On September 24, 2021 a
Party Discovery
was filed
involving a dispute between
Diocese Of Central Florida,
and
for Circuit Civil
in the District Court of Lake County.
Preview
Filing # 151234056 E-Filed 06/10/2022 09:02:32 AM
IN THE CIRCUIT COURT OF THE 5TH JUDICIAL CIRCUIT,
IN AND FOR LAKE COUNTY, FLORIDA
THE DIOCESE OF CENTRAL FLORIDA,
Plaintiff,
vs. CASE NO: 35-2021-CA-001639-AXXX-XX
CERTAIN UNDERWRITERS AT LLOYD’S,
LONDON SUBSCRIBING TO POLICY NO.
MSRC-2830-00-00,
Defendant.
/
RESPONSE TO DEFENDANT’S SECOND REQUEST FOR PRODUCTION TO
PLAINTIFF
COME NOW, Plaintiff, THE DIOCESE OF CENTRAL FLORIDA, by and through the
undersigned counsel, and file this, its response to Defendant’s Request for Production and as such
would state as follows:
1. Copies of all maintenance or repair records regarding any repairs, replacements, and acts
of maintenance to the roofs at the property identified in the Complaint for the last seven (7)
years.
Response
Objection, overly broad, unduly burdensome, and not reasonably calculated to lead to
the discovery of admissible evidence. Notwithstanding and subject to said objections see
documents produced in Defendant’s first request for production.
2. Copies of all contracts, estimates, proposals, invoices, and reports for related to repairs,
replacements, and acts of maintenance to the roofs at the
in the Complaint for the last seven (7) years.
Response
Objection, overly broad, unduly burdensome, and not reasonably calculated to lead to
the discovery of admissible evidence. Notwithstanding and subject to said objections see
documents produced in Defendant’s first request for production.
FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 06/10/2022 10:00:07 AM
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-
Mail and/or E-Portal to Attorneys for Defendant, Patrick E. Betar, Esquire, Berk, Merchant &
Sims, PLC, 2 Alhambra Plaza, Suite 700, Coral Gables, Florida 33134 at pbetar@berklawfirm.com
kmendez@berklawfirm.com; Itapia@berklawfirm.com and anorwitch@berklawfirm.com; on this
10th day of June, 2022.
By: Us/ Jeremy T. Schilling
JEREMY T. SCHILLING, ESQ.
Florida Bar No: 0098111
Schilling & Silvers PLLC
Attorneys for Plaintiff
1700 NW 64th Street, Suite 460
Fort Lauderdale, Florida 33309
phone: (954) 712-8877
fax: (954) 824-2201
Email: jschilling@schillingsilvers.com
dadams@schillingsilvers.com
Document Filed Date
June 10, 2022
Case Filing Date
September 24, 2021
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Filing # 151234056 E-Filed 06/10/2022 09:02:32 AM IN THE CIRCUIT COURT OF THE 5TH JUDICIAL CIRCUIT, IN AND FOR LAKE COUNTY, FLORIDA THE DIOCESE OF CENTRAL FLORIDA, Plaintiff, vs. CASE NO: 35-2021-CA-001639-AXXX-XX CERTAIN UNDERWRITERS AT LLOYD’S, LONDON SUBSCRIBING TO POLICY NO. MSRC-2830-00-00, Defendant. / RESPONSE TO DEFENDANT’S SECOND REQUEST FOR PRODUCTION TO PLAINTIFF COME NOW, Plaintiff, THE DIOCESE OF CENTRAL FLORIDA, by and through the undersigned counsel, and file this, its response to Defendant’s Request for Production and as such would state as follows: 1. Copies of all maintenance or repair records regarding any repairs, replacements, and acts of maintenance to the roofs at the property identified in the Complaint for the last seven (7) years. Response Objection, overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. Notwithstanding and subject to said objections see documents produced in Defendant’s first request for production. 2. Copies of all contracts, estimates, proposals, invoices, and reports for related to repairs, replacements, and acts of maintenance to the roofs at the in the Complaint for the last seven (7) years. Response Objection, overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. Notwithstanding and subject to said objections see documents produced in Defendant’s first request for production. FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 06/10/2022 10:00:07 AM CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E- Mail and/or E-Portal to Attorneys for Defendant, Patrick E. Betar, Esquire, Berk, Merchant & Sims, PLC, 2 Alhambra Plaza, Suite 700, Coral Gables, Florida 33134 at pbetar@berklawfirm.com kmendez@berklawfirm.com; Itapia@berklawfirm.com and anorwitch@berklawfirm.com; on this 10th day of June, 2022. By: Us/ Jeremy T. Schilling JEREMY T. SCHILLING, ESQ. Florida Bar No: 0098111 Schilling & Silvers PLLC Attorneys for Plaintiff 1700 NW 64th Street, Suite 460 Fort Lauderdale, Florida 33309 phone: (954) 712-8877 fax: (954) 824-2201 Email: jschilling@schillingsilvers.com dadams@schillingsilvers.com