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Filing # 137757167 E-Filed 11/02/2021 03:54:47 PM
THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT IN AND
FOR OSCEOLA COUNTY, FLORIDA
VILLAS AT EMERALD LAKE HOMEOWNERS | Case No.: 2020-CA-002942
ASSOCIATION, INC., a Florida not for profit
corporation,
Plaintiff,
Vv.
ROYAL OAK HOMES, LLC, a Florida limited
liability company; ADVANCED WRAPPING AND
CONCRETE SOLUTIONS OF CENTRAL
FLORIDA, INC., a Florida corporation; DON
KING’S CONCRETE, INC., a Florida corporation;
HUGH MACDONALD CONSTRUCTION, INC., a
Florida corporation; IMPERIAL BUILDING
CORPORATION, a Florida corporation; PREMIER
PLASTERING OF CENTRAL FLORIDA, INC
N/K/A TGK STUCCO, INC., a Florida corporation;
WEATHERMASTER BUILDING PRODUCTS,
INC., a Florida corporation; WEINTRAUB
INSPECTIONS & FORENSICS, INC. N/K/A
WEINTRAUB ENGINEERING AND
INSPECTIONS, INC., a Florida corporation; THE
DIMILLO GROUP, LLC, a Florida limited liability
company; WOLF’S IRRIGATION &
LANDSCAPING, INC., a Florida corporation;
SUMMERPARK HOMES, INC., a Florida
corporation; BROWN + COMPANY
ARCHITECTURE, INC., a Florida corporation;
EXPERT PAINTING & PRESSURE WASHING,
INC., a Florida Profit Corporation
Defendants.
ROYAL OAKS HOME, LLC.,
Cross-Claimant,
Vv.
ADVANCED WRAPPING AND CONCRETE
SOLUTIONS OF CENTRAL FLORIDA, INC., a
Florida corporation; DON KING'S CONCRETE,
INC., a Florida corporation; HUGH MACDONALD
CONSTRUCTION, INC., a Florida corporation;
IMPERIAL BUILDING CORPORATION, a Florida
corporation; PREMIER PLASTERING OF
CENTRAL FLORIDA, INC N/K/A TGK STUCCO,
INC., a Florida corporation, WEATHERMASTER
BUILDING PRODUCTS, INC., a Florida
corporation; WEINTRAUB INSPECTIONS &
FORENSICS, INC. N/K/A WEINTRAUB
ENGINEERING AND _ INSPECTIONS, INC.,
WOLF'S IRRIGATION & LANDSCAPING, INC.,
a Florida corporation, BROWN+COMPANY
ARCHITECTURE, INC., a Florida corporation;
Cross-Defendants
/
WEATHERMASTER BUILDING PRODUCTS,
INC., a Florida Corporation,
Third-Party Plaintiff,
v
ALL GLASS INSTALLATION CORP., a Florida
corporation, CASEY HAWKINS, GLASS, INC., a
Florida corporation; DEAN NESBIT, LLC, a Florida
limited liability company; HELBERG
ENTERPRISES, LLC, a Florida limited liability
company; HOBBIT WINDOWS, LLC, a Florida
limited liability company; T&M CONSTRUCTION
OF SANFORD, INC., a Florida corporation; WELL
DONE WINDOWS, INC., a Florida corporation; and
WELL HUNG WINDOWS & DOORS, LLC, a
Florida limited liability company;
Third-Party Defendants.
/
DON KING’S CONCRETE, INC., a Florida
corporation,
Third-Party Plaintiff
Vv.
ER.O. CONSTRUCTION, _ INC., a Florida
corporation; LIOS CONCRETE CORP., a Florida
corporation; and ATLANTIC CONCRETE
SYSTEMS, INC., a Florida corporation.
Third-Party Defendants.
PLAINTIFF’S RESPONSE TO DEFENDANT DON KING’S CONCRETE, INC.’S
FIRST REQUEST FOR PRODUCTION
Plaintiff, VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION, INC.
(hereinafter “Plaintiff’) hereby responds to Defendant, DON KING’S CONCRETE, INC.’s
(hereinafter “Defendant”) First Request for Production.
RESPONSE TO FIRST REQUEST FOR PRODUCTION OF DOCUMENTS
1 All documents, including but not limited to, correspondence, notices, newsletters,
announcements, posters and postings to or from tenants/occupants/unit owners relating or
referring to the condition, maintenance, repair or replacement of any concrete and/or masonry
work at the Property.
RESPONSE: Plaintiff has produced all relevant documents in its possession, custody,
or control, not of a privileged nature, relating to the Property at issue in this litigation, as
they are maintained in the ordinary course of business. Accordingly, to the extent non-
privileged documents responsive to this Request are in Plaintiffs possession, custody, or
control, they are included in that production. Documents withheld on the basis of privilege
are listed on the privilege log produced by Plaintiff.
2. All documents or other forms of communication between or received by any
management company of Plaintiff for the Property relating or referring to the condition,
maintenance, repair or replacement of concrete and/or masonry at the Property.
RESPONSE: Plaintiff has produced all documents in its possession, custody, or
control, not of a privileged nature, relating to the Property at issue in this litigation, as they
are maintained in the ordinary course of business. Accordingly, to the extent non-privileged
documents responsive to this Request are in Plaintiffs possession, custody, or control, they
are included in that production. Documents withheld on the basis of privilege are listed on
the privilege log produced by Plaintiff.
3 All documents relating to the design, installation, inspection, evaluation, testing,
maintenance, repair or replacement of the concrete and/or masonry at the Property.
RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its
possession, custody, or control relating to the Project at issue in this litigation as they are
maintained in the ordinary course of business. Accordingly, to the extent non-privileged
documents responsive to this Request are in Plaintiff’s possession, custody, or control, they
have been included in that production. Documents withheld on the basis of privilege are
listed on the privilege log produced by Plaintiff.
4 All documents, including but not limited to electronic mail, written
communications, letters, notes, tapes, recordings, memoranda, reports, summaries, notes, minutes,
logs, diaries, journals, or other documents that refer or relate to the concrete and/or masonry at the
Property.
RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its
possession, custody, or control relating to the Project at issue in this litigation as they are
maintained in the ordinary course of business. Accordingly, to the extent non-privileged
documents responsive to this Request are in Plaintiffs possession, custody, or control, they
have been included in that production. Documents withheld on the basis of privilege are
listed on the privilege log produced by Plaintiff.
5 All computer files, e-mails, and electronic data files of any kind relating to the
concrete and/or masonry at the Property.
RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its
possession, custody, or control relating to the Project at issue in this litigation as they are
maintained in the ordinary course of business. Accordingly, to the extent non-privileged
documents responsive to this Request are in Plaintiff’s possession, custody, or control, they
have been included in that production. Documents withheld on the basis of privilege are
listed on the privilege log produced by Plaintiff.
