Preview
Filing # 132532433 E-Filed 08/12/2021 10:39:04 AM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE-21-007713 (08)
VICKI KATCHMERE,
Plaintiff.
V
MEADOWBROOK LAKES VIEW
CONDOMINIUM ASSOCIATION"A",INC.,
a Florida Not-For-Profit Corporation, and
FRANCISCO COLET,
Defendants.
I
FRANCISCO COLET'S FIRST REOUEST FOR PRODUCTION TO
MEADOWBROOK LAKES VIEW CONDOMINIUMASSOCIATION "A". INC.
Pursuant to Florida Rules of Civil Procedure 1.280 and 1.350, Defendant, FRANCISCO
COLET ("Colet"), requests that Defendant, MEADOWBROOK LAKES VIEW
CONDOMINIUM ASSOCIATION "A", INC. ("Meadowbrook"), produces for inspection and
copying the documents requested herein in accordance with the Florida Rules of Civil Procedure
and all applicable rules, definitions, and instructions set forth below within thirty (30) days after
service of the request.
DEFINITIONS
In addition to the definitions set forth in Florida Rules of Civil Procedure 1.280 and 1.350,
the following definitions shall apply to these documents:
1. "Complaint" means the Complaint in the above-captioned action filed in the Seventeenth
Judicial Circuit.
2. "Underlying Action" and "Lawsuit" means the above-captioned action filed in the
Seventeenth Judicial Circuit.
VINCENT F. VACCARELLA, P.A.
888 E. LAS OLAS BLVD, SUITE 700, FORT LAUDERDALE, FL 33301
TELEPHONE 305-932-4044 FACSIMILE 305-932-4990
-
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/13/2021 09:59:49 AM.****
".' ".'
3. "And," "or," "each,' any" shall be construed as necessary in each case to make each
all,
request inclusive rather than exclusive. The singular form of a noun or pronoun shall be
considered to include within its meaning the plural form of the noun or pronoun so used,
and vice versa; the use of the masculine form of a pronoun shall be considered to include
also within the meaning the feminine form of the pronoun so used, and vice versa; the use
of either "and" or "or" shall be considered to include both "and" and "or"; and the use of
any tense of any verb shall be considered to include also within its meaning all other tenses
of the verb so used.
., C. ., C.
4. "Relating to, concerning, regarding," and "pertaining to" shall retain their plain
language meaning and shall also mean comprising, setting forth, identifying, recording,
summarizing,supporting, providing a basis for, digesting, commenting upon, describing,
reporting, listing, analyzing, studying, discussing, mentioning, or in any other way
reflecting, memorializing, or having to do with the subject matter identified in the request.
5. "Document" or "documents" shall mean any written, typed, printed, recorded, or graphic
matter, however produced or reproduced, of any type or descr*tion, regardless of origin
or location, including, without limitation: all correspondence, records, tables, charts,
analyses, graphs, schedules, reports, memoranda, notes, lists, calendar and diary entries,
letter (sent or received), telegrams, telexes, telefaxes, messages (including, but not limited
to reports of telephone conversations and conferences), complaints, claims, claim letters,
studies, books, periodicals, magazines, booklets, circulars, bulletins, instructions, papers,
files, minutes, other communications (including, but not limited to, inter and intra office
communications), questionnaires, contracts, memoranda or agreements, assignments,
licenses, ledgers, books of account, orders, invoices, statements, bills, checks, vouchers,
notebooks, receipts, acknowledgements,data processing cards, computer generatedmatter,
photographs, photographic negatives, phonograph records, tape recordings, wire
recordings, microfilm, microfiche, other mechanical or electronic recordings, transcripts
or logs of any such recordings, e-mails, word processing files, all other data compilations
from which information can be obtained or translated if necessary, and any other tangible
means of preserving thought or expression.
6. "Communication" shall mean any transfer or exchange between two or more persons of
any information whatsoever, by written or oral meanings, including but not limited to,
personal conversations, correspondence, telephone calls, telegrams, notes, facsimiles,
voice recordings, and electronic messages or e-mails. This definition includes all
communicationfor which you claim a privilege.
7. "Identify" shall mean:
a. When referring to a natural person, to state his or her full name, present or last
known business and home address, present or last known occupation, position, and
employer, and all relationships,if any, which he or she has had with plaintiff at any
time.
