Preview
Filing # 130834460 E-Filed 07/16/2021 03:54:40 PM
IN
THE
CIRCUIT COURT OF THE
17TH
JUDICIAL CIRCUIT, IN AND FOR BROWARD
COUNTY, FLORIDA
Case No. CACE 21-007598
STEVE MESA AND MARIA MESA,
Plaintiffs,
VS.
HERITAGE PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
DEFENDANT'SRESPONSE TO PLAINTIFFS' FIRST REQUEST FOR PRODUCTION
COMES
NOW,
the
Defendant,
HERITAGE
PROPERTY
&
CASUALTY
INSURANCE COMPANY ("Defendant"), by and through their undersigned counsel and
pursuant to the Florida Rules of Civil Procedure, files this Response to the Plaintiffs Request
for Production as follows:
OBJECTIONS TO DEFINITIONSAND INSTRUCTIONS
Defendant objects to Plaintiffs instructionsand definitions to the extent they invade
the work product, claim file, or attorney/client privilege. Defendant further objects to the
extent that the instructions and definitions seek information from persons or entities not
parties to this lawsuit. Finally, Defendant objects to Plaintiffsinstructionsand definitions to
the extent that same impose greater burdens than those set forth in the Florida Rules of
Civil Procedure.
PRODUCTION REQUESTS
1. See the attached policy.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/16/2021 03:54:40 PM.****
2. Objection, vague, ambiguous, overbroad, not reasonably calculated to lead to the
discoveryof admissible evidence, work product and claim file privilege.
3. Objection, vague, ambiguous, overbroad, not reasonably calculated to lead to the
discovery of admissible evidence, work product and claim file privilege. Subject to
and without waiving the foregoing objections, see the attached non-privileged
documents. See also Defendant's Privilege Log filed under separate cover.
4. See attached.
5. See attached.
6. None.
7. Objection, vague, ambiguous, overbroad, not reasonably calculated to lead to the
discovery of admissible evidence, work product and claim file privilege. Subject to
and without waiving the foregoing objections, see the attached recorded statement
of PlaintiffSteve Mesa taken on or about November 6,2020 and the additional non-
privileged documents. See also Defendant's Privilege Log filed under separate
cover.
8. See attached.
9. None.
10. Objection, vague, ambiguous, overbroad, not reasonably calculated to lead to the
discovery of admissible evidence, work product and claim file privilege. Subject to
and without waiving the foregoing objections, see the attached non-privileged
documents. See also Defendant's Privilege Log filed under separate cover.
11. See attached.
12. Objection, vague, ambiguous, overbroad, not reasonably calculated to lead to the
discovery of admissible evidence, work product and claim file privilege. Subject to
and without waiving the foregoing objections, see the attached recorded statement
of PlaintiffSteve Mesa taken on or about November 6,2020 and the additional non-
privileged documents. See also Defendant's Privilege Log filed under separate
cover.
13. Objection, vague, ambiguous, overbroad, not reasonably calculated to lead to the
discovery of admissible evidence, work product and claim file privilege. Subject to
and without waiving the foregoing objections, see the attached non-privileged
documents. See also Defendant's Privilege Log filed under separate cover.
14. Objection, vague, ambiguous, overbroad, irrelevant, not reasonably calculated to
lead to the discoveryof admissible evidence,work product and claim file privilege.
15. Objection, vague, ambiguous, overbroad, irrelevant, not reasonably calculated to
lead to the discoveryof admissible evidence, work product and claim file privilege.
16. Objection, vague, ambiguous, overbroad, irrelevant, not reasonably calculated to
lead to the discoveryof admissible evidence, work product and claim file privilege.
17. None.
18. None.
WE HEREBY CERTIFY that a copy of the foregoing was served via Florida Courts
E-Filing
Portal
to
Joanna
M.
Alemany,
Your Insurance
Attorney, PLLC, 2601 South Bayshore Drive, Suite 850, Coconut Grove, FL 33133,
305/444-5969,this 16h day of July, 2021.
