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Filing # 144947065 E-Filed 03/02/2022 05:21:27 PM
IN THE CIRCUIT COURT OF THE
15TH JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
PACITA JAYE, CASE NO.: 50-2021-CA-005222-XXXX-MB
Petitioner,
v.
CASTLE KEY INDEMNITY COMPANY,
Respondent.
/
PETITIONER’S RESPONSE TO DEFENDANT’S REQUEST FOR PRODUCTION
COME NOW the Petitioner, PACITA JAYE, by and through undersigned counsel, hereby
files the attached Responses to First Request For Production propounded by Respondent, pursuant to
Rule 1.350 of the Florida Rules of Civil Procedure, and states that the Answers by Petitioner, have been
served upon the Respondent.
DOCUMENTS TO BE PRODUCED
PRELIMINARY OBJECTION
Objection is made to any definitionsand instructions accompanying this discovery request
in that they create ambiguity, are vague, overbroad, unduly burdensome, onerous, and attempt to
create duties in excess of those provided by the Florida Rules of Civil Procedure. To the extent
that the instructions, definitions, questions and requests attempt to impose a duty to supplement
they are objected to as burdensome, onerous and violative of Rule 1.280(e) of the Florida Rules of
Civil Procedure.
Objection is made that these responses are made solely for the purpose of this litigation.
These responses represent efforts to respond to written discovery based on the information
presently known. There may exist further information responsive to this discovery that is not
within this responding party’s present knowledge or analysis, and the responses below do not
constitute an admission or presentation of additional information or waiver of the any rights or
objections. The fact that the responding party answered all or part of any request is not intended
as, nor should it be construed to be, a waiver of all or any part of any objections to the requests
presented by Defendant.
1. All written communications (including e-mails and text messages) between Petitioner, or
Petitioner’s agents, and Castle Key with regard to the Loss and/or Claim.
RESPONSE:
*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 03/02/2022 05:21:27 PM ***Objection, overbroad, not limited in time or scope, unduly burdensome insofar same is
equally available to respondent as a drafter/party to the communication(s) and, in that
same respect, not reasonably calculated to lead to the discovery of admissible evidence.
Please see attached documents in Petitioner’s possession.
All documents which memorialize any communications, written or oral, between
Petitioner, or Petitioner’s agents, and Castle Key with regard to the Loss and/or Claim.
RESPONSE:
Objection, overbroad, not limited in time or scope, unduly burdensome insofar same is
equally available to respondent as a drafter/party to the communication(s) and, in that
same respect, not reasonably calculated to lead to the discovery of admissible evidence.
Without waiving the objectionl, see copies of documents in Petitioner’s possession
attached hereto.
All written communications (including e-mails and text messages) between Petitioner and
Petitioner’ agents that relate to the Loss and/or Claim, excluding any communications
between Petitioner and Petitioner’s attorney(s).
RESPONSE:
Objection, overbroad, vague and ambiguous, cumulative, overbroad, not limited scope,
unduly burdensome, calls for attorneys’ mental impressions as to what documents (if
any) not reasonably calculated to lead to the discovery of admissible evidence. Objection
is also made to the extent it seeks information protected by the work product, consulting
expert, potential expert, investigative, party communication, and attorney-client
privileges.
All written communications (including e-mails and text messages) between Petitioner, or
Petitioner’s agents, and third parties with regard to the Loss and/or Claim, including but not
limited to any vendors who provided services with regard to the Loss and/or Claim.
RESPONSE:
Objection, overbroad, vague and ambiguous, cumulative, overbroad, not limited scope,
unduly burdensome, calls for attorneys’ mental impressions and not reasonably
calculated to lead to the discovery of admissible evidence. Objection is also made to the
extent it seeks information protected by the work product, consulting expert, potential
expert, investigative, party communication, and attorney-client privileges. Without
waiving the objectionl, see copies of documents in Petitioner’s possession attached hereto.All invoices, receipts, contracts, statements, bills, canceled checks, and/or other
documentation which relate and/or pertain to the damage which Petitioner alleges
occurred at the Property as a result of the Loss.
