Preview
Filing # 175207487 E-Filed 06/13/2023 01:05:46 PM
IN THE CIRCUIT COURT, FOURTH
JUDICIAL CIRCUIT, IN AND FOR
DUVAL COUNTY, FLORIDA
CASE NO.: 16-2022-CA-006853
DIVISION: CV-B
JEROME BONNETT, an individual,
Plaintiff,
v.
JAX PRO CONSTRUCTION, INC.,
a Florida corporation,
Defendant.
______________________________________/
PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT
Plaintiff, JEROME BONNETT (“Bonnett”), through the undersigned attorney and
pursuant to Florida Rule of Civil Procedure 1.350, does hereby request Defendant, JAX PRO
CONSTRUCTION, INC. (“JAX PRO”), produce the following:
Instructions
1. Whenever “documents” are requested, that term shall be defined in accordance with
the definitions included herein.
2. If any of the documents requested herein were formally in the possession, custody
or control of JAX PRO and have been destroyed, that document shall be identified by author(s),
addressee(s), date, subject matter, number of pages, attachments or pendencies, all persons to
whom distributed, shown or explained, all persons who had custody of each said document, the
date of destruction, and the name and title of the person who ordered the destruction.
3. If any documents otherwise required to be produced by this request are withheld,
the document shall be identified by stating its date, author, a short description of the content,
recipients, and reason for withholding.
4. If any documents requested are withheld under a claim of privilege, identify each
such document and state the date of the document, identify its author and addressee and each
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 06/13/2023 01:43:59 PM
person to whom copies of the document were furnished or to whom the contents were
communicated, provide a summary of the subject matter of the document, its present location and
custodian, the basis upon which the asserted privilege is claimed, and the request to which the
document is responsive.
5. All documents requested in each individual paragraph shall be produced. While the
request in one paragraph may be more specific or limited in scope than a request contained in
another paragraph, it in no way limits or defines the scope of that paragraph.
6. Documents shall be produced as they are kept in the regular course of business or
in the alternative, organized and labeled so as to correspond to the categories of the request.
7. This Request for Production of Documents is continuing in nature so as to require
the Defendant to immediately provide such additional information as they, its counsel, or anyone
acting on behalf of, or in concert with it may have or may obtain between the time the documents
responsive to this request are produced are produced and the time of trial.
Definitions
1. The term “documents” shall mean the original, and if not available, any copy of the
original, of writings of every kind, manner, description, including, but not limited to, any abstracts,
accounts, accountings, agreements, appointment books, appointment records, audio recordings
(whether transcribed or not), balance sheets, bids, bid evaluations, bid summaries, bid tabulations,
bills, bills of lading, blanks, books, books of account, cable grams, calculations, calendars, cards,
certificates, change orders, charters, charts, checks, communications, comments, compilations
from which information can be obtained or translated through detection devices, computer guards,
computer disks, computer printouts, computer programs, computer tapes, contracts,
correspondence, cost estimates, cost records, construction progress charts, construction progress
conference minutes, delivery records, diaries, disks, drafts, drafts of documents, drawings,
electronic or mechanical recordation in whatever medium, endorsements, entries, estimates,
expense accounts, expense reports, evaluations, field books, field correspondence, field
memoranda, field notes, field orders, field reports, files, films, financial analyses, financial reports,
financial statements, forms, graphs, handbooks, income reports, income statements, indices,
instructions, instruments, inter-office and intra office communications, invoices, itemizations, job
minutes, letters, licenses, logs, magnetic tapes, mail grams, manuals, meeting reports, memoranda,
memos, messages, microform, microfiche, minutes, moving pictures, notes, notices, opinions,
order forms, orders, papers, paper memoranda, pillar records, permits, phonograph records,
photocopies, photographs, pictures, planographs, plans, plats, preliminary sketches or drawings,
prospectuses, publications, receipts, recordings, records, records of account, renderings, statistical
records, studies, sub-contracts, summaries, surveys, system analyses, tapes, telexes, telegrams
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teletype messages, tests, test reports, text, timecards, time records, training manuals, training
materials, transcripts, transcriptions or summaries of conversations, transmittal letters or memos,
transmittals, warehouse receipts, and other electronic or mechanical recordings or transcripts or
any other instrument or device from which information can be perceived, or which is used to
memorialized human thought, speech or in JAX PRO’s possession, custody or control, wherever
located. The term “documents” also includes copies containing information whatsoever in
addition to that contained on the original and copies which differ from the original in any way
whatsoever as well as any and all amendments, modifications, alternations, and changes to any of
the documents described in this Request. The term “documents” shall also include all the
attachments, and quarters or documents referred to in any document described in this Request.
