On May 03, 2021 a
Party Discovery
was filed
involving a dispute between
Lattibeaudiere, Lashawn,
Thermoset Roofing Corp,
Turn Two Electric Inc,
and
Lattibeaudiere, Lashawn,
Thermoset Roofing Corp.,
Turn Two Electric Inc,
for Contract and Indebtedness
in the District Court of Broward County.
Preview
Filing# 140436909 E-Filed 12/15/2021 02:11:30 PM
IN THE CIRCUIT COURT IN THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE-21-008854
DIVISION: 21
THERMOSET ROOFING CORP.,
Plaintiff,
V.
TURN TWO ELECTRIC, INC.,
a Florida Corporation,and
LASHAWN LATTIBEAUDIERE, an
individual,
Defendants.
'
PLAINTIFF, THERMOSET ROOFING CORP.'S FIRST REQUEST FOR ADMISSIONS
TO DEFENDANT, TURN TWO ELECTRIC, INC.
Thermoset Roofing Corp. ("Thermoset"),by and through
Plaintiff, its undersigned counsel,
requests responses to the followingRequests for Admissions by the Defendant, Turn Two Electric,
Inc. ("Turn Two"), to be answered in writingand under oath within thirty(30)days from the date of
service hereofin accordance with Rule 1.370, Florida Rule of Civil Procedure.
GENERAL INSTRUCTIONS
1. The followinginstructions are made pursuant Florida Rules of Civil Procedure 1.370(a).
2. If an objectionis made, pleasestate the reason.
3. Please admit, specificallydeny, or set forth in detail the reasons why you cannot truthfully
admit or deny the matter.
4. When good faith requiresyou to qualilj? an answer or deny only a part ofthe matter ofwhich
an admission is requested,then pleasespeci]?so much of it as is true and quali? or deny the
remainder.
5. You may not givelack o finformation or knowledge as a reason for a failure to admit or deny
unless you you have made
state that a reasonable inquiryand that the information known or
readilyobtainable by you is insufficient to enable you to admit or deny.
6. Ifyou consider a matter ofwhich an admission has been requesteda genuine issue for trial,
you may not objectto the request on that ground alone;you may deny the matter or set forth
reasons why you cannot admit or deny it,subjectto rule 1.380(c).
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/15/2021 02:11:29 PM.****
CACE-21-008854
7. If necessary, refer to the definitions section in Plaintiff First Request for Production of
Documents explanationo f defined terms.
for
8. Also, please be advised that if a party fails to admit the genuinenessof any document or the
truth of any matter as requestedherein,and ifPlaintiffthereafter proves the genuinenessof
the document or the truth o fthe matter, Plaintiffmayapply to the court for an order requiring
Defendant to pay Plaintiff the reasonable expenses incurred in making that proof,including
reasonable attorney'sfees.
9. The term"Property" means 500NW 12thAve. Pompano Beach, Florida,thepropertywhichis
the subjectofthis action.
REQUESTS FOR ADMISSION
1. Admit that you served as an electrical contractor for the Property.
2. Admit that you failed to obtain all ofthe requiredpermit(s)for the work at the Property.
3. Admit that you performed unpermittedwork at the Property.
4. Admit that you allowed defective work to be performed at the Property.
5. Admit that you failed to retain properlyqualifiedsubcontractors, laborers and/or material
for the
suppliers work at the Property.
6. Admit that you submitted one or more change order requests for work alreadywithin Turn
Two's contracted scope ofwork.
7. Admit that you received a change order for temporary power for the amount of $900.00.
8. Admit that you were paid for the change order for temporarypower referenced in paragraph
7 above.
9. Admit that you failed to contact Florida Power and Light ("FPL") regardingthe installation of
legaltemporary power for the Property.
10. Admit that you set up unmetered power for the Property without the knowledge or consent of
FPL.
11. Admit that you contacted local code enforcement followingTurn Two'sterminationto advise
them ofthe unmetered power set up by Turn Two at the Property.
12. Admit that you failed or refused to cooperate with Thermoset to transfer your permit to
Pacman Electric followingTurn Two's termination.
13. Admit that you failed to properlysuperviseand manage the work at the Property.
14. Admit that you failed to achieve Substantial Completion ofthe work within the time frame
by December 12, 2020).
allowed in the Contract (i.e.,
2
CACE-21-008854
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy ofthe foregoinghas been furnished bythe
Florida Courts E-FilingPortal System to all electronic filing with respect
participants to this
proceeding,this December 15, 2021.
