Party Discovery: VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION INC vs. ROYAL OAK HOMES LLC

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                                Filing # 152090260 E-Filed 06/23/2022 04:13:09 PM



                        IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
                                IN AND FOR OSCEOLA COUNTY FLORIDA

         VILLAS         AT        EMERALD                LAKE
         HOMEOWNERS            ASSOCIATION,            INC., a
         Florida not for profit corporation,

                 Plaintiff,
                                                                      Case No. 2020-CA-002942
         V.

         ROYAL    OAK HOMES,       LLC, a Florida
         limited liability company; ADVANCED
         WRAPPING           AND        CONCRETE
         SOLUTIONS       OF CENTRAL     FLORIDA,
         INC., a Florida Corporation; DON KING’S
         CONCRETE,      INC., a Florida corporation;
         HUGH      MACDONALD      CONSTRUCTION,
         INC.,   a Florida corporation; IMPERIAL
         BUILDING      CORPORATION,      a  Florida
         corporation; PREMIER PLASTERING OF
         CENTRAL      FLORIDA,    INC N/K/A TGK
         STUCCO, INC., a Florida corporation;
         WEATHERMASTER                  BUILDING
         PRODUCTS,        INC.,   a   Florida    corporation;
         WEINTRAUB            INSPECTIONS        &
         FORENSICS,     INC. N/K/A WEINTRAUB
         ENGINEERING AND INSPECTIONS, INC.,
         a   Florida corporation;   THE   DIMILLO
         GROUP, LLC, a Florida limited liability
         company;    WOLF’S       IRRIGATION     &
         LANDSCAPING,         INC., a Florida corporation;
         SUMMERPARK HOMES, INC., a Florida
         corporation; BROWN       +  COMPANY
         ARCHITECTURE,      INC.,   a   Florida
         corporation;

                 Defendants.

                                                                  /

         ROYAL      OAK HOMES,            LLC,     a    Florida
         limited Liability company,

                 Crossclaim Plaintiff,
V.

ADVANCED               WRAPPING             AND
CONCRETE          SOLUTIONS OF          CENTRAL
FLORIDA,     INC., a Florida corporation; DON
KING’S       CONCRETE,       INC.,    a   Florida
corporation;       HUGH         MACDONALD
CONSTRUCTION,           INC.,      a      Florida
corporation;       IMPERIAL          BUILDING
CORPORATION,          a  Florida     corporation;
PREMIER PLASTERING             OF CENTRAL
FLORIDA, INC N/K/A TGK STUCCO, INC.,
a Florida corporation; WEATHERMASTER
BUILDING PRODUCTS, INC., a Florida
corporation; WEINTRAUB INSPECTIONS &
FORENSICS,       INC. N/K/A WEINTRAUB
ENGINEERING AND INSPECTIONS, INC.,
WOLF’S IRRIGATION & LANDSCAPING,
INC., a Florida corporation; BROWN +
COMPANY         ARCHITECTURE, — INC.,             a
Florida corporation;

           Crossclaim Defendants.
                                                     /

WEATHERMASTER                          BUILDING
PRODUCTS,         INC., a Florida corporation,

           Third-Party Plaintiff,

V.

ALL GLASS INSTALLATION CORP., a
Florida corporation; CASEY HAWKINS,
GLASS,    INC.,    a Florida   corporation;   DEAN
NESBIT, LLC, a Florida limited liability
company; HELBERG ENTERPRISES, LLC a
Florida limited liability company; HOBBIT
WINDOWS, LLC, a Florida limited liability
company;     T&M      CONSTRUCTION       OF
SANFORD,       INC., a Florida corporation;
WELL DONE WINDOWS, INC., a Florida
corporation; and WELL HUNG WINDOWS &
DOORS, LLC, a Florida limited liability
company;
Third-Party Defendants.
                                                    /

      THIRD-PARTY DEFENDANT, WELL HUNG WINDOWS & DOORS, LLC’S
       RESPONSES AND OBJECTIONS TO DEFENDANT BROWN + COMPANY
             ARCHITECTURE’S FIRST REQUEST FOR PRODUCTION

        Third-Party Defendant, Well Hung Windows & Doors, LLC, (“WHWD7”) by and through

its undersigned     counsel,   pursuant   to Fla. R. Civ.   P.    1.350,   hereby   files its Responses    and

Objections   to Defendant,      BROWN       + COMPANY            ARCHITECTURE’S          (“BROWN”)        First

Request for Production, as follows:

                                      RESPONSES AND OBJECTIONS

        1         Any and all contracts You entered into related to the Project.

        RESPONSE:

        WHWD       has no documents in its possession, custody, or control responsive to this Request.

