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Filing# 160986444 E-Filed 11/09/2022 05:10:21 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.,
and
a Florida Corporation,
LASHAWN LATTIBEAUDIERE, an
individual,
Defendants.
'
PLAINTIFF'S SUPPLEMENTAL RESPONSES TO DEFENDANT, TURN TWO
ELECTRIC, INC'S FIRST REQUEST FOR PRODUCTION
THERMOSET
Plaintiff, ROOFING CORP. ("Thermoset"),by and through undersigned
counsel,hereby files its SupplementalResponses to Defendant, Turn Two Electric,Inc.,("Turn
Two") First Request for Production, served on February 16, 2022.
THERMOSET SUPPLEMENTAL RESPONSES TO TURN TWO FIRST REQUEST
FOR PRODUCTION
1. Produce all documents relatingto, concerning or affectingthe claims or defenses asserted
in this lawsuit,includingbut not limited to, the following:
To the extent Thermoset has non-privileged, responsivedocuments within its
non-objectionable,
possession,see documents Bates Nos. 1-4620 produced via email on 11/8/22 via the following
link-
eceb9ff2cal a.
https://kelleykronenberg.sharefile.coin/d-s2c412d3b6d174(8aad41
Bates Nos. 60-61, 92-95, 241-244, 300-303, 2305,2300-2301, 2306-2307, 2390, 3202-3204, 3357,
3392, 3690, 3996, 3998, 4143, 4145, and 4256-4259 were initiallywithheld from the above link
as potentiallyprivilegedbut are now being produced herewith. Thermoset's full production,
includingdocuments previouslywithheld from the 11/8/22 production,is at this link:
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/09/2022 05:10:20 PM.****
CASE NO.: CACE-21-008854
new sharefile link:
17
https://kelleykronenberg.sharefile.com/d-s8fe66d8298004858ad7a672afe54bl
2. Documents and communications (including,
but not limited to, emails, texts, letters and
notes)Plaintiff submitted to, or received from, the following persons or partiesconcerning the
Project.(a)Turn Two Electric;(b)Lattibeaudiere;(c)Florida Power & Light Company; (d)Metal
Edge Technology, Inc.; (e) Pacman Enterprises,LLC, d/b/a Pacman Electric;and (f)City of
Pompano Beach, Florida.
RESPONSE:
Please see response to Request No. 1.
3 Permits issued by the City of Pompano Beach that any contractor or subcontractor used to
provide electrical services to Plaintiff during the Project.
RESPONSE:
Please see response to Request No. 1.
4. Documents and communications (including,
but not limited to, emails, texts, letters and
notes)Plaintiff submitted to, or received from, the Defendants concerning your requests for Turn
Two Electric to provide exterior underground electric service to the Property.
RESPONSE:
Please see response to Request No. 1.
5. Documents and communications (including,
but not limited to, emails, texts, letters and
notes)Plaintiff submitted to, or received from, the Defendants concerningyour requests for Turn
Two Electric to provide exterior overhead electric service to the Property.
RESPONSE:
Please see response to Request No. 1.
6. Release of lien for payments from Plaintiff to Turn Two Electric concerningthe Project.
RESPONSE:
Please see response to Request No. 1.
Page 2 of 3
CASE NO.: CACE-21-008854
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on November 9,2022 a true and correct copy of the foregoing
has been furnished by the Florida Courts E-FilingPortal System to all electronic filing
participants
with respect to this proceeding.
KELLEY KRONENBERG, PA
10360 West State Road 84
Fort Lauderdale, FL 33324
Telephone No.: (954) 370-9970
Facsimile No.: (954) 382-1988
By-. /s/ Gary L. Brown
GARY L. BROWN
Florida Bar No.: 0054585
JOHN M. DEJAGER
Florida Bar No.: 1005233
gbrown@kelleykronenberg.com
jdejager@kelleykronenberg.com
co
ygonzalo@kelleykronenberg.
Page 3 of 3
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Filing# 160986444 E-Filed 11/09/2022 05:10:21 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., and a Florida Corporation, LASHAWN LATTIBEAUDIERE, an individual, Defendants. ' PLAINTIFF'S SUPPLEMENTAL RESPONSES TO DEFENDANT, TURN TWO ELECTRIC, INC'S FIRST REQUEST FOR PRODUCTION THERMOSET Plaintiff, ROOFING CORP. ("Thermoset"),by and through undersigned counsel,hereby files its SupplementalResponses to Defendant, Turn Two Electric,Inc.,("Turn Two") First Request for Production, served on February 16, 2022. THERMOSET SUPPLEMENTAL RESPONSES TO TURN TWO FIRST REQUEST FOR PRODUCTION 1. Produce all documents relatingto, concerning or affectingthe claims or defenses asserted in this lawsuit,includingbut not limited to, the following: To the extent Thermoset has non-privileged, responsivedocuments within its non-objectionable, possession,see documents Bates Nos. 1-4620 produced via email on 11/8/22 via the following link- eceb9ff2cal a. https://kelleykronenberg.sharefile.coin/d-s2c412d3b6d174(8aad41 Bates Nos. 60-61, 92-95, 241-244, 300-303, 2305,2300-2301, 2306-2307, 2390, 3202-3204, 3357, 3392, 3690, 3996, 3998, 4143, 4145, and 4256-4259 were initiallywithheld from the above link as potentiallyprivilegedbut are now being produced herewith. Thermoset's full production, includingdocuments previouslywithheld from the 11/8/22 production,is at this link: *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/09/2022 05:10:20 PM.**** CASE NO.: CACE-21-008854 new sharefile link: 17 https://kelleykronenberg.sharefile.com/d-s8fe66d8298004858ad7a672afe54bl 2. Documents and communications (including, but not limited to, emails, texts, letters and notes)Plaintiff submitted to, or received from, the following persons or partiesconcerning the Project.(a)Turn Two Electric;(b)Lattibeaudiere;(c)Florida Power & Light Company; (d)Metal Edge Technology, Inc.; (e) Pacman Enterprises,LLC, d/b/a Pacman Electric;and (f)City of Pompano Beach, Florida. RESPONSE: Please see response to Request No. 1. 3 Permits issued by the City of Pompano Beach that any contractor or subcontractor used to provide electrical services to Plaintiff during the Project. RESPONSE: Please see response to Request No. 1. 4. Documents and communications (including, but not limited to, emails, texts, letters and notes)Plaintiff submitted to, or received from, the Defendants concerning your requests for Turn Two Electric to provide exterior underground electric service to the Property. RESPONSE: Please see response to Request No. 1. 5. Documents and communications (including, but not limited to, emails, texts, letters and notes)Plaintiff submitted to, or received from, the Defendants concerningyour requests for Turn Two Electric to provide exterior overhead electric service to the Property. RESPONSE: Please see response to Request No. 1. 6. Release of lien for payments from Plaintiff to Turn Two Electric concerningthe Project. RESPONSE: Please see response to Request No. 1. Page 2 of 3 CASE NO.: CACE-21-008854 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on November 9,2022 a true and correct copy of the foregoing has been furnished by the Florida Courts E-FilingPortal System to all electronic filing participants with respect to this proceeding. KELLEY KRONENBERG, PA 10360 West State Road 84 Fort Lauderdale, FL 33324 Telephone No.: (954) 370-9970 Facsimile No.: (954) 382-1988 By-. /s/ Gary L. Brown GARY L. BROWN Florida Bar No.: 0054585 JOHN M. DEJAGER Florida Bar No.: 1005233 gbrown@kelleykronenberg.com jdejager@kelleykronenberg.com co ygonzalo@kelleykronenberg. Page 3 of 3