Preview
Filing # 129167418 E-Filed 06/21/2021 02:54:15 PM
IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE #: CACE21010712 (21)
JOHNATHAN WESLEY,
Plaintiff,
VS.
UNDERWRITERS LLOYD'S,
AT
LONDON, SUBSCRIBING TO POLICY
NUMBER NPHOAR5000308,
Defendant.
DEFENDANT'S NOTICE OF INTENT TO SERVE
SUBPOENAS DUCES TECUM FOR RECORDS ON NON-PARTY
YOU ARE HEREBY NOTIFIED that the undersigned, pursuant to the Florida Rules
of Civil Procedure 1.351, will issue the attached subpoena duces tecum for documents
without deposition after ten (10) days from the service of this notice, which subpoena is
directed to:
1. Records Custodian for
JMD Consultants, Inc.
do Juan Maza, as Registered Agent
15062 S.W. 36 Street
Davie, Florida 33331
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on June 21, 2021, a true and correct copy of the
foregoing sent via electronic filing and email to: THE PROPERTY ADVOCATES, P.A.
2525
Ponce De Leon Boulevard, Suite 600, Coral Gables, Florida 33134.
LEVY LAW GROUP
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/21/2021 02:54:14 PM.****
CASE #: CACE21010712 (21)
/s/ Lauren D. Levy
LAUREN D. LEVY, ESQ.
Florida Bar No.- 0116490
PAULA LEVY PARKES, ESQ.
Florida Bar No.- 0117031
3399 Ponce de Leon Boulevard, Suite 202
Coral Gables, Florida 33134
Telephone: (305) 444-1500
Facsimile: (305) 503-9295
Attorneys for Defendant
Page 2 of 2
IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE #: CACE21010712 (21)
JOHNATHAN WESLEY,
Plaintiff,
VS.
UNDERWRITERS LLOYD'S,
AT
LONDON, SUBSCRIBING TO POLICY
NUMBER NPHOAR5000308,
Defendant.
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
**1 -**
'RECORDS MAY BE MAILED IN LIEU OF APPEARANCE
THE STATE OF FLORIDA:
Records Custodian for
JMD Consultants, Inc.
do Juan Maza, as Registered Agent
15062 S.W. 36 Street
Davie, Florida 33331
YOU ARE HEREBY COMMANDED to appear at Levy Law Group, 3399 Ponce de
Leon Boulevard, Suite 202, Coral Gables, Florida 33134, on rDATE AND TIME TBD1,
and to have with you at that time and place the following:
SEE EXHIBIT "A" FOR DOCUMENT REQUESTS
These items will be inspected and may be copied at that time. You will not be
required to surrenderthe original items. You may comply with this Subpoena by providing
legible copies of the items to be produced to the attorney whose name appears on this
Subpoena on or before the scheduled date of production. You may condition the
preparation of the copies upon the payment in advance of the reasonable cost of
preparation. You may mail or deliver the copies to the attorney whose name appears on
CASE #: CACE21010712 (21)
this Subpoena and thereby eliminate your appearance at the time and place specified
above. You have the right to object to the production pursuant to this Subpoena at any
time before production by giving written notice to the attorney whose name appears on
this Subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE
TAKEN.
If you fail to:
(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this Subpoena,
you may be in contempt of Court. You are subpoenaed by the following attorney, and
unless excused from this Subpoena by this attorney or the Court, you shall respond to
this Subpoena as directed.
DATED on [DATE TBD1,2021.
LEVY LAW GROUP
/s/ Lauren D. Levy
LAUREN D. LEVY, ESQ.
Florida Bar No.- 0116490
PAULA LEVY PARKES, ESQ.
Florida Bar No.- 0117031
3399 Ponce de Leon Boulevard, Suite 202
Coral Gables, Florida 33134
Telephone: (305) 444-1500
Facsimile: (305) 503-9295
Attorneys for Defendant
***
AS AN ALTERNATIVE, AN ELECTRONIC COPY OF THE RECORDS MAY BE
***
SENT VIA EMAIL TO:
Page 2 of 8
CASE #: CACE21010712 (21)
DEFINITIONS
1. The term "communication" shall mean any transmission of information by any means,
including, without limitation, by spoken language, electronic transmission of data or
any other means. The term "communication" shall include, without limitation, any
copies of written information received by the person or entity responding to this
request, even if such person or entity is not the primary or direct addressee of such
written information.