2. “Relating to” and “related to” mean to constitute, refer to, reflect, mention,
evidence, concern, pertain to, identify, or in any way logically or factually connected with the
matter requested.
3. The term “you” and “your” means the party to whom these requests are addressed,
including the party’s employees and agents and all other persons acting or purporting to act on the
party’s behalf.
4. The term “Person” shall refer to any individual, corporation, partnership,
association, joint venture, sole proprietorship, form or other entity, along with their respective
parents, subsidiaries, affiliates, divisions, partners, officers, directors, stockholders, agents,
employees, consultations, advisors, attorneys, independent contractors, and any other related
person or persons acting on his, her or their behalf.
5. The terms “communication” and “correspondence” shall mean every manner or
means of disclosure, transfer or exchange, and every disclosure, transfer or exchange of
information whether orally or face-to-face, or by telephone, mail, e-mail, personal delivery,
commercial delivery, document, or otherwise.
6. The term “or” shall be construed to either conjunctively or disjunctively to bring
within the scope of these requests any information which might otherwise be construed to be
outside their scope.
7. The term “any” shall mean any and all. The term all shall mean any and all.
8. “Complaint” or “Litigation” shall refer to the action styled Jerome Bonnett v. Jax
Pro Construction, Inc., which in the Circuit Court, for the 4th Judicial Circuit, in and for Duval
County, Florida and is number 16-2022-CA-006853.
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9. “Bonnett Project” or “Project” shall refer to the project identified in Exhibit A of
Bonnett’s Complaint.
10. “Owner” shall mean Jerome Bonnett.
11. “Jax Pro” shall mean Yossi Kaslasi, Jax Pro Construction Inc., any and all
employees of Jax Pro Construction Inc., any and all representatives, agents, etc. of Jax Pro
Construction Inc.
DOCUMENTS TO BE PRODUCED
RELATING TO THE BONNETT PROJECT:
1. Your entire construction file related to the Bonnett Project, including, but not limited
to, plans, drawings, specifications, permits, inspection reports.
2. All contracts, subcontracts, documents, proposals relating to each and every
subcontractor, supplier, materialman, tradesman, worker, etc. that provided a bid, pricing, proposal
etc. for any scope of work on the Project. including all subcontracts, modifications, addendums,
change orders, drawings, plans, specifications, photographs, schedules, etc. related to the Bonnett
Project.
3. Contact information for each and every subcontractor, supplier, materialman,
tradesman, worker, etc. engaged in any work or supply relating to the Project including scope of
work, name of company, name of contact person, address, phone number, email, and all other
contact information.
4. A detailed job cost accounting report (spreadsheet, report, printout, register, etc.) of
all construction costs incurred on the Project showing type of payment made (i.e. check, credit card
charge, cash, etc.) including payee, check number, date and category of payment, (i.e. framing
labor, drywall, electrical, plumbing, etc.)
5. Receipts for all costs incurred on the Project including any and all cancelled checks,
credit card receipts, statements, invoices, including but not limited to any forms of evidence of
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payments made by Jax Pro for any cost incurred on the Bonnett Project.
6. A detailed accounting of all payments received by Jax Pro from Owner regarding the
Project. Including all payments on the contract, any change orders,
7. All communications or correspondences, including email, text messages, letters, etc.,
exchanged between Bonnett and Jax Pro from March 23, 2018, to present.
8. Any and all expert, retained or consulting, reports related to the Bonnett Project
including all contact information for such expert or consultant.
9. All daily, weekly or monthly job logs, progress reports, etc., for the Bonnett Project.
10. All timesheets for Jax Pro employees, subcontractors, independent contractors, agents,
etc. for the Bonnett Project.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been filed on the
State of Florida’s E-Filing Portal on June 13, 2023, causing a true and correct copy to be served to
all counsel of record:
Alan D. Henderson, Esq.
Henderson Law, P.A.
230 Canal Blvd., Ste 3
Ponte Vedra Beach, FL 32082
ahenderson@hendersonlawjax.net
Willis · Lucas Law Group, P.A.,
/s/ David H. Willis
David H. Willis / Fla. Bar No.: 48820
E-mail: david@willislucaslaw.com
Jonathan B.B. Lucas / Fla. Bar No.: 89823
E-mail: jonathan@willislucaslaw.com
Willis ∙ Lucas Law Group, P.A.