6 All “as built” plans for the concrete and/or masonry at the Property.
RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its
possession, custody, or control relating to the Project at issue in this litigation as they are
maintained in the ordinary course of business. Accordingly, to the extent non-privileged
documents responsive to this Request are in Plaintiffs possession, custody, or control, they
have been included in that production. Documents withheld on the basis of privilege are
listed on the privilege log produced by Plaintiff.
7 All notices of default regarding the concrete and/or masonry at the Property.
RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its
possession, custody, or control relating to the Project at issue in this litigation as they are
maintained in the ordinary course of business. Accordingly, to the extent non-privilege
documents responsive to this Request are in Plaintiff’s possession, custody, or control, they
have been included in that production. Documents withheld on the basis of privilege are
listed on the privilege log produced by Plaintiff.
8 All documents, correspondence and/or communications with all persons or entities
that inspected, evaluated, tested, maintained or repaired any component of the concrete and/or
masonry at the Property.
RESPONSE: Plaintiff objects to this request on the grounds that it is overbroad and
vague as the phrase “[a]ll documents, correspondence, and/or communication with all
persons or entities that inspected, evaluated, tested, maintained or repaired any component
of the concrete and/or masonry . ..” could reference any person or entity involved with the
construction of the masonry or concrete, repairs, if any, to the masonry or concrete, or
inspections on the Project. Plaintiff has produced all relevant, non-privileged documents in
its possession, custody, or control relating to the Project at issue in this litigation as they are
maintained in the ordinary course of business. Accordingly, to the extent non-privileged
documents responsive to this Request are in Plaintiffs possession, custody, or control, they
have been included in that production. Documents withheld on the basis of privilege are
listed on the privilege log produced by Plaintiff.
9 All documents, including any expert reports, which show any alleged construction
defect or damage pertaining to the concrete and/or masonry at the Property.
RESPONSE: Plaintiff refers Don King’s Concrete to its expert disclosure(s) and all
related information. Plaintiff has produced all relevant, non-privileged documents in its
possession, custody, or control relating to the Project at issue in this litigation as they are
maintained in the ordinary course of business. Accordingly, to the extent non-privileged
documents responsive to this Request are in Plaintiffs possession, custody, or control, they
have been included in that production. Documents withheld on the basis of privilege are
listed on the privilege log produced by Plaintiff.
10. All documents that evidence or relate to the amount of the Plaintiff's actual
damages and losses sustained as a result of alleged defects or deficiencies pertaining tothe
concrete and/or masonry at the Property.
RESPONSE: Plaintiff refers Don King’s Concrete to its expert disclosure(s) and all
related information. Plaintiff has produced all relevant, non-privileged documents in its
possession, custody, or control relating to the Project at issue in this litigation as they are
maintained in the ordinary course of business. Accordingly, to the extent non-privileged
documents responsive to this Request are in Plaintiffs possession, custody, or control, they
have been included in that production. Documents withheld on the basis of privilege are
listed on the privilege log produced by Plaintiff.
11. All documents reflecting any remediation of the concrete and/or masonry at the
Property, including but not limited to drawings, specifications, photographs, plans, budgeting,
bids, bids analysis, blueprints, shop drawings and contracts.
RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its
possession, custody, or control relating to the Project at issue in this litigation as they are
maintained in the ordinary course of business. Accordingly, to the extent non-privileged
documents responsive to this Request are in Plaintiff's possession, custody, or control, they
have been included in that production. Documents withheld on the basis of privilege are
listed on the privilege log produced by Plaintiff.
12. All documents and correspondence related to any quotes, bids, proposal, estimates,
or contractors for remediation of the concrete and/or masonry work at the Property.
RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its
possession, custody, or control relating to the Project at issue in this litigation as they are
maintained in the ordinary course of business. Accordingly, to the extent non-privileged
documents responsive to this Request are in Plaintiffs possession, custody, or control, they
have been included in that production. Documents withheld on the basis of privilege are
listed on the privilege log produced by Plaintiff.
13. All photographs, videos, sketches, diagrams, or depictions of any kind relating to
the Property construction, repairs or restoration, construction deficiencies, alleged construction
deficiencies related to the concrete and/or masonry at the Property.
RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its
possession, custody, or control relating to the Project at issue in this litigation as they are
maintained in the ordinary course of business. Accordingly, to the extent non-privileged
documents responsive to this Request are in Plaintiffs possession, custody, or control, they
have been included in that production. Documents withheld on the basis of privilege are
listed on the privilege log produced by Plaintiff.
14. All maintenance records for the Property, including but not limited to, maintenance
schedules, invoices, checks, daily logs, and maintenance requests.
RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its
possession, custody, or control relating to the Project at issue in this litigation as they are
maintained in the ordinary course of business. Accordingly, to the extent non-privileged
documents responsive to this Request are in Plaintiff's possession, custody, or control, they
have been included in that production. Documents withheld on the basis of privilege are
listed on the privilege log produced by Plaintiff.
15. All 558 notices received or sent by Plaintiff in connection with this Project.
RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its
possession, custody, or control relating to the Project at issue in this litigation as they are
maintained in the ordinary course of business. Accordingly, to the extent non-privileged
documents responsive to this Request are in Plaintiff’s possession, custody, or control, they
have been included in that production. Documents withheld on the basis of privilege are
listed on the privilege log produced by Plaintiff.
16. All documents which support all claims made by you regarding the work
performed by DON KING’S at the Property.
RESPONSE: Plaintiff refers Don King’s Concrete to its previous disclosed expert
reports and job files. Alternatively, Plaintiff has produced all relevant, non-privileged
documents in its possession, custody, or control relating to the Project at issue in this
litigation as they are maintained in the ordinary course of business. Accordingly, to the
extent non-privileged documents responsive to this Request are in Plaintiff’s possession,
custody, or control, they have been included in that production. Documents withheld on the
basis of privilege are listed on the privilege log produced by Plaintiff.
17. All documents exchanged between you and any third party regarding the
concrete and/or masonry at the Property.
RESPONSE: Plaintiff has produced all relevant, non-privileged documents in
its possession, custody, or control relating to the Project at issue in this litigation as they are
maintained in the ordinary course of business. Accordingly, to the extent non-privileged
documents responsive to this Request are in Plaintiff’s possession, custody, or control, they
have been included in that production. Documents withheld on the basis of privilege are
listed on the privilege log produced by Plaintiff.
18. All insurance policies that may provide any coverage for any of the claims alleged in
this cause of action, including applicable declaration pages.
RESPONSE: Plaintiff objects to this request on the grounds that it is asking for
Plaintiff to improperly make a legal conclusion regarding which insurance policies, if any,
may provide benefits or coverage to the Plaintiff for any of the claims alleged in this cause of
action.