2. The term "document" or "documents" is used in its broadest sense and includes,
without limitation, drafts, documents whether printed, recorded, stored or reproduced
by any mechanical or electronic process, or written or produced by hand, and including
computer tapes (including backup tapes) and all other computer-related documents,
within your possession, custody or control. "Documents" shall also include (1) each
copy that is not identical to the original or to any other copy, and (2) any tangible thing
that is called for by or identified in response to any request. "Document" as used
herein shall be construed broadly to include all documents and things within the scope
of the Florida Rules of Civil Procedure and refers to all writings or other graphic matter,
as well as any other medium by which information is stored or recorded. It includes
originals, drafts, copies and reproductions; and it includes, without limiting the
generality of the foregoing, letters; memoranda; reports and/or summaries of
investigations; police reports; accident reports; opinions or reports of consultants;
diagrams; marginal comments appearing on any documents; accounts; telegrams;
studies; lists of persons attending meetings or conferences; records or memoranda of
telephone conversations; written statements; transcripts or recorded statements;
recorded statements; records of personal conversations or interviews; calculations;
computations; specifications; drawings; advertisements; circulars; trade letters; press
releases; prints; recordings; positive or negative films, slides or photographs;
magnetic, electronic or video tapes; computer tapes, cards or printouts; and all other
things of like nature; and any and all containers, boxes or other receptacles or
repositorieshousing or containing such "documents."
3. "You", "Your", "Yourself' means "JMD CONSULTANTS, INC.", its affiliates, agents,
employees and representatives.
4. "Plaintiff'" means Plaintiff, "JOHNATHAN WESLEY", his affiliates, agents, employees
and representatives.
5. "Defendant" and/or "CERTAIN UNDERWRITERS AT LLOYD'S OF LONDON
SUBSCRIBING TO POLICY NUMBER NPHOARS000308", its affiliates, agents,
employees and representatives.
6. "Person" means a natural person, firm, association, partnership, corporation or other
firm of legal or business entity, public or private.
Page 3 of 8
CASE #: CACE21010712 (21)
7. The term "referring" or "relating" shall mean showing, disclosing, averting to,
comprising, evidencing, constituting or reviewing.
8. The term "representative" as used herein with regard to a person or entity means and
includes each and every present and former director, officer, partner, employee,
agent, independent consultant or expert or other person (including attorneys) acting
or purporting to act on behalf of the person or entity.
9. The "subject property" means the property located at 1800 NW 6th Avenue, Pompano
Beach, Florida, 33060.
10. The singular includes the plural and vice versa; the words "and" and "or" shall be both
conjunctive; the word "all" means "any and all"; the word "any" means "any and all";
the word "including" means "including, without limitation."
11. All other words have their plain and ordinary meaning.
Page 4 of 8
CASE #: CACE21010712 (21)
INSTRUCTIONS
1. You are instructed either to produce documents as they are kept in the ordinary course
of business or to produce documents organized and labeled to correspond with the
categories on Exhibit "A". In addition, documents are to be produced in full and
unexpurgatedform."
2. This request shall be deemed continuing so as to require further and supplemental
production in the event that the party requested to produce, or any of his or her
attorneys, agents or representatives, obtains or discovers additional information or
documents between the time of the initial production and the time of hearing or trial.
3. If any document covered by Exhibit "A" is withheld
by reason of a claim of privilege,
work product immunity or other ground of non-production, a list is to be furnished at
the time that documents are produced identifying each such document not produced
specifically by its nature (e.g., letter, memorandum, etc.) together with the following
information with respect to any such document withheld: Author(s); recipient(s);
sender(s); indicated or blind copies; date; subject matter; basis for non-production;
number of pages; and the paragraph(s) of Exhibit "A" to which such document relates.
4. If a portion of an otherwise responsive document contains information that is subject
to a claim of privilege, only those portions of the document subject to the claim of
privilege shall be deleted or redacted from the document and the rest of the document
shall be produced.
5. In the event that any document called for by Exhibit "A" has been destroyed, lost,
discarded or otherwise disposed of, each such document is to be identified as
completely as possible, including, without limitation, the
following information:
Author(s); recipient(s); sender(s); subject matter; date prepared or received; date of
disposal; person(s) currently in possession of the document; and person disposing of
the document.
6. All objections to any category of documents to be
produced pursuant to this request
or to any definition or instruction it contains shall be in writing and delivered to
Defendant's counsel at or before the time of production.
