Preview
Filing # 125150397 E-Filed 04/19/2021 11:41:02 AM
IN THE CIRCUIT COURT OF THE
17™ JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE-21-003794
RIGUHEY ANDREU and
FRANCISCO VARGAS,
Plaintiffs,
v.
FEDNAT INSURANCE COMPANY,
Defendant.
/
TIFFS’ RESPONSE TO DEFENDANT’S FIRST REQUEST FOR PRODUCTION
COME NOW, Plaintiffs RIGUHEY ANDREU and FRANCISCO VARGAS (collectively
“Plaintiffs”), through undersigned attorney and pursuant to Fla. R. Civ. P. 1.350, hereby file their
responses to Defendant’s First Request for Production to Plaintiffs and state as follows:
Discovery is ongoing and Plaintiff consequently does not presently know of all facts or
Witnesses who have knowledge concerning this matter. Plaintiff expressly reserves the right to
supplement, alter and/or amend its responses after the date hereof, if necessary or appropriate.
Plaintiff reserves the right to object to the use of information produced in response to these
Interrogatories for any purpose, in this or any other proceeding, action, or matter; to object to
further inquiry with respect to the subject matter of these discovery requests; and to object to the
admissibility at trial of any information produced in response to these discovery requests, including
without limitation, all objections on the grounds that such information is not relevant to the subject
matter involved in the action or to the claims or defenses of any party. In the interest of economy
of time and clarity, Plaintiff will state at the outset, in separate numbered paragraphs, its objections
to the scope of Defendant's discovery requests.
1. GENERAL OBJECTION
Plaintiff objects to any definitions and instructions to the extent they are vague, ambiguous,
overly broad, and unduly burdensome, exceed the usual and ordinary meaning of the words defined
therein and are beyond the permissible scope of discovery as set forth in the applicable procedural
tules. Plaintiff will define the referenced words with their usual and customary meaning and/or in
accordance with the applicable procedural rules.
2. GENERAL OBJECTION
Plaintiff objects to each discovery request, or portion thereof, in which Defendant has asked
Plaintiff to identify "each," "every," "any," or "all" person(s) or document(s) relating to a specific
matter on the grounds that it would be unduly burdensome for Plaintiff to review every document
in its files at numerous locations or to interview each, every or all of Plaintiff's personnel employed
Page 1of7
SCHIRMER LAW LLC
888 SE 3rd Ave, Ste 300 | Fort Lauderdale, FL 33316 | Phone:(754) 260-5410
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/19/2021 11:41:02 AM.****during the relevant time period to ensure that it has not overlooked documents possibly containing
information only remotely related to the issues in controversy in this case, or persons with
knowledge of facts only remotely related to the issues in controversy in this case. Without waiving
these objections, and in the interest of minimizing controversy requiring the Court's attention,
Plaintiff will respond to such requests not otherwise objected to with information and/or
documents located by a reasonable, good faith effort.
3. GENERAL OBJECTION
Plaintiff objects to each discovery request to the extent that it seeks information protected from
discovery by the attorney-client privilege and/or the attorney work product doctrine, or information
subject to protection as trial preparation material, or information protected from discovery by any
other applicable privileges, or information which is otherwise immune from discovery. Plaintiff
will not produce any information or materials protected by the attorney client privilege, the work
product doctrine or other available legal privileges or protections against discovery. Generally, any
information within the scope of the engagement of any expert identified by Plaintiff's counsel
results precisely from services which were engaged specifically for this litigation or other
litigation. As such, the work-product privilege attaches, and is asserted unless specifically waived.
See Alachua General Hospital, Inc. v. Zimmer USA, Inc., 403 So.2d 1087 (Fla. Ist DCA 1981);
Shawmut Van Lines, Inc. v. Small, 148 So0.2d 556 (Fla. 3d DCA 1963).
4. GENERAL OBJECTION
Plaintiff objects to each discovery request to the extent that it is not limited to a relevant or
reasonable period of time or the time period at issue on the grounds that it is overly broad, unduly
burdensome, vague, ambiguous and harassing, in that it is neither relevant nor reasonably
calculated to lead to the discovery of admissible evidence.
5. GENERAL OBJECTION
Plaintiff objects to any discovery request, or portion thereof, that seeks sensitive and private
information, including but not limited to the home address and/or telephone number of any of its
current employees on the grounds that disclosure of such information may be considered an
invasion of the employee's privacy.