VINCENT F.
VACCARELLA, P.A.
888 E. LAS OLASBLVD, SUITE 700, FORT LAUDERDALE, FL 33301
TELEPHONE 305-932-4044 FACSIMILE 305-932-4990 -
2
b. When referring to a business entity, to state the full name and present or last known
office address or addresses of such business entity and to designate the type of
businessentity involved (such as a corporation, partnership, or limited liability
company);
c. When referring to a document, to identify its signer
signers, each person who in
or
any way participated in its preparation, each person or entity represented or
purported to be represented by each person identified as having signed or
participated in the preparation of the document, its type (e.g., letter, inter- or
intraofficememoranda, report, etc.), the title, heading, nature and substance of the
document with sufficient particularityto enable it to be identified, the address and
the person or persons for whom such was prepared, by whom it was received or for
whom it was addressed or copied, each person or entity represented or purported to
be represented by each person identified as an addressee or recipient, its title or
heading, and the present or last known location or custodian of the original of the
document (or, ifthat is unavailable,the most legible copy thereof). If any document
requested and identified was at any time in your possession or subject to its control,
but is no longer so, state what disposition was made of it and when and why and by
whom it was disposed;
d. As to any document of which identification is requested herein which is not
presently in your possession, or subject to your control, identify each person whom
you have reason to believe has or had knowledge of its contents, and each person
whom you have reason to believe received a copy thereof.
e. Whenever requested to identify a conversation, oral statement, communication,
meeting, or transaction, or whenever, in answering these interrogatories,you refer
to any of the foregoing, state the date and place thereof, whether by phone,
electronic correspondence, or in person, identify the person or persons who made
it, all persons present and, as to each, each person or entity represented or purported
to be represented, state the substance thereof, and identify each document which in
any way pertains to any such conversation, oral statement, communication,
meeting, or transaction.
8. "Refers to" or "relates to" mean evidencing,
constituting,reflecting, showing, comprising,
including, containing, describing, considering, discussing, regarding, setting forth,
studying, analyzing, commenting upon, recommending, alluding to, or mentioning, in
whole or in part.
9. "Person" shall mean any individual, corporation, proprietorship, partnership, trust,
association, or any other entity.
10. "Plaintiff' and "Katchmere" shall KATCHMERE, as well as her agents,
mean VICKI
employees, attorneys, officers, directors, consultants, representatives, parent, affiliates,
subsidiaries,or other persons acting or purporting to act on its behalf.
VINCENT F.
VACCARELLA, P.A.
888 E. LAS OLASBLVD, SUITE 700, FORT LAUDERDALE, FL 33301
TELEPHONE 305-932-4044 FACSIMILE 305-932-4990
-
3
11. "Colet" shall mean FRANCISCO COLET, as well as his agents, employees, attorneys,
officers, directors, consultants, representatives, parent, affiliates, subsidiaries, or other
persons acting or purporting to act on its behalf.
12. "Association" and "Meadowbrook" shall mean MEADOWBROOK LAKES VIEW
CONDOMINIUM ASSOCIATION "A", INC., as well as its agents,
employees, attorneys,
officers, directors, consultants, representatives, parent, affiliates, subsidiaries, or other
persons acting or purporting to act on its behalf.
13. "Property" shall mean the property commonly referred to the MeadowbrookLakes View
Condominium located in Broward County, Florida.
14. "Unit 107" shall mean the property owned by Plaintiff at the Property.
15. "Unit 108" shall mean the property owned by Colet at the Property.
INSTRUCTIONS
1. All objections to the production of documents requested shall be made in writing and
delivered to the office of Vincent F. Vaccarella, P.A., 888 East Las Olas Boulevard, Suite
700, Fort Lauderdale, Florida 33301, on or before the date set for production.
2. Ifthere is a claim ofprivilege with respect to any documentsrequested, Plaintiffis required
to provide a statement setting forth the basis for the claim of privilege in compliance with
Florida Rules of Civil Procedure 1.280 and 1.350.
3. All documentsare to be produced as they are kept in the usual course ofbusiness, including
any labels, file
markings, or similar identifying
features, or shall be organized and labeled
to correspond to the categories requested. If there are no documents responsive to a
particular request, Plaintiffshall state so in writing in response to that specific request.