        2.        All documents, drawings, specifications or plans prepared by BROWN                that You

examined or relied upon in performing Your scope of service/work for the Project.

        RESPONSE:

        WHWD       has no documents in its possession, custody, or control responsive to this Request.

        3         All documents evidencing or detailing approvals by BROWN related to Your scope

of work at the Project.

        RESPONSE:

        WHWD       has no documents in its possession, custody, or control responsive to this Request.

        4         All documents evidencing or detailing approvals by BROWN related to Your scope

of work at the Project.

        RESPONSE:

        WHWD       has no documents in its possession, custody, or control responsive to this Request.
5      All documents evidencing, or detailing work accepted by BROWN related to Your

scope of work at the Project.

        RESPONSE:

        WHWD     has no documents in its possession, custody, or control responsive to this Request.

        6      All   change     orders,   change    directives,    requests     for    information,     or   similar

documents evidencing changes, modifications, additions, or reductions in Your scope of work at

the Project.

        RESPONSE:

        WHWD     has no documents in its possession, custody, or control responsive to this Request.

        7      All correspondence evidencing changes, modifications, additions, or reductions in

Your scope of work at the Project.

        RESPONSE:

        WHWD     has no documents in its possession, custody, or control responsive to this Request.

        8      All   product      submittals,      product    specifications,         installation     instructions,

maintenance instructions, product manuals, or similar documents for the products, supplies and

building components You installed or constructed at the Project.

        RESPONSE:

        WHWD     has no documents in its possession, custody, or control responsive to this Request.

        9      All   correspondence       concerning     product     submittals,        product      specifications,

installation instructions, maintenance instructions, product manuals, or similar documents for the

products, supplies and building components You installed or constructed at the Project.

        RESPONSE:

        WHWD     has no documents in its possession, custody, or control responsive to this Request.
10.        All invoices, requests for payment, work orders, job tickets, and similar documents

related to Your scope of work for the Project.

        RESPONSE:

        WHWD        has no documents in its possession, custody, or control responsive to this Request.

        11.        Any improper designs and/or specifications that You relied upon at the Project.

        RESPONSE:

        WHWD        has no documents in its possession, custody, or control responsive to this Request.

        12.        All communications between You and BROWN           related to the Project.

        RESPONSE:

        WHWD        has no documents in its possession, custody, or control responsive to this Request.

         13.       All communications exchanged between You and anyone related to the designs

prepared by BROWN         for the Project.

        RESPONSE:

        WHWD        has no documents in its possession, custody, or control responsive to this Request.

         14.       All communications exchanged between You and ROYAL              OAK HOMES,       INC.

for the Project.

        RESPONSE:

        WHWD        has no documents in its possession, custody, or control responsive to this Request.

         15.       All plans, product submittals, designs, construction plans, specifications, or similar

documents and information transmitted or submitted by You to the Osceola County Building

Department for the Project.

        RESPONSE:

        WHWD        has no documents in its possession, custody, or control responsive to this Request.
16.    All permit applications and any related attachments or documents submitted by You

to the Osceola County Building Department for the Project.

           RESPONSE:

           WHWD    has no documents in its possession, custody, or control responsive to this Request.

           17.    All permit applications any related attachments or other documents submitted by

You to any other authority having jurisdiction for the Project.

           RESPONSE:

           WHWD    has no documents in its possession, custody, or control responsive to this Request.

           18.    All Osceola County Product Approval forms related to Your scope of work        at the

Project.

           RESPONSE:

           WHWD    has no documents in its possession, custody, or control responsive to this Request.

           19.    All product approvals from any authority having jurisdiction for the Project related

to Your scope of work for the Project.

           RESPONSE:

           WHWD    has no documents in its possession, custody, or control responsive to this Request.




                                   CERTIFICATE OF SERVICE

           I HEREBY CERTIFY that on the 23" day of June, 2022, I electronically filed the foregoing

with the Clerk of the Court by using the Florida Court’s e-Filing Portal, which will deliver

electronic copies of said filing pursuant to Fla. R. Jud. Admin.       2516 to the designated email

addresses for all counsel of record.

                                         WRIGHT, FULFORD, MOORHEAD                 & BROWN, P.A.
/s/ Cole J. Copertino
COLE J. COPERTINO, ESQUIRE
Florida Bar Number: 76456
505 Maitland Avenue, Suite 1000
Altamonte Springs, Florida 32701
Telephone:   (407) 425-0234
Facsimile:   (407) 425-0260
 copertino@wfmblaw.com
cbraungart@wfmblaw.com
lwilliams@wfmblaw.com
Attorney for Well Hung Windows & Doors, LLC
2611-001