Legal Document: Thermoset Roofing Corp, et al Plaintiff vs. Turn Two Electric Inc, et al Defendant

On May 03, 2021 a Joint Pre-Trial Stipulation was filed involving a dispute between Lattibeaudiere, Lashawn, Thermoset Roofing Corp, Turn Two Electric Inc, and Lattibeaudiere, Lashawn, Thermoset Roofing Corp., Turn Two Electric Inc, for Contract and Indebtedness in the District Court of Broward County.

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Filing# 170646732 E-Filed 04/10/2023 01:22:55 PM

IN THE CIRCUIT COURT IN THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA

CASE NO.: CACE-21-008854
DIVISION: 21

THERMOSET ROOFING CORP.,

Plaintiff.
V

TURN TWO ELECTRIC, INC.,
a Florida Corporation,and
LASHAWN LATTIBEAUDIERE, an
individual,

Defendants.
'

JOINT PRETRIAL STIPULATION

Plaintiff/Counter-Defendant, Thermoset Roofing Corp ("Thermoset" or

and Defendants/Counter-Plaintiffs
"Plaintiff/Counter-Defendant") TURN TWO ELECTRIC, INC

("Turn Two") and LASHAWN LATTIBEAUDIERE ("Lattibeaudiere") (collectively

pursuant to the July 12, 2022, Uniform Trial Order SettingCase
"Defendants/Counter-Plaintiffs"),

for Jury Trial ("TrialOrder") and the February 1,2023, Agreed Order on Joint Motion to Continue

Trial,hereby file this regardingthis matter that is set for jury trial during
Joint Pretrial Stipulation

the three (3)week docket commencing April 10, 2023.

I. Statement of the Nature of the Action

This case involves claims by Thermoset against Defendant Turn Two, an electrical

contractor, for breach of contract and fraudulent inducement. This matter also involves a claim by

Thermoset for fraudulent inducement againstDefendant Lashawn Lattibeaudiere in his individual

capacity.Pursuant to the AIA contract entered into by the partieson or about September 8,2020,

Turn Two agreed to perform certain electrical and related work to both the interior and exterior

*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/10/2023 01:22:54 PM.****
CASE NO.: CACE-21-008854
Joint Pretrial Stipulation

portions of the Plaintiff's property located at 500 NW 12 Ave. Pompano Beach, Florida 33069

(the"Project"), but not limited to, securingand paying for the necessary buildingpermit
including,

as well as for other permits,fees,licenses,and inspectionsby government agenciesnecessary for

proper execution and completion of the Work; complying with and giving notices required by

applicablelaws, statutes, and lawful orders of public
ordinances, codes, rules and regulations,

authorities applicableto performance of the work; and bearingthe costs attributable to correction

of the Work. It is allegedby Thermoset that due to a failure and/or refusal by Turn Two to complete

the work in accordance with the contract, Turn Two materiallybreached the contact and was

terminated for cause.

Moreover, it is allegedthat after being terminated from the Projectfor cause, Turn Two

contacted Florida Power and Light ("FPL") to notify FPL that Thermoset was obtainingun-

metered temporary power from FPL despite Turn
allegedlyillegally, Two having set up the

temporary power as part of complying with its obligationsunder §§ 3.7.1 through 3.7.2 of the

contract. As a result,FPL disconnected the temporary power to the Projectwhich disruptedthe

Plaintiff's business operationsresultingin further economic damage to the Plaintiff.