19. Please provide a listing of every individual tenant/occupant/owner of any
townhome who, to your knowledge, has made a complaint regarding any issues withrespect to
the concrete and/or masonry, including the specifics of the complaint, the dateof complaint, full
name of the tenant/occupant/owner, and building and unit number involved.
RESPONSE: Plaintiff objects to this request on grounds Plaintiff is not required to
prepare or create any documents in response to a request. Plaintiff has produced all relevant,
non-privileged documents in its possession, custody, or control relating to the Project at issue
in this litigation as they are maintained in the ordinary course of business. Accordingly, to
the extent non-privileged documents responsive to this Request are in Plaintiff’s possession,
custody, or control, they have been included in that production. Documents withheld on the
basis of privilege are listed on the privilege log produced by Plaintiff.
20. All communications and documents, including but not limited to correspondence,
memoranda, messages, letters, electronic mail, telegrams, teletypes, telefax, bulletins, meetings or
other communications between Plaintiff and any party to this lawsuit relating to DON KING’S
work performed at the Property.
PONSE: Plaintiff has produced all relevant, non-privileged documents in its
possession, custody, or control relating to the Project at issue in this litigation as they are
maintained in the ordinary course of business. Accordingly, to the extent non-privileged
documents responsive to this Request are in Plaintiffs possession, custody, or control, they
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have been included in that production. Documents withheld on the basis of privilege are
listed on the privilege log produced by Plaintiff.
21. All expert or consultant reports and all written documentation in any form regarding
any expert or consultant findings, conclusions or opinions relating to the concrete and/or masonry
at the Property.
RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its
possession, custody, or control relating to the Project at issue in this litigation as they are
maintained in the ordinary course of business. Accordingly, to the extent non-privileged
documents responsive to this Request are in Plaintiff’s possession, custody, or control, they
have been included in that production. Documents withheld on the basis of privilege are
listed on the privilege log produced by Plaintiff.
22. All records of warranty requests and warranty work performed by DON KING’S
at the Property.
RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its
possession, custody, or control relating to the Project at issue in this litigation as they are
maintained in the ordinary course of business. Accordingly, to the extent non-privileged
documents responsive to this Request are in Plaintiff’s possession, custody, or control, they
have been included in that production. Documents withheld on the basis of privilege are
listed on the privilege log produced by Plaintiff.
23. All records of any work performed by any individual or entity from the date of
issuance of the certificates of occupancy to the present relating to the concrete and/or masonry at
the Property.
RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its
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possession, custody, or control relating to the Project at issue in this litigation as they are
maintained in the ordinary course of business. Accordingly, to the extent non-privileged
documents responsive to this Request are in Plaintiff’s possession, custody, or control, they
have been included in that production. Documents withheld on the basis of privilege are
listed on the privilege log produced by Plaintiff.
24. All contracts and agreements relating to the property management services
performed from the date of issuance of the certificates of occupancy to the present for the Property.
RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its
possession, custody, or control relating to the Project at issue in this litigation as they are
maintained in the ordinary course of business. Accordingly, to the extent non-privileged
documents responsive to this Request are in Plaintiffs possession, custody, or control, they
have been included in that production. Documents withheld on the basis of privilege are
listed on the privilege log produced by Plaintiff.
25. All documents that evidence or relate to any violations of building codes pertaining
to the concrete and/or masonry at the Property.
RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its
possession, custody, or control relating to the Project at issue in this litigation as they are
maintained in the ordinary course of business. Accordingly, to the extent non-privileged
documents responsive to this Request are in Plaintiffs possession, custody, or control, they
have been included in that production. Documents withheld on the basis of privilege are
listed on the privilege log produced by Plaintiff.
26. All reserve studies and financial statements related to the subject Property.
RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its
12
possession, custody, or control relating to the Project at issue in this litigation as they are
maintained in the ordinary course of business. Accordingly, to the extent non-privileged
documents responsive to this Request are in Plaintiff’s possession, custody, or control, they
have been included in that production. Documents withheld on the basis of privilege are
listed on the privilege log produced by Plaintiff.
27. All Board of Director meeting minutes from the date of turnover through thepresent.
RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its
possession, custody, or control relating to the Project at issue in this litigation as they are
maintained in the ordinary course of business. Accordingly, to the extent non-privileged
documents responsive to this Request are in Plaintiffs possession, custody, or control, they
have been included in that production. Documents withheld on the basis of privilege are
listed on the privilege log produced by Plaintiff.
DATED: November 2, 2021.
BALL JANIK LLP
By: _/s/ Christopher S. Tribbey
Phillip E. Joseph, FL Bar No. 1000368
Evan J. Small, FL Bar No. 57306
Jeffrey A. Widelitz FL Bar No. 105642
Christopher S. Tribbey, FL Bar No. 1003114
Kasey L. Joyce, FL Bar No. 1024705
201 E Pine Street, Suite 600
Orlando, FL 32801
Telephone: (407) 455-5664
Facsimile: (407) 902-2105
pjoseph@balljanik.com
small@balljanik.com
jwidelitz@pballjanik.com
ctribbey@balljanik.com
kjoyce@balljanik.com
ypalmer@balljanik.com
dtodd@balljanik.com
cbetancourt@balljanik.com
bburton@balljanik.com
rmack@balljanik.com
13
dmiksell balljanik.com
orlandodocket@balljanik.com
Counsel for Plaintiff Villas at Emerald Lake
Homeowners Association, Inc.
CERTIFICATE OF SERVICE
I certify that a true copy of the foregoing has been filed via the Florida Courts E-Filing
Portal on this 2"4 day of November, 2021.
/s/ Christopher S. Tribbey
Christopher S. Tribbey
SERVICE LIST
LANNIE D. HOUGH JR. THAMIR A.R. KADDOURI, JR.
ROBIN H. LEAVENGOOD PENELOPE T. ROWLETT
JAMES MICHAEL WALLS BETH ANN TOBEY
BRIAN C. PORTER Law Office of Thamir A.R. Kaddouri, Jr. P.A.
Carlton Fields, P.A. 3220 West Cypress Street
4221 W. Boy Scout Boulevard Tampa, FL 33607
Tampa, FL 33607-5780 P. 813-879-5752
P. 813-223-7000 F. 813-879-5707
F. 813-229-4133 Thamir.kaddouri@tampalaw.org
lhough@carltonfields.com ervice@tampalaw.org
nbonilla@carltonfields.cor beth. tobey@tampalaw.org
rleavengood@carltonfields.com
bporter@carltonfields.com Counsel for Defendant, Imperial Building
mwalls@carltonfields.com
Mwausidecantonherds.conr Corporation
johnson@earltonfields.com
bwoolard@ecarltonfields.com
Counsel for Defendant, Royal Oak Homes,
LLC
PAUL SIDNEY ELLIOTT PETER J. KAPSALES
P.O. Box 274204 MARGARET M. EFTA
Tampa, FL 33688-4204 Milne Law Group, P.A.
