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Filing # 127705515 E-Filed 05/27/2021 04:42:52 PM
IN THE CIRCUIT COURT OF THE 17H
JUDICIAL CIRCUIT IN AND FOR BROWARD
COUNTY, FLORIDA.
ERIC DEININGER AND MARIE
DEININGER,
CASE NO. CACE 20-017353 (18)
Plaintiff,
V.
GULFSTREAM PROPERTY & CASUALTY INSURANCE COMPANY,
A Florida Corporation
Defendant.
PLAINTIFFS' RESPONSES TO DEFENDANT'S FIRST BEQUEST FOR
PRODUCTION OF DOCUMENTS
COMES NOW, the Plaintiffs, ERIC DEININGER and MARIE DEININGER,
by and through their undersigned counsel, and hereby files its
Responses to Defendant'sl GULFSTREAM PROPERTY & CASUALTY INSURANCE
COMPANY'S, First Request for Production of Documents, as follows:
1. Objection, unduly burdensome, overbroad. Without waiving objection, please see
attached.
2. See attached in Plaintiffs' possession.
3. Objection, unduly burdensome, overbroad, harassing, not reasonably calculated to
lead to admissible evidence, work product. Without waiving said objection, see
attached in Plaintiffs' possession.
*** FILED: BROWARDCOUNTY, FL BRENDA D. FORMAN, CLERK 05/27/2021 04:42:52 PM.****
4. Objection, unduly burdensome, not narrowly tailored, overbroad, harassing, not
reasonably calculated to lead to admissible evidence, work product. Without
waiving said objection, see attached in Plaintiffs' possession.
5. Objection, unduly burdensome, overbroad, harassing, not reasonably calculated to
lead to admissible evidence.
Without waiving said objection, see attached in
Plaintiffs' possession.
6. Objection, unduly burdensome, overbroad, harassing. Without waiving said
objection, please see attached in Plaintiffs' possession.
7. Objection, unduly burdensome,overbroad, harassing, not reasonably calculated to
lead to admissible evidence. Without waiving said objection, please see attached
in Plaintiffs' possession.
8. Objection, unduly burdensome, overbroad, harassing, not reasonably calculated to
lead to admissible evidence. Without waiving said objection, please see attached
in Plaintiffs' possession.
9. Objection, unduly burdensome, overbroad, harassing, not reasonably calculated to
lead to admissible evidence. Without waiving said objection, please see attached
in Plaintiffs' possession.
10. Objection, overbroad, not narrowly tailored, compound, duplicative, ambiguous.
harassing.
Without waiving said objection, please see attached in Plaintiffs'
possession.
11. Please see attached our public adjuster estimate.
12. Please see attached.
13. Objection, duplicative,overbroad, not narrowly tailored, ambiguous, not reasonably
calculated to lead to admissible evidence. Without waiving said objection, please
see attached in Plaintiffs' possession.
14. Please see attached in Plaintiffs' possession.
15. Objection, not narrowlytailored in time and scope, harassing, unduly burdensome,
overbroad, harassing, not reasonably calculated to lead to admissible evidence.
Withoutwaiving said objection, none in Plaintiffs' possession other than that which
was provided in connection with the instant claim, and as such, please see
attached in Plaintiffs' possession.
16. Please see response to number 15.
17. Please see response to number 15.
18. Objection, unduly burdensome, harassing, duplicative. Without waiving said
objection, please see attached as to the instant claim.
19.See response to number 15.
20. See response to number 15, otherwise, none in Plaintiffs possession relative to
the Hurricane Irma claim. However, Gulfstream was Plaintiffs' insurance company
during and for the Hurricane Irma loss and has those documents.
21. Please see attached.
22.Objection, unduly burdensome, harassing, not reasonably calculated to lead to
admissible evidence.
23. Please see attached.
24. Please see attached plumbers' receipts and documents from Entrusted, the
company that completed remediation in connection with the subject loss
25.Objection,harassing, not reasonably calculated to lead to admissible evidence.
26. Objection, unduly burdensome, harassing, not reasonably calculated to lead to
admissible evidence. Without waiving said objection, none in Plaintiffs' possession.
27.See response to number 20.
28. See attached.
CERTIFICATE OF SERVICE
I HEREBY CERT]FY that a true and correct copy of the foregoing was served via
email delivery, upon: SER]C J. FALLON, ESQUIRE Gulfstream Property & Casualty Ins.
Co., Attorneys for Defendant, 1401 NW 136h Avenue, Suite 200, Sunrise, FL 33323 on
this 27th day of May, 2021.
The Glassman Legal Group
Attorneysfor Plaintiffs
2200 N. Commerce Parkway, Ste. 105
Fort Lauderdale, Florida 33326
Telephone No.: (954) 915-8800
Facsimile: (954) 915-8900
Email: lee@Ieeglassman.com
By:
/s/ Monica E. McWilliams
LEE D. GLASSMAN, ESQ.