Turn Two and liability
denies the Plaintiff' s allegations for the Plaintiff' s claims, and has

brought its own claims against Thermoset by way of a counterclaim for breach of contract,

anticipatorybreach of contract, and conversion. In its counterclaim, Turn Two asserts that

Thermoset breached the contract when they "demanded Turn Two Electric engage in what the

company believed was a fraudulent or, at a minimum, misleading applicationthat violated

municipal permit protocol-the submission of an incomplete permit package (without fire-

Turn
approved drawings) to the City."Additionally, Two has asserted that Thermoset breached

the contract in that Thermoset issued its Notice of Default in violation of section 7.2.1 of the

2
CASE NO.: CACE-21-008854
Joint Pretrial Stipulation

contract. Moreover, Turn Two' s claim for conversion asserts that Turn Two ordered certain

materials for the Projectand that after being terminated from the Projecthas been unable to access

these materials. Additionally,Turn Two asserts that Thermoset has utilized some or all of the

materials without Turn Two's permission or knowledge resultingin economic damages to Turn

Two.

asserted in Turn Two's counterclaim and liability
Thermoset denies the allegations for

Turn Two's claims.

Additionally, disputethe amount of damages being claimed by each
the parties side.

II. Stipulated Facts

This section contains stipulated which will requireno proof at
facts by the parties, trial.

1. The Projectis a warehouse buildinglocated in Pompano Beach, Florida.

2. The Projectis owned by Thermoset.

3 Turn Two was hired by Thermoset to perform certain electrical and related

work to both the interior and exterior portionsof the Projectas set forth in the parties'

AIA contact.

4. Turn Two purchased certain materials to be utilized or installed at the

Project.

5. Turn Two was terminated from the Projectfor cause on January 29,2021,

pursuant to a written Notice of Default.

6. Following termination, Defendants notified FPL of the un-metered

in
temporary power, resulting FPL disconnectingthe temporary power.

7. Following termination,Thermoset hired a replacement contractor Pacman

Electric,Inc. to complete the electrical work at the Project.

3
CASE NO.: CACE-21-008854
Joint Pretrial Stipulation

III. Statement of Disputed Issues of Law & Fact
1. Whether in connection with the work, Turn Two demolished Plaintiff's existing

electrical system at the projectand thereafter installed/set up unmetered, temporary power for the

buildingsuppliedthrough Florida Power and Light FPL).

2. Whether Turn Two committed a priormaterial breach of the contract?

3 Whether Thermoset committed a priormaterial breach of the contract?

4. Whether Turn Two anticipatorily
breached the contract?

5. Whether Thermoset anticipatorily
breached the contract?

6. Whether Turn Two fraudulentlyinduced Thermoset to enter into the contract?

7. Whether Lashawn Lattibeaudiere,individually, induced Thermoset
fraudulently to
enter into the contract?

8 Whether Thermoset wrongfully asserted dominion and control over Turn Two's
property as to amount to a conversion?

9- The amount ofThermoset's damages.

10. The amount of Turn Two's damages.

IV. Exhibit Lists

Plaintiff' s Exhibit list is attached as Exhibit A.

Defendants' Exhibit list are attached as Exhibit B.

V. Demonstrative Exhibit Lists

The partieshave not yet identified demonstrative exhibits that may be used at trial. The
partieswill confer priorto trial to identifyand attempt to agree on demonstrative exhibits.

VI. Witness Lists

Plaintiff' s Witness List is attached as Exhibit C.

Defendants' Witness List is attached as Exhibit D.

4
CASE NO.: CACE-21-008854
Joint Pretrial Stipulation

VII. Jury Instructions

Attached as Exhibit E.

VIII. Verdict Forms

Attached as Exhibit F.

IX. Peremptory Challenges
I 3 preemptory challengesfor Plaintiff.
I 3 preemptory challengestotal for Defendants.

X. Pending Motions

I None.

XI. Trial Estimate

o
5-day Jury Trial

XII. Expert Challenges

I None.

Respectfullysubmitted, April 10, 2023.