P. 813-265-1314 301 E. Pine Street, Suite 525
F. 813-961-1103 Orlando, FL 32801
14
pse@psejd.com P. 321-558-7700
pkapsales(@milnelawgroup.com
Counsel for Defendant, Hugh MacDonald mefta@milnelawgroup.com
Construction, Inc. (HMC) eservice@milnelawgroup.com
DENISE M. ANDERSON Counsel for Defendant, Weathermaster
ASHLEY M. MATTINGLY Building Products, Inc.
Butler Weihmuller Katz Craig LLP
400 N. Ashley Drive, Suite 2300
Tampa, FL 33602
P. 813-281-1900
danderson@butler.legal
mattingly@butler.legal
~
jjacobs@butler.legal
jorge@butler legal
Co-Counsel for Defendant, Hugh MacDonald
Construction, Inc.
DENISE M. ANDERSON TIMOTHY C. FORD
DAVID A. MERCER ANDREW E. HOLWAY
Butler Weihmuller Katz Craig, LLP Hill Ward Henderson
400 N. Ashley Drive, Suite 2300 101 E. Kennedy Blvd., Suite 3700
Tampa, FL 33602 Tampa, FL 33602
danderson@butler.Jegal P. 813-221-3900
dmercer@butler legal F. 813-221-2900
krieck@butler. legal Tim.ford@hwhlaw.com
jorge@butler. legal Andrew. holway@hwhlaw.com
tharry@butler.legal Tracy.coale@hwhlaw.com
Kathy.wernsing@hwhlaw.com
Counsel for Defendant, Don King’s Concrete, Derrick.calandra@hwhlaw.com
Inc.
Counsel for Defendant, Weintraub
Inspections & Forensics, Inc. n/k/a Weintraub
Engineering and Inspections, Inc.
JAYNE ANN PITTMAN BRUCE R. CALDERON
NATALIE C, FISCHER D. BRYAN HILL
Conroy Simberg AUDRA R. CREECH
Two South Orange Avenue, Suite 300 Milber Makris Plousadis & Seiden, LLP
Orlando, FL 32801 1900 NW Corporate Blvd.
P. (407) 649-9797 East Tower, Suite 440
F. (407) 649-1968 Boca Raton, FL 33431
eserviceorl@conroysimberg.com P. (561) 994-7310
jpittman@conroysimberg.com F. (561) 994-7313
mmaitland@conroysimberg.com bealderon@milbermakris.com
15
nfischer@conroysimberg.com dhill@milbermakris.com
creech@milbermakris.com
Counsel for Defendant, Advanced Wrapping kmedowell@milbermakris.com
and Concrete Solutions of Central Florida,
Ine. Counsel for Defendant, Brown + Company
Architecture, Inc.
WILLIAM M. WOODS S. SCOTT ROSS
The Law Offices of William Woods Groelle & Salmon, P.A.
100 S Missouri Ave Ste 201 1715 N. Westshore Blvd., Suite 320
Clearwater, FL 33756-5763 Tampa, FL 33607
O: 727-799-1229 Ext. 4063 P. (813) 849-7200
C: 727-282-7277 gstcourtdocs@gspalaw.com
F: 727-252-1088 ross@gs salaw.com
cebanks@gspalaw.com
wwoods@willwoodslaw.com meoleman@gspalaw.com
AnneLM@willwoodslaw.com
Pleadings@willwoodslaw.com Counsel for Third-Party Defendant, Helberg
Enterprises, LLC
Counsel for Third-Party Defendant, All Glass
Installation Corp.
MICKH-AMBERF ANDREW T. MARSHALL
SARA W. MAPES
Lal HH. Peteilt & Ceh: Hamilton, Price & Marshall, P.A.
204-S-O. A Suite 400 2400 Manatee Ave. W.
Orlando,
FL 3280+ Bradenton, FL 34205
P. 941-748-0550
F. 941-745-2079
px ist HF andrew@hamiltonpricelaw.com
ed: defe ara@hamiltonpricelaw.com
ipes def nancy@hamiltonpricelaw.com
kelsey@hamiltonpricelaw.com
Lh& ThirdP. Defend Cc
atmservice@hamiltonpricelaw.com
Hawkins-Glasstne-
Counsel for T&M Construction of Sanford,
MICHAEL D. RUEL Ine.
BRENDEN C. COLLINS
Galloway, Johnson, Tompkins, Burr & Smith,
P.L.C.
400 N. Ashley Dr., Suite 1000
Tampa, FL 33602
P. 813-977-1200
F. 813-977-1288
tampaservbice@gallowaylawfirm.com
mruel@gallowaylawfirm.com
beollinsl@gallowaylawfirm.com
16
Counsel for Third-Party Defendant, Casey
Hawkins Glass, Inc.
BRUCE R. CALDERON COLE J. COPERTINO
D. BRYAN HILL RICHARD L. RUSSO
AUDRA R. CREECH Wright, Fulford, Moorhead & Brown, P.A.
Milber Makris Plousadis & Seiden, LLP 505 Maitland Avenue, Suite 1000
1900 NW Corporate Blvd., Altamonte Springs, Florida 32701
East Tower, Suite 440 P. (407) 425-0234
Boca Raton, FL 33431 F. (407) 425-0260
P. 561-994-7310 copertino@wfmblaw.com
F. 561-994-7313 rrusso@wfmblaw.com
TTUSSO(@ Wim olaw com
bealderon@milbermakris.com cbraungart@wfmblaw.com
dhill@milbermakris.con twilliams@wfmblaw.com
creech@milbermakris.com
Counsel for Well Hung Windows & Doors
Counsel for Defendant, Brown + Company
Architecture, Inc.
JOSEPH L. ZOLLNER CHESLEY G. MOODY, JR.
Law Office of Christopher Norris MAI M. LE
PO Box 7217 Moody & Graf, P.A.
London, KY 40742 1101 N. Lake Destiny Road, Suite 200
P. 904-346-5422 Maitland, FL 32751
F. 866-270-1372 P. (407) 755-6900
FloridaCDLegalMail@LibertyMutual.com F. (407) 755-6913
joseph.zollner@libertymutual.com moody@moodygraf.com
ule@moodygraf.com
Counsel for Lios Concrete Corp kpollak@moodygraf.com
tdixon@moodygraf.com
Counsel for Premier Plastering of Central
Florida, Inc. & Wolf's Irrigation &
Landscaping, Inc.
NICOLE SEROPIAN WAYNE M. ALDER
JENNIFE SHIPPOLE Fisher Broyles, LLP
Law Office of Jennifer L. Shippole 7668 N. W. 125" Way
14050 NW 14th Street, Suite 180 Pompano Beach, FL 33076
Sunrise, Florida 33323 P. 954-603-6174
Phone: 954-417-3066 Ext. 4645 Wayne.alder@fisherbroyles.com
jlspleadings@fednat.com wmalder@bellsouthnet.com
seropian@fednat.com
jshippole@fednat.com Counsel for E.R.O. Construction, Inc.