RESPONSE:
Objection, vague and ambiguous, unduly burdensome, overbroad as to “other
documentation,” cumulative, calls for attorney’s mental impressions, and not reasonably
calculated to lead to the discovery of admissible evidence. Objection is also made to the
extent it seeks information protected by the work product, consulting expert, potential
expert, investigative, party communication, and attorney-client privileges. Without
waiving the objection, please see documents in Petitioner’s possession attached hereto.
All documentation memorializing verbal remarks of witnesses with knowledge of
Petitioner’s allegations in the Complaint and/or damage to the Property, including but not
limited to any public adjuster or loss consultant.
RESPONSE:
None.
All claim forms, proofs of loss, and/or other documentation prepared for and/or submitted to
Castle Key and/or its agents regarding the Loss and/or the Claim prior to the filing of this
litigation.
RESPONSE:
Objection, unduly burdensome insofar requested dosumentation is equally available to
respondent as a party to the communication(s) and, in that same respect, not reasonably
calculated to lead to the discovery of admissible evidence. Without waiving the objection,
none.
All documents, including, but not limited to, invoices and receipts, relating to the
mitigation of damage to the Property following the Loss.
RESPONSE:
Objection, overbroad, not limited in time or scope, unduly burdensome, calls for
attorneys’ mental impressions. Moreover, request may seek irrelevant/immaterial
information insofar it seeks information regarding “damage” concerning subsequent,
potential loss(ess) of a different nature/kind/type than alleged in Petitioner’s Complaint
and/or unrelated to the loss, and in that same respect, request is overbroad, not limited in
scope, unduly burdensome and not reasonably calculated to lead to the discovery of
admissible evidence. Lastly, objection is also made to the extent request seeks information
protected by the work product, consulting expert, potential expert, investigative and
party communication privileges. Without waiving the objection, all photographs in
Petitioner’s possession are being produced herein.10.
12.
All documents, including, but not limited to, invoices and receipts, relating to any repairs to
the Property following the Loss.
RESPONSE:
Objection, overbroad, cumulative, vague and ambiguous insofar request fails to specify
whether it seeks information concerning any/all repairs following the loss without
limitation or those related to the loss; and, in that same respect, unduly burdensome, may
seek irrelevant/immaterial information, not limited in scope, and not reasonably
calculated to lead to the discovery of admissible evidence. Objection is also made to the
extent request seeks information protected by the work product, consulting expert,
potential expert, investigative and party communication privileges. Without waiving the
objection, see documents in Petitioner’s possession attached hereto.
All documents, including, but not limited to photographs, which depict or otherwise
evidence the presence of water at the Property in relation to the Loss.
RESPONSE:
Objection, overbroad, vague and ambiguous, cumulative, not limited scope, unduly
burdensome, and not reasonably calculated to lead to the discovery of admissible
evidence. Objection is also made to the extent request seeks information protected by the
work product, consulting expert, potential expert, investigative, party communication
privileges. Without waiving the objection, see photographs in Petitioner’s possession
attached hereto.
All pictures, videos, or depictions in any other media showing repairs and/or
improvements made to the Property following the Loss.
RESPONSE:
Objection, overbroad, cumulative, vague and ambiguous insofar request fails to specify
whether it seeks information concerning any/all repairs and/or improvements following
the loss without limitation or those related to the loss; and, in that same respect, unduly
burdensome, may seek irrelevant/immaterial information, not limited in scope, and not
reasonably calculated to lead to the discovery of admissible evidence. Objection is also
made to the extent request seeks information protected by the work product, consulting
expert, potential expert, investigative and party communication privileges. Without
waiving the objection, see documents in Petitioner’s possession attached hereto.
All pictures, videos, or depictions in any other media showing repairs and/or
improvements made to the Property in the five years preceding the Loss.
RESPONSE:
None.13.
14.
15.
16.
17.
All documents relating to or reflecting criticisms of Castle Key’s actions with regard to the
Loss and/or subject matter of this lawsuit.
RESPONSE:
Objection, vague and ambiguous as to “criticisms of [Respondent’s] actions” to the extent
it does not specify said any action toward which any potential “criticism” would relate,
overbroad, unduly burdensome, harassing, seeks irrelevant/immaterial information
insofar the requested is necessarily unrelated to any element of the claim nor could it ever
raise an inference as to the existence/non-existence of any material fact, and not
reasonably calculated to lead to the discovery of admissible evidence.