6. GENERAL OBJECTION
Plaintiff objects to each discovery request to the extent it calls for information or documents
already in the public domain, already in Defendants’ possession, custody or control, or equally
available to Defendants.
7. GENERAL OBJECTION
Plaintiff objects to each discovery request that seeks information that is either irrelevant to this
action or not reasonably calculated to lead to the discovery of admissible evidence. Without
waiving this objection, Plaintiff will respond to such interrogatories to the extent that Defendants
seek relevant information or information reasonably calculated to lead to the discovery of
admissible evidence.
Page 2 of 7
SCHIRMER LAW LLC
888 SE 3rd Ave, Ste 300 | Fort Lauderdale, FL 33316 | Phone:(754) 260-54108. GENERAL OBJECTION
Plaintiff objects to any discovery request which is not relevant or not reasonably calculated to
lead to admissible evidence including but not limited to private financial information, personal
data, family data, mortgage information of any kind, prior lawsuits whether criminal or civil, prior
judgments, prior insurance claims, bankruptcy information, tax data of any sort, absent a proffer
related to the pleadings making such an inquiry relevant upon an evidentiary hearing as
contemplated in Spry v. Professional Employer Plans, 985 So. 2d 1187 (Fla 1st DCA 2008) (the
party seeking discovery must provide evidence to show that the information is relevant), Friedman
v. Heart Inst. of Port St. Lucie, Inc., 863 So. 2d 189 (Fla. 2003).
These responses are made without waiver of, and with preservation of: All questions as to
competency, relevancy, materiality, privilege and admissibility of these responses, the documents
produced hereunder and the subject matter thereof, as evidence for any purpose in any further
proceeding in this action (including the trial of this action) and in any other action; the right to
object to the use of any grounds in any further proceeding of this action (including the trial of this
action) and in any other action; the right to object on any grounds at any time to a demand or
request for further discovery proceedings involving or relating to the subject matter hereof ; and
the right at any time to revise, correct, add to, supplement, or clarify any of the responses contained
herein.
Subject to and without in any way waiving any of the foregoing objections, Plaintiff responds
to Defendants’ discovery requests as follows:
Page 3 of 7
SCHIRMER LAW LLC
888 SE 3rd Ave, Ste 300 | Fort Lauderdale, FL 33316 | Phone:(754) 260-5410All bills incurred as a result of the incident which is the subject matter of this litigation.
RESPONSE: See Production File.
All photographs of the scene of the loss which depict conditions which have changed since
the time of the discovery of the loss which is the subject of this lawsuit.
RESPONSE: Objection, uncertain, unintelligible, overly broad and unduly
burdensome, seeks information from third parties not within its possession, custody,
control or personal knowledge. Objection, seeks information in the possession of,
known to, or otherwise equally available to Defendant.
Any and all photographs and/or videos of the alleged loss(es) and/or the alleged resulting
damage.
RESPONSE: See Production File
All photographs which the Plaintiffs intend to place into evidence or use at trial.
RESPONSE: Objection, request is premature as discovery is ongoing and Plaintiffs
have yet to determine the documents and exhibits they intend to use at trial.
All statements of the Defendant including, but not limited to, statements taken from agents,
servants, or employees of the Defendant.
RESPONSE: None.
Repair estimates, repair bills, appraisals, permits, contracts, or any other documents
regarding property damage or loss (including structural and/or contents damage or loss) in
the incident which is the subject of this litigation.
RESPONSE: See Production File.
Invoices, receipts, or other evidence of expenses incurred as a result of the incident which
is the subject of this litigation and not produced in response to Paragraph 6.
RESPONSE: See Production File.
All documents supporting the claim for money damages in this lawsuit and not produced
in response to the preceding paragraphs, including proof of payment (such as checks, credit
card statements or receipts) for any such damages.
RESPONSE: See Production File.
Page 4 of 7
SCHIRMER LAW LLC
888 SE 3rd Ave, Ste 300 | Fort Lauderdale, FL 33316 | Phone:(754) 260-541010.
11.
12.
13.
The complete report of each person whom the Plaintiff expects to call as an expert witness
at trial.
RESPONSE: Objection, request is premature as discovery is ongoing and Plaintiffs
have not yet retained any trial experts. Plaintiffs’ expert witness(es) will be designated
pursuant to the entry of an Order setting this case for trial.