Counsel for Atlantic Concrete Systems, Inc.
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UNREPRESENTED PARTIES
Expert Painting & Pressure Washing, Inc.
c/o Richard C. Bates, Registered Agent
3631 Late Morning Cir.
Kissimmee, FL 34744
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Filing # 137757167 E-Filed 11/02/2021 03:54:47 PM THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA VILLAS AT EMERALD LAKE HOMEOWNERS | Case No.: 2020-CA-002942 ASSOCIATION, INC., a Florida not for profit corporation, Plaintiff, Vv. ROYAL OAK HOMES, LLC, a Florida limited liability company; ADVANCED WRAPPING AND CONCRETE SOLUTIONS OF CENTRAL FLORIDA, INC., a Florida corporation; DON KING’S CONCRETE, INC., a Florida corporation; HUGH MACDONALD CONSTRUCTION, INC., a Florida corporation; IMPERIAL BUILDING CORPORATION, a Florida corporation; PREMIER PLASTERING OF CENTRAL FLORIDA, INC N/K/A TGK STUCCO, INC., a Florida corporation; WEATHERMASTER BUILDING PRODUCTS, INC., a Florida corporation; WEINTRAUB INSPECTIONS & FORENSICS, INC. N/K/A WEINTRAUB ENGINEERING AND INSPECTIONS, INC., a Florida corporation; THE DIMILLO GROUP, LLC, a Florida limited liability company; WOLF’S IRRIGATION & LANDSCAPING, INC., a Florida corporation; SUMMERPARK HOMES, INC., a Florida corporation; BROWN + COMPANY ARCHITECTURE, INC., a Florida corporation; EXPERT PAINTING & PRESSURE WASHING, INC., a Florida Profit Corporation Defendants. ROYAL OAKS HOME, LLC., Cross-Claimant, Vv. ADVANCED WRAPPING AND CONCRETE SOLUTIONS OF CENTRAL FLORIDA, INC., a Florida corporation; DON KING'S CONCRETE, INC., a Florida corporation; HUGH MACDONALD CONSTRUCTION, INC., a Florida corporation; IMPERIAL BUILDING CORPORATION, a Florida corporation; PREMIER PLASTERING OF CENTRAL FLORIDA, INC N/K/A TGK STUCCO, INC., a Florida corporation, WEATHERMASTER BUILDING PRODUCTS, INC., a Florida corporation; WEINTRAUB INSPECTIONS & FORENSICS, INC. N/K/A WEINTRAUB ENGINEERING AND _ INSPECTIONS, INC., WOLF'S IRRIGATION & LANDSCAPING, INC., a Florida corporation, BROWN+COMPANY ARCHITECTURE, INC., a Florida corporation; Cross-Defendants / WEATHERMASTER BUILDING PRODUCTS, INC., a Florida Corporation, Third-Party Plaintiff, v ALL GLASS INSTALLATION CORP., a Florida corporation, CASEY HAWKINS, GLASS, INC., a Florida corporation; DEAN NESBIT, LLC, a Florida limited liability company; HELBERG ENTERPRISES, LLC, a Florida limited liability company; HOBBIT WINDOWS, LLC, a Florida limited liability company; T&M CONSTRUCTION OF SANFORD, INC., a Florida corporation; WELL DONE WINDOWS, INC., a Florida corporation; and WELL HUNG WINDOWS & DOORS, LLC, a Florida limited liability company; Third-Party Defendants. / DON KING’S CONCRETE, INC., a Florida corporation, Third-Party Plaintiff Vv. ER.O. CONSTRUCTION, _ INC., a Florida corporation; LIOS CONCRETE CORP., a Florida corporation; and ATLANTIC CONCRETE SYSTEMS, INC., a Florida corporation. Third-Party Defendants. PLAINTIFF’S RESPONSE TO DEFENDANT DON KING’S CONCRETE, INC.’S FIRST REQUEST FOR PRODUCTION Plaintiff, VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION, INC. (hereinafter “Plaintiff’) hereby responds to Defendant, DON KING’S CONCRETE, INC.’s (hereinafter “Defendant”) First Request for Production. RESPONSE TO FIRST REQUEST FOR PRODUCTION OF DOCUMENTS 1 All documents, including but not limited to, correspondence, notices, newsletters, announcements, posters and postings to or from tenants/occupants/unit owners relating or referring to the condition, maintenance, repair or replacement of any concrete and/or masonry work at the Property. RESPONSE: Plaintiff has produced all relevant documents in its possession, custody, or control, not of a privileged nature, relating to the Property at issue in this litigation, as they are maintained in the ordinary course of business. Accordingly, to the extent non- privileged documents responsive to this Request are in Plaintiffs possession, custody, or control, they are included in that production. Documents withheld on the basis of privilege are listed on the privilege log produced by Plaintiff. 2. All documents or other forms of communication between or received by any management company of Plaintiff for the Property relating or referring to the condition, maintenance, repair or replacement of concrete and/or masonry at the Property. RESPONSE: Plaintiff has produced all documents in its possession, custody, or control, not of a privileged nature, relating to the Property at issue in this litigation, as they are maintained in the ordinary course of business. Accordingly, to the extent non-privileged documents responsive to this Request are in Plaintiffs possession, custody, or control, they are included in that production. Documents withheld on the basis of privilege are listed on the privilege log produced by Plaintiff. 3 All documents relating to the design, installation, inspection, evaluation, testing, maintenance, repair or replacement of the concrete and/or masonry at the Property. RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its possession, custody, or control relating to the Project at issue in this litigation as they are maintained in the ordinary course of business. Accordingly, to the extent non-privileged documents responsive to this Request are in Plaintiff’s possession, custody, or control, they have been included in that production. Documents withheld on the basis of privilege are listed on the privilege log produced by Plaintiff. 4 All documents, including but not limited to electronic mail, written communications, letters, notes, tapes, recordings, memoranda, reports, summaries, notes, minutes, logs, diaries, journals, or other documents that refer or relate to the concrete and/or masonry at the Property. RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its possession, custody, or control relating to the Project at issue in this litigation as they are maintained in the ordinary course of business. Accordingly, to the extent non-privileged documents responsive to this Request are in Plaintiffs possession, custody, or control, they have been included in that production. Documents withheld on the basis of privilege are listed on the privilege log produced by Plaintiff. 5 All computer files, e-mails, and electronic data files of any kind relating to the concrete and/or masonry at the Property. RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its possession, custody, or control relating to the Project at issue in this litigation as they are maintained in the ordinary course of business. Accordingly, to the extent non-privileged documents responsive to this Request are in Plaintiff’s possession, custody, or control, they have been included in that production. Documents withheld on the basis of privilege are listed on the privilege log produced by Plaintiff. 6 All “as built” plans for the concrete and/or masonry at the Property. RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its possession, custody, or control relating to the Project at issue in this litigation as they are maintained in the ordinary course of business. Accordingly, to the extent non-privileged documents responsive to this Request are in Plaintiffs possession, custody, or control, they have been included in that production. Documents withheld on the basis of privilege are listed on the privilege log produced by Plaintiff. 