By
/s/ Glenn H. Malin
GLENN H. MALIN
Florida Bar # 974595
PETERSON BERNARD
Attorneysfor Defendant
707 S.E. 3rd Avenue, Suite 500
Fort Lauderdale, Florida 33316
(954) 763-3200
(954) 728-9019 facsimile
GHM:maf
2876.36175
Preview
Filing # 130834460 E-Filed 07/16/2021 03:54:40 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA Case No. CACE 21-007598 STEVE MESA AND MARIA MESA, Plaintiffs, VS. HERITAGE PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. DEFENDANT'SRESPONSE TO PLAINTIFFS' FIRST REQUEST FOR PRODUCTION COMES NOW, the Defendant, HERITAGE PROPERTY & CASUALTY INSURANCE COMPANY ("Defendant"), by and through their undersigned counsel and pursuant to the Florida Rules of Civil Procedure, files this Response to the Plaintiffs Request for Production as follows: OBJECTIONS TO DEFINITIONSAND INSTRUCTIONS Defendant objects to Plaintiffs instructionsand definitions to the extent they invade the work product, claim file, or attorney/client privilege. Defendant further objects to the extent that the instructions and definitions seek information from persons or entities not parties to this lawsuit. Finally, Defendant objects to Plaintiffsinstructionsand definitions to the extent that same impose greater burdens than those set forth in the Florida Rules of Civil Procedure. PRODUCTION REQUESTS 1. See the attached policy. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/16/2021 03:54:40 PM.**** 2. Objection, vague, ambiguous, overbroad, not reasonably calculated to lead to the discoveryof admissible evidence, work product and claim file privilege. 3. Objection, vague, ambiguous, overbroad, not reasonably calculated to lead to the discovery of admissible evidence, work product and claim file privilege. Subject to and without waiving the foregoing objections, see the attached non-privileged documents. See also Defendant's Privilege Log filed under separate cover. 4. See attached. 5. See attached. 6. None. 7. Objection, vague, ambiguous, overbroad, not reasonably calculated to lead to the discovery of admissible evidence, work product and claim file privilege. Subject to and without waiving the foregoing objections, see the attached recorded statement of PlaintiffSteve Mesa taken on or about November 6,2020 and the additional non- privileged documents. See also Defendant's Privilege Log filed under separate cover. 8. See attached. 9. None. 10. Objection, vague, ambiguous, overbroad, not reasonably calculated to lead to the discovery of admissible evidence, work product and claim file privilege. Subject to and without waiving the foregoing objections, see the attached non-privileged documents. See also Defendant's Privilege Log filed under separate cover. 11. See attached. 12. Objection, vague, ambiguous, overbroad, not reasonably calculated to lead to the discovery of admissible evidence, work product and claim file privilege. Subject to and without waiving the foregoing objections, see the attached recorded statement of PlaintiffSteve Mesa taken on or about November 6,2020 and the additional non- privileged documents. See also Defendant's Privilege Log filed under separate cover. 13. Objection, vague, ambiguous, overbroad, not reasonably calculated to lead to the discovery of admissible evidence, work product and claim file privilege. Subject to and without waiving the foregoing objections, see the attached non-privileged documents. See also Defendant's Privilege Log filed under separate cover. 14. Objection, vague, ambiguous, overbroad, irrelevant, not reasonably calculated to lead to the discoveryof admissible evidence,work product and claim file privilege. 15. Objection, vague, ambiguous, overbroad, irrelevant, not reasonably calculated to lead to the discoveryof admissible evidence, work product and claim file privilege. 16. Objection, vague, ambiguous, overbroad, irrelevant, not reasonably calculated to lead to the discoveryof admissible evidence, work product and claim file privilege. 17. None. 18. None. WE HEREBY CERTIFY that a copy of the foregoing was served via Florida Courts E-Filing Portal to Joanna M. Alemany, Your Insurance Attorney, PLLC, 2601 South Bayshore Drive, Suite 850, Coconut Grove, FL 33133, 305/444-5969,this 16h day of July, 2021. By /s/ Glenn H. Malin GLENN H. MALIN Florida Bar # 974595 PETERSON BERNARD Attorneysfor Defendant 707 S.E. 3rd Avenue, Suite 500 Fort Lauderdale, Florida 33316 (954) 763-3200 (954) 728-9019 facsimile GHM:maf 2876.36175