On June 13, 2023 a
No Value
was filed
involving a dispute between
Ksd Partners, Llc, An Ohio Limited Liability Compa,
and
Fileman Law Firm, P.A., A Florida Corporation,
Punta Gorda Health Investors, Llc, A Florida Limit,
for Contracts
in the District Court of Charlotte County.
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Filing # 181938735 E-Filed 09/15/2023 04:03:22 PM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA
KSD PARTNERS, LLC, an
Ohio limited liability company,
Plaintiff,
VS. CASE: 2023-002230-CA
PUNTA GORDA HEALTH
INVESTORS, LLC, a Florida limited
liability company,
Defendant. /
RESPONSE TO DEFENDANT’S FIRST REQUEST TO PRODUCE
Plaintiff, KSD PARTNERS, LLC., by and through its undersigned attorney, hereby files
its Response to Defendant’s First Request to Produce dated August 10, 2023, and states as follows:
GENERAL OBJECTIONS
The following general objections, individually and collectively, are specifically directed to
and incorporated by reference in Plaintiff's Response to Defendant’s First Request to Produce:
a. Plaintiff objects to Defendant’s First Request to Produce to the extent the directions
and/or requests stated therein modify, abridge or otherwise alter the Plaintiff's rights and
obligations established pursuant to applicable Florida Rules of Civil Procedure and case law.
b Plaintiff objects to Defendant’s First Request to Produce to the extent the directions
and/or requests stated therein seek discovery of information protected by the attorney/client
privilege, or information which constitutes work product or trial preparation materials.
¢. A response that the requested documents will be produced does not mean that any
and/or all of the documents exist. It means only that, subject to and as limited by these General
Objections, the documents will be produced to the extent that they exist and the documents are
under one of Plaintiff's control.
Page 1 of 3
SPECIFIC RESPONSES AND OBJECTIONS
Without waiving the foregoing general objections, and expressly reserving the same,
Plaintiff further asserts its specific responses and objections to Defendant’s First Request to
Produce as set forth herein below.
RESPONSE TO DEFENDANT’S FIRST REQUEST TO PRODUCE
1 Any and all communications with any third-party regarding the allegations raised
in Plaintiff's Complaint.
RESPONSE: Documents responsive to this request that are in the custody and
control of Defendant will be produced under separate cover at a mutually convenient date and time
at the sole expense of Plaintiff.
2. Any and all communications or documents exchanged between the Plaintiff and
Defendants,
RESPONSE: Documents responsive to this request that are in the custody and
control of Defendant will be produced under separate cover at a mutually convenient date and time
at the sole expense of Plaintiff.
3 Any and all documents that you intend or anticipate you will use and/or offer into
evidence at the trial of this matter.
RESPONSE: Not yet determined.
4 All documents reviewed, received or considered by an expert that you intend to call
as a witness at trial.
RESPONSE: Not yet determined.
5 Your entire file pertaining to the contract entered into between the parties.
RESPONSE: Documents responsive to this request that are in the custody and
control of Defendant will be produced under separate cover at a mutually convenient date and time
Page 2 of 3
at the sole expense of Plaintiff.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY a true and correct copy of the foregoing was served via the e-filing
portal to all counsel of record this 15 day of September, 2023.
LAW OFFICE OF JURSINSKI & MURPHY, PLLC
15701 South Tamiami Trail
Fort Myers, Florida 33908
Tel: (239) 337-1147
lol Keuiu F. Yursiushi
By:
Kevin F. Jursinski, Esq.
Florida Bar: 318851
Page 3 of 3
Document Filed Date
January 03, 2024
Case Filing Date
June 13, 2023
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Filing # 181938735 E-Filed 09/15/2023 04:03:22 PM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA KSD PARTNERS, LLC, an Ohio limited liability company, Plaintiff, VS. CASE: 2023-002230-CA PUNTA GORDA HEALTH INVESTORS, LLC, a Florida limited liability company, Defendant. / RESPONSE TO DEFENDANT’S FIRST REQUEST TO PRODUCE Plaintiff, KSD PARTNERS, LLC., by and through its undersigned attorney, hereby files its Response to Defendant’s First Request to Produce dated August 10, 2023, and states as follows: GENERAL OBJECTIONS The following general objections, individually and collectively, are specifically directed to and incorporated by reference in Plaintiff's Response to Defendant’s First Request to Produce: a. Plaintiff objects to Defendant’s First Request to Produce to the extent the directions and/or requests stated therein modify, abridge or otherwise alter the Plaintiff's rights and obligations established pursuant to applicable Florida Rules of Civil Procedure and case law. b Plaintiff objects to Defendant’s First Request to Produce to the extent the directions and/or requests stated therein seek discovery of information protected by the attorney/client privilege, or information which constitutes work product or trial preparation materials. ¢. A response that the requested documents will be produced does not mean that any and/or all of the documents exist. It means only that, subject to and as limited by these General Objections, the documents will be produced to the extent that they exist and the documents are under one of Plaintiff's control. Page 1 of 3 SPECIFIC RESPONSES AND OBJECTIONS Without waiving the foregoing general objections, and expressly reserving the same, Plaintiff further asserts its specific responses and objections to Defendant’s First Request to Produce as set forth herein below. RESPONSE TO DEFENDANT’S FIRST REQUEST TO PRODUCE 1 Any and all communications with any third-party regarding the allegations raised in Plaintiff's Complaint. RESPONSE: Documents responsive to this request that are in the custody and control of Defendant will be produced under separate cover at a mutually convenient date and time at the sole expense of Plaintiff. 2. Any and all communications or documents exchanged between the Plaintiff and Defendants, RESPONSE: Documents responsive to this request that are in the custody and control of Defendant will be produced under separate cover at a mutually convenient date and time at the sole expense of Plaintiff. 3 Any and all documents that you intend or anticipate you will use and/or offer into evidence at the trial of this matter. RESPONSE: Not yet determined. 4 All documents reviewed, received or considered by an expert that you intend to call as a witness at trial. RESPONSE: Not yet determined. 5 Your entire file pertaining to the contract entered into between the parties. RESPONSE: Documents responsive to this request that are in the custody and control of Defendant will be produced under separate cover at a mutually convenient date and time Page 2 of 3 at the sole expense of Plaintiff. CERTIFICATE OF SERVICE I HEREBY CERTIFY a true and correct copy of the foregoing was served via the e-filing portal to all counsel of record this 15 day of September, 2023. LAW OFFICE OF JURSINSKI & MURPHY, PLLC 15701 South Tamiami Trail Fort Myers, Florida 33908 Tel: (239) 337-1147 lol Keuiu F. Yursiushi By: Kevin F. Jursinski, Esq. Florida Bar: 318851 Page 3 of 3