7 All notices of default regarding the concrete and/or masonry at the Property. RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its possession, custody, or control relating to the Project at issue in this litigation as they are maintained in the ordinary course of business. Accordingly, to the extent non-privilege documents responsive to this Request are in Plaintiff’s possession, custody, or control, they have been included in that production. Documents withheld on the basis of privilege are listed on the privilege log produced by Plaintiff. 8 All documents, correspondence and/or communications with all persons or entities that inspected, evaluated, tested, maintained or repaired any component of the concrete and/or masonry at the Property. RESPONSE: Plaintiff objects to this request on the grounds that it is overbroad and vague as the phrase “[a]ll documents, correspondence, and/or communication with all persons or entities that inspected, evaluated, tested, maintained or repaired any component of the concrete and/or masonry . ..” could reference any person or entity involved with the construction of the masonry or concrete, repairs, if any, to the masonry or concrete, or inspections on the Project. Plaintiff has produced all relevant, non-privileged documents in its possession, custody, or control relating to the Project at issue in this litigation as they are maintained in the ordinary course of business. Accordingly, to the extent non-privileged documents responsive to this Request are in Plaintiffs possession, custody, or control, they have been included in that production. Documents withheld on the basis of privilege are listed on the privilege log produced by Plaintiff. 9 All documents, including any expert reports, which show any alleged construction defect or damage pertaining to the concrete and/or masonry at the Property. RESPONSE: Plaintiff refers Don King’s Concrete to its expert disclosure(s) and all related information. Plaintiff has produced all relevant, non-privileged documents in its possession, custody, or control relating to the Project at issue in this litigation as they are maintained in the ordinary course of business. Accordingly, to the extent non-privileged documents responsive to this Request are in Plaintiffs possession, custody, or control, they have been included in that production. Documents withheld on the basis of privilege are listed on the privilege log produced by Plaintiff. 10. All documents that evidence or relate to the amount of the Plaintiff's actual damages and losses sustained as a result of alleged defects or deficiencies pertaining tothe concrete and/or masonry at the Property. RESPONSE: Plaintiff refers Don King’s Concrete to its expert disclosure(s) and all related information. Plaintiff has produced all relevant, non-privileged documents in its possession, custody, or control relating to the Project at issue in this litigation as they are maintained in the ordinary course of business. Accordingly, to the extent non-privileged documents responsive to this Request are in Plaintiffs possession, custody, or control, they have been included in that production. Documents withheld on the basis of privilege are listed on the privilege log produced by Plaintiff. 11. All documents reflecting any remediation of the concrete and/or masonry at the Property, including but not limited to drawings, specifications, photographs, plans, budgeting, bids, bids analysis, blueprints, shop drawings and contracts. RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its possession, custody, or control relating to the Project at issue in this litigation as they are maintained in the ordinary course of business. Accordingly, to the extent non-privileged documents responsive to this Request are in Plaintiff's possession, custody, or control, they have been included in that production. Documents withheld on the basis of privilege are listed on the privilege log produced by Plaintiff. 12. All documents and correspondence related to any quotes, bids, proposal, estimates, or contractors for remediation of the concrete and/or masonry work at the Property. RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its possession, custody, or control relating to the Project at issue in this litigation as they are maintained in the ordinary course of business. Accordingly, to the extent non-privileged documents responsive to this Request are in Plaintiffs possession, custody, or control, they have been included in that production. Documents withheld on the basis of privilege are listed on the privilege log produced by Plaintiff. 13. All photographs, videos, sketches, diagrams, or depictions of any kind relating to the Property construction, repairs or restoration, construction deficiencies, alleged construction deficiencies related to the concrete and/or masonry at the Property. RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its possession, custody, or control relating to the Project at issue in this litigation as they are maintained in the ordinary course of business. Accordingly, to the extent non-privileged documents responsive to this Request are in Plaintiffs possession, custody, or control, they have been included in that production. Documents withheld on the basis of privilege are listed on the privilege log produced by Plaintiff. 14. All maintenance records for the Property, including but not limited to, maintenance schedules, invoices, checks, daily logs, and maintenance requests. RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its possession, custody, or control relating to the Project at issue in this litigation as they are maintained in the ordinary course of business. Accordingly, to the extent non-privileged documents responsive to this Request are in Plaintiff's possession, custody, or control, they have been included in that production. Documents withheld on the basis of privilege are listed on the privilege log produced by Plaintiff. 15. All 558 notices received or sent by Plaintiff in connection with this Project. RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its possession, custody, or control relating to the Project at issue in this litigation as they are maintained in the ordinary course of business. Accordingly, to the extent non-privileged documents responsive to this Request are in Plaintiff’s possession, custody, or control, they have been included in that production. Documents withheld on the basis of privilege are listed on the privilege log produced by Plaintiff. 16. All documents which support all claims made by you regarding the work performed by DON KING’S at the Property. RESPONSE: Plaintiff refers Don King’s Concrete to its previous disclosed expert reports and job files. Alternatively, Plaintiff has produced all relevant, non-privileged documents in its possession, custody, or control relating to the Project at issue in this litigation as they are maintained in the ordinary course of business. Accordingly, to the extent non-privileged documents responsive to this Request are in Plaintiff’s possession, custody, or control, they have been included in that production. Documents withheld on the basis of privilege are listed on the privilege log produced by Plaintiff. 