The week before the trial, while the lawyer in charge of the Publix case was out of the country, his staff again changed the list of witnesses. This time, however, an address for Martinez appeared — 12745 Woodbury Glen Drive — and this time it was identified as the last known address. It turned out that the “last known address” finally given was the same address where Martinez had lived continuously long before the 2001 accident. In 2008, however, when the Joneses` lawyer contacted him at Woodbury Glen Drive, he couldn`t remember what had happened. The Joneses` lawyer filed a motion to strike from Publix`s pleadings and a motion to discontinue this breach of the discovery. At the first hearing, Publix`s lawyer told the judge they didn`t know how to contact Martinez, but the trial judge was skeptical. She ordered that the case be heard further. She specifically ordered Publix`s lawyer to be prepared to explain when and where they received Martinez`s address. It also ordered Publix to bring Martinez`s testimony and all other discovery information about Martinez to a hearing. In a remarkable understatement, the trial judge told Publix`s lawyer, “But if the victim doesn`t know how to reach the witness, and you know that, and they ask and you don`t tell them, that`s a problem.” Publix offers excellent customer service on Twitter.
The food chain is available for any questions via social media – especially if they relate to their food delivery services. Companies can take a page from Publix`s book and also provide excellent support via social media. In the appeal, Publix does not defend the non-disclosure of the address; Moreover, he simply ignores the point. Instead, Publix argues that they gave the name of witness Ivan Martinez in 2008 and that the plaintiffs` lawyer should have found the address himself. Publix also claims that there is no evidence that the Jones case was harmed by the failure to disclose Martinez`s address, as it is impossible for the Joneses to show when he forgot what he knew in 2001.6 It is important for a company to stay in touch with its customers, and it is even more important that they maintain an open flow of communication. Whether you need to find a phone number or email address, or want to know when they`re open, we have all the details you need to reach Publix in one place. The Joneses deny that Jones was guilty of wrongdoing or cover-up. He and his lawyer denied knowledge of the statement when he answered questioning.
They point out that Publix did not include any questions in its interrogations of Ms. Jones that allegedly provoked the content of the confession; that Mr. Jones was not aware of the statement; that Ms. Jones did not assist Mr. Jones in responding to the interrogations addressed to him; that Publix took her testimony and did not take the opportunity to ask Ms. Jones questions that would have provoked the content of the confession; and that Ms. Jones “as a layman and was not aware of the legal significance of admission, did not understand it as something she should voluntarily report.” Look for Publix`s phone number, email address, contact information, and head office address, then you`ve come to the right place where you can find the answers to all your questions. Still puzzled, the trial judge said, “You know, if I were in your shoes, I wouldn`t just invent an address or arbitrarily remove one from the phone book that I haven`t confirmed after years of saying you don`t know how to reach it.” The attorney then elaborated again: “Well, Your Honor, basically, we haven`t been able to locate Mr. Martinez, and so I`ve basically told my staff to find all the Ivan Martinez that you can find in the Central Florida area, and we`ll send him a letter and see. if we can get an answer.
These are the addresses you see. The judge went on to say, “Oh, there is only one address that was given. They called him as a witness and gave an address, and the plaintiffs` lawyer went crazy. Publix`s lawyer replied: “And what I say to the court as a court official is that I have no idea what Mr. Martinez`s real address is. He is certainly a man with a similar name, but I cannot confirm the alleged witness in this case one way or another. 5. Provide the name, home address, business address and telephone number of each person whom you, your agents or lawyers believe they have heard or who have heard that the defendant made a statement, remark or comment about the accident described in the complaint, and the content of any statement, Note or remark. Based on the evidence on file, there is no doubt that Publix, through its counsel, violated the most basic rule of disclosure by failing to disclose the address of its testimony in a timely manner. The minutes also show that the Joneses were able to contact Martinez very quickly thanks to the address finally provided in 2008. Unfortunately, Martinez testified that he did not remember the details of the incident. Based on the evidence in the files, Publix`s late disclosure of Martinez`s speech undermined the Jones case and its trial preparation.
While Martinez was able to describe the details of the incident shortly after it happened, he was unable to do so when the Joneses were able to extract Publix`s contact information and get in touch with him. Importantly, the details described by Martinez indicate that Mr. Jones fell because of the water on the ground, that Publix was aware of the water pollution before the fall, and that Publix likely had contact information for the customer who spilled the water. Had the Joneses received Martinez`s address when it was first requested and should have been provided, Martinez might have been able to give the Joneses the same or better details of the incident he gave to Publix. Otherwise, according to the rules of discovery, the Joneses would have had the opportunity to advocate for the disclosure of the product of the work to support his memory. 6. At the hearing, Publix`s lawyer stated that there was no disclosure obligation because the address on the statement was `false`. When questioned on this point, the lawyer explained that the address was “misspelled”. It turns out that the “wrong” address on the statement was 12745 Woodbury Glenn Drive, not 12745 Woodbury Glen Drive.
When the hearing resumed, Publix`s lawyer reiterated that he had not provided the address in his answers to the February 24, 2006 interrogations because “we have not and have never done”. Still doubtful, the judge asked, “Where did you get that address that arrived four days ago?” The lawyer replied that the address they had provided four days earlier was just one of many addresses found in the phone book or any other reference for Ivan Martinez. The lawyer said: “If we disclose `a` address, we are not sure if it is `the` address. We still don`t know. Not so easily deterred, the trial judge began asking about Publix`s testimony, which was mentioned in the initial response to the interrogation as a possible source of the address. Publix`s lawyer told the court that there was no statement from Martinez. Instead, a representative from Specialty Risk Services interviewed him, but it was not a question or answer. That was a summary. Your email must include your name, email address, contact information, date of the incident, location of the incident, store where the incident occurred, and a summary of what happened. Your email address will not be published. Required fields are marked * Robert Jones and Julie Jones [“the Joneses”] are appealing a final judgment in favor of Publix Super Markets, Inc.