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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