All documents identified in Petitioner’s responses to Castle Key’s Interrogatories served
contemporaneously with this First Request for Production.
RESPONSE:
Objection, overbroad, seeks mental impressions of attorney, calls for legal conclusion,
and seeks to invade the consulting expert, investigative, party communication, work
product and attorney-client privileges.
All purchase documents, warranties, invoices, contracts, assignments of benefits,
receipts, inspection reports, estimates, and appraisals created by contractors, companies,
and/or persons who have performed repairs, inspections, estimates, appraisals, or
proposals for any repairs to the Property from January 1, 2015 to the present.
RESPONSE:
Objection, overbroad, cumulative, vague and ambiguous insofar request fails to specify
whether it seeks information concerning any/all repairs following the loss without
limitation or those related to the loss; and, in that same respect, unduly burdensome, may
seek irrelevant/immaterial information, not limited in scope, and not reasonably
calculated to lead to the discovery of admissible evidence. Without waiving the objection,
see documents in Petitioner’s possession attached hereto.
All documents relating to the rent of the subject property between January 1, 2015 to
present time, including but not limited to, rental agreements, invoices, receipts and evidence of
rental payments.
RESPONSE:
None.
All documents relating to any claims made against anyone other than Castle Key for the
damage resulting from the Loss and/or claimed by Petitioner in this lawsuit.
RESPONSE:18.
20.
21.
22.
None.
All documents including, but not limited to, contracts, invoices, estimates, and/or reports, from
any vendors hired by Petitioner or Petitioner’s agents for any purpose related to the Loss
and/or Claim.
RESPONSE:
Objection, overbroad, vague and ambiguous, cumulative, duplicative, overbroad, unduly
burdensome, and not reasonably calculated to lead to the discovery of admissible evidence.
Objection is also made to the extent it seeks information protected by the work product
and attorney-client privileges. Without waiving the objection, documents in Petitioner’s
possession attached hereto.
All documents reflecting an assignment of benefits relating to damage Petitioner alleges
resulted from the Loss.
RESPONSE:
None to Petititoner’s knowledge.
All documents including, but not limited to, proofs of loss, public adjuster reports,
inspection reports, invoices for repairs, estimates for repairs, photographs, and proof of
payment by the insurance company pertaining to any other insurance claims made on the
Property in the past five years, other than this Loss.
RESPONSE:
Objection, overbroad, seeks mental impressions of attorney, calls for legal conclusion, and
seeks to invade the consulting expert, investigative, party communication, work product
and attorney-client privileges. Without waiving the objection, see response to No. 16.
All applications, insurance policies, files, records, letters, notes, and/or other written
communications which pertain to the Loss.
RESPONSE:
Objection, overbroad, vague and ambiguous, unduly burdensome, and not reasonably
calculated to lead to the discovery of admissible evidence. Moreover, may seek
information protected by the work product, consulting expert, potential expert,
investigative, party communication, and attorney-client privileges. Lastly, this request
constitutes a "fishing expedition" and fails to describe the items sought with reasonable
particularity as required by Rule 1.350(b) of the Florida Rule of Civil Procedure.
Without waiving the objection, see documents in Petitioner’s possession attached hereto.
Any and all electronically stored information/content/data that depicts the Property after the
Loss occurred, including pictures and video saved in cloud storage or on social media, in
native format, ie., the format in which the document or record was created, or in which
the originating application stores records, including, but not limited to, drafts of documents
6which were subsequently modified.
RESPONSE:
Objection, overbroad, not limited in time or scope, unduly burdensome, irrelevant,
immaterial, vague and ambiguous, cumulative, duplicative, and not reasonably calculated
to lead to the discovery of admissible evidence. Without waiving the objection, Petitioner
has no such documents in her possession.
23. Any and all electronically stored information/content/data that depicts the Property in the two
years prior to the Loss, including pictures and video saved in cloud storage or on social
media, in native format, ie., the format in which the document or record was created, or in
which the originating application stores records, including, but not limited to, drafts of
documents which were subsequently modified.
RESPONSE:
Objection, overbroad, not limited in time or scope, unduly burdensome, irrelevant,
immaterial, vague and ambiguous, cumulative, duplicative, and not reasonably calculated
to lead to the discovery of admissible evidence. Without waiving the objection, Petitioner
has no such documents in her possession.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing instrument has been
electronically filed and sent via electronic mail by the Court using the Florida Courts E-Filing Portal
and the Portal was used as a means of service upon all counsel of record.