320 First Street N., Suite 613
Jacksonville Beach, FL 32250
Pleadings to: service@willislucaslaw.com
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(904) 270-8707 (Office)
Attorneys for Jerome Bonnett
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Preview
Filing # 175207487 E-Filed 06/13/2023 01:05:46 PM IN THE CIRCUIT COURT, FOURTH JUDICIAL CIRCUIT, IN AND FOR DUVAL COUNTY, FLORIDA CASE NO.: 16-2022-CA-006853 DIVISION: CV-B JEROME BONNETT, an individual, Plaintiff, v. JAX PRO CONSTRUCTION, INC., a Florida corporation, Defendant. ______________________________________/ PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT Plaintiff, JEROME BONNETT (“Bonnett”), through the undersigned attorney and pursuant to Florida Rule of Civil Procedure 1.350, does hereby request Defendant, JAX PRO CONSTRUCTION, INC. (“JAX PRO”), produce the following: Instructions 1. Whenever “documents” are requested, that term shall be defined in accordance with the definitions included herein. 2. If any of the documents requested herein were formally in the possession, custody or control of JAX PRO and have been destroyed, that document shall be identified by author(s), addressee(s), date, subject matter, number of pages, attachments or pendencies, all persons to whom distributed, shown or explained, all persons who had custody of each said document, the date of destruction, and the name and title of the person who ordered the destruction. 3. If any documents otherwise required to be produced by this request are withheld, the document shall be identified by stating its date, author, a short description of the content, recipients, and reason for withholding. 4. If any documents requested are withheld under a claim of privilege, identify each such document and state the date of the document, identify its author and addressee and each ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 06/13/2023 01:43:59 PM person to whom copies of the document were furnished or to whom the contents were communicated, provide a summary of the subject matter of the document, its present location and custodian, the basis upon which the asserted privilege is claimed, and the request to which the document is responsive. 5. All documents requested in each individual paragraph shall be produced. While the request in one paragraph may be more specific or limited in scope than a request contained in another paragraph, it in no way limits or defines the scope of that paragraph. 6. Documents shall be produced as they are kept in the regular course of business or in the alternative, organized and labeled so as to correspond to the categories of the request. 7. This Request for Production of Documents is continuing in nature so as to require the Defendant to immediately provide such additional information as they, its counsel, or anyone acting on behalf of, or in concert with it may have or may obtain between the time the documents responsive to this request are produced are produced and the time of trial. Definitions 1. The term “documents” shall mean the original, and if not available, any copy of the original, of writings of every kind, manner, description, including, but not limited to, any abstracts, accounts, accountings, agreements, appointment books, appointment records, audio recordings (whether transcribed or not), balance sheets, bids, bid evaluations, bid summaries, bid tabulations, bills, bills of lading, blanks, books, books of account, cable grams, calculations, calendars, cards, certificates, change orders, charters, charts, checks, communications, comments, compilations from which information can be obtained or translated through detection devices, computer guards, computer disks, computer printouts, computer programs, computer tapes, contracts, correspondence, cost estimates, cost records, construction progress charts, construction progress conference minutes, delivery records, diaries, disks, drafts, drafts of documents, drawings, electronic or mechanical recordation in whatever medium, endorsements, entries, estimates, expense accounts, expense reports, evaluations, field books, field correspondence, field memoranda, field notes, field orders, field reports, files, films, financial analyses, financial reports, financial statements, forms, graphs, handbooks, income reports, income statements, indices, instructions, instruments, inter-office and intra office communications, invoices, itemizations, job minutes, letters, licenses, logs, magnetic tapes, mail grams, manuals, meeting reports, memoranda, memos, messages, microform, microfiche, minutes, moving pictures, notes, notices, opinions, order forms, orders, papers, paper memoranda, pillar records, permits, phonograph records, photocopies, photographs, pictures, planographs, plans, plats, preliminary sketches or drawings, prospectuses, publications, receipts, recordings, records, records of account, renderings, statistical records, studies, sub-contracts, summaries, surveys, system analyses, tapes, telexes, telegrams 2 teletype messages, tests, test reports, text, timecards, time records, training manuals, training materials, transcripts, transcriptions or summaries of conversations, transmittal letters or memos, transmittals, warehouse receipts, and other electronic or mechanical recordings or transcripts or any other instrument or device from which information can be perceived, or which is used to memorialized human thought, speech or in JAX PRO’s possession, custody or control, wherever located. The term “documents” also includes copies containing information whatsoever in addition to that contained on the original and copies which differ from the original in any way whatsoever as well as any and all amendments, modifications, alternations, and changes to any of the documents described in this Request. The term “documents” shall also include all the attachments, and quarters or documents referred to in any document described in this Request. 