17. All documents exchanged between you and any third party regarding the concrete and/or masonry at the Property. RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its possession, custody, or control relating to the Project at issue in this litigation as they are maintained in the ordinary course of business. Accordingly, to the extent non-privileged documents responsive to this Request are in Plaintiff’s possession, custody, or control, they have been included in that production. Documents withheld on the basis of privilege are listed on the privilege log produced by Plaintiff. 18. All insurance policies that may provide any coverage for any of the claims alleged in this cause of action, including applicable declaration pages. RESPONSE: Plaintiff objects to this request on the grounds that it is asking for Plaintiff to improperly make a legal conclusion regarding which insurance policies, if any, may provide benefits or coverage to the Plaintiff for any of the claims alleged in this cause of action. 19. Please provide a listing of every individual tenant/occupant/owner of any townhome who, to your knowledge, has made a complaint regarding any issues withrespect to the concrete and/or masonry, including the specifics of the complaint, the dateof complaint, full name of the tenant/occupant/owner, and building and unit number involved. RESPONSE: Plaintiff objects to this request on grounds Plaintiff is not required to prepare or create any documents in response to a request. Plaintiff has produced all relevant, non-privileged documents in its possession, custody, or control relating to the Project at issue in this litigation as they are maintained in the ordinary course of business. Accordingly, to the extent non-privileged documents responsive to this Request are in Plaintiff’s possession, custody, or control, they have been included in that production. Documents withheld on the basis of privilege are listed on the privilege log produced by Plaintiff. 20. All communications and documents, including but not limited to correspondence, memoranda, messages, letters, electronic mail, telegrams, teletypes, telefax, bulletins, meetings or other communications between Plaintiff and any party to this lawsuit relating to DON KING’S work performed at the Property. PONSE: Plaintiff has produced all relevant, non-privileged documents in its possession, custody, or control relating to the Project at issue in this litigation as they are maintained in the ordinary course of business. Accordingly, to the extent non-privileged documents responsive to this Request are in Plaintiffs possession, custody, or control, they 10 have been included in that production. Documents withheld on the basis of privilege are listed on the privilege log produced by Plaintiff. 21. All expert or consultant reports and all written documentation in any form regarding any expert or consultant findings, conclusions or opinions relating to the concrete and/or masonry at the Property. RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its possession, custody, or control relating to the Project at issue in this litigation as they are maintained in the ordinary course of business. Accordingly, to the extent non-privileged documents responsive to this Request are in Plaintiff’s possession, custody, or control, they have been included in that production. Documents withheld on the basis of privilege are listed on the privilege log produced by Plaintiff. 22. All records of warranty requests and warranty work performed by DON KING’S at the Property. RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its possession, custody, or control relating to the Project at issue in this litigation as they are maintained in the ordinary course of business. Accordingly, to the extent non-privileged documents responsive to this Request are in Plaintiff’s possession, custody, or control, they have been included in that production. Documents withheld on the basis of privilege are listed on the privilege log produced by Plaintiff. 23. All records of any work performed by any individual or entity from the date of issuance of the certificates of occupancy to the present relating to the concrete and/or masonry at the Property. RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its 11 possession, custody, or control relating to the Project at issue in this litigation as they are maintained in the ordinary course of business. Accordingly, to the extent non-privileged documents responsive to this Request are in Plaintiff’s possession, custody, or control, they have been included in that production. Documents withheld on the basis of privilege are listed on the privilege log produced by Plaintiff. 24. All contracts and agreements relating to the property management services performed from the date of issuance of the certificates of occupancy to the present for the Property. RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its possession, custody, or control relating to the Project at issue in this litigation as they are maintained in the ordinary course of business. Accordingly, to the extent non-privileged documents responsive to this Request are in Plaintiffs possession, custody, or control, they have been included in that production. Documents withheld on the basis of privilege are listed on the privilege log produced by Plaintiff. 25. All documents that evidence or relate to any violations of building codes pertaining to the concrete and/or masonry at the Property. RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its possession, custody, or control relating to the Project at issue in this litigation as they are maintained in the ordinary course of business. Accordingly, to the extent non-privileged documents responsive to this Request are in Plaintiffs possession, custody, or control, they have been included in that production. Documents withheld on the basis of privilege are listed on the privilege log produced by Plaintiff. 26. All reserve studies and financial statements related to the subject Property. RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its 12 possession, custody, or control relating to the Project at issue in this litigation as they are maintained in the ordinary course of business. Accordingly, to the extent non-privileged documents responsive to this Request are in Plaintiff’s possession, custody, or control, they have been included in that production. Documents withheld on the basis of privilege are listed on the privilege log produced by Plaintiff. 