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N0 DESCRIPTION OBJECTIONS RESERVED
4 Piece of road tar Relevancy and materiality
5 Two photographs of Defendant's
vehicle prior to accident Relevancy and materiality
6 Alcohol test result from Lawnwood
Medical Center Relevancy and materiality
7 Any exhibits listed on Pretrial State-
ments filed -by all parties All objections reserved
8 Certified copy of Plaintiff's past- ~ ~
driving record as accumulated by
State of Florida All objections reserved
i
9 Medical records and reports of Lawnwood
Medical Center, E.M. Marshall, ri.D., and
Bruce Platzek, t%.. D. All objections reserved
COUNTERDEFENDANTS'
NO DESCRIPTION GBJECTIONS RESERVED
1 Any exhibits listed on Pretrial State-
ments filed by all parties All objections reserved.
2 Any exhibits discovered subsequent ~ ~
to this date upon specific provision
that opposing counsel be immediately
notified All objections reserved
3 Proof of collateral source benefits
paid or payable to Counterplaintiff All objections reserved
4 Photographs of accident scene and
vehicles involved in accident All objections reserved
5 Lawnwood Medical hospital records
as to Counterplaintiff All objections reserved
6 Any or all x-rays taken of Counter-
plaintiff in past five years All objections reserved
7 Copy of pertinent court records which
reflect guilty plea entered by Plain-
tiff in connection with traffic citations
issued as a result of this accident All objections reserved
8 Certified copy of Claimant's past.
driving record as accumulated by State
of Florida.' ~ All objections reserved
9 Diagram of accident scene All objections reserved
10 Counterplaintiff's tax returns for
past five years All objections reserved
3. OTHER PROVISIONS: Discovery will be left open until
five (5) days prior to trial. Additions may be made to the
witness list and list of exhibits on proper notice to other
parties until five (5) days prior to trial.
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