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Posted: September 21st, 2022
Civil 4
Request for Manufacturing
THE STATE COURT IN CUYAHOGA COUNTY, OHIO
MATHEWS
Plaintiff,
v.
SALLY SMITH
Defendant.
IN THE STATE COURT IN CUYAHOGA COUNTY, OHIO
CASE NO.
REQUEST FOR PRODUCTION
Plaintiff Mathews asks that defendant Sally Smith, offers the under talked about paperwork in reference to this case. If there’s any objection to this request, kindly present the rationale for the objection. In case you are denying the request, kindly present in particulars the explanations as to why the occasion is just not in a position to present all of the paperwork requested.
i. The copy of the driving force’s license, and another doc that pertains to amendments, or renewals
ii. A replica of the insurance coverage coverage of the defendant that gives cowl for this prevalence as claimed
iii. All copies of papers that show possession of the automotive by the defendant
iv. Copy of all statements made by witnesses gotten earlier than this lawsuit was filed by insurance coverage brokers appearing on the behalf of the insurance coverage provider of the defendant, if any.
v. Copies of all pictures that illustrate any injury to the bicycles of the plaintiff, the automotive of the defendant, and place of the incident claimed
vi. Copies of all writings that deny in complete or partiallt the diploma, rating and nature of the present medical situation of the plaintiff
vii. Copies of all videotapes, if any, manufactured from the incident
Dated this 14th Day of March, 2020
Legal professional
Deposition Discover
MATHEWS
Plaintiff,
v.
SALLY SMITH
Defendant.
IN THE STATE COURT IN CUYAHOGA COUNTY, OHIO
CASE NO.
NOTICE TO TAKE DEPOSITION
The Mathews, who’re the defendants, by their lawyer, in keeping with the Ohio Guidelines of Civil Process, will receive a deposition after conducting an oral examination on the person referred under on the time and date and on the place acknowledged under previous to a person suitably sanctioned to direct an oath beneath the legal guidelines set in Ohio. The recordings with reference to the deposition can be accomplished by way of audio and videotaped means for discovery functions. The recordings may even be utilized as proof and/or for any functions as allowed by the Guidelines of Civil Process in Ohio, encompassing the utilization throughout court docket proceedings, and can go on every day till accomplished.
The paperwork/issues indicated on “Schedule Z” (hooked up under) can be introduced by the Deponent to the Deposition.
Identify: Mathews
Date:
Place:
SCHEDULE “Z”
1. Any and all audiotapes, photos, diagrams or videotapes, pictures or different paperwork that relate to the incident in any method
2. Any and each doc identified in your responses to the interrogatories to this occasion
three. Any and each doc that relate to any launch, compromise, settlement offered to, or gotten by, you for any injury or damage ensuing from the incident in any method
4. Each doc that serves to bolster particular damages (earnings misplaced, workdays misplaced, medical prices) that are claimed on this motion
5. Every doc which acknowledges everybody or entity that has paid any form of profit which are funded by the federal authorities with respect to the grievances or incident complained of on this lawsuit, and for each such particular person or entity, present all paperwork which checklist the type and quantity of advantages paid, contact particular person, and declare payable to the advantages funded by the federal authorities
Due to this fact, TAKE NOTICE that on 15th March, 2020, the Regulation places of work, beginning at 11.00am, within the presence of a Notary Public, the undersigned, by counsel, will go on to take Mathews’ deposition, after oral examination. This deposition can be utilized as proof or discovery on this lawsuit beneath the Guidelines of Process in Ohio. Within the occasion that the deposition is just not full right this moment, it can resume and proceed on one other day till its full completion.
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