4. Electronically stored information ("ESI") must be produced in PDF format with
corresponding load files containing the document's text and all available metadata.
5. Each request contemplates production of all documents in their entirety. If only a portion
of a document is responsive to one or more requests, the document shall be produced in its
entirety.
6. If there are no documents in response to any particular request, Plaintiff shall state so in
writing.
7. These requests are continuing and your response to these requests must be promptly
supplemented when appropriate or necessary.
VINCENT F.
VACCARELLA, P.A.
888 E. LAS OLAS BLVD, SUITE 700, FORT LAUDERDALE, FL 33301
TELEPHONE 305-932-4044 FACSIMILE 305-932-4990
-
4
DOCUMENTS REQUESTED
Document Request No. 1:
Any and all contracts, proposals, agreements, subcontracts, purchase orders, invoices,
estimates, repair costs, and bids relating to the alleged water intrusion and mold remediation to
Units 107 and 108 at the Property, including general conditions, addenda, supplements,
amendments, modifications, and revisions.
Document Request No. 2:
Any and all internal communicationrecords relating to the alleged water intrusion to Unit
107 at the Property (any correspondence, e-mails, and faxes whether handwritten, printed, in
electronic, or any other format).
Document Request No. 3:
Any and all communication records between Meadowbrook and Colet relating to the
alleged water intrusion to Unit 107 at the Property (any correspondence, e-mails, and faxes
whether handwritten, printed, in electronic, orany other format).
Document Reauest No. 4:
Any and all communication records among Plaintiff and Meadowbrook relating to the
alleged water intrusion to Unit 107 at the Property, including but not limited to the Association's
property manager (any correspondence, e-mails, and faxes whether handwritten, printed, in
electronic, or any other format).
Document Reauest No. 5:
Any and all communication records among Meadowbrookand any non-party or third-party
relating to the alleged water intrusion to Unit 107 at the Property (any correspondence, e-mails,
texts, and faxes whether handwritten, printed, in electronic, or any other format).
Document Reauest No. 6:
Any and all communicationrecords among Meadowbrook and its insurer relating to the
alleged water intrusion to Unit 107 at the Property (any correspondence, e-mails, and faxes
whether handwritten, printed, in electronic, or any other format).
Document Request No. 7:
and all evidence of payments made by Meadowbrook relating to any repairs for the
Any
alleged water intrusion and mold remediation at the Property, including but not limited to, invoices,
receipts, canceled checks, credit card, and wire transfers.
VINCENT F.
VACCARELLA, P.A.
888 E. LAS OLAS
BLVD, SUITE 700, FORT LAUDERDALE, FL 33301
TELEPHONE 305-932-4044 FACSIMILE 305-932-4990
-
5
Document Request No. 8:
Any and all photographs or videos in Meadowbrook's possession, control, or custody
depicting the alleged water intrusion and damages sustained to Unit 107 at the Property.
Document Request No. 9:
Any and all photographs or videos in Meadowbrook's possession, control, or custody
depicting the piping in the wall between Units 107 and 108 and the drainage system at the Property.
Document Request No. 10:
Any and all insurance policies in full force and effect on the date of the loss alleged in the
Complaint relating to Unit 107 at the Property, including but not limited to, declaration pages,
amendments, supplements, and other endorsements.
Document Request No. 11:
Any and all property loss forms relating to the alleged water intrusion and damages to Unit
107 at the Property.
Document Reauest No. 12:
Any and all inspections conducted by Plaintiff, Association, or any city, county, state, or
other governmental entity relating to the alleged water intrusion and damages to Unit 107 at the
Property.
Document Reauest No. 13:
Any and all shop drawings, plans specifications,surveys, charts, and engineering drawings
relating to Unit 107, the location of the drainage system, and the p*ing in the wall between Units
107 and 108 at the Property.
Document Reauest No. 14:
Any and all documents provided to any person expected to be called as an expert witness,
including but not limited to any oral or written report and any supporting data or information.
Document Request No. 15:
Any and all documentsprovided to any person expected to be called as a witness, including
but not limited to any oral or written report and any supporting data or information.
Document Request No. 16:
VINCENT F.VACCARELLA, P.A.
