On September 08, 2021 a
was filed
involving a dispute between
Stayton, Robert Jl,
and
Celebration Community Development District,
for CIRCUIT CIVIL
in the District Court of Osceola County.
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Filing # 155062584 E-Filed 08/10/2022 02:39:12 PM
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT, IN
AND FOR OSCEOLA COUNTY,
FLORIDA
ROBERT J.L. STAYTON, CASE NO.: 2021-CA-2435
Plaintiff,
Vv.
CELEBRATION COMMUNITY
DEVELOPMENT DISTRICT,
Defendant.
DEFENDANT’S AMENDED RESPONSES TO PLAINTIFF’S REQUEST FOR
PRODUCTION # 9, 10, 11, AND 12, PER THE COURT’S JULY 21, 2022 ORDER
COMES NOW the Defendant, CELEBRATION COMMUNITY DEVELOPMENT
DISTRICT, by and through its undersigned counsel and, pursuant to Florida Rule of Civil
Procedure 11.350, hereby files their Responses to Plaintiff's Request for Production.
9 Copies of any policy and procedures, manuals, memoranda, bulletins, directives or
other documents which purport or attempt to direct, advise, guide, control or reference in any
other manner which provides instruction on/or repairs of the condition of the sidewalk on
the comer of Campus Street and Celebration Avenue in effect on January 16, 2021.
RESPONSE: Defendant is not in possession of any documents which provide
instruction of the repairs to the sidewalk that is the subject of this suit.
Case No.: 2021-CA-2435
10. Copies of any work schedules or other personnel documentation indicating the
names of employees who had knowledge of sidewalk disrepair or damages on the January 16,
2021.
RESPONSE: Please see the attached service request and work order in response to
this request.
LL. Copies of any compilation logs, incident reports, exhibits or other documents
regarding the memorialization or listing of any and all complaints and/or incidents involving trips
or falls that occurred within the premises maintained by the Defendant C.C.D.D., located at the
sidewalk on the corner of Campus Street and Celebration Avenue, Osceola County, Florida,
for the years of 2017 through 2020.
RESPONSE: Defendant is not in possession of any documents responsive to this
request.
12. Copies of any non-privileged incident reports, exhibits or other documents
regarding the memorialization of the incident that is the subject of this Complaint.
RESPONSE: Please see the attached service request and work order in response to
this request.
CERTIFICATE OF SERVICE
1 HEREBY CERTIFY that on this 10" day of August, 2022 a true and correct copy of the
foregoing has been furnished via E-Service, compliant with Rule of Judicial Administration 2.516,
to; mramos-toja@boginmunns.com; bmmservice@boginmunns.com.
Case No.: 2021-CA-2435
KELLEY KRONENBERG
Attorneys for Defendant
20 North Orange Avenue, Suite 1207
Orlando, Florida 32801
Phone: (407) 648-9450
Fax: (407) 648-4167
Primary: dgordon@kelleykronenberg.com
Secondary: dshpleadings@kelleykronenberg.com
Tertiary: kphilipson@kelleykronenberg.com
By: /s/ DavidM. Gordon
DAVID M. GORDON, ESQ.
Florida Bar No.: 115723
Document Filed Date
November 03, 2023
Case Filing Date
September 08, 2021
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Filing # 155062584 E-Filed 08/10/2022 02:39:12 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA ROBERT J.L. STAYTON, CASE NO.: 2021-CA-2435 Plaintiff, Vv. CELEBRATION COMMUNITY DEVELOPMENT DISTRICT, Defendant. DEFENDANT’S AMENDED RESPONSES TO PLAINTIFF’S REQUEST FOR PRODUCTION # 9, 10, 11, AND 12, PER THE COURT’S JULY 21, 2022 ORDER COMES NOW the Defendant, CELEBRATION COMMUNITY DEVELOPMENT DISTRICT, by and through its undersigned counsel and, pursuant to Florida Rule of Civil Procedure 11.350, hereby files their Responses to Plaintiff's Request for Production. 9 Copies of any policy and procedures, manuals, memoranda, bulletins, directives or other documents which purport or attempt to direct, advise, guide, control or reference in any other manner which provides instruction on/or repairs of the condition of the sidewalk on the comer of Campus Street and Celebration Avenue in effect on January 16, 2021. RESPONSE: Defendant is not in possession of any documents which provide instruction of the repairs to the sidewalk that is the subject of this suit. Case No.: 2021-CA-2435 10. Copies of any work schedules or other personnel documentation indicating the names of employees who had knowledge of sidewalk disrepair or damages on the January 16, 2021. RESPONSE: Please see the attached service request and work order in response to this request. LL. Copies of any compilation logs, incident reports, exhibits or other documents regarding the memorialization or listing of any and all complaints and/or incidents involving trips or falls that occurred within the premises maintained by the Defendant C.C.D.D., located at the sidewalk on the corner of Campus Street and Celebration Avenue, Osceola County, Florida, for the years of 2017 through 2020. RESPONSE: Defendant is not in possession of any documents responsive to this request. 12. Copies of any non-privileged incident reports, exhibits or other documents regarding the memorialization of the incident that is the subject of this Complaint. RESPONSE: Please see the attached service request and work order in response to this request. CERTIFICATE OF SERVICE 1 HEREBY CERTIFY that on this 10" day of August, 2022 a true and correct copy of the foregoing has been furnished via E-Service, compliant with Rule of Judicial Administration 2.516, to; mramos-toja@boginmunns.com; bmmservice@boginmunns.com. Case No.: 2021-CA-2435 KELLEY KRONENBERG Attorneys for Defendant 20 North Orange Avenue, Suite 1207 Orlando, Florida 32801 Phone: (407) 648-9450 Fax: (407) 648-4167 Primary: dgordon@kelleykronenberg.com Secondary: dshpleadings@kelleykronenberg.com Tertiary: kphilipson@kelleykronenberg.com By: /s/ DavidM. Gordon DAVID M. GORDON, ESQ. Florida Bar No.: 115723