IN THE CIRCUIT COURT OF THE

NINETEENTH JUDICIAL CIRCUIT,

IN AND FOR ST. LUCIE COUNTY,

FLORIDA

Case No. OO-CA-001074-(OC)

JUDGE: ROBERT A. HAWLEY

FIGG BRIDGE ENGINEERS, INC.

Plantiff,

V.

CHARLES GRANDE, EDWARD

McKAY, ROGER SHARP and

KEVIN STINNETTE,

Defendants.

PLANTIFF’S RESPONSE TO DEFENDANTS’

FIRST REOUEST TO PRODUCE DOCUMENTS

Plantiff, FIGG BRIDGE ENGINNERS, INC. ("Figg") hereby responds to the Defendants’ First Request to Produce Documents served on October 16, 2000 as follows:

1. Figg objects to those categories of documents described in paragraphs 1, 2, 9, 10, 11, 12, 13 and 14 of the Request to Produce in that said categories call for the work product analysis of counsel and for a conclusion of law in that the categories demand production of all documents "probative," or which would "support a finding," or "support a contention" described. Notwithstanding these objections, Figg will produce, upon reasonable notice and at a mutually convenient time, in the offices of its counsel all

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Melville & Sowerby, P. A.

2940 SOUTH 25TH STREET, FORT PIERCE, FLORIDA 34981 5605 • TELEPHONE (561) 464-7900

documents currently in its possession relating to the defamatory statements made by Defendants, the damages suffered by Figg as a result of those statements and Figg’s status in connection with the Federal and State investigations described.

2. Figg objects to the production of those documents described in paragraphs 3,

4, 5, 6, 7, and 8 of the Request to Produce in that said categories of documents are overly broad, burdensome, vexatious, harassing and not reasonably calculated to lead to the discovery of admissible evidence.

3. With regard to the documents described in paragraphs 15, 16,17, 18, 19 and

20 of the Request to Produce, Figg will produce all such documents currently in its possession, with the exception of privileged or work product documents, in the office of its counsel upon reasonable notice and at a mutually convenient date.

Respectfully submitted,

MELVILL & SOWERBY, P.A.

 

 

 

H OLD . MELVILLE

Laurel Professional Park

2940 South 2511 Street

Fort Pierce, FL 3498 1-5605 (561) 464-7900

Fla. Bar No. 148214

ATTORNEYS FOR PLANTIFF

 

 

 

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Melville & Sowerby, P. A.

2940 SOUTH 25TH STREET, FORT PIERCE, FLORIDA 34981 5605 • TELEPHONE (561) 464-7900

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a copy of the foregoing has been furnished by U.S. Mail this __________ day of November, 2000, to ROBERT RIVAS, ESQ., The Rivas Law Firm, 311 S. Calhoun St., Suite 206, Tallahassee, FL 32301-1802.

 

 

 

HAROLD G. MELVILLE

Attorney for Plantiff

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Melville & Sowerby, P. A.

2940 SOUTH 25TH STREET, FORT PIERCE, FLORIDA 34981 5605 • TELEPHONE (561) 464-7900

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