Page 5 of 8
CASE #: CACE21010712 (21)
EXHIBIT "A"
RE: JOHNATHAN WESTLEY v. UNDERWRITERS AT LLOYD'S,
LONDON, SUBSCRIBING TO POLICY NUMBER NPHOAR5000308
PROPERTY: 1800 NW 6th Avenue, Pompano Beach, Florida, 33060
Pursuant to Rule 1.351 of the Florida Rules of Civil Procedure, JMD
CONSULTANTS, INC. shall produce the following at the time and place above:
1. Your complete file (cover to cover) pertaining to the subject property
located at 1800 NW 6:th Avenue, Pompano Beach, Florida, 33060 (hereinafter referred
to as the
"subject property"). The file should include but is not limited to agreements,
appraisals, photographs, videotapes, invoices, estimates, contracts, permits, notice of
commencements, correspondence including emails, letters and facsimile, authored or
received by you, evaluations, notes, recommendations, reports, prepared (or reviewed)
by you and/or any other representatives or employees of JMD CONSULTANTS, INC.
pertaining to the subject property.
2. All
reports, records, documents, diagrams, photographs, tests, test results,
statements, correspondence, and any other documentation prepared and/or relied upon
that were gathered or provided to any experts or received from any experts directly or
indirectly relating to the subject property.
3. All charts, graphs, summaries or any other type of data representationthat
in any way depicts or relates to the subject property.
4. Any and all estimates, draft estimates, bids, reports, records, tests, test
results, evaluations, quotes, work orders and/or proposals, change orders, memoranda,
calculations, invoices, evaluations, payment transactions, proposals, receipts, and
statement of accounts prepared or received by you regarding the subject property.
5. Any and all documentation
evidencing repairs completed or proposed
repairs to be the subject property. This request includes but is not limited
performed at
to any and all documentation reflecting calculation and/or measurements regarding such
actual or contemplated repairs.
6. Work
logs, computer or paper, or list identifying the names and last known
contact information of the employees who performed work at the subject property.
Page 6 of 8
CASE #: CACE21010712 (21)
7. Any and all photographs, videotapes, films, negatives, and color prints
depicting any portion of the subject property.
8- Any and all documentation evidencing permit fees, administration fees or
expert fees incurred as a result of work performed at the subject property including copies
of the invoices for said charges and copies of all payments issued for the charges
including checks and/or redacted credit card statements
9. Any and all correspondence, including email, facsimile and letter(s) sent or
received regarding the subject property.
10. Any and all notices of commencement, change orders, permits obtained or
permits applied for, for work to be performed by JMD CONSULTANTS, INC. at the
subject property.
11. Any and all electronic files maintained in the regular course of business that
are responsive to the above ten (10) requests are required to be produced to Defendant
in their electronic, pristine, native format. Any USB or external drive forwarded to
Defendant producing the requested electronic files will be returned to the nonparty once
the electronic files are in Defendant's possession. If a chain of custody letter is required
by the producer of the electronic files, please contact the person listed on the subpoena
to make arrangements.
12. A copy of your professional license(s) issued within the State of Florida.
***
IF DUPLICATION OF THE REQUESTED RECORDS WILL COST IN EXCESS OF
[$50.00/OTHER], WE REQUEST THAT YOU CONTACT OUR OFFICE PRIOR TO
***
DUPLICATING/SENDINGTHE RECORDS. ALL INVOICES MUST BE ITEMIZED.
Page 7 of 8
CASE #: CACE21010712 (21)
IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE #: CACE21010712 (21)
JOHNATHAN WESLEY,
Plaintiff,
VS.
UNDERWRITERS AT LLOYD'S, LONDON,
SUBSCRIBING TO POLICY NUMBER
NPHOAR5000308,
Defendant.
i
AFFIDAVIT OF RECORDS CUSTODIAN CERTIFICATE OF AUTHENTICITY
IT IS HEREBY CERTIFIED that (p/ease fill out either A or B):
C] A. The attached records with regard to the Subject Property are authentic copies
of the records in the possession of JMD CONSULTANTS, INC. is further certified that said
records attached represent the complete records available and consist of - pages and/or
description of production.
C] B. l have performed a diligent search of the records of JMD CONSULTANTS,
INC. and have determined that there are no records with regard to the subject property in our
possession. I searched back - years and/or JMD CONSULTANTS, INC.'s records are
maintained in the following manner:
and none were found relative to the in this litigation.
