Preview
Filing # 172513444 E-Filed 05/05/2023 10:10:39 AM
IN THE CIRCUIT COURT OF
THE NINTH JUDICIAL CIRCUIT
IN AND FOR OSCEOLA
COUNTY, FLORIDA
VILLAS AT EMERALD LAKE
HOMEOWNERS ASSOCIATION, INC., a
Florida not for profit corporation,
Plaintiff, Case No.: 2020-CA-002942
v.
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,
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Defendants.
___________________________________/
ROYAL OAKS HOME, LLC.,
Cross-Claimant,
v.
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,
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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,
v.
E.R.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/CROSS-DEFENDANT
ADVANCED WRAPPING AND CONCRETE SOLUTIONS OF CENTRAL
FLORIDA, INC.’S FIRST REQUEST FOR PRODUCTION
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Plaintiff, VILLAS AT EMERALD LAKE HOMEOWNERS
ASSOCIATION, INC. (hereinafter “Plaintiff”) hereby responds to
Defendant/Cross-Defendant ADVANCED WRAPPING AND CONCRETE
SOLUTIONS OF CENTRAL FLORIDA, INC.’s (hereinafter “Defendant”) First
Request for Production.
RESPONSE TO FIRST REQUEST FOR PRODUCTION OF
DOCUMENTS
1. All maintenance records for the townhomes and common areas of
townhome community known as Villas at Emerald Lake located Kissimmee, in O
County, Florida (the “Property”).
RESPONSE: Pursuant to the CMO, Plaintiff has produced (and will
supplement the same) non-privileged documents relating to the Subject
Property as the same are ordinarily maintained in the course of business. To
the extent non-privileged documents that are responsive to this request are
within Plaintiff’s possession, custody, or control, such documents were included
in that production. If documents were withheld on the basis of privilege, such
documents were identified on a contemporaneously produced privilege log.
2. All reports as to the inspection, observation, evaluation or testing of the
Property.
RESPONSE: Plaintiff objects to this request to the extent it seeks
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information protected by attorney-client privilege and/or the attorney work
product doctrine. Notwithstanding, Plaintiff has produced its experts’ reports
in the expert disclosure pursuant to the operative CMO. Plaintiff has produced
its experts’ job files in accordance with the operative CMO deadlines.
3. All consultants and experts reports rendered before, during and/or after
construction, not limited to geotechnical reports, subsurface condition reports,
building envelope conditions reports and structural reports.
RESPONSE: Plaintiff objects to this request to the extent it seeks
information protected by attorney-client privilege and/or the attorney work
product doctrine. Further, Plaintiff was not involved in the original
construction, neither before nor during the same. As such, it is not in the
possession of any reports created during those times, if any.
Notwithstanding, Plaintiff has produced its experts’ reports in the expert
disclosure pursuant to the operative CMO. Plaintiff has also produced its
experts’ job files in accordance with the operative CMO deadlines.
4. All documents showing ADVANCED knew or should have known of
any condition alleged in the Complaint.
RESPONSE: Plaintiff has produced its experts’ reports in the expert
disclosure pursuant to the operative CMO. Plaintiff has also produced its
experts’ job files in accordance with the operative CMO deadlines.
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5. All document showing repairs performed by ADVANCED at the
Property.
RESPONSE: Upon information and belief, none.
6. Any and all documents and/or lists of contractors who have performed
work or services on the Property.
RESPONSE: Plaintiff states that it was not involved in the original
construction. Notwithstanding, to the extent this request seeks information
regarding regular maintenance or temporary repairs, pursuant to the CMO,
Plaintiff has produced (and will supplement the same) non-privileged
documents relating to the Subject Property as the same are ordinarily
maintained in the course of business. To the extent non-privileged documents
that are responsive to this request are within Plaintiff’s possession, custody, or
control, such documents were included in that production. If documents were
withheld on the basis of privilege, such documents were identified on a
contemporaneously produced privilege log.
7. Any and all lists of employees (with addresses and phone numbers) who
have worked at the Property for you.
RESPONSE: Plaintiff is not required to create a list for the purposes of
production. Notwithstanding, Plaintiff is a Board consisting of volunteers. It
does not have direct employees. If this request seeks information related to
community association management companies or repair and/or maintenance
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contractors, Plaintiff has produced (and will supplement the same) non-
privileged documents relating to the Subject Property as the same are
ordinarily maintained in the course of business. To the extent non-privileged
documents that are responsive to this request are within Plaintiff’s possession,
custody, or control, such documents were included in that production. If
documents were withheld on the basis of privilege, such documents were
identified on a contemporaneously produced privilege log.