KELLEY KRONENBERG, PA BUCKNER LEGAL SELF-HELP
PROGRAM, INC
By-. /s/ Gary L. Brown By: /s/ Michael L. Buckner
Gary L. Brown, Esquire Michael L. Buckner, Esquire
Florida Bar No. 0054585 Florida Bar No. 106331.
10360 West State Road 84 5224 NW 96th Drive
Fort Lauderdale, FL 33324 Coral Springs,Florida 33076-2487
gbrown@kelleykronenberg.com Office: +1-954-347-0112
com
ygonzalo@kelleykronenberg. Facsimile: +1-954-513-4796
Counsel for Plaintiff Email: michaelbuckneilaw@gmail-com
Counsel for the Defendants,
Turn Two Electric Inc., and LaShawn
Lattibeaudiere

5
CASE NO.: CACE-21-008854
Joint Pretrial Stipulation

EXHIBIT A

IN THE CIRCUIT COURT IN THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA

CASE NO.: CACE-21-008854
DIVISION: 21

THERMOSET ROOFING CORP.,

Plaintiff.
V

TURN TWO ELECTRIC, INC.,
a Florida Corporation,and
LASHAWN LATTIBEAUDIERE, an
individual,

Defendants.
'

PLAINTIFF/COUNTER-DEFENDANT, THERMOSET ROOFING CORP.'S EXHIBIT
LIST

Plaintiff/Counter-Defendant,THERMOSET ROOFING CORP. ("THERMOSET ..,

'),by

and through undersigned counsel and pursuant to this Court's Order Scheduling Jury Trial and

DirectingPre-Trial Procedure, herein disclose the exhibits itemized below that may be used at the

trial of this matter. All referenced exhibits are available at this link:

EXH. DEPO. EXH. NO. DESCRIPTION BATE NO. GROUNDS
NO. FOR
OBJECTION
All exhibits listed by any
other Party to the matter
1
without waiving Thermoset's
rightto objectto the same.
and
Deposition transcript
exhibits thereto (#s 1 -30) of
2
11/14/2022, Depositionof
Lashawn Lattibeaudiere.

6
CASE NO.: CACE-21-008854
Joint Pretrial Stipulation

EXH. DEPO. EXH. NO. DESCRIPTION BATE NO. GROUNDS
NO. FOR
OBJECTION
Plaintiff' s Ex. 1- Amended Notice of Taking
3
Lattibeaudiere Videotaped Deposition of the
Corporate Representativeof
Turn Two Electric,Inc.
Plaintiff' s Ex. 2- Defendants 2/3/2022 TTE-1- TTE-
Lattibeaudiere Response to Plaintiff' s 148
4 Request for Production
(includingPrivilegeLog and
Responsive Documents)
Plaintiff' s Ex. 3- AIA Contract between
Lattibeaudiere Thermoset and Turn Two
5 dated 9/8/2020, including
copies ofthe Project
plans/drawings.
Plaintiff' s Ex. 4- Thermoset payment receipt
6 Lattibeaudiere for Turn Two Invoice #699
dated 8/20/19
Plaintiff' s Ex. 5- Email from Turn Two to
7 Lattibeaudiere Thermoset containing
photographs dated 9/23/2020
Plaintiff' s Ex. 6- Handwritten diagram of
8 Lattibeaudiere Projectpower connections
dated 1 1/14/2022.
Plaintiff' s Ex. 7- WhatsApp messages between
Lattibeaudiere Thermoset and Lashawn
9
Lattibeaudiere from Turn
Two dated 8/20/19 to 1/22/21
Plaintiff' s Ex. 8- Email from Turn Two to
10 Lattibeaudiere Thermoset Re: Cost dated
6/19/2020
Plaintiff' s Ex. 9- Email compositeranging
Lattibeaudiere from 6/11/2020 to 6/19/2020,
11 Re: Main Contract A401 &
A201 for final review by
Subcontractor
Plaintiff' s Ex. 10- Email from Thermoset to
Lattibeaudiere Turn Two Re: Contract
12
Documents dated 8/28/2020,
with attachments.
Plaintiff's Ex. 11- Email from Turn Two to
13
Lattibeaudiere Thermoset Re: Estimate 1474

