesses or documents protected under such privileges or doctrines or otherwise covered by Evidence Code section 1115 et seq. WebYou may request the Clerk to prepare the Subpoena Form in compliance with the requirements set forth in the Florida Rules of Civil Procedure. R. Civ. 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 documents, papers or evidence to be introduced at trial. (1) DEFINITIONS. 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. 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. 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. 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. P. 1.390(b). 2 0 obj 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. /s/ Michael Massey Michael Massey Fla. Bar No. REQUEST A DEMO. 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. President Trump signed this into law to provide relief in, Injuries from ladders are very common during construction. 63 0 obj <> endobj xZo8AO@65=v#73$%bXl-p8LM?4?}yzf90,ySKM/v6Kn&7;0./X,Q2XR&+gc^^"ym2nynz-BfdJL',O[LgLG!YdcdWr.meN)e:G M %0 Subdivision (b) is amended to set out a procedure for determining the form to be used in producing electronically stored information. WebPOSITION SUMMARY: HIAS seeks a Policy Analyst to conduct policy research and analysis in support of the Policy Centers mission and goals. 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). Requests for production and responses are not be filed with the court. See Rule 81(c), We also provide some thoughts concerning compliance and risk mitigation in this challenging environment. hmk0>nbIla^bC^J,)4%>Vt;D3`1+T fFj&-apfE&8pzwzoas U=5ZInXj\\~h6&9rQ\jjQ.\TY@/d5zQIu&8.r^yx6j7xvx_TLv]7u;; The Difference Between Workers Compensation and Disability Benefits with Associated Work Related COVID-19 Illnesses. 0 Section 2. As used in this section: (a) 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. If the court needs to consider a document or item produced in a matter pending before it, the 15. Your response to this request should be periodically supplemented. The Notice of Production is not to be sent to 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. Please produce all documents relating to alco-sensor, breathalyzer or blood-alcohol tests you performed on the date of the collision. 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. 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. INTRODUCTORY NOTES I. Definitions 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 addressed and all other persons acting or purporting to act on said persons behalf. : 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. II. 153680 855 E. Univ. 19. Rule 1.390 states an experts testimony can be obtained in accordance with the rules for taking depositions. Fla. R. Civ. (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. Read court documents, court records online and search Trellis.law comprehensive legal database for any state court documents. Nonverification of Pleadings Rule 1.040. WebRequests for the production of documents are another form of discovery available to litigants in Georgia. % This memorandum surveys U.S. economic sanctions and anti-money laundering (AML) developments and trends in 2022 and provides an outlook for 2023. (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. Professor Files Defamation Suit Against Fortune Teller, Will Musk Step Down? Please produce copies of your current drivers license and the registration for the vehicle involved in the collision described in Plaintiffs Complaint. 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. 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. WebWolter is a forensic geologist and television host. 'F!zv0@Wj(GlULb$[4c:z 8=}^f*XdP^;-7Uvvn 6{SDQuMho+0P^;IZ' WebRequest for Production of Documents - TO DEFENDANTParty: Defendant Florida Peninsula Insurance Co January 27, 2014. 3 0 obj 3. Please produce a copy of all transcripts containing the testimony of any party or witness pertaining to the instant collision. Make your practice more effective and efficient with Casetexts legal research suite. 4. P. 1.350(b). Fla. R. Civ. 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. 22. 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.
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