THE FARBER LAW FIRM
Attorney for Petitioner
2199 Ponce De Leon Blvd., Suite 301
Coral Gables, FL 33134
Telephone: (305) 774-0134
Facsimile: (305) 774-0135
Primary: dfarber@dfarberlaw.com
Secondary: Sebastian@dfarberalw.com
maria@dfarberlaw.com
By: /s/ David S. Farber
David S. Farber
FBN: 0370230
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Filing # 144947065 E-Filed 03/02/2022 05:21:27 PM IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA PACITA JAYE, CASE NO.: 50-2021-CA-005222-XXXX-MB Petitioner, v. CASTLE KEY INDEMNITY COMPANY, Respondent. / PETITIONER’S RESPONSE TO DEFENDANT’S REQUEST FOR PRODUCTION COME NOW the Petitioner, PACITA JAYE, by and through undersigned counsel, hereby files the attached Responses to First Request For Production propounded by Respondent, pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, and states that the Answers by Petitioner, have been served upon the Respondent. DOCUMENTS TO BE PRODUCED PRELIMINARY OBJECTION Objection is made to any definitionsand instructions accompanying this discovery request in that they create ambiguity, are vague, overbroad, unduly burdensome, onerous, and attempt to create duties in excess of those provided by the Florida Rules of Civil Procedure. To the extent that the instructions, definitions, questions and requests attempt to impose a duty to supplement they are objected to as burdensome, onerous and violative of Rule 1.280(e) of the Florida Rules of Civil Procedure. Objection is made that these responses are made solely for the purpose of this litigation. These responses represent efforts to respond to written discovery based on the information presently known. There may exist further information responsive to this discovery that is not within this responding party’s present knowledge or analysis, and the responses below do not constitute an admission or presentation of additional information or waiver of the any rights or objections. The fact that the responding party answered all or part of any request is not intended as, nor should it be construed to be, a waiver of all or any part of any objections to the requests presented by Defendant. 1. All written communications (including e-mails and text messages) between Petitioner, or Petitioner’s agents, and Castle Key with regard to the Loss and/or Claim. RESPONSE: *** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 03/02/2022 05:21:27 PM ***Objection, overbroad, not limited in time or scope, unduly burdensome insofar same is equally available to respondent as a drafter/party to the communication(s) and, in that same respect, not reasonably calculated to lead to the discovery of admissible evidence. Please see attached documents in Petitioner’s possession. All documents which memorialize any communications, written or oral, between Petitioner, or Petitioner’s agents, and Castle Key with regard to the Loss and/or Claim. RESPONSE: Objection, overbroad, not limited in time or scope, unduly burdensome insofar same is equally available to respondent as a drafter/party to the communication(s) and, in that same respect, not reasonably calculated to lead to the discovery of admissible evidence. Without waiving the objectionl, see copies of documents in Petitioner’s possession attached hereto. All written communications (including e-mails and text messages) between Petitioner and Petitioner’ agents that relate to the Loss and/or Claim, excluding any communications between Petitioner and Petitioner’s attorney(s). RESPONSE: Objection, overbroad, vague and ambiguous, cumulative, overbroad, not limited scope, unduly burdensome, calls for attorneys’ mental impressions as to what documents (if any) not reasonably calculated to lead to the discovery of admissible evidence. Objection is also made to the extent it seeks information protected by the work product, consulting expert, potential expert, investigative, party communication, and attorney-client privileges. All written communications (including e-mails and text messages) between Petitioner, or Petitioner’s agents, and third parties with regard to the Loss and/or Claim, including but not limited to any vendors who provided services with regard to the Loss and/or Claim. RESPONSE: Objection, overbroad, vague and ambiguous, cumulative, overbroad, not limited scope, unduly burdensome, calls for attorneys’ mental impressions and not reasonably calculated to lead to the discovery of admissible evidence. Objection is also made to the extent it seeks information protected by the work product, consulting expert, potential expert, investigative, party communication, and attorney-client privileges. Without waiving the objectionl, see copies of documents in Petitioner’s possession attached hereto.All invoices, receipts, contracts, statements, bills, canceled checks, and/or other documentation which relate and/or pertain to the damage which Petitioner alleges occurred at the Property as a result of the Loss. RESPONSE: Objection, vague and ambiguous, unduly burdensome, overbroad as to “other documentation,” cumulative, calls for attorney’s mental impressions, and not reasonably calculated to lead to the discovery of admissible evidence. Objection is also made to the extent