7
CASE NO.: CACE-21-008854
Joint Pretrial Stipulation

EXH. DEPO. EXH. NO. DESCRIPTION BATE NO. GROUNDS
NO. FOR
OBJECTION
from Turn Two Electric with
attachment dated 9/16/2020.
Plaintiff' s Ex. 12- Email from Thermoset to
Lattibeaudiere Turn Two Re: Estimate 1474
14
from Turn Two Electric dated
9/16/2020.
Plaintiff's Ex. 13- Email from Turn Two to
Lattibeaudiere Thermoset Re: Estimate 1474
15
from Turn Two Electric dated
9/16/2020.
Plaintiff's Ex. 14- Email from Turn Two to
Lattibeaudiere Thermoset Re: Estimate 1475
16
from Turn Two Electric with
attachment dated 9/16/2020.
Plaintiff' s Ex. 15- Email from Thermoset to
Lattibeaudiere Turn Two Re: Estimate 1474
17
from turn Two Electric dated
9/16/2020
Plaintiff's Ex. 16- Email from Turn Two to
Lattibeaudiere Thermoset, Chris Stroud, and
18
Megan Bailey with FPL Re:
500 Building dated 9/21/2020.
Plaintiff' s Ex. 17- Email from Thermoset to
Lattibeaudiere Megan Bailey with FPL Re:
19 Thermoset Roofing #500-
Electrical Plans including
attachments dated 10/5/2020.
Plaintiff' s Ex. 18- Electrical Riser Diagram
Lattibeaudiere Sheet E5.1 prepared by
20
Kamm Consulting dated
10/5/2020.
Plaintiff's Ex. 19- Turn Two Estimate #1549
21
Lattibeaudiere dated 1/15/2021.
Plaintiff's Ex. 20- Electrical Riser Diagram
Lattibeaudiere Sheet E5.1 prepared by
22
Kamm Consulting dated
10/5/2020.
Plaintiff' s Ex. 21- Broward County Uniform TTE-139
23 Lattibeaudiere Building Permit Application
# 20-1277.
Plaintiff's Ex. 22- City of Pompano Beach TTE-140
24
Lattibeaudiere Notice of Commencement.

8
CASE NO.: CACE-21-008854
Joint Pretrial Stipulation

EXH. DEPO. EXH. NO. DESCRIPTION BATE NO. GROUNDS
NO. FOR
OBJECTION
Plaintiff's Ex. 23- City of Pompano Beach TTE-142
25
Lattibeaudiere Electrical Permit Application.

Plaintiff's Ex. 24- City of Pompano Beach TTE-146
26
Lattibeaudiere Notice of Commencement.
Plaintiff's Ex. 25- Thermoset Ground Floor TTE-147
27
Lattibeaudiere Electrical Plan
Plaintiff' s Ex. 26- Thermoset Ground Floor TTE-148
28
Lattibeaudiere Electrical Plan
Plaintiff' s Ex. 27- Broward County Uniform
29 Lattibeaudiere Building Permit Application
for Electrical.
Plaintiff's Ex. 28- Broward County Uniform
30 Lattibeaudiere Building Permit Application
for Electrical.
Plaintiff's Ex. 29- Email composite from Turn
Lattibeaudiere Two to Thermoset Re: Invoice
31 848 from Turn Two Electric
ranging from 4/10/2020 to
5/11/2020 with attachments.
Plaintiff's Ex. 30- Email from Thermoset to Turn
Lattibeaudiere Two Re- 1543 from Turn Two
32
Electric with attachments dated
1/13/2021.

Depositiontranscript and
exhibits thereto (#s31-46) of
33 3/15/2023, Continued
Deposition of Lashawn
Lattibeaudiere.
Plaintiff' s Ex. 31- Notice of Continued Deposition
34 Lattibeaudiere of the Corp. Representativefor
Turn Two Electric,Inc.

