On May 05, 2022 a
Party Discovery
was filed
involving a dispute between
and
for CONTRACT
in the District Court of Leon County.
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Filing # 155811227 E-Filed 08/22/2022 01:58:14 PM
IN THE CIRCUIT COURT OF THE
SECOND JUDICIAL CIRCUIT, IN AND
FOR LEON COUNTY, FLORIDA
CYPRESS RESTORATION, INC.,
A Florida corporation, d/b/a Paul
Davis Restoration of Tallahassee,
CIVIL DIVISION
Plaintiff, CASE NO.: 2022-CA-000752
VS.
BEVERLY A. WOODSON,
Defendant.
/
DEFENDANT, BEVERLY A. WOODSON’S SUPPLEMENTAL RESPONSE
TO PLAINTIFF’S FIRST REQUEST FOR PRODUCTION
Defendant, BEVERLY A. WOODSON, by and through her undersigned counsel, and
pursuant to Florida Rule of Civil Procedure 1.350, hereby provides her supplemental responses to
Plaintiffs First Request for Production as follows:
Additional documents in Defendant’s possession related to construction work performed
at the Subject Property have been located and are being provided to Plaintiff's counsel. In general,
these documents include the following:
Text messages between Defendant and Plaintiff's representative Jay White.
Text messages between Defendant and Plaintiff's representative Robby Tucker.
Photos of the defectively installed air conditioning exterior air handler unit.
Correspondence between Defendant and her mortgage company.
Miscellaneous construction and permitting documentation for remediation of the
Subject Property.
Additional documentation, if located, will be provided upon receipt.
Respectfully submitted this 22nd day of August 2022.
oo
et, ge.
STUART C. POAGE, ESQUIRE
Florida Bar Number: 388246
RACHEL GIVENS, ESQUIRE
Florida Bar Number 1024797
PENNINGTON, P.A.
215 South Monroe Street, Suite 200
Tallahassee, Florida 32301
Telephone: (850) 222-3533
Facsimile: (850) 222-2126
spoage@penningtonlaw.com
givens@penningtonlaw.com
jduquetoro@penningtonlaw.com
Attorneys for Defendant
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing document was filed
electronically on August 22, 2022, with the Clerk of Court and sent via the court’s e-service system
to:
John W. Black, Esq.
2155 Delta Blvd., Suite 210-A
Tallahassee, Florida 32303
jwhlack@nettally.com
jwblack2 155@outlook.com
Attorney for Plaintiff
Attorney
Document Filed Date
August 22, 2022
Case Filing Date
May 05, 2022
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Filing # 155811227 E-Filed 08/22/2022 01:58:14 PM IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT, IN AND FOR LEON COUNTY, FLORIDA CYPRESS RESTORATION, INC., A Florida corporation, d/b/a Paul Davis Restoration of Tallahassee, CIVIL DIVISION Plaintiff, CASE NO.: 2022-CA-000752 VS. BEVERLY A. WOODSON, Defendant. / DEFENDANT, BEVERLY A. WOODSON’S SUPPLEMENTAL RESPONSE TO PLAINTIFF’S FIRST REQUEST FOR PRODUCTION Defendant, BEVERLY A. WOODSON, by and through her undersigned counsel, and pursuant to Florida Rule of Civil Procedure 1.350, hereby provides her supplemental responses to Plaintiffs First Request for Production as follows: Additional documents in Defendant’s possession related to construction work performed at the Subject Property have been located and are being provided to Plaintiff's counsel. In general, these documents include the following: Text messages between Defendant and Plaintiff's representative Jay White. Text messages between Defendant and Plaintiff's representative Robby Tucker. Photos of the defectively installed air conditioning exterior air handler unit. Correspondence between Defendant and her mortgage company. Miscellaneous construction and permitting documentation for remediation of the Subject Property. Additional documentation, if located, will be provided upon receipt. Respectfully submitted this 22nd day of August 2022. oo et, ge. STUART C. POAGE, ESQUIRE Florida Bar Number: 388246 RACHEL GIVENS, ESQUIRE Florida Bar Number 1024797 PENNINGTON, P.A. 215 South Monroe Street, Suite 200 Tallahassee, Florida 32301 Telephone: (850) 222-3533 Facsimile: (850) 222-2126 spoage@penningtonlaw.com givens@penningtonlaw.com jduquetoro@penningtonlaw.com Attorneys for Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing document was filed electronically on August 22, 2022, with the Clerk of Court and sent via the court’s e-service system to: John W. Black, Esq. 2155 Delta Blvd., Suite 210-A Tallahassee, Florida 32303 jwhlack@nettally.com jwblack2 155@outlook.com Attorney for Plaintiff Attorney