By:
Records Custodian
STATE OF:
COUNTY OF:
THE FOREGOING INSTRUMENT was acknowledged before me this
day of
2021 by who is personally known to me
or who has produced as identification.
NOTARY PUBLIC
My Commission Expires:
Page 8 of 8
Preview
Filing # 129167418 E-Filed 06/21/2021 02:54:15 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE #: CACE21010712 (21) JOHNATHAN WESLEY, Plaintiff, VS. UNDERWRITERS LLOYD'S, AT LONDON, SUBSCRIBING TO POLICY NUMBER NPHOAR5000308, Defendant. DEFENDANT'S NOTICE OF INTENT TO SERVE SUBPOENAS DUCES TECUM FOR RECORDS ON NON-PARTY YOU ARE HEREBY NOTIFIED that the undersigned, pursuant to the Florida Rules of Civil Procedure 1.351, will issue the attached subpoena duces tecum for documents without deposition after ten (10) days from the service of this notice, which subpoena is directed to: 1. Records Custodian for JMD Consultants, Inc. do Juan Maza, as Registered Agent 15062 S.W. 36 Street Davie, Florida 33331 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on June 21, 2021, a true and correct copy of the foregoing sent via electronic filing and email to: THE PROPERTY ADVOCATES, P.A. 2525 Ponce De Leon Boulevard, Suite 600, Coral Gables, Florida 33134. LEVY LAW GROUP *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/21/2021 02:54:14 PM.**** CASE #: CACE21010712 (21) /s/ Lauren D. Levy LAUREN D. LEVY, ESQ. Florida Bar No.- 0116490 PAULA LEVY PARKES, ESQ. Florida Bar No.- 0117031 3399 Ponce de Leon Boulevard, Suite 202 Coral Gables, Florida 33134 Telephone: (305) 444-1500 Facsimile: (305) 503-9295 Attorneys for Defendant Page 2 of 2 IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE #: CACE21010712 (21) JOHNATHAN WESLEY, Plaintiff, VS. UNDERWRITERS LLOYD'S, AT LONDON, SUBSCRIBING TO POLICY NUMBER NPHOAR5000308, Defendant. SUBPOENA DUCES TECUM WITHOUT DEPOSITION **1 -** 'RECORDS MAY BE MAILED IN LIEU OF APPEARANCE THE STATE OF FLORIDA: Records Custodian for JMD Consultants, Inc. do Juan Maza, as Registered Agent 15062 S.W. 36 Street Davie, Florida 33331 YOU ARE HEREBY COMMANDED to appear at Levy Law Group, 3399 Ponce de Leon Boulevard, Suite 202, Coral Gables, Florida 33134, on rDATE AND TIME TBD1, and to have with you at that time and place the following: SEE EXHIBIT "A" FOR DOCUMENT REQUESTS These items will be inspected and may be copied at that time. You will not be required to surrenderthe original items. You may comply with this Subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this Subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on CASE #: CACE21010712 (21) this Subpoena and thereby eliminate your appearance at the time and place specified above. You have the right to object to the production pursuant to this Subpoena at any time before production by giving written notice to the attorney whose name appears on this Subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. If you fail to: (1) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this Subpoena, you may be in contempt of Court. You are subpoenaed by the following attorney, and unless excused from this Subpoena by this attorney or the Court, you shall respond to this Subpoena as directed. DATED on [DATE TBD1,2021. LEVY LAW GROUP /s/ Lauren D. Levy LAUREN D. LEVY, ESQ. Florida Bar No.- 0116490 PAULA LEVY PARKES, ESQ. Florida Bar No.- 0117031 3399 Ponce de Leon Boulevard, Suite 202 Coral Gables, Florida 33134 Telephone: (305) 444-1500 Facsimile: (305) 503-9295 Attorneys for Defendant *** AS AN ALTERNATIVE, AN ELECTRONIC COPY OF THE RECORDS MAY BE *** SENT VIA EMAIL TO: Page 2 of 8 CASE #: CACE21010712 (21) DEFINITIONS 1. The term "communication" shall mean any transmission of information by any means, including, without limitation, by spoken language, electronic transmission of data or any other means. The term "communication" shall include, without limitation, any copies of written information received by the person or entity responding to this request, even if such person or entity is not the primary or direct addressee of such written information. 2. The term "document" or "documents" is used in its broadest sense and includes, without limitation, drafts, documents whether printed, recorded, stored or reproduced by any mechanical or electronic process, or written or produced by hand, and including computer tapes (including backup tapes) and all other computer-related documents, within your possession, custody or control. "Documents" shall also include (1) each copy that is not identical to the original or to any other copy, and (2) any tangible thing that is called for by or identified in response to any request. "Document" as used herein shall be construed broadly to include all documents and things within the scope of the Florida Rules of Civil Procedure and refers to all writings or other graphic