35
Plaintiff's Ex. 32- Pacman Electric Project PACMAN-1-
Lattibeaudiere Proposaldated 2/25/2021. PACMAN-12
Plaintiff's Ex. 33- PACMAN-
Lattibeaudiere 56,58,59,60,
Email composite from
61,62,63,64,
Thermoset to Pacman Electric
36 66,70,71,72,
ranging from 1/25/2021 to
2/25/21.
73,75,76,77,
78,88,100,
119,121.
Plaintiffs Ex. 34- Turn Two Electric Invoice
37
Lattibeaudiere #1039 dated 1/21/2021.

9
CASE NO.: CACE-21-008854
Joint Pretrial Stipulation

EXH. DEPO. EXH. NO. DESCRIPTION BATE NO. GROUNDS
NO. FOR
OBJECTION
Plaintiff's Ex. 35- Thermoset payment receipt
38
Lattibeaudiere dated 8/20/19.
Plaintiff's Ex. 36- Email composite from Turn
Lattibeaudiere Two to Thermoset Re: Invoice
39 848 from Turn Two Electric
ranging from 4/10/2020 to
5/11/2020 with attachments.
Plaintiff's Ex. 37- Email from Thermoset to Turn
Lattibeaudiere two Re: Estimate 1543 from
40
Turn Two Electric with
attachment dated 1/13/2021.
Plaintiff's Ex. 38- Email from Turn Two to
Lattibeaudiere Thermoset Re: Estimate 1474
41
from Turn Two Electric dated
9/16/2020.
Plaintiff's Ex. 39- Email composite from
Lattibeaudiere Thermoset to Turn Two Re-
42 Estimate 1549 from Turn Two
Electric from 1/22/2021 to
1/23/2021.
Plaintiff's Ex. 40- Turn two Electric Invoice #873
43
Lattibeaudiere dated 5/15/2020.
Plaintiff' s Ex. 41- Email composite between
Lattibeaudiere Thermoset and Turn Two Re-
Turn Two electric- Exterior
44
Service Permit Resubmit for
Overhead Service dated
1/22/21.
Plaintiff's Ex. 42- Thermoset's Notice of Default TTE-54-55
45 Lattibeaudiere and Termination to Turn Two
dated 2/3/21.
Plaintiff's Ex. 43- Thermoset's Notice of Default
46 Lattibeaudiere and Termination to Turn Two
dated 1/29/21.
Plaintiff's Ex. 44- Turn Two's Answer and Aff.
Lattibeaudiere Defenses and Counterclaim to
47
Thermoset's Complaint for
Damages
Plaintiff's Ex. 45- Turn Two's Notice and
48 Lattibeaudiere Answers to Thermoset's
dated 1/14/22.
Interrogatories

10
CASE NO.: CACE-21-008854
Joint Pretrial Stipulation

EXH. DEPO. EXH. NO. DESCRIPTION BATE NO. GROUNDS
NO. FOR
OBJECTION
Plaintiff's Ex. 46- Turn Two's Notice of TTE-23-233 -
Lattibeaudiere Compliance with Order TTE-23-348

49 includingresponsive
documents and Declaration of
Lashawn Lattibeaudiere dated
3/6/23.

Depositiontranscript and
exhibits thereto (#s 1 -10) of
50
3/28/2023, Deposition of
Megan Bailey.
Plaintiff' s Ex. 1- Notice of Taking Depositionof
Bailey the Corporate Representative
51
for Florida Power &
Light
("FPL")
Plaintiff' s Ex. 2- FPL Notification of New Thermoset-
52 Bailey Construction Applicationdated FPL 130
3/3/2020.
Plaintiff' s Ex. 3- Email composite from Thermoset
Bailey Thermoset to Turn Two and 003615
53 Megan Bailey Re: FPL Site