888 E. LAS OLAS BLVD, SUITE 700, FORT LAUDERDALE, FL 33301
TELEPHONE 305-932-4044 FACSIMILE 305-932-4990
-
6
Any and all warranties relating to the waterproofing, repairs, or renovations at Units 107
and 108.
Document Request No. 17:
Any and all documents evidencing the manufacturers ofthe drainage system and the piping
in the walls between Units 107 and 108 at the Property.
Document Request No. 18:
Any and all construction, maintenance, repairs, modifications, and alterations relating to
Units 107 and 108 at the Property within the previous three (3) years.
Document Request No. 19:
Any and all Board of Director Meetings where the Board discussed any issue relating to
Units 107 and 108.
Document Request No. 20:
Any and all Board of Director Meetings where the Board discussed any leak, water
intrusion, mold remediation, or repairs relating to the alleged water intrusion at Units 107 and 108
at the Property.
Document Request No. 21:
Any and all reports and test results of any leak detection test conducted by the Association.
VINCENT F. VACCARELLA, P.A.
Counsel for Francisco Colet
888 E. Las Olas Blvd, Suite 700
Fort Lauderdale, Florida 33301
Telephone: (305) 932-4044
Facsimile: (305) 932-4990
By: /s/ Dylan E. Goldberg
Vincent F. Vaccarella
Fla. Bar No. 017426
vincent@v-law.net
Dylan E. Goldberg
Fla. Bar No. 1015677
dgoldberg@v-law.net
VINCENT F.
VACCARELLA, P.A.
888 E. LAS OLAS BLVD, SUITE 700, FORT LAUDERDALE, FL 33301
TELEPHONE 305-932-4044 FACSIMILE 305-932-4990
-
7
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served this 12th
day of August, 2021 by the Florida Courts E-Filing Portal to Edward F. Holodak, Esq., Edward F.
Holodak, P.A., 7580 NW 5th Street, Suite 15125, Plantation, Florida 33317 (edward@ho-
lodakpa.com; com) and Scott R. Shapiro, Esq., Straley Otto, 2699 Stirling
Road, Suite C-207, Fort Lauderdale, Florida 33312 attor-
Respectfully submitted,
By: /s/Dylan E. Goldberg
Dylan E. Goldberg, Esq.
VINCENT F.
VACCARELLA, P.A.
888 E. LAS OLAS
BLVD, SUITE 700, FORT LAUDERDALE, FL 33301
TELEPHONE 305-932-4044 FACSIMILE 305-932-4990
-
8
Preview
Filing # 132532433 E-Filed 08/12/2021 10:39:04 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-21-007713 (08) VICKI KATCHMERE, Plaintiff. V MEADOWBROOK LAKES VIEW CONDOMINIUM ASSOCIATION"A",INC., a Florida Not-For-Profit Corporation, and FRANCISCO COLET, Defendants. I FRANCISCO COLET'S FIRST REOUEST FOR PRODUCTION TO MEADOWBROOK LAKES VIEW CONDOMINIUMASSOCIATION "A". INC. Pursuant to Florida Rules of Civil Procedure 1.280 and 1.350, Defendant, FRANCISCO COLET ("Colet"), requests that Defendant, MEADOWBROOK LAKES VIEW CONDOMINIUM ASSOCIATION "A", INC. ("Meadowbrook"), produces for inspection and copying the documents requested herein in accordance with the Florida Rules of Civil Procedure and all applicable rules, definitions, and instructions set forth below within thirty (30) days after service of the request. DEFINITIONS In addition to the definitions set forth in Florida Rules of Civil Procedure 1.280 and 1.350, the following definitions shall apply to these documents: 1. "Complaint" means the Complaint in the above-captioned action filed in the Seventeenth Judicial Circuit. 2. "Underlying Action" and "Lawsuit" means the above-captioned action filed in the Seventeenth Judicial Circuit. VINCENT F. VACCARELLA, P.A. 888 E. LAS OLAS BLVD, SUITE 700, FORT LAUDERDALE, FL 33301 TELEPHONE 305-932-4044 FACSIMILE 305-932-4990 - *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/13/2021 09:59:49 AM.**** ".' ".' 3. "And," "or," "each,' any" shall be construed as necessary in each case to make each all, request inclusive rather than exclusive. The singular form of a noun or pronoun shall be considered to include within its meaning the plural form of the noun or pronoun so used, and vice versa; the use of the masculine form of a pronoun shall be considered to include also within the meaning the feminine form of the pronoun so used, and vice versa; the use of either "and" or "or" shall be considered to include both "and" and "or"; and the use of any tense of any verb shall be considered to include also within its meaning all other tenses of the verb so used. ., C. ., C. 4. "Relating to, concerning, regarding," and "pertaining to" shall retain their plain language meaning and shall also mean comprising, setting forth, identifying, recording, summarizing,supporting, providing a basis for, digesting, commenting upon, describing, reporting, listing, analyzing, studying, discussing, mentioning, or in any other way reflecting, memorializing, or having to do with the subject matter identified in the request. 