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  • VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION INC vs. ROYAL OAK HOMES LLC CONSTRUCTION DEFECT-OTHER NEGLIGENCE document preview
  • VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION INC vs. ROYAL OAK HOMES LLC CONSTRUCTION DEFECT-OTHER NEGLIGENCE document preview
  • VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION INC vs. ROYAL OAK HOMES LLC CONSTRUCTION DEFECT-OTHER NEGLIGENCE document preview
  • VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION INC vs. ROYAL OAK HOMES LLC CONSTRUCTION DEFECT-OTHER NEGLIGENCE document preview
  • VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION INC vs. ROYAL OAK HOMES LLC CONSTRUCTION DEFECT-OTHER NEGLIGENCE document preview
  • VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION INC vs. ROYAL OAK HOMES LLC CONSTRUCTION DEFECT-OTHER NEGLIGENCE document preview
  • VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION INC vs. ROYAL OAK HOMES LLC CONSTRUCTION DEFECT-OTHER NEGLIGENCE document preview
  • VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION INC vs. ROYAL OAK HOMES LLC CONSTRUCTION DEFECT-OTHER NEGLIGENCE document preview 
						
                                
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                                Filing # 151493680 E-Filed 06/14/2022 04:32:33 PM


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


        VILLAS AT EMERALD LAKE                       CASE NO: 2020-CA-002942
        HOMEOWNERS ASSOCIATION, INC.,

              Plaintiff,

        v.

        ROYAL OAK HOMES, LLC, et al.,

              Defendants.
        _________________________________________/

        ROYAL OAK HOMES, LLC,

              Cross-Claimant,

        v.

        ADVANCED WRAPPING AND CONCRETE
        SOLUTIONS OF CENTRAL FLORIDA, INC.,
        et al.,

               Cross-Defendants.
        _________________________________________/

        WEATHERMASTER BUILDING PRODUCTS,
        INC.

             Third-Party Plaintiff,
        v.

        T&M CONSTRUCTION OF
        SANFORD, INC., et al.,

              Third-Party Defendants.
        _____________________________________/


         THIRD-PARTY DEFENDANTS, RESPONSE TO DEFENDANT, BROWN+ COMPANY
                  ARCHITECTURE, INC.’S, REQUEST FOR PRODUCTION
                                                                        CASE NO.: 2020-CA-002942
                                                                                     2 | Page

       Third-Party Defendants, T&M CONSTRUCTION OF SANFORD, INC. (“T&M”) by and

through the undersigned counsel, in accordance with Florida Rules of Civil Procedure, hereby

responds to DEFENDANT, BROWN+ COMPANY ARCHITECTURE, INC.’S, Request for

Production served on May 20, 2022, as follows:


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

   RESPONSE: T&M will produce all relevant contracts in its possession, in compliance
   with Case Management Order at bates numbers TM000001- TM000004.


2. All documents, drawings, specifications or plans prepared by BROWN that You examined or relied
   upon in performing Your scope of services/work for the Project.

   RESPONSE: T&M objects to this request to the extent that it is overly broad, unduly
   burdensome and not limited in time or scope. Subject to the foregoing objections, none
   in T&M’s possession.


3. All documents evidencing or detailing any inspections performed by BROWN related to Your
   scope of work at the Project.

   RESPONSE: None in T&M’s possession.


4. All documents evidencing or detailing approvals by BROWN related to Your scope of work at the
   Project.

   RESPONSE: None in T&M’s possession.

5. All documents evidencing or detailing work accepted by BROWN related to Your scope of work
   at the Project.

   RESPONSE: None in T&M’s possession.

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: T&M objects to this request to the extent that it is overly broad, unduly
   burdensome and not limited in time or scope. Subject to the foregoing objections, none
   in T&M’s possession.
                                                                            CASE NO.: 2020-CA-002942
                                                                                         3 | Page


7. All correspondence evidencing changes, modifications, additions, or reductions in Your scope of
   work at the Project.


   RESPONSE: T&M objects to this request to the extent that it is overly broad, unduly
   burdensome and not limited in time or scope. Subject to the foregoing objections, none
   in T&M’s possession.

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: None in T&M’s possession.

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: T&M objects to this request as it could be construed as seeking privileged
   attorney-client communications or work product. Subject to the foregoing objection,
   none in T&M’s possession.

10. All invoices, requests for payment, work orders, job tickets, and similar documents related to Your
    scope of work for the Project.

   RESPONSE: T&M will produce all relevant contracts in its possession, in compliance
   with Case Management Order at bates numbers TM000005- TM000008.

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

   RESPONSE: None in T&M’s possession.

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

   RESPONSE: None in T&M’s possession.

13. All communications exchanged between You and anyone related to the designs prepared by
    BROWN for the Project.

   RESPONSE: None in T&M’s possession.

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

   RESPONSE: T&M objects to this request to the extent that it is overly broad, unduly
   burdensome and not limited in time or scope. Subject to the foregoing objections, none
   in T&Ms’ possession.
                                                                             CASE NO.: 2020-CA-002942
                                                                                          4 | Page

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: T&M objects to this request to the extent that it requires the collection and
   production of documents that are contained in public records or are otherwise available
   to the public, as these documents as equally available to the Plaintiff. Subject to the
   foregoing objection, none in T&M’s possession.

16. All permit applications and any related attachments or documents submitted by You to the Osceola
    County Building Department for the Project.


    RESPONSE: T&M objects to this request to the extent that it requires the collection and
    production of documents that are contained in public records or are otherwise available
    to the public, as these documents as equally available to the Plaintiff. Subject to the
    foregoing objection, none in T&M’s possession.


17. All permit applications any related attachments or other documents submitted by You to any other
    authority having jurisdiction for the Project.

    RESPONSE: T&M objects to this request to the extent that it requires the collection and
    production of documents that are contained in public records or are otherwise available
    to the public, as these documents as equally available to the Plaintiff. Subject to the
    foregoing objection, none in T&M’s possession.


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


    RESPONSE: T&M objects to this request to the extent that it requires the collection and
    production of documents that are contained in public records or are otherwise available
    to the public, as these documents as equally available to the Plaintiff. Subject to the
    foregoing objection, none in T&M’s possession.

19. All product approvals from any authority having jurisdiction for the Project related to Your scope
of work for the Project.

    RESPONSE: None in T&M’s possession.




                           [Certificate of service on the following page]