FLORIDA BAR NO.: 0999954
MONICA E MCWILLIAMS, ESQ.
FLORIDA BAR NO.: 105385
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Filing # 127705515 E-Filed 05/27/2021 04:42:52 PM IN THE CIRCUIT COURT OF THE 17H JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA. ERIC DEININGER AND MARIE DEININGER, CASE NO. CACE 20-017353 (18) Plaintiff, V. GULFSTREAM PROPERTY & CASUALTY INSURANCE COMPANY, A Florida Corporation Defendant. PLAINTIFFS' RESPONSES TO DEFENDANT'S FIRST BEQUEST FOR PRODUCTION OF DOCUMENTS COMES NOW, the Plaintiffs, ERIC DEININGER and MARIE DEININGER, by and through their undersigned counsel, and hereby files its Responses to Defendant'sl GULFSTREAM PROPERTY & CASUALTY INSURANCE COMPANY'S, First Request for Production of Documents, as follows: 1. Objection, unduly burdensome, overbroad. Without waiving objection, please see attached. 2. See attached in Plaintiffs' possession. 3. Objection, unduly burdensome, overbroad, harassing, not reasonably calculated to lead to admissible evidence, work product. Without waiving said objection, see attached in Plaintiffs' possession. *** FILED: BROWARDCOUNTY, FL BRENDA D. FORMAN, CLERK 05/27/2021 04:42:52 PM.**** 4. Objection, unduly burdensome, not narrowly tailored, overbroad, harassing, not reasonably calculated to lead to admissible evidence, work product. Without waiving said objection, see attached in Plaintiffs' possession. 5. Objection, unduly burdensome, overbroad, harassing, not reasonably calculated to lead to admissible evidence. Without waiving said objection, see attached in Plaintiffs' possession. 6. Objection, unduly burdensome, overbroad, harassing. Without waiving said objection, please see attached in Plaintiffs' possession. 7. Objection, unduly burdensome,overbroad, harassing, not reasonably calculated to lead to admissible evidence. Without waiving said objection, please see attached in Plaintiffs' possession. 8. Objection, unduly burdensome, overbroad, harassing, not reasonably calculated to lead to admissible evidence. Without waiving said objection, please see attached in Plaintiffs' possession. 9. Objection, unduly burdensome, overbroad, harassing, not reasonably calculated to lead to admissible evidence. Without waiving said objection, please see attached in Plaintiffs' possession. 10. Objection, overbroad, not narrowly tailored, compound, duplicative, ambiguous. harassing. Without waiving said objection, please see attached in Plaintiffs' possession. 11. Please see attached our public adjuster estimate. 12. Please see attached. 13. Objection, duplicative,overbroad, not narrowly tailored, ambiguous, not reasonably calculated to lead to admissible evidence. Without waiving said objection, please see attached in Plaintiffs' possession. 14. Please see attached in Plaintiffs' possession. 15. Objection, not narrowlytailored in time and scope, harassing, unduly burdensome, overbroad, harassing, not reasonably calculated to lead to admissible evidence. Withoutwaiving said objection, none in Plaintiffs' possession other than that which was provided in connection with the instant claim, and as such, please see attached in Plaintiffs' possession. 16. Please see response to number 15. 17. Please see response to number 15. 18. Objection, unduly burdensome, harassing, duplicative. Without waiving said objection, please see attached as to the instant claim. 19.See response to number 15. 20. See response to number 15, otherwise, none in Plaintiffs possession relative to the Hurricane Irma claim. However, Gulfstream was Plaintiffs' insurance company during and for the Hurricane Irma loss and has those documents. 21. Please see attached. 22.Objection, unduly burdensome, harassing, not reasonably calculated to lead to admissible evidence. 23. Please see attached. 24. Please see attached plumbers' receipts and documents from Entrusted, the company that completed remediation in connection with the subject loss 25.Objection,harassing, not reasonably calculated to lead to admissible evidence. 26. Objection, unduly burdensome, harassing, not reasonably calculated to lead to admissible evidence. Without waiving said objection, none in Plaintiffs' possession. 27.See response to number 20. 28. See attached. CERTIFICATE OF SERVICE I HEREBY CERT]FY that a true and correct copy of the foregoing was served via email delivery, upon: SER]C J. FALLON, ESQUIRE Gulfstream Property & Casualty Ins. Co., Attorneys for Defendant, 1401 NW 136h Avenue, Suite 200, Sunrise, FL 33323 on this 27th day of May, 2021. The Glassman Legal Group Attorneysfor Plaintiffs 2200 N. Commerce Parkway, Ste. 105 Fort Lauderdale, Florida 33326 Telephone No.: (954) 915-8800 Facsimile: (954) 915-8900 Email: lee@Ieeglassman.com By: /s/ Monica E. McWilliams LEE D. GLASSMAN, ESQ. FLORIDA BAR NO.: 0999954 MONICA E MCWILLIAMS, ESQ. FLORIDA BAR NO.: 105385