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Filing# 166426988 E-Filed 02/08/2023 04:58:06 PM
AWA-34896B/:JNM
INTHE CIRCUIT COURT, 17TH
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE21010715
JUSTIN BLEVINS,
Plaintiff,
V.
ORVILL WEIR, CAMBRIDGE SECURITY SERVICES
CORP., A FLA CORP., AND WESTON
APARTMENTS CORP., D/B/A WESTON PLACE
APARTMENTS, A FLA CORP.,
Defendants.
DEFENDANTS RESPONSE TO DEFENDANT, WESTON APARTMENTS CORP., D/B/A WESTON
PLACE APARTMENTS REQUEST FOR PRODUCTION #5
Defendants, ORVILL WEIR and CAMBRIDGE SECURITY SERVICES CORP., by and through
its undersigned attorneys, and pursuant to Florida Rules of Civil Procedure, files its Response to
Defendant, WESTON APARTMENTS CORP., D/B/A WESTON PLACE APARTMENTS Request for
Production served on served with the Complaint, and states:
1. A copy of the
entire personnel file for ORVILL WEIR including, but not limited to, employment
application, income or payment information, W-2 forms, W-4 forms, 1099 forms, tax
information, bonus, salary and other compensation records, attendance records, sick days,
vacation or other time missed, hours and days worked, contract for employment, accident or
Worker's Compensation Claim information, medical evaluation, treatment, testing or histories,
record of treatment, medical bills incurred or paid, health, life,disabilityand accidental death
insurance applications, insurance claims, payment or other information, company reviews or
recommendations on work performance, promotions, demotions or change in job duties or
functions, any description of job duties and ability to perform those duties, termination
information, background screening reports, and pre-employment drug testing results.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/08/2023 04:58:06 PM.****
Case No.: CACE21010715
Page 2
RESPONSE: Attached.
2. A copy of safety manuals or videos, inspection manuals or videos, and training manuals or
videos given or shown to ORVILL WEIR during his employment with CAMBRIDGE SECURITY
SERVICES CORP.
RESPONSE: Attached.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via
Electronic Mail, to all counsel of record on the attached Service List,this *b day of February
2023.
LUKS, SANTANIELLO, PETRILLO,
COHEN & PETERFRIEND
Attorneys for Defendant
301 Yamato Road, Suite 4150
Boca Raton, FL 33431
Telephone: (561) 893-9088
Facsimile: (561) 893-9048
By: /s/James Sparkman
T.
DANIEL J. SANTANIELLO
Florida Bar No.: 860948
JAMES T. SPARKMAN
Florida Bar No.: 396966
LUKSBOCA-PIeadings@LS-Law.com
Case No.: CACE21010715
Page 3
SERVICE LIST
Counsel for Plaintiff:
Elie Anidjar, Esquire
LAW OFFICES OF ANIDJAR & LEVINE, P.A.
300 SE 17 Street
Ft. Lauderdale, FL 33316
PLEADINGS@ANL-LAW.COM
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Filing# 166426988 E-Filed 02/08/2023 04:58:06 PM AWA-34896B/:JNM INTHE CIRCUIT COURT, 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE21010715 JUSTIN BLEVINS, Plaintiff, V. ORVILL WEIR, CAMBRIDGE SECURITY SERVICES CORP., A FLA CORP., AND WESTON APARTMENTS CORP., D/B/A WESTON PLACE APARTMENTS, A FLA CORP., Defendants. DEFENDANTS RESPONSE TO DEFENDANT, WESTON APARTMENTS CORP., D/B/A WESTON PLACE APARTMENTS REQUEST FOR PRODUCTION #5 Defendants, ORVILL WEIR and CAMBRIDGE SECURITY SERVICES CORP., by and through its undersigned attorneys, and pursuant to Florida Rules of Civil Procedure, files its Response to Defendant, WESTON APARTMENTS CORP., D/B/A WESTON PLACE APARTMENTS Request for Production served on served with the Complaint, and states: 1. A copy of the entire personnel file for ORVILL WEIR including, but not limited to, employment application, income or payment information, W-2 forms, W-4 forms, 1099 forms, tax information, bonus, salary and other compensation records, attendance records, sick days, vacation or other time missed, hours and days worked, contract for employment, accident or Worker's Compensation Claim information, medical evaluation, treatment, testing or histories, record of treatment, medical bills incurred or paid, health, life,disabilityand accidental death insurance applications, insurance claims, payment or other information, company reviews or recommendations on work performance, promotions, demotions or change in job duties or functions, any description of job duties and ability to perform those duties, termination information, background screening reports, and pre-employment drug testing results. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/08/2023 04:58:06 PM.**** Case No.: CACE21010715 Page 2 RESPONSE: Attached. 2. A copy of safety manuals or videos, inspection manuals or videos, and training manuals or videos given or shown to ORVILL WEIR during his employment with CAMBRIDGE SECURITY SERVICES CORP. RESPONSE: Attached. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via Electronic Mail, to all counsel of record on the attached Service List,this *b day of February 2023. LUKS, SANTANIELLO, PETRILLO, COHEN & PETERFRIEND Attorneys for Defendant 301 Yamato Road, Suite 4150 Boca Raton, FL 33431 Telephone: (561) 893-9088 Facsimile: (561) 893-9048 By: /s/James Sparkman T. DANIEL J. SANTANIELLO Florida Bar No.: 860948 JAMES T. SPARKMAN Florida Bar No.: 396966 LUKSBOCA-PIeadings@LS-Law.com Case No.: CACE21010715 Page 3 SERVICE LIST Counsel for Plaintiff: Elie Anidjar, Esquire LAW OFFICES OF ANIDJAR & LEVINE, P.A. 300 SE 17 Street Ft. Lauderdale, FL 33316 PLEADINGS@ANL-LAW.COM