5. "Document" or "documents" shall mean any written, typed, printed, recorded, or graphic matter, however produced or reproduced, of any type or descr*tion, regardless of origin or location, including, without limitation: all correspondence, records, tables, charts, analyses, graphs, schedules, reports, memoranda, notes, lists, calendar and diary entries, letter (sent or received), telegrams, telexes, telefaxes, messages (including, but not limited to reports of telephone conversations and conferences), complaints, claims, claim letters, studies, books, periodicals, magazines, booklets, circulars, bulletins, instructions, papers, files, minutes, other communications (including, but not limited to, inter and intra office communications), questionnaires, contracts, memoranda or agreements, assignments, licenses, ledgers, books of account, orders, invoices, statements, bills, checks, vouchers, notebooks, receipts, acknowledgements,data processing cards, computer generatedmatter, photographs, photographic negatives, phonograph records, tape recordings, wire recordings, microfilm, microfiche, other mechanical or electronic recordings, transcripts or logs of any such recordings, e-mails, word processing files, all other data compilations from which information can be obtained or translated if necessary, and any other tangible means of preserving thought or expression. 6. "Communication" shall mean any transfer or exchange between two or more persons of any information whatsoever, by written or oral meanings, including but not limited to, personal conversations, correspondence, telephone calls, telegrams, notes, facsimiles, voice recordings, and electronic messages or e-mails. This definition includes all communicationfor which you claim a privilege. 7. "Identify" shall mean: a. When referring to a natural person, to state his or her full name, present or last known business and home address, present or last known occupation, position, and employer, and all relationships,if any, which he or she has had with plaintiff at any time. VINCENT F. VACCARELLA, P.A. 888 E. LAS OLASBLVD, SUITE 700, FORT LAUDERDALE, FL 33301 TELEPHONE 305-932-4044 FACSIMILE 305-932-4990 - 2 b. When referring to a business entity, to state the full name and present or last known office address or addresses of such business entity and to designate the type of businessentity involved (such as a corporation, partnership, or limited liability company); c. When referring to a document, to identify its signer signers, each person who in or any way participated in its preparation, each person or entity represented or purported to be represented by each person identified as having signed or participated in the preparation of the document, its type (e.g., letter, inter- or intraofficememoranda, report, etc.), the title, heading, nature and substance of the document with sufficient particularityto enable it to be identified, the address and the person or persons for whom such was prepared, by whom it was received or for whom it was addressed or copied, each person or entity represented or purported to be represented by each person identified as an addressee or recipient, its title or heading, and the present or last known location or custodian of the original of the document (or, ifthat is unavailable,the most legible copy thereof). If any document requested and identified was at any time in your possession or subject to its control, but is no longer so, state what disposition was made of it and when and why and by whom it was disposed; d. As to any document of which identification is requested herein which is not presently in your possession, or subject to your control, identify each person whom you have reason to believe has or had knowledge of its contents, and each person whom you have reason to believe received a copy thereof. e. Whenever requested to identify a conversation, oral statement, communication, meeting, or transaction, or whenever, in answering these interrogatories,you refer to any of the foregoing, state the date and place thereof, whether by phone, electronic correspondence, or in person, identify the person or persons who made it, all persons present and, as to each, each person or entity represented or purported to be represented, state the substance thereof, and identify each document which in any way pertains to any such conversation, oral statement, communication, meeting, or transaction. 