2. “Relating to” and “related to” mean to constitute, refer to, reflect, mention, evidence, concern, pertain to, identify, or in any way logically or factually connected with the matter requested. 3. The term “you” and “your” means the party to whom these requests are addressed, including the party’s employees and agents and all other persons acting or purporting to act on the party’s behalf. 4. The term “Person” shall refer to any individual, corporation, partnership, association, joint venture, sole proprietorship, form or other entity, along with their respective parents, subsidiaries, affiliates, divisions, partners, officers, directors, stockholders, agents, employees, consultations, advisors, attorneys, independent contractors, and any other related person or persons acting on his, her or their behalf. 5. The terms “communication” and “correspondence” shall mean every manner or means of disclosure, transfer or exchange, and every disclosure, transfer or exchange of information whether orally or face-to-face, or by telephone, mail, e-mail, personal delivery, commercial delivery, document, or otherwise. 6. The term “or” shall be construed to either conjunctively or disjunctively to bring within the scope of these requests any information which might otherwise be construed to be outside their scope. 7. The term “any” shall mean any and all. The term all shall mean any and all. 8. “Complaint” or “Litigation” shall refer to the action styled Jerome Bonnett v. Jax Pro Construction, Inc., which in the Circuit Court, for the 4th Judicial Circuit, in and for Duval County, Florida and is number 16-2022-CA-006853. 3 9. “Bonnett Project” or “Project” shall refer to the project identified in Exhibit A of Bonnett’s Complaint. 10. “Owner” shall mean Jerome Bonnett. 11. “Jax Pro” shall mean Yossi Kaslasi, Jax Pro Construction Inc., any and all employees of Jax Pro Construction Inc., any and all representatives, agents, etc. of Jax Pro Construction Inc. DOCUMENTS TO BE PRODUCED RELATING TO THE BONNETT PROJECT: 1. Your entire construction file related to the Bonnett Project, including, but not limited to, plans, drawings, specifications, permits, inspection reports. 2. All contracts, subcontracts, documents, proposals relating to each and every subcontractor, supplier, materialman, tradesman, worker, etc. that provided a bid, pricing, proposal etc. for any scope of work on the Project. including all subcontracts, modifications, addendums, change orders, drawings, plans, specifications, photographs, schedules, etc. related to the Bonnett Project. 3. Contact information for each and every subcontractor, supplier, materialman, tradesman, worker, etc. engaged in any work or supply relating to the Project including scope of work, name of company, name of contact person, address, phone number, email, and all other contact information. 4. A detailed job cost accounting report (spreadsheet, report, printout, register, etc.) of all construction costs incurred on the Project showing type of payment made (i.e. check, credit card charge, cash, etc.) including payee, check number, date and category of payment, (i.e. framing labor, drywall, electrical, plumbing, etc.) 5. Receipts for all costs incurred on the Project including any and all cancelled checks, credit card receipts, statements, invoices, including but not limited to any forms of evidence of 4 payments made by Jax Pro for any cost incurred on the Bonnett Project. 6. A detailed accounting of all payments received by Jax Pro from Owner regarding the Project. Including all payments on the contract, any change orders, 7. All communications or correspondences, including email, text messages, letters, etc., exchanged between Bonnett and Jax Pro from March 23, 2018, to present. 8. Any and all expert, retained or consulting, reports related to the Bonnett Project including all contact information for such expert or consultant. 9. All daily, weekly or monthly job logs, progress reports, etc., for the Bonnett Project. 10. All timesheets for Jax Pro employees, subcontractors, independent contractors, agents, etc. for the Bonnett Project. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been filed on the State of Florida’s E-Filing Portal on June 13, 2023, causing a true and correct copy to be served to all counsel of record: Alan D. Henderson, Esq. Henderson Law, P.A. 230 Canal Blvd., Ste 3 Ponte Vedra Beach, FL 32082 ahenderson@hendersonlawjax.net Willis · Lucas Law Group, P.A., /s/ David H. Willis David H. Willis / Fla. Bar No.: 48820 E-mail: david@willislucaslaw.com Jonathan B.B. Lucas / Fla. Bar No.: 89823 E-mail: jonathan@willislucaslaw.com Willis ∙ Lucas Law Group, P.A. 320 First Street N., Suite 613 Jacksonville Beach, FL 32250 Pleadings to: service@willislucaslaw.com 5 (904) 270-8707 (Office) Attorneys for Jerome Bonnett 6