As to each following type of insurance in favor of the Plaintiff, namely homeowners’;
renters’, or general liability insurance, and any umbrella or excess insurance:
a. Complete copies of each such contract or policy;
b. The Declaration Sheet of each such contract or policy;
c. Each and every application for benefits made by the Plaintiff under any of the
policies, whether pertaining to the incident which is the subject of this litigation or
not;
d. All evidence of payment from any collateral source including checks, check stubs,
cancelled checks, payout sheets, paid invoices or receipts, memos and
correspondence relating to payments made under any of the policies listed above.
RESPONSE: Objection, overly broad, irrelevant, immaterial, not reasonably limited
to time or scope, and not reasonably calculated to lead to the discovery of admissible
evidence. Subject to and with waiving said objections, see Production File for relevant
policy only.
A copy of any general or partial release executed by the Plaintiffs as a result of the incident
which is the subject of this lawsuit. This request includes, but is not limited to, property
damage releases, and releases printed on the backs of checks or drafts.
RESPONSE: Objection, uncertain, unintelligible. Furthermore, any payments issued
by Defendant should already be in Defendant’s possession.
A complete copy of any settlement agreement between the Plaintiffs and any other person
or entity.
RESPONSE: Objection, overly broad, unduly burdensome, not reasonably limited in
scope or time, and not reasonably calculated to lead to the discovery of admissible
evidence. Subject to and without waiving said objections, none.
Copies of any pre-purchase or post-purchase inspection reports and photos obtained by you
and/or your mortgage holder on the property in question, prior to the subject loss(es).
RESPONSE: Objection, overly broad, unduly burdensome, not reasonably limited in
scope or time, and not reasonably calculated to lead to the discovery of admissible
evidence.
Page 5 of 7
SCHIRMER LAW LLC
888 SE 3rd Ave, Ste 300 | Fort Lauderdale, FL 33316 | Phone:(754) 260-541014.
15.
16.
17.
18.
19.
20.
Any and all documents, correspondence, photographs, videotapes, audio tapes, data,
samples, or other tangible items supporting your damage claims.
RESPONSE: See Production File.
Any and all agreements, contracts, and/or invoices between the insured and any public
adjuster, including any agreements to pay fees or contingent fee agreements.
RESPONSE: Objection, overly broad, unduly burdensome and not reasonably
limited in scope or time. Notwithstanding, See Production File for the contract related
to the subject claim.
Any and all documents, correspondence, photographs, videotapes, audio tapes, data,
samples, or other tangible items relating to any inspection, assessment, appraisal, review,
or investigation of the property for the five years prior to the loss through the present.
RESPONSE: Objection, overly broad, unduly burdensome, not reasonably limited in
scope or time, and not reasonably calculated to lead to the discovery of admissible
evidence.
Any and all documents, correspondence, photographs, videotapes, audio tapes, data,
samples, or other tangible items reflecting efforts by you to mitigate damages.
RESPONSE: See Production File.
Any and all documents, correspondence, photographs, videotapes, audio tapes, data,
samples, or other tangible items relating to your discovery or notice of the damage that is
the basis of the claim.
RESPONSE: See Production File.
Any and all yearly budgets that reflect the amount of money you spent, and/or expected to
spend for maintenance of the property.
RESPONSE: Objection, overly broad, irrelevant, immaterial, not reasonably limited
to time or scope, and not reasonably calculated to lead to the discovery of admissible
evidence.
Any and all documents and communications exchanged between you and your public
adjuster.
RESPONSE: See Production File.
Page 6 of 7
SCHIRMER LAW LLC
888 SE 3rd Ave, Ste 300 | Fort Lauderdale, FL 33316 | Phone:(754) 260-541021. Copies of your tax returns for three years prior to the date of loss through the present.
RESPONSE: Objection, overly broad, irrelevant, immaterial, not reasonably limited
to time or scope, and not reasonably calculated to lead to the discovery of admissible
evidence.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served by
electronic mail designation pursuant to Fla. R. Jud. Admin 2.516, to Bruce Trybus, Esq.
(reception@ctkplaw.com, yhall@ctkplaw.com, Icalzadilla@ctkplaw.com, gvioli@ctkplaw.com)
and e-filed with the Clerk of Court on April 19, 2021.