KELLEY KRONENBERG, PA
10360 West State Road 84
Fort Lauderdale, FL 33324
Telephone No.: (954) 370-9970
Facsimile No.: (954) 382-1988
By-. /s/ John M. DeJager
GARY L. BROWN
Florida Bar No.. 0054585
JOHN M. DEJAGER
Florida Bar No.. 1005233
Mm@kelleykronenberg.com
idejager@kelleykronenberg.com
dhavens@kelleykronenberg.com
ygonzalo@kelleykronenberg.com
3
Document Filed Date
December 15, 2021
Case Filing Date
May 03, 2021
Category
Contract and Indebtedness
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing# 140436909 E-Filed 12/15/2021 02:11:30 PM IN THE CIRCUIT COURT IN THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-21-008854 DIVISION: 21 THERMOSET ROOFING CORP., Plaintiff, V. TURN TWO ELECTRIC, INC., a Florida Corporation,and LASHAWN LATTIBEAUDIERE, an individual, Defendants. ' PLAINTIFF, THERMOSET ROOFING CORP.'S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT, TURN TWO ELECTRIC, INC. Thermoset Roofing Corp. ("Thermoset"),by and through Plaintiff, its undersigned counsel, requests responses to the followingRequests for Admissions by the Defendant, Turn Two Electric, Inc. ("Turn Two"), to be answered in writingand under oath within thirty(30)days from the date of service hereofin accordance with Rule 1.370, Florida Rule of Civil Procedure. GENERAL INSTRUCTIONS 1. The followinginstructions are made pursuant Florida Rules of Civil Procedure 1.370(a). 2. If an objectionis made, pleasestate the reason. 3. Please admit, specificallydeny, or set forth in detail the reasons why you cannot truthfully admit or deny the matter. 4. When good faith requiresyou to qualilj? an answer or deny only a part ofthe matter ofwhich an admission is requested,then pleasespeci]?so much of it as is true and quali? or deny the remainder. 5. You may not givelack o finformation or knowledge as a reason for a failure to admit or deny unless you you have made state that a reasonable inquiryand that the information known or readilyobtainable by you is insufficient to enable you to admit or deny. 6. Ifyou consider a matter ofwhich an admission has been requesteda genuine issue for trial, you may not objectto the request on that ground alone;you may deny the matter or set forth reasons why you cannot admit or deny it,subjectto rule 1.380(c). *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/15/2021 02:11:29 PM.**** CACE-21-008854 7. If necessary, refer to the definitions section in Plaintiff First Request for Production of Documents explanationo f defined terms. for 8. Also, please be advised that if a party fails to admit the genuinenessof any document or the truth of any matter as requestedherein,and ifPlaintiffthereafter proves the genuinenessof the document or the truth o fthe matter, Plaintiffmayapply to the court for an order requiring Defendant to pay Plaintiff the reasonable expenses incurred in making that proof,including reasonable attorney'sfees. 9. The term"Property" means 500NW 12thAve. Pompano Beach, Florida,thepropertywhichis the subjectofthis action. REQUESTS FOR ADMISSION 1. Admit that you served as an electrical contractor for the Property. 2. Admit that you failed to obtain all ofthe requiredpermit(s)for the work at the Property. 3. Admit that you performed unpermittedwork at the Property. 4. Admit that you allowed defective work to be performed at the Property. 5. Admit that you failed to retain properlyqualifiedsubcontractors, laborers and/or material for the suppliers work at the Property. 6. Admit that you submitted one or more change order requests for work alreadywithin Turn Two's contracted scope ofwork. 7. Admit that you received a change order for temporary power for the amount of $900.00. 8. Admit that you were paid for the change order for temporarypower referenced in paragraph 7 above. 9. Admit that you failed to contact Florida Power and Light ("FPL") regardingthe installation of legaltemporary power for the Property. 10. Admit that you set up unmetered power for the Property without the knowledge or consent of FPL. 11. Admit that you contacted local code enforcement followingTurn Two'sterminationto advise them ofthe unmetered power set up by Turn Two at the Property. 12. Admit that you failed or refused to cooperate with Thermoset to transfer your permit to Pacman Electric followingTurn Two's termination. 13. Admit that you failed to properlysuperviseand manage the work at the Property. 14. Admit that you failed to achieve Substantial Completion ofthe work within the time frame by December 12, 2020). allowed in the Contract (i.e., 2 CACE-21-008854 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy ofthe foregoinghas been furnished bythe Florida Courts E-FilingPortal System to all electronic filing with respect participants to this proceeding,this December 15, 2021. KELLEY KRONENBERG, PA 10360 West State Road 84 Fort Lauderdale, FL 33324 Telephone No.: (954) 370-9970 Facsimile No.: (954) 382-1988 By-. /s/ John M. DeJager GARY L. BROWN Florida Bar No.. 0054585 JOHN M. DEJAGER Florida Bar No.. 1005233 Mm@kelleykronenberg.com idejager@kelleykronenberg.com dhavens@kelleykronenberg.com ygonzalo@kelleykronenberg.com 3