Party Discovery: William Gentry Plaintiff vs. G & H Concrete And Sod Inc, et al Defendant

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                                Filing# 172396859 E-Filed 05/03/2023 07:25:27              PM


                       IN   THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                                        IN AND FOR BROWARD COUNTY,


        WILLIAM GENTRY,                                           CASE   NO.:   CACE21-010718

               Plaintiff(s),

        VS.


        G & H CONCRETE AND SOD, INC.,
        LAKESHORE MANAGEMET, INC., and
        SV DAVIE MHC, LLC,

               Defendant(s).
                                                I




               PLAINTIFF, WILLIAM GENTRY'S NOTICE                    OF SERVING RESPONSES TO
          DEFENDANT, LAKESHORE MANAGEMENT,                         INC.'S, REQUEST FOR PRODUCTION


               COMES NOW,                      WILLIAM
                                   the Plaintiff,               GENTRY, by and through     his   undersigned

        attorney, pursuant to     Fla. R. Civ. P. 1.350,   and gives notice of filingPlaintiffs Responses

        to Defendant,       LAKESHORE MANAGEMENT,               INC.'S, Request for Production and states as

        follows:



              RESPONSE:
         1.


              None.

              RESPONSE:
         2.
              Objection work product. Plaintiff has 14 injuryphotographs taken by Barbara
              Gentry. Plaintiff has 8 scene photographs taken by Barbara Gentry.

              RESPONSE:
         3.


              See   attached.
              RESPONSE:
         4.


              Not applicable.
              RESPONSE:
         5.


              None.




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          *** FILED:   BROWARD COUNTY,     FL   BRENDA D. FORMAN, CLERK 05/03/2023 07:25:27       PM.****
      RESPONSE:
6.


      None.

      RESPONSE:
7.
      Objection work product. Plaintiff has 14 injuryphotographs taken by Barbara
      Gentry. Plaintiff has 8 scene photographs taken by Barbara Gentry.

      RESPONSE:
8
      Objection. The request calls for    Plaintiff to   disclose theirwork product, mental
      impressions and seeks Plaintiffto compile data using their      mental impressions and
      invades Plaintiffs work product.


      RESPONSE:
9.


      None. Not applicable.

      RESPONSE:
10.

      Any documents            by Plaintiff as being produced herein are produced
                           identified

      according to the requests above and below this request. Otherwise, unless
      identified in the   interrogatoryresponses, none.

      RESPONSE:
11.

      None.

      RESPONSE:
12.

      None.

      RESPONSE:
13.

      See   attached.


      RESPONSE:
14.

      See   attached.


      RESPONSE:
15.

      Not   in   possession   of.




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          RESPONSE:
 16.

          See    attached.


          RESPONSE:
 17.

          See    attached.


          RESPONSE:
 18.

          Not    in   possession   of.


          RESPONSE:
 19.

          Not    in   possession   of.


          RESPONSE:
 20.

          None.

                                          CERTIFICATE OF SERVICE

           I   HEREBY CERTIFY that        a true and correct copy of the foregoing was served pursuant to

Fla. R.   Jud. Admin. 2.516 via email       to:   Paul Woodson, Esq.,     LAW OFFICES OF BAUMANN, GANT
& KEELEY,        P.A., Attorney for      Defendant (G&H), 1401 East Broward Boulevard, Suite 200, Fort

Lauderdale, FL 33301; pwoodson@baumannlegal.com; (954) 440-4611, Fax: (954) 440-4613 and

Mark      D. Goldstein, Esq./Dale Friedman, Esq.           CONROY SIMBERG,         3440 Hollywood Boulevard,

2nd   Floor, Hollywood,       FL 33021; (945) 961-1400          email:     eservicehwd@conroysimberg.com;

dfriedman@conroysimberg.com; mgoldstein@conroysimberg.com                        this the   3rd day of May, 2023.

                                                               COFFEY IMCPHARLIN
                                                               550   S.   Andrews Ave.
                                                               Suite 600
                                                               Fort Lauderdale, FL 33301
                                                                             -
                                                               (954) 541-3194 Main
                                                                             -
                                                               (954) 780-8668 Fax



                                                           By: Todd McPharlin
                                                               TODD       R.   MCPHARLIN
                                                               Florida Bar #: 114685




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