Meeting dated 9/10/2020
-

9/16/2020.
Plaintiff' s Ex. 4- Email from Megan Bailey to Thermoset
54 Bailey Thermoset Re- 500 NW
12th 003616
Ave- Recap dated 9/17/2020.
Plaintiff' s Ex. 5- Email composite from Thermoset
Bailey Thermoset to Megan Bailey 003660
55 includingattachments from
Kamm Consultingdated
10/5/2020.
Plaintiff' s Ex. 6- Photo of electrical pole at 500 Thermoset
56
Bailey NW 12thAve 003682
Plaintiff' s Ex. 7- Email from Thermoset to Thermoset
57
Bailey Megan Bailey dated 1/22/21. 003685
Plaintiff' s Ex. 8- Email composite from Megan TTE-23-68-
Bailey Bailey to Thermoset and Turn TTE-23-69
58 Two Re: Thermoset Roofing
#500- Electrical Plans dated
from 9/24/2020- 9/25/2020.
Plaintiff' s Ex. 9- Email composite from Turn TTE-23-94-
59 Bailey Two to Megan Bailey and TTE-23-96
Thermoset Re: Payment

11
CASE NO.: CACE-21-008854
Joint Pretrial Stipulation

EXH. DEPO. EXH. NO. DESCRIPTION BATE NO. GROUNDS
NO. FOR
OBJECTION
Completed dated from
10/14/2020.
Plaintiff' s Ex. 10- Turn Two's Notice of Service Thermoset-
Bailey ofNon-Party Florida Power & FPL001-
60 Lightsresponse toSubpoena Thermoset-
includingresponsive FPL059
documents.
Depositiontranscript and
exhibits thereto (#s 11-20) of
61
3/31/2023, Continued
Deposition of Megan Bailey.
Plaintiff' s Ex. 11- Notice of Continued Deposition
62 Bailey of the Corp. Representative
for
FPL.
Plaintiff' s Ex. 12- Thermoset-
FPL document productionpart
63 Bailey FPL-060 to
1.
FPL-089
Plaintiff' s Ex. 13 - Thermoset-
FPL document productionpart
64 Bailey FPL-090 to
2.
FPL-119
Plaintiff' s Ex. 14- Thermoset-
FPL document productionpart
65 Bailey FPL-120 to
3
FPL-149
Plaintiff' s Ex. 15- Thermoset-
FPL document productionpart
66 Bailey FPL-150 to
4.
FPL- 179
Plaintiff' s Ex. 16- Thermoset-
FPL documents productionpart
67 Bailey FPL-180 to
5.
FPL-209
Plaintiff' s Ex. 17- Thermoset-
FPL documents productionpart
68 Bailey FPL-210 to
6.
FPL-239
Plaintiff' s Ex. 18- Thermoset-
FPL document productionpart
69 Bailey FPL-240 to
7.
FPL-269
Plaintiff' s Ex. 19- Thermoset-
FPL document productionpart
70 Bailey FPL-270 to
8
FPL-294
Plaintiff's Ex. 20- Thermoset FPL payment Thermoset-
71
Bailey coupon dated 9/29/2020 FPL-128

12
CASE NO.: CACE-21-008854
Joint Pretrial Stipulation

EXH. DEPO. EXH. NO. DESCRIPTION BATE NO. GROUNDS
NO. FOR
OBJECTION
Thermoset-
City of Pompano Beach Public
72 Records: 20-00005067 Current Pompano-
00001 to
ProjectAll Emails Sent. 000744
Thermoset-
City of Pompano Beach Public
73 Records: 20-5067 Inspection Pompano-
000745 to
History. 000747
Thermoset-
City of Pompano Beach Public
74 Records: 21-00000868 Current
Pompano-
000748 to
Project-All Emails Sent. 000874
City of Pompano Beach Public Thermoset-
Records: 21-00000868 Not Pompano-
75
Approved Drawing- One Line- 000875
Temp Power.
Thermoset-
City of Pompano Beach Public
76 Records: 21-00003277 Current
Pompano-
000876 to
Project-All Emails Sent. 000979
Thermoset-
City of Pompano Beach Public
77 Records: Zipped Folder
Pompano-
000980 to
Approved-20-00001277. 000992
Thermoset-
City of Pompano Beach Public
78 Records: Zipped Folder Pompano-
000993 to
Approved-20-00005067. 001072
Thermoset-
City of Pompano Beach Public
79 Records: Not Approved
Pompano-
001073 to
Documents 20-00001277.
001081
Thermoset-
City of Pompano Beach Public
80 Records: Not Approved
Pompano-
001082 to
Documents 20-00005067.
001141
Thermoset-
City of Pompano Beach Public
81 Records: Not Approved
Pompano-
001142 to
Documents 21-00000868.
001148