8. "Refers to" or "relates to" mean evidencing, constituting,reflecting, showing, comprising, including, containing, describing, considering, discussing, regarding, setting forth, studying, analyzing, commenting upon, recommending, alluding to, or mentioning, in whole or in part. 9. "Person" shall mean any individual, corporation, proprietorship, partnership, trust, association, or any other entity. 10. "Plaintiff' and "Katchmere" shall KATCHMERE, as well as her agents, mean VICKI employees, attorneys, officers, directors, consultants, representatives, parent, affiliates, subsidiaries,or other persons acting or purporting to act on its behalf. VINCENT F. VACCARELLA, P.A. 888 E. LAS OLASBLVD, SUITE 700, FORT LAUDERDALE, FL 33301 TELEPHONE 305-932-4044 FACSIMILE 305-932-4990 - 3 11. "Colet" shall mean FRANCISCO COLET, as well as his agents, employees, attorneys, officers, directors, consultants, representatives, parent, affiliates, subsidiaries, or other persons acting or purporting to act on its behalf. 12. "Association" and "Meadowbrook" shall mean MEADOWBROOK LAKES VIEW CONDOMINIUM ASSOCIATION "A", INC., as well as its agents, employees, attorneys, officers, directors, consultants, representatives, parent, affiliates, subsidiaries, or other persons acting or purporting to act on its behalf. 13. "Property" shall mean the property commonly referred to the MeadowbrookLakes View Condominium located in Broward County, Florida. 14. "Unit 107" shall mean the property owned by Plaintiff at the Property. 15. "Unit 108" shall mean the property owned by Colet at the Property. INSTRUCTIONS 1. All objections to the production of documents requested shall be made in writing and delivered to the office of Vincent F. Vaccarella, P.A., 888 East Las Olas Boulevard, Suite 700, Fort Lauderdale, Florida 33301, on or before the date set for production. 2. Ifthere is a claim ofprivilege with respect to any documentsrequested, Plaintiffis required to provide a statement setting forth the basis for the claim of privilege in compliance with Florida Rules of Civil Procedure 1.280 and 1.350. 3. All documentsare to be produced as they are kept in the usual course ofbusiness, including any labels, file markings, or similar identifying features, or shall be organized and labeled to correspond to the categories requested. If there are no documents responsive to a particular request, Plaintiffshall state so in writing in response to that specific request. 4. Electronically stored information ("ESI") must be produced in PDF format with corresponding load files containing the document's text and all available metadata. 5. Each request contemplates production of all documents in their entirety. If only a portion of a document is responsive to one or more requests, the document shall be produced in its entirety. 6. If there are no documents in response to any particular request, Plaintiff shall state so in writing. 7. These requests are continuing and your response to these requests must be promptly supplemented when appropriate or necessary. VINCENT F. VACCARELLA, P.A. 888 E. LAS OLAS BLVD, SUITE 700, FORT LAUDERDALE, FL 33301 TELEPHONE 305-932-4044 FACSIMILE 305-932-4990 - 4 DOCUMENTS REQUESTED Document Request No. 1: Any and all contracts, proposals, agreements, subcontracts, purchase orders, invoices, estimates, repair costs, and bids relating to the alleged water intrusion and mold remediation to Units 107 and 108 at the Property, including general conditions, addenda, supplements, amendments, modifications, and revisions. Document Request No. 2: Any and all internal communicationrecords relating to the alleged water intrusion to Unit 107 at the Property (any correspondence, e-mails, and faxes whether handwritten, printed, in electronic, or any other format). Document Request No. 3: Any and all communication records between Meadowbrook and Colet relating to the alleged water intrusion to Unit 107 at the Property (any correspondence, e-mails, and faxes whether handwritten, printed, in electronic, orany other format). Document Reauest No. 4: Any and all communication records among Plaintiff and Meadowbrook relating to the alleged water intrusion to Unit 107 at the Property, including but not limited to the Association's property manager (any correspondence, e-mails, and faxes whether handwritten, printed, in electronic, or any other format). Document Reauest No. 5: Any and all communication records among Meadowbrookand any non-party or third-party relating to the alleged water intrusion to Unit 107 at the Property (any correspondence, e-mails, texts, and