/s/ Jaci Mattocks-Schirmer
Jaci Mattocks-Schirmer, Esquire
Bar No.: 115765
Attorney for Plaintiff
Schirmer Law LLC
888 SE 3™ Ave, Ste 300
Fort Lauderdale, FL 33316
Tel: (754) 260-5410
Primary: tpomaranski@schirmerlaw.com
Secondary: jmattocks@schirmerlaw.com
Tertiary: eservice@schirmerlaw.com
Page 7 of 7
SCHIRMER LAW LLC
888 SE 3rd Ave, Ste 300 | Fort Lauderdale, FL 33316 | Phone:(754) 260-5410
Preview
Filing # 125150397 E-Filed 04/19/2021 11:41:02 AM IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-21-003794 RIGUHEY ANDREU and FRANCISCO VARGAS, Plaintiffs, v. FEDNAT INSURANCE COMPANY, Defendant. / TIFFS’ RESPONSE TO DEFENDANT’S FIRST REQUEST FOR PRODUCTION COME NOW, Plaintiffs RIGUHEY ANDREU and FRANCISCO VARGAS (collectively “Plaintiffs”), through undersigned attorney and pursuant to Fla. R. Civ. P. 1.350, hereby file their responses to Defendant’s First Request for Production to Plaintiffs and state as follows: Discovery is ongoing and Plaintiff consequently does not presently know of all facts or Witnesses who have knowledge concerning this matter. Plaintiff expressly reserves the right to supplement, alter and/or amend its responses after the date hereof, if necessary or appropriate. Plaintiff reserves the right to object to the use of information produced in response to these Interrogatories for any purpose, in this or any other proceeding, action, or matter; to object to further inquiry with respect to the subject matter of these discovery requests; and to object to the admissibility at trial of any information produced in response to these discovery requests, including without limitation, all objections on the grounds that such information is not relevant to the subject matter involved in the action or to the claims or defenses of any party. In the interest of economy of time and clarity, Plaintiff will state at the outset, in separate numbered paragraphs, its objections to the scope of Defendant's discovery requests. 1. GENERAL OBJECTION Plaintiff objects to any definitions and instructions to the extent they are vague, ambiguous, overly broad, and unduly burdensome, exceed the usual and ordinary meaning of the words defined therein and are beyond the permissible scope of discovery as set forth in the applicable procedural tules. Plaintiff will define the referenced words with their usual and customary meaning and/or in accordance with the applicable procedural rules. 2. GENERAL OBJECTION Plaintiff objects to each discovery request, or portion thereof, in which Defendant has asked Plaintiff to identify "each," "every," "any," or "all" person(s) or document(s) relating to a specific matter on the grounds that it would be unduly burdensome for Plaintiff to review every document in its files at numerous locations or to interview each, every or all of Plaintiff's personnel employed Page 1of7 SCHIRMER LAW LLC 888 SE 3rd Ave, Ste 300 | Fort Lauderdale, FL 33316 | Phone:(754) 260-5410 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/19/2021 11:41:02 AM.****during the relevant time period to ensure that it has not overlooked documents possibly containing information only remotely related to the issues in controversy in this case, or persons with knowledge of facts only remotely related to the issues in controversy in this case. Without waiving these objections, and in the interest of minimizing controversy requiring the Court's attention, Plaintiff will respond to such requests not otherwise objected to with information and/or documents located by a reasonable, good faith effort. 3. GENERAL OBJECTION Plaintiff objects to each discovery request to the extent that it seeks information protected from discovery by the attorney-client privilege and/or the attorney work product doctrine, or information subject to protection as trial preparation material, or information protected from discovery by any other applicable privileges, or information which is otherwise immune from discovery. Plaintiff will not produce any information or materials protected by the attorney client privilege, the work product doctrine or other available legal privileges or protections against discovery. Generally, any information within the scope of the engagement of any expert identified by Plaintiff's counsel results precisely from services which were engaged specifically for this litigation or other litigation. As such, the work-product privilege attaches, and is asserted unless specifically waived. See Alachua General Hospital, Inc. v. Zimmer USA, Inc., 403 So.2d 1087 (Fla. Ist DCA 1981); Shawmut Van Lines, Inc. v. Small, 148 So0.2d 556 (Fla. 3d DCA 1963). 4. GENERAL OBJECTION Plaintiff objects to each discovery request to the extent that it is not limited to a relevant or reasonable period of time or the time period at issue on the grounds that it is overly broad, unduly burdensome, vague, ambiguous and harassing, in that it is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. 