On December 31, 2014 a
Response to Request for Production
was filed
involving a dispute between
Dewey, Brendan,
and
Kw Property Management Llc,
Pacifica Loan Four Llc,
for Negligence - Premises Liability Commercial
in the District Court of Collier County.
Preview
Filing # 29452695 E-Filed 07/09/2015 01:42:08 PM
IN THE CIRCUIT COURT OF THE 20TH
JUDICIAL CIRCUIT COURT IN AND
FOR COLLIER COUNTY, FL
BRENDAN DEWEY,
CASE NO: 14-CA-002819
Plaintiff,
VS.
PACIFICA LOAN FOUR, LLC, a Foregin
Limited Liability Company, and KW
PROPERTY MANAGEMENT, LLC, a
Florida Limited Liability Company
Defendants.
/
DEFENDANTS’ RESPONSES TO REQUEST FOR PRODUCTION
Defendants, PACIFICA LOAN FOUR, LLC and KW PROPERTY MANAGEMENT,
LLC, by and through undersigned attorneys, file this their Response to Plaintiff's Request for
Production and respectfully state as follows:
1. Objection on the basis of relevancy and overbroad. In addition, the insurance
policy information is over 600 pages. See Defendants’ Answers to Interrogatory
Number 3 for the pertinent insurance policy information.
None.
None.
None.
None.
See attached.
raw F YD
Objection on the basis of relevancy; objection on the basis of and overbroad; and
objection on the basis of subsequent remedial measures; however, without
waiving these objections, see attached.
Other than produced by Plaintiffs attorney, see attached.
9 None.
10 None.
11 None.
12 None.
13 None as to these Defendants.
FILED: COLLIER COUNTY, DWIGHT E. BROCK, CLERK, 07/10/2015 10:53:18 AM14 None.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on July 9, 2015, I electronically filed the foregoing document
with the Clerk of Court using Florida Courts eFiling Portal. I also certify that the foregoing
document is being served this day on all counsel of record or pro se parties identified as follows,
either via transmission of Notices of Electronic Filing generated by Florida Courts eFiling Portal or
in some other authorized manner for those counsel or parties who are not authorized to receive
electronic Notices of Electronic Filing, to: Judson L. Cohen, Esquire, 14125 NW 80 Avenue,
Suite 400, Miami Lakes, FL 33016 (eservice@weinsteincohen.com).
LAW OFFICES OF JAMES W. KEHOE, III
Counsel for Defendants
3230 West Commercial Blvd., Suite 250
Fort Lauderdale, FL 33309
Telephone No.: (954) 677-3723
Facsimile No.: (866) 292-4641
mkatler@travelers.com
058Law1@travelers.com
Pech othe
MITCHELL HL KATLER, ESQUIRE
Florida Bar Number: 454982
Case Filing Date
December 31, 2014
Category
Negligence - Premises Liability Commercial
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Filing # 29452695 E-Filed 07/09/2015 01:42:08 PM IN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT COURT IN AND FOR COLLIER COUNTY, FL BRENDAN DEWEY, CASE NO: 14-CA-002819 Plaintiff, VS. PACIFICA LOAN FOUR, LLC, a Foregin Limited Liability Company, and KW PROPERTY MANAGEMENT, LLC, a Florida Limited Liability Company Defendants. / DEFENDANTS’ RESPONSES TO REQUEST FOR PRODUCTION Defendants, PACIFICA LOAN FOUR, LLC and KW PROPERTY MANAGEMENT, LLC, by and through undersigned attorneys, file this their Response to Plaintiff's Request for Production and respectfully state as follows: 1. Objection on the basis of relevancy and overbroad. In addition, the insurance policy information is over 600 pages. See Defendants’ Answers to Interrogatory Number 3 for the pertinent insurance policy information. None. None. None. None. See attached. raw F YD Objection on the basis of relevancy; objection on the basis of and overbroad; and objection on the basis of subsequent remedial measures; however, without waiving these objections, see attached. Other than produced by Plaintiffs attorney, see attached. 9 None. 10 None. 11 None. 12 None. 13 None as to these Defendants. FILED: COLLIER COUNTY, DWIGHT E. BROCK, CLERK, 07/10/2015 10:53:18 AM14 None. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on July 9, 2015, I electronically filed the foregoing document with the Clerk of Court using Florida Courts eFiling Portal. I also certify that the foregoing document is being served this day on all counsel of record or pro se parties identified as follows, either via transmission of Notices of Electronic Filing generated by Florida Courts eFiling Portal or in some other authorized manner for those counsel or parties who are not authorized to receive electronic Notices of Electronic Filing, to: Judson L. Cohen, Esquire, 14125 NW 80 Avenue, Suite 400, Miami Lakes, FL 33016 (eservice@weinsteincohen.com). LAW OFFICES OF JAMES W. KEHOE, III Counsel for Defendants 3230 West Commercial Blvd., Suite 250 Fort Lauderdale, FL 33309 Telephone No.: (954) 677-3723 Facsimile No.: (866) 292-4641 mkatler@travelers.com 058Law1@travelers.com Pech othe MITCHELL HL KATLER, ESQUIRE Florida Bar Number: 454982