matter, as well as any other medium by which information is stored or recorded. It includes originals, drafts, copies and reproductions; and it includes, without limiting the generality of the foregoing, letters; memoranda; reports and/or summaries of investigations; police reports; accident reports; opinions or reports of consultants; diagrams; marginal comments appearing on any documents; accounts; telegrams; studies; lists of persons attending meetings or conferences; records or memoranda of telephone conversations; written statements; transcripts or recorded statements; recorded statements; records of personal conversations or interviews; calculations; computations; specifications; drawings; advertisements; circulars; trade letters; press releases; prints; recordings; positive or negative films, slides or photographs; magnetic, electronic or video tapes; computer tapes, cards or printouts; and all other things of like nature; and any and all containers, boxes or other receptacles or repositorieshousing or containing such "documents." 3. "You", "Your", "Yourself' means "JMD CONSULTANTS, INC.", its affiliates, agents, employees and representatives. 4. "Plaintiff'" means Plaintiff, "JOHNATHAN WESLEY", his affiliates, agents, employees and representatives. 5. "Defendant" and/or "CERTAIN UNDERWRITERS AT LLOYD'S OF LONDON SUBSCRIBING TO POLICY NUMBER NPHOARS000308", its affiliates, agents, employees and representatives. 6. "Person" means a natural person, firm, association, partnership, corporation or other firm of legal or business entity, public or private. Page 3 of 8 CASE #: CACE21010712 (21) 7. The term "referring" or "relating" shall mean showing, disclosing, averting to, comprising, evidencing, constituting or reviewing. 8. The term "representative" as used herein with regard to a person or entity means and includes each and every present and former director, officer, partner, employee, agent, independent consultant or expert or other person (including attorneys) acting or purporting to act on behalf of the person or entity. 9. The "subject property" means the property located at 1800 NW 6th Avenue, Pompano Beach, Florida, 33060. 10. The singular includes the plural and vice versa; the words "and" and "or" shall be both conjunctive; the word "all" means "any and all"; the word "any" means "any and all"; the word "including" means "including, without limitation." 11. All other words have their plain and ordinary meaning. Page 4 of 8 CASE #: CACE21010712 (21) INSTRUCTIONS 1. You are instructed either to produce documents as they are kept in the ordinary course of business or to produce documents organized and labeled to correspond with the categories on Exhibit "A". In addition, documents are to be produced in full and unexpurgatedform." 2. This request shall be deemed continuing so as to require further and supplemental production in the event that the party requested to produce, or any of his or her attorneys, agents or representatives, obtains or discovers additional information or documents between the time of the initial production and the time of hearing or trial. 3. If any document covered by Exhibit "A" is withheld by reason of a claim of privilege, work product immunity or other ground of non-production, a list is to be furnished at the time that documents are produced identifying each such document not produced specifically by its nature (e.g., letter, memorandum, etc.) together with the following information with respect to any such document withheld: Author(s); recipient(s); sender(s); indicated or blind copies; date; subject matter; basis for non-production; number of pages; and the paragraph(s) of Exhibit "A" to which such document relates. 4. If a portion of an otherwise responsive document contains information that is subject to a claim of privilege, only those portions of the document subject to the claim of privilege shall be deleted or redacted from the document and the rest of the document shall be produced. 5. In the event that any document called for by Exhibit "A" has been destroyed, lost, discarded or otherwise disposed of, each such document is to be identified as completely as possible, including, without limitation, the following information: Author(s); recipient(s); sender(s); subject matter; date prepared or received; date of disposal; person(s) currently in possession of the document; and person disposing of the document. 