it seeks information protected by the work product, consulting expert, potential expert, investigative, party communication, and attorney-client privileges. Without waiving the objection, please see documents in Petitioner’s possession attached hereto. All documentation memorializing verbal remarks of witnesses with knowledge of Petitioner’s allegations in the Complaint and/or damage to the Property, including but not limited to any public adjuster or loss consultant. RESPONSE: None. All claim forms, proofs of loss, and/or other documentation prepared for and/or submitted to Castle Key and/or its agents regarding the Loss and/or the Claim prior to the filing of this litigation. RESPONSE: Objection, unduly burdensome insofar requested dosumentation is equally available to respondent as a party to the communication(s) and, in that same respect, not reasonably calculated to lead to the discovery of admissible evidence. Without waiving the objection, none. All documents, including, but not limited to, invoices and receipts, relating to the mitigation of damage to the Property following the Loss. RESPONSE: Objection, overbroad, not limited in time or scope, unduly burdensome, calls for attorneys’ mental impressions. Moreover, request may seek irrelevant/immaterial information insofar it seeks information regarding “damage” concerning subsequent, potential loss(ess) of a different nature/kind/type than alleged in Petitioner’s Complaint and/or unrelated to the loss, and in that same respect, request is overbroad, not limited in scope, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Lastly, objection is also made to the extent request seeks information protected by the work product, consulting expert, potential expert, investigative and party communication privileges. Without waiving the objection, all photographs in Petitioner’s possession are being produced herein.10. 12. All documents, including, but not limited to, invoices and receipts, relating to any repairs to the Property following the Loss. RESPONSE: Objection, overbroad, cumulative, vague and ambiguous insofar request fails to specify whether it seeks information concerning any/all repairs following the loss without limitation or those related to the loss; and, in that same respect, unduly burdensome, may seek irrelevant/immaterial information, not limited in scope, and not reasonably calculated to lead to the discovery of admissible evidence. Objection is also made to the extent request seeks information protected by the work product, consulting expert, potential expert, investigative and party communication privileges. Without waiving the objection, see documents in Petitioner’s possession attached hereto. All documents, including, but not limited to photographs, which depict or otherwise evidence the presence of water at the Property in relation to the Loss. RESPONSE: Objection, overbroad, vague and ambiguous, cumulative, not limited scope, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. Objection is also made to the extent request seeks information protected by the work product, consulting expert, potential expert, investigative, party communication privileges. Without waiving the objection, see photographs in Petitioner’s possession attached hereto. All pictures, videos, or depictions in any other media showing repairs and/or improvements made to the Property following the Loss. RESPONSE: Objection, overbroad, cumulative, vague and ambiguous insofar request fails to specify whether it seeks information concerning any/all repairs and/or improvements following the loss without limitation or those related to the loss; and, in that same respect, unduly burdensome, may seek irrelevant/immaterial information, not limited in scope, and not reasonably calculated to lead to the discovery of admissible evidence. Objection is also made to the extent request seeks information protected by the work product, consulting expert, potential expert, investigative and party communication privileges. Without waiving the objection, see documents in Petitioner’s possession attached hereto. All pictures, videos, or depictions in any other media showing repairs and/or improvements made to the Property in the five years preceding the Loss. RESPONSE: None.13. 14. 15. 16. 17. All documents relating to or reflecting criticisms of Castle Key’s actions with regard to the Loss and/or subject matter of this lawsuit. RESPONSE: Objection, vague and ambiguous as to “criticisms of [Respondent’s] actions” to the extent it does not specify said any action toward which any potential “criticism” would relate, overbroad, unduly burdensome, harassing, seeks irrelevant/immaterial information insofar the requested is necessarily unrelated to any element of the claim nor could it ever raise an inference as to the existence/non-existence of any material fact, and not reasonably calculated to lead to the discovery of admissible evidence. All documents identified in Petitioner’s responses to Castle Key’s Interrogatories served contemporaneously with this First Request for Production. RESPONSE: Objection, overbroad, seeks mental impressions of attorney, calls for legal conclusion, and seeks to invade the