8. Copies of any and all photographs of the Property.
RESPONSE: Plaintiff objects to this request to the extent it seeks any
information protected by attorney-client privilege and/or the attorney work
product privilege. Notwithstanding, Plaintiff has produced its experts’ reports
in the expert disclosure pursuant to the operative CMO. Plaintiff has also
produced its experts’ job files in accordance with the operative CMO deadlines.
Further, pursuant to the CMO, Plaintiff has produced non-privileged
documents relating to the Subject Property as the same are ordinarily
maintained in the course of business. To the extent non-privileged documents
that are responsive to this request are within Plaintiff’s possession, custody, or
control, such documents were included in that production. If documents were
withheld on the basis of privilege, such documents were identified on a
contemporaneously produced privilege log.
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9. Any and all videotapes depicting any areas of the Property exhibiting
alleged construction defects at the Project.
RESPONSE: Plaintiff objects to this request to the extent it seeks any
information protected by attorney-client privilege and/or the attorney work
product privilege. Notwithstanding, Plaintiff has produced its experts’ reports
in the expert disclosure pursuant to the operative CMO. Plaintiff has also
produced its experts’ job files in accordance with the operative CMO deadlines.
Further, pursuant to the CMO, Plaintiff has produced non-privileged
documents relating to the Subject Property as the same are ordinarily
maintained in the course of business. To the extent non-privileged documents
that are responsive to this request are within Plaintiff’s possession, custody, or
control, such documents were included in that production. If documents were
withheld on the basis of privilege, such documents were identified on a
contemporaneously produced privilege log.
10. Any and all documents stating qualification and/or opinions of any
expert or consultant retained by you.
RESPONSE: Plaintiff objects to this request to the extent it seeks any
information protected by attorney-client privilege and/or the attorney work
product privilege. Notwithstanding, Plaintiff has produced its experts’ reports
in the expert disclosure pursuant to the operative CMO. Plaintiff has also
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produced its experts’ job files in accordance with the operative CMO deadlines.
11. Any and all correspondence, memorandum and notes to any consultant
or contractor, regarding conditions of the Property.
RESPONSE: Plaintiff objects to this request to the extent it seeks any
information protected by attorney-client privilege and/or the attorney work
product privilege. Notwithstanding, Plaintiff has produced its experts’ reports
in the expert disclosure pursuant to the operative CMO. Plaintiff has also
produced its experts’ job files in accordance with the operative CMO deadlines.
12. Any and all estimates for the alleged damage and/or remediation at
the Property.
RESPONSE: Plaintiff has produced its experts’ reports in the expert
disclosure pursuant to the operative CMO. Plaintiff has also produced its
experts’ job files in accordance with the operative CMO deadlines.
To the extent this request seeks information regarding regular
maintenance or temporary repairs, pursuant to the CMO, Plaintiff has
produced (and will supplement the same) non-privileged documents relating to
the Subject Property as the same are ordinarily maintained in the course of
business. To the extent non-privileged documents that are responsive to this
request are within Plaintiff’s possession, custody, or control, such documents
were included in that production. If documents were withheld on the basis of
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privilege, such documents were identified on a contemporaneously produced
privilege log.
13. Any witness statements/affidavits.
RESPONSE: Plaintiff objects to this request to the extent it seeks any
information protected by attorney-client privilege and/or the attorney work
product privilege.
Plaintiff has produced non-privileged documents relating to the Subject
Property as the same are ordinarily maintained in the course of business. To
the extent non-privileged documents that are responsive to this request are
within Plaintiff’s possession, custody, or control, such documents were included
in that production. If documents were withheld on the basis of privilege, such
documents were identified on a contemporaneously produced privilege log.
14. All settlement agreements, assignments, releases or other records or
releases of any person or entity regardless of whether a lawsuit was initiated arising
out of alleged construction defects at the Property, including, but not limited to, issues
relating to design or inspection.
RESPONSE: Plaintiff objects to this request to the extent it seeks any
information protected by attorney-client privilege and/or the attorney work
product privilege. Notwithstanding, any dismissals filed in this case, if any, are
a matter of public record and such information can be discerned from the case
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docket via the Osceola County Clerk of Court’s office.
15. All requests for