13
CASE NO.: CACE-21-008854
Joint Pretrial Stipulation

EXH. DEPO. EXH. NO. DESCRIPTION BATE NO. GROUNDS
NO. FOR
OBJECTION
Thermoset-
City of Pompano Beach Public
82 Records: Not Approved Pompano-
001149 to
Documents 21-00003277.
001150
Thermoset-
City of Pompano Beach Public
83 Records: Not Approved Pompano-
001151 to
Drawings-20-00001277. 001154
Thermoset-
City of Pompano Beach Public
84 Records: Not Approved
Pompano-
001155 to
Drawings-20-00005067. 001162
Thermoset-
City of Pompano Beach Public
85 Records: Not Approved
Pompano-
001163 to
001167
Thermoset-
City of Pompano Beach Public
86 Records: PR--2022-1111 Notes
Pompano-
001168 to
and Receipts500 NW12th Ave.
001169
Copy of AIA Contract
87 Agreement between Thermoset
and Turn Two
Copy of Notice of Default
88 Letter from Thermoset to Turn
Two dated 1/29/21

Copy of Letter from Turn Two
89 inResponse to Thermoset's
Notice of Default dated 2/1/21

90 Copy of letter from Thermoset
to Turn Two dated 2/3/21

91 Copy of letter from Turn Two
to Thermoset dated 2/11/21

92 Copy of Letter from Thermoset
to Turn Two dated 3/19/21
Documents from Florida Power FPL Thermoset
93
and Light 00001-0007
Copy of Estimate #1549 from TTE-27
94
Turn Two dated 1/15/21
Turn Two Invoice #1035 dated TTE-28
95
1/18/21

14
CASE NO.: CACE-21-008854
Joint Pretrial Stipulation

EXH. DEPO. EXH. NO. DESCRIPTION BATE NO. GROUNDS
NO. FOR
OBJECTION
Turn Two Invoice #1036 dated TTE-29
96
1/18/21
Turn Two Invoice #1039 dated TTE-30
97
1/21/21
Turn Two Invoice #813 dated TTE-141
98
2/12/20
Notice of Commencement with TTE-140
99 City of Pompano Beach dated
3/9/20
Broward County Building TTE-144
100 Permit Applicationdated
12/14/20

City of Pompano Beach TTE-145
101 Electrical30-day Temporary
Permit
Correspondence between TTE-31 to
102
Thermoset and Turn Two TTE-138
City of Pompano Beach TTE-142 to
103 and Permit
Electrical Invoice TTE-143
Errors
Turn Two' s Notice of TTE-23-233 to

Compliance with Court's TTE-23-348
2/9/23, Order including
104
responsivedocuments and
Declaration of Lashawn
Lattibeaudiere dated 3/6/22.
Turn Two' s supplemental
document productionincluding
105
WhatsApp messages, dated
3/20/23.

106 Copies of invoices from Turn
Two to Thermoset
Contract between Thermoset
107
and Pac-Man Electric
Invoices from Pac-Man Electric
108
to Thermoset
Copies of Permit applications
109 from Pac-Man Electric for the

subjectProperty
Copies of correspondence
110 between Pac-Man Electric and
Thermoset

15
CASE NO.: CACE-21-008854
Joint Pretrial Stipulation

EXH. DEPO. EXH. NO. DESCRIPTION BATE NO. GROUNDS
NO. FOR
OBJECTION
Documents provided by Thermoset-
111 Scotland Electric Supply,Inc. Scotland-001 to
pursuant to subpoena. Scotland-002
Documents provided by Thermoset-
112 SuperiorLightingpursuant to Superior-001to
subpoena. Superior-002
Emails from SuperiorLighting Thermoset-