faxes whether handwritten, printed, in electronic, or any other format). Document Reauest No. 6: Any and all communicationrecords among Meadowbrook and its insurer relating to the alleged water intrusion to Unit 107 at the Property (any correspondence, e-mails, and faxes whether handwritten, printed, in electronic, or any other format). Document Request No. 7: and all evidence of payments made by Meadowbrook relating to any repairs for the Any alleged water intrusion and mold remediation at the Property, including but not limited to, invoices, receipts, canceled checks, credit card, and wire transfers. VINCENT F. VACCARELLA, P.A. 888 E. LAS OLAS BLVD, SUITE 700, FORT LAUDERDALE, FL 33301 TELEPHONE 305-932-4044 FACSIMILE 305-932-4990 - 5 Document Request No. 8: Any and all photographs or videos in Meadowbrook's possession, control, or custody depicting the alleged water intrusion and damages sustained to Unit 107 at the Property. Document Request No. 9: Any and all photographs or videos in Meadowbrook's possession, control, or custody depicting the piping in the wall between Units 107 and 108 and the drainage system at the Property. Document Request No. 10: Any and all insurance policies in full force and effect on the date of the loss alleged in the Complaint relating to Unit 107 at the Property, including but not limited to, declaration pages, amendments, supplements, and other endorsements. Document Request No. 11: Any and all property loss forms relating to the alleged water intrusion and damages to Unit 107 at the Property. Document Reauest No. 12: Any and all inspections conducted by Plaintiff, Association, or any city, county, state, or other governmental entity relating to the alleged water intrusion and damages to Unit 107 at the Property. Document Reauest No. 13: Any and all shop drawings, plans specifications,surveys, charts, and engineering drawings relating to Unit 107, the location of the drainage system, and the p*ing in the wall between Units 107 and 108 at the Property. Document Reauest No. 14: Any and all documents provided to any person expected to be called as an expert witness, including but not limited to any oral or written report and any supporting data or information. Document Request No. 15: Any and all documentsprovided to any person expected to be called as a witness, including but not limited to any oral or written report and any supporting data or information. Document Request No. 16: VINCENT F.VACCARELLA, P.A. 888 E. LAS OLAS BLVD, SUITE 700, FORT LAUDERDALE, FL 33301 TELEPHONE 305-932-4044 FACSIMILE 305-932-4990 - 6 Any and all warranties relating to the waterproofing, repairs, or renovations at Units 107 and 108. Document Request No. 17: Any and all documents evidencing the manufacturers ofthe drainage system and the piping in the walls between Units 107 and 108 at the Property. Document Request No. 18: Any and all construction, maintenance, repairs, modifications, and alterations relating to Units 107 and 108 at the Property within the previous three (3) years. Document Request No. 19: Any and all Board of Director Meetings where the Board discussed any issue relating to Units 107 and 108. Document Request No. 20: Any and all Board of Director Meetings where the Board discussed any leak, water intrusion, mold remediation, or repairs relating to the alleged water intrusion at Units 107 and 108 at the Property. Document Request No. 21: Any and all reports and test results of any leak detection test conducted by the Association. VINCENT F. VACCARELLA, P.A. Counsel for Francisco Colet 888 E. Las Olas Blvd, Suite 700 Fort Lauderdale, Florida 33301 Telephone: (305) 932-4044 Facsimile: (305) 932-4990 By: /s/ Dylan E. Goldberg Vincent F. Vaccarella Fla. Bar No. 017426 vincent@v-law.net Dylan E. Goldberg Fla. Bar No. 1015677 dgoldberg@v-law.net VINCENT F. VACCARELLA, P.A. 888 E. LAS OLAS BLVD, SUITE 700, FORT LAUDERDALE, FL 33301 TELEPHONE 305-932-4044 FACSIMILE 305-932-4990 - 7 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served this 12th day of August, 2021 by the Florida Courts E-Filing Portal to Edward F. Holodak, Esq., Edward F. Holodak, P.A., 7580 NW 5th Street, Suite 15125, Plantation, Florida 33317 (edward@ho- lodakpa.com; com) and Scott R. Shapiro, Esq., Straley Otto, 2699 Stirling Road, Suite C-207, Fort Lauderdale, Florida 33312 attor- Respectfully submitted, By: /s/Dylan E. Goldberg Dylan E. Goldberg, Esq. VINCENT F. VACCARELLA, P.A. 888 E. LAS OLAS BLVD, SUITE 700, FORT LAUDERDALE, FL 33301 TELEPHONE 305-932-4044 FACSIMILE 305-932-4990 - 8