6. All objections to any category of documents to be produced pursuant to this request or to any definition or instruction it contains shall be in writing and delivered to Defendant's counsel at or before the time of production. Page 5 of 8 CASE #: CACE21010712 (21) EXHIBIT "A" RE: JOHNATHAN WESTLEY v. UNDERWRITERS AT LLOYD'S, LONDON, SUBSCRIBING TO POLICY NUMBER NPHOAR5000308 PROPERTY: 1800 NW 6th Avenue, Pompano Beach, Florida, 33060 Pursuant to Rule 1.351 of the Florida Rules of Civil Procedure, JMD CONSULTANTS, INC. shall produce the following at the time and place above: 1. Your complete file (cover to cover) pertaining to the subject property located at 1800 NW 6:th Avenue, Pompano Beach, Florida, 33060 (hereinafter referred to as the "subject property"). The file should include but is not limited to agreements, appraisals, photographs, videotapes, invoices, estimates, contracts, permits, notice of commencements, correspondence including emails, letters and facsimile, authored or received by you, evaluations, notes, recommendations, reports, prepared (or reviewed) by you and/or any other representatives or employees of JMD CONSULTANTS, INC. pertaining to the subject property. 2. All reports, records, documents, diagrams, photographs, tests, test results, statements, correspondence, and any other documentation prepared and/or relied upon that were gathered or provided to any experts or received from any experts directly or indirectly relating to the subject property. 3. All charts, graphs, summaries or any other type of data representationthat in any way depicts or relates to the subject property. 4. Any and all estimates, draft estimates, bids, reports, records, tests, test results, evaluations, quotes, work orders and/or proposals, change orders, memoranda, calculations, invoices, evaluations, payment transactions, proposals, receipts, and statement of accounts prepared or received by you regarding the subject property. 5. Any and all documentation evidencing repairs completed or proposed repairs to be the subject property. This request includes but is not limited performed at to any and all documentation reflecting calculation and/or measurements regarding such actual or contemplated repairs. 6. Work logs, computer or paper, or list identifying the names and last known contact information of the employees who performed work at the subject property. Page 6 of 8 CASE #: CACE21010712 (21) 7. Any and all photographs, videotapes, films, negatives, and color prints depicting any portion of the subject property. 8- Any and all documentation evidencing permit fees, administration fees or expert fees incurred as a result of work performed at the subject property including copies of the invoices for said charges and copies of all payments issued for the charges including checks and/or redacted credit card statements 9. Any and all correspondence, including email, facsimile and letter(s) sent or received regarding the subject property. 10. Any and all notices of commencement, change orders, permits obtained or permits applied for, for work to be performed by JMD CONSULTANTS, INC. at the subject property. 11. Any and all electronic files maintained in the regular course of business that are responsive to the above ten (10) requests are required to be produced to Defendant in their electronic, pristine, native format. Any USB or external drive forwarded to Defendant producing the requested electronic files will be returned to the nonparty once the electronic files are in Defendant's possession. If a chain of custody letter is required by the producer of the electronic files, please contact the person listed on the subpoena to make arrangements. 12. A copy of your professional license(s) issued within the State of Florida. *** IF DUPLICATION OF THE REQUESTED RECORDS WILL COST IN EXCESS OF [$50.00/OTHER], WE REQUEST THAT YOU CONTACT OUR OFFICE PRIOR TO *** DUPLICATING/SENDINGTHE RECORDS. ALL INVOICES MUST BE ITEMIZED. Page 7 of 8 CASE #: CACE21010712 (21) IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE #: CACE21010712 (21) JOHNATHAN WESLEY, Plaintiff, VS. UNDERWRITERS AT LLOYD'S, LONDON, SUBSCRIBING TO POLICY NUMBER NPHOAR5000308, Defendant. i AFFIDAVIT OF RECORDS CUSTODIAN CERTIFICATE OF AUTHENTICITY IT IS HEREBY CERTIFIED that (p/ease fill out either A or B): C] A. The attached records with regard to the Subject Property are authentic copies of the records in the possession of JMD CONSULTANTS, INC. is further certified that said records attached represent the complete records available and consist of - pages and/or description of production. C] B. l have performed a diligent search of the records of JMD CONSULTANTS, INC. and have determined that there are no records with regard to the subject property in our possession. I searched back - years and/or JMD CONSULTANTS, INC.'s records are maintained in the following manner: and none were found relative to the in this litigation. By: Records Custodian STATE OF: COUNTY OF: THE FOREGOING INSTRUMENT was acknowledged before me this day of 2021 by who is personally known to me or who has produced as identification. NOTARY PUBLIC My Commission Expires: Page 8 of 8