consulting expert, investigative, party communication, work product and attorney-client privileges. All purchase documents, warranties, invoices, contracts, assignments of benefits, receipts, inspection reports, estimates, and appraisals created by contractors, companies, and/or persons who have performed repairs, inspections, estimates, appraisals, or proposals for any repairs to the Property from January 1, 2015 to the present. RESPONSE: Objection, overbroad, cumulative, vague and ambiguous insofar request fails to specify whether it seeks information concerning any/all repairs following the loss without limitation or those related to the loss; and, in that same respect, unduly burdensome, may seek irrelevant/immaterial information, not limited in scope, and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving the objection, see documents in Petitioner’s possession attached hereto. All documents relating to the rent of the subject property between January 1, 2015 to present time, including but not limited to, rental agreements, invoices, receipts and evidence of rental payments. RESPONSE: None. All documents relating to any claims made against anyone other than Castle Key for the damage resulting from the Loss and/or claimed by Petitioner in this lawsuit. RESPONSE:18. 20. 21. 22. None. All documents including, but not limited to, contracts, invoices, estimates, and/or reports, from any vendors hired by Petitioner or Petitioner’s agents for any purpose related to the Loss and/or Claim. RESPONSE: Objection, overbroad, vague and ambiguous, cumulative, duplicative, overbroad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. Objection is also made to the extent it seeks information protected by the work product and attorney-client privileges. Without waiving the objection, documents in Petitioner’s possession attached hereto. All documents reflecting an assignment of benefits relating to damage Petitioner alleges resulted from the Loss. RESPONSE: None to Petititoner’s knowledge. All documents including, but not limited to, proofs of loss, public adjuster reports, inspection reports, invoices for repairs, estimates for repairs, photographs, and proof of payment by the insurance company pertaining to any other insurance claims made on the Property in the past five years, other than this Loss. RESPONSE: Objection, overbroad, seeks mental impressions of attorney, calls for legal conclusion, and seeks to invade the consulting expert, investigative, party communication, work product and attorney-client privileges. Without waiving the objection, see response to No. 16. All applications, insurance policies, files, records, letters, notes, and/or other written communications which pertain to the Loss. RESPONSE: Objection, overbroad, vague and ambiguous, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. Moreover, may seek information protected by the work product, consulting expert, potential expert, investigative, party communication, and attorney-client privileges. Lastly, this request constitutes a "fishing expedition" and fails to describe the items sought with reasonable particularity as required by Rule 1.350(b) of the Florida Rule of Civil Procedure. Without waiving the objection, see documents in Petitioner’s possession attached hereto. Any and all electronically stored information/content/data that depicts the Property after the Loss occurred, including pictures and video saved in cloud storage or on social media, in native format, ie., the format in which the document or record was created, or in which the originating application stores records, including, but not limited to, drafts of documents 6which were subsequently modified. RESPONSE: Objection, overbroad, not limited in time or scope, unduly burdensome, irrelevant, immaterial, vague and ambiguous, cumulative, duplicative, and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving the objection, Petitioner has no such documents in her possession. 23. Any and all electronically stored information/content/data that depicts the Property in the two years prior to the Loss, including pictures and video saved in cloud storage or on social media, in native format, ie., the format in which the document or record was created, or in which the originating application stores records, including, but not limited to, drafts of documents which were subsequently modified. RESPONSE: Objection, overbroad, not limited in time or scope, unduly burdensome, irrelevant, immaterial, vague and ambiguous, cumulative, duplicative, and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving the objection, Petitioner has no such documents in her possession. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing instrument has been electronically filed and sent via electronic mail by the Court using the Florida Courts E-Filing Portal and the Portal was used as a means of service upon all counsel of record. THE FARBER LAW FIRM Attorney for Petitioner 2199 Ponce De Leon Blvd., Suite 301 Coral Gables, FL 33134 Telephone: (305) 774-0134 Facsimile: (305) 774-0135 Primary: dfarber@dfarberlaw.com Secondary: Sebastian@dfarberalw.com maria@dfarberlaw.com By: /s/ David S. Farber David S. Farber FBN: 0370230