113 containingresponsive Superior-003to
documents pursuant to Superior-004
subpoena.
Copies of correspondence
between Turn Two and Florida
114
Power and Lightrelatingto the

subjectProperty
All Answers to Interrogatories
115 by the Plaintiffs includingall
relevant documents
All Answers to Interrogatories
116 by any Defendants includingall
relevant documents
All responses to Requests for
117
Production by Plaintiffs
All responses to Requests for
118
Production by the Defendants
Curriculum vitae of expert
119
witnesses.

120 Any reports prepared by
experts
Any and all demonstrative aids
121 brought and used by experts to
assist in their testimony
Any and all applicable
122 ordinance, codes, statutes or
case law

Depositiontranscript and
exhibits thereto (#s 1 -14) of
123
4/6/2023, Deposition of Micky
Bray

16
CASE NO.: CACE-21-008854
Joint Pretrial Stipulation

EXHIBIT B

IN THE CIRCUIT COURT IN THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA

CASE NO.: CACE-21-008854
DIVISION: 21

THERMOSET ROOFING CORP.,

Plaintiff.
V

TURN TWO ELECTRIC, INC.,
a Florida Corporation,and
LASHAWN LATTIBEAUDIERE, an
individual,

Defendants.
'

DEFENDANT/COUNTER-PLAINTIFFS, TURN TWO ELECTRIC, INC. AND
LASHAWN LATTIBEAUDIERE'S EXHIBIT LIST

Defendant/Counter-Plaintiffs, TURN TWO ELECTRIC, INC. ("TURN TWO"), and

LASHAWN LATTIBEAUDIERE ("LATTIBEAUDIERE") ("collectively the

by and through undersigned counsel and pursuant to
"Defendants/Counter-Plaintiffs) this Court's

Order Scheduling Jury Trial and Directing Pre-Trial Procedure, herein disclose the exhibits

itemized below that may be used at the trial of this matter. All referenced exhibits are available at

this link:

PLF. DATE MARKED OBJECTION ADMITTED DESCRIPTION OF EXHIBITS
No. OFF.

1 September 8, 2020, AIA A401-2017
Form of Agreement
2 September 16-17, 2020, email
correspondence between FPL and
parties

17
CASE NO.: CACE-21-008854
Joint Pretrial Stipulation

3 September 21, 2020, email
correspondence between FPL and
parties
4 September 23, 2020, email
correspondencebetween parties
5 September 24-25, 2020, email
correspondence between FPL and
parties
6 September 29-30, 2020, email
correspondence between FPL and
parties
7 October 5,2020, email correspondence
between FPL and parties

8 October 14, 2020, email
correspondence between FPL and
parties
9 October 16, 2020, email
correspondence between FPL

Case Info

Judge

Singer, Michele Towbin Track Judge’s New Case

Case No.

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Document Filed Date

April 10, 2023

Case Filing Date

May 03, 2021

County

Parties

Brown, Gary Louis Attorney for the Plaintiff
Brown, Gary Louis Attorney for the Plaintiff
Buckner, Michael Lamar Attorney for the Defendant
Buckner, Michael Lamar Attorney for the Defendant
Buckner, Michael Lamar Attorney for the Plaintiff
Lattibeaudiere, Lashawn Defendant
Lattibeaudiere, Lashawn Plaintiff
Thermoset Roofing Corp Plaintiff
Thermoset Roofing Corp. Defendant
Turn Two Electric Inc Defendant
Turn Two Electric Inc Plaintiff
John DeJager Attorney
Steven Lessne Attorney
Steven Lesser Attorney
Robyn DiTocco Attorney
Monica Barnes Attorney

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Document for Thermoset Roofing Corp, et al Plaintiff vs. Turn Two Electric Inc, et al Defendant

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Case Info

Parties