5. GENERAL OBJECTION Plaintiff objects to any discovery request, or portion thereof, that seeks sensitive and private information, including but not limited to the home address and/or telephone number of any of its current employees on the grounds that disclosure of such information may be considered an invasion of the employee's privacy. 6. GENERAL OBJECTION Plaintiff objects to each discovery request to the extent it calls for information or documents already in the public domain, already in Defendants’ possession, custody or control, or equally available to Defendants. 7. GENERAL OBJECTION Plaintiff objects to each discovery request that seeks information that is either irrelevant to this action or not reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, Plaintiff will respond to such interrogatories to the extent that Defendants seek relevant information or information reasonably calculated to lead to the discovery of admissible evidence. Page 2 of 7 SCHIRMER LAW LLC 888 SE 3rd Ave, Ste 300 | Fort Lauderdale, FL 33316 | Phone:(754) 260-54108. GENERAL OBJECTION Plaintiff objects to any discovery request which is not relevant or not reasonably calculated to lead to admissible evidence including but not limited to private financial information, personal data, family data, mortgage information of any kind, prior lawsuits whether criminal or civil, prior judgments, prior insurance claims, bankruptcy information, tax data of any sort, absent a proffer related to the pleadings making such an inquiry relevant upon an evidentiary hearing as contemplated in Spry v. Professional Employer Plans, 985 So. 2d 1187 (Fla 1st DCA 2008) (the party seeking discovery must provide evidence to show that the information is relevant), Friedman v. Heart Inst. of Port St. Lucie, Inc., 863 So. 2d 189 (Fla. 2003). These responses are made without waiver of, and with preservation of: All questions as to competency, relevancy, materiality, privilege and admissibility of these responses, the documents produced hereunder and the subject matter thereof, as evidence for any purpose in any further proceeding in this action (including the trial of this action) and in any other action; the right to object to the use of any grounds in any further proceeding of this action (including the trial of this action) and in any other action; the right to object on any grounds at any time to a demand or request for further discovery proceedings involving or relating to the subject matter hereof ; and the right at any time to revise, correct, add to, supplement, or clarify any of the responses contained herein. Subject to and without in any way waiving any of the foregoing objections, Plaintiff responds to Defendants’ discovery requests as follows: Page 3 of 7 SCHIRMER LAW LLC 888 SE 3rd Ave, Ste 300 | Fort Lauderdale, FL 33316 | Phone:(754) 260-5410All bills incurred as a result of the incident which is the subject matter of this litigation. RESPONSE: See Production File. All photographs of the scene of the loss which depict conditions which have changed since the time of the discovery of the loss which is the subject of this lawsuit. RESPONSE: Objection, uncertain, unintelligible, overly broad and unduly burdensome, seeks information from third parties not within its possession, custody, control or personal knowledge. Objection, seeks information in the possession of, known to, or otherwise equally available to Defendant. Any and all photographs and/or videos of the alleged loss(es) and/or the alleged resulting damage. RESPONSE: See Production File All photographs which the Plaintiffs intend to place into evidence or use at trial. RESPONSE: Objection, request is premature as discovery is ongoing and Plaintiffs have yet to determine the documents and exhibits they intend to use at trial. All statements of the Defendant including, but not limited to, statements taken from agents, servants, or employees of the Defendant. RESPONSE: None. Repair estimates, repair bills, appraisals, permits, contracts, or any other documents regarding property damage or loss (including structural and/or contents damage or loss) in the incident which is the subject of this litigation. RESPONSE: See Production File. Invoices, receipts, or other evidence of expenses incurred as a result of the incident which is the subject of this litigation and not produced in response to Paragraph 6. RESPONSE: See Production File. All documents supporting the claim for money damages in this lawsuit and not produced in response to the preceding paragraphs, including proof of payment (such as checks, credit card statements or receipts) for any such damages. RESPONSE: See Production File. Page 4 of 7 SCHIRMER LAW LLC 888 SE 3rd Ave, Ste 300 | Fort Lauderdale, FL 33316 | Phone:(754) 260-541010. 11. 12. 13. The complete report of each person whom the Plaintiff expects to call as an expert witness at trial. RESPONSE: Objection, request is premature as discovery is ongoing and Plaintiffs have not yet retained any trial experts. Plaintiffs’ expert witness(es) will be designated pursuant to the entry of an Order setting this case for trial. As to each following type of insurance in favor of the Plaintiff, namely homeowners’; renters’, or general liability insurance, and any umbrella or excess insurance: a. Complete copies of each such contract or policy; b. The Declaration Sheet of each such contract or policy; c. Each and every application for benefits made by the Plaintiff under any of the policies, whether pertaining to the incident which is the subject of this litigation or not; d. All evidence of payment from any collateral source including checks, check stubs, cancelled checks, payout sheets, paid invoices or receipts, memos and correspondence relating to payments made under any of the policies listed above. RESPONSE: Objection, overly broad, irrelevant, immaterial, not reasonably limited to time or scope, and not reasonably calculated to lead to the discovery of admissible evidence. Subject to and with waiving said objections, see Production File for relevant policy only. A copy of any general or partial release executed by the Plaintiffs as a result of the incident which is the subject of this lawsuit. This request includes, but is not limited to, property damage releases, and releases printed on the backs of checks or drafts. RESPONSE: Objection, uncertain, unintelligible. Furthermore, any payments issued by Defendant should already be in Defendant’s possession. A complete copy of any settlement agreement between the Plaintiffs and any other person or entity. RESPONSE: Objection, overly broad, unduly burdensome, not reasonably limited in scope or time, and not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving said objections, none. Copies of any pre-purchase or post-purchase inspection reports and photos obtained by you and/or your mortgage holder on the property in question, prior to the subject loss(es). RESPONSE: Objection, overly broad, unduly burdensome, not reasonably limited in scope or time, and not reasonably calculated to lead to the discovery of admissible evidence. Page 5 of 7 SCHIRMER LAW LLC 888 SE 3rd Ave, Ste 300 | Fort Lauderdale, FL 33316 | Phone:(754) 260-541014. 15. 16. 17. 18. 19. 20. Any and all documents, correspondence, photographs, videotapes, audio tapes, data, samples, or other tangible items supporting your damage claims. RESPONSE: See Production File. Any and all agreements, contracts, and/or invoices between the insured and any public adjuster, including any agreements to pay fees or contingent fee agreements. RESPONSE: Objection, overly broad, unduly burdensome and not reasonably limited in scope or time. Notwithstanding, See Production File for the contract related to the subject claim. Any and all documents, correspondence, photographs, videotapes, audio tapes, data, samples, or other tangible items relating to any inspection, assessment, appraisal, review, or investigation of the property for the five years prior to the loss through the present. RESPONSE: Objection, overly broad, unduly burdensome, not reasonably limited in scope or time, and not reasonably calculated to lead to the discovery of admissible evidence. Any and all documents, correspondence, photographs, videotapes, audio tapes, data, samples, or other tangible items reflecting efforts by you to mitigate damages. RESPONSE: See Production File. Any and all documents, correspondence, photographs, videotapes, audio tapes, data, samples, or other tangible items relating to your discovery or notice of the damage that is the basis of the claim. RESPONSE: See Production File. Any and all yearly budgets that reflect the amount of money you spent, and/or expected to spend for maintenance of the property. RESPONSE: Objection, overly broad, irrelevant, immaterial, not reasonably limited to time or scope, and not reasonably calculated to lead to the discovery of admissible evidence. Any and all documents and communications exchanged between you and your public adjuster. RESPONSE: See Production File. Page 6 of 7 SCHIRMER LAW LLC 888 SE 3rd Ave, Ste 300 | Fort Lauderdale, FL 33316 | Phone:(754) 260-541021. Copies of your tax returns for three years prior to the date of loss through the present. RESPONSE: Objection, overly broad, irrelevant, immaterial, not reasonably limited to time or scope, and not reasonably calculated to lead to the discovery of admissible evidence. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served by electronic mail designation pursuant to Fla. R. Jud. Admin 2.516, to Bruce Trybus, Esq. (reception@ctkplaw.com, yhall@ctkplaw.com, Icalzadilla@ctkplaw.com, gvioli@ctkplaw.com) and e-filed with the Clerk of Court on April 19, 2021. /s/ Jaci Mattocks-Schirmer Jaci Mattocks-Schirmer, Esquire Bar No.: 115765 Attorney for Plaintiff Schirmer Law LLC 888 SE 3™ Ave, Ste 300 Fort Lauderdale, FL 33316 Tel: (754) 260-5410 Primary: tpomaranski@schirmerlaw.com Secondary: jmattocks@schirmerlaw.com Tertiary: eservice@schirmerlaw.com Page 7 of 7 SCHIRMER LAW LLC 888 SE 3rd Ave, Ste 300 | Fort Lauderdale, FL 33316 | Phone:(754) 260-5410