RESPONSE TO REQ TO PRODUCE

On December 16, 2020 a premises liability commercial case was filed by Jose Y Pacheco Castillo, represented by R Timothy Vannatta, against Udr Inc, and Udr Okeeelee Llc, represented by Eric Reichenberger, in the jurisdiction of Palm Beach County. Judge PAIGE GILLMAN presiding.

                        
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Filing # 124068676 E-Filed 03/31/2021 09:39:58 AM IN THE CIRCUIT COURT OF THE 15!" JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA. JOSE YSMAEL PACHECO CASTILLO CASE NO.: 502020CA013988 Plaintiff, Vv. UDR, INC., Defendants. / DEFENDANT’S RESPONSE TO REQUEST FOR PRODUCTION TO DEFENDANT UDR OKEEHEELEE, LLC. The following are the responses of Defendant, UDR OKEEHEELEE, LLC to the Request for Production propounded by the Plaintiff with his Complaint, pursuant to Rule 1.340 of the Florida Rules of Civil Procedure. 1. Any and all policies, procedures, and/or other written documents in effect in the One year leading up to and including December 27, 2019 that discuss, touch on, or concern the prevention of the accumulation of, and/or the cleaning of foreign substances such as mold, mildew, algae, and/or other similar substance on the ground/floor/common areas of its premises located at 317 Olive Tree Circle, Greenacres, FL 33413, in Palm Beach County. RESPONSE: Defendant object…

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