27. All Board of Director meeting minutes from the date of turnover through thepresent. RESPONSE: Plaintiff has produced all relevant, non-privileged documents in its possession, custody, or control relating to the Project at issue in this litigation as they are maintained in the ordinary course of business. Accordingly, to the extent non-privileged documents responsive to this Request are in Plaintiffs possession, custody, or control, they have been included in that production. Documents withheld on the basis of privilege are listed on the privilege log produced by Plaintiff. DATED: November 2, 2021. BALL JANIK LLP By: _/s/ Christopher S. Tribbey Phillip E. Joseph, FL Bar No. 1000368 Evan J. Small, FL Bar No. 57306 Jeffrey A. Widelitz FL Bar No. 105642 Christopher S. Tribbey, FL Bar No. 1003114 Kasey L. Joyce, FL Bar No. 1024705 201 E Pine Street, Suite 600 Orlando, FL 32801 Telephone: (407) 455-5664 Facsimile: (407) 902-2105 pjoseph@balljanik.com small@balljanik.com jwidelitz@pballjanik.com ctribbey@balljanik.com kjoyce@balljanik.com ypalmer@balljanik.com dtodd@balljanik.com cbetancourt@balljanik.com bburton@balljanik.com rmack@balljanik.com 13 dmiksell balljanik.com orlandodocket@balljanik.com Counsel for Plaintiff Villas at Emerald Lake Homeowners Association, Inc. CERTIFICATE OF SERVICE I certify that a true copy of the foregoing has been filed via the Florida Courts E-Filing Portal on this 2"4 day of November, 2021. /s/ Christopher S. Tribbey Christopher S. Tribbey SERVICE LIST LANNIE D. HOUGH JR. THAMIR A.R. KADDOURI, JR. ROBIN H. LEAVENGOOD PENELOPE T. ROWLETT JAMES MICHAEL WALLS BETH ANN TOBEY BRIAN C. PORTER Law Office of Thamir A.R. Kaddouri, Jr. P.A. Carlton Fields, P.A. 3220 West Cypress Street 4221 W. Boy Scout Boulevard Tampa, FL 33607 Tampa, FL 33607-5780 P. 813-879-5752 P. 813-223-7000 F. 813-879-5707 F. 813-229-4133 Thamir.kaddouri@tampalaw.org lhough@carltonfields.com ervice@tampalaw.org nbonilla@carltonfields.cor beth. tobey@tampalaw.org rleavengood@carltonfields.com bporter@carltonfields.com Counsel for Defendant, Imperial Building mwalls@carltonfields.com Mwausidecantonherds.conr Corporation johnson@earltonfields.com bwoolard@ecarltonfields.com Counsel for Defendant, Royal Oak Homes, LLC PAUL SIDNEY ELLIOTT PETER J. KAPSALES P.O. Box 274204 MARGARET M. EFTA Tampa, FL 33688-4204 Milne Law Group, P.A. P. 813-265-1314 301 E. Pine Street, Suite 525 F. 813-961-1103 Orlando, FL 32801 14 pse@psejd.com P. 321-558-7700 pkapsales(@milnelawgroup.com Counsel for Defendant, Hugh MacDonald mefta@milnelawgroup.com Construction, Inc. (HMC) eservice@milnelawgroup.com DENISE M. ANDERSON Counsel for Defendant, Weathermaster ASHLEY M. MATTINGLY Building Products, Inc. Butler Weihmuller Katz Craig LLP 400 N. Ashley Drive, Suite 2300 Tampa, FL 33602 P. 813-281-1900 danderson@butler.legal mattingly@butler.legal ~ jjacobs@butler.legal jorge@butler legal Co-Counsel for Defendant, Hugh MacDonald Construction, Inc. DENISE M. ANDERSON TIMOTHY C. FORD DAVID A. MERCER ANDREW E. HOLWAY Butler Weihmuller Katz Craig, LLP Hill Ward Henderson 400 N. Ashley Drive, Suite 2300 101 E. Kennedy Blvd., Suite 3700 Tampa, FL 33602 Tampa, FL 33602 danderson@butler.Jegal P. 813-221-3900 dmercer@butler legal F. 813-221-2900 krieck@butler. legal Tim.ford@hwhlaw.com jorge@butler. legal Andrew. holway@hwhlaw.com tharry@butler.legal Tracy.coale@hwhlaw.com Kathy.wernsing@hwhlaw.com Counsel for Defendant, Don King’s Concrete, Derrick.calandra@hwhlaw.com Inc. Counsel for Defendant, Weintraub Inspections & Forensics, Inc. n/k/a Weintraub Engineering and Inspections, Inc. JAYNE ANN PITTMAN BRUCE R. CALDERON NATALIE C, FISCHER D. BRYAN HILL Conroy Simberg AUDRA R. CREECH Two South Orange Avenue, Suite 300 Milber Makris Plousadis & Seiden, LLP Orlando, FL 32801 1900 NW Corporate Blvd. P. (407) 649-9797 East Tower, Suite 440 F. (407) 649-1968 Boca Raton, FL 33431 eserviceorl@conroysimberg.com P. (561) 994-7310 jpittman@conroysimberg.com F. (561) 994-7313 mmaitland@conroysimberg.com bealderon@milbermakris.com 15 nfischer@conroysimberg.com dhill@milbermakris.com creech@milbermakris.com Counsel for Defendant, Advanced Wrapping kmedowell@milbermakris.com and Concrete Solutions of Central Florida, Ine. Counsel for Defendant, Brown + Company Architecture, Inc. WILLIAM M. WOODS S. SCOTT ROSS The Law Offices of William Woods Groelle & Salmon, P.A. 100 S Missouri Ave Ste 201 1715 N. Westshore Blvd., Suite 320 Clearwater, FL 33756-5763 Tampa, FL 33607 O: 727-799-1229 Ext. 4063 P. (813) 849-7200 C: 727-282-7277 gstcourtdocs@gspalaw.com F: 727-252-1088 ross@gs salaw.com cebanks@gspalaw.com wwoods@willwoodslaw.com meoleman@gspalaw.com AnneLM@willwoodslaw.com Pleadings@willwoodslaw.com Counsel for Third-Party Defendant, Helberg Enterprises, LLC Counsel for Third-Party Defendant, All Glass Installation Corp. MICKH-AMBERF ANDREW T. MARSHALL SARA W. MAPES Lal HH. Peteilt & Ceh: Hamilton, Price & Marshall, P.A. 204-S-O. A Suite 400 2400 Manatee Ave. W. Orlando, FL 3280+ Bradenton, FL 34205 P. 941-748-0550 F. 941-745-2079 px ist HF andrew@hamiltonpricelaw.com ed: defe ara@hamiltonpricelaw.com ipes def nancy@hamiltonpricelaw.com kelsey@hamiltonpricelaw.com Lh& ThirdP. Defend Cc atmservice@hamiltonpricelaw.com Hawkins-Glasstne- Counsel for T&M Construction of Sanford, MICHAEL D. RUEL Ine. BRENDEN C. COLLINS Galloway, Johnson, Tompkins, Burr & Smith, P.L.C. 400 N. Ashley Dr., Suite 1000 Tampa, FL 33602 P. 813-977-1200 F. 813-977-1288 tampaservbice@gallowaylawfirm.com mruel@gallowaylawfirm.com beollinsl@gallowaylawfirm.com 16 Counsel for Third-Party Defendant, Casey Hawkins Glass, Inc. BRUCE R. CALDERON COLE J. COPERTINO D. BRYAN HILL RICHARD L. RUSSO AUDRA R. CREECH Wright, Fulford, Moorhead & Brown, P.A. Milber Makris Plousadis & Seiden, LLP 505 Maitland Avenue, Suite 1000 1900 NW Corporate Blvd., Altamonte Springs, Florida 32701 East Tower, Suite 440 P. (407) 425-0234 Boca Raton, FL 33431 F. (407) 425-0260 P. 561-994-7310 copertino@wfmblaw.com F. 561-994-7313 rrusso@wfmblaw.com TTUSSO(@ Wim olaw com bealderon@milbermakris.com cbraungart@wfmblaw.com dhill@milbermakris.con twilliams@wfmblaw.com creech@milbermakris.com Counsel for Well Hung Windows & Doors Counsel for Defendant, Brown + Company Architecture, Inc. JOSEPH L. ZOLLNER CHESLEY G. MOODY, JR. Law Office of Christopher Norris MAI M. LE PO Box 7217 Moody & Graf, P.A. London, KY 40742 1101 N. Lake Destiny Road, Suite 200 P. 904-346-5422 Maitland, FL 32751 F. 866-270-1372 P. (407) 755-6900 FloridaCDLegalMail@LibertyMutual.com F. (407) 755-6913 joseph.zollner@libertymutual.com moody@moodygraf.com ule@moodygraf.com Counsel for Lios Concrete Corp kpollak@moodygraf.com tdixon@moodygraf.com Counsel for Premier Plastering of Central Florida, Inc. & Wolf's Irrigation & Landscaping, Inc. NICOLE SEROPIAN WAYNE M. ALDER JENNIFE SHIPPOLE Fisher Broyles, LLP Law Office of Jennifer L. Shippole 7668 N. W. 125" Way 14050 NW 14th Street, Suite 180 Pompano Beach, FL 33076 Sunrise, Florida 33323 P. 954-603-6174 Phone: 954-417-3066 Ext. 4645 Wayne.alder@fisherbroyles.com jlspleadings@fednat.com wmalder@bellsouthnet.com seropian@fednat.com jshippole@fednat.com Counsel for E.R.O. Construction, Inc. Counsel for Atlantic Concrete Systems, Inc. 17 UNREPRESENTED PARTIES Expert Painting & Pressure Washing, Inc. c/o Richard C. Bates, Registered Agent 3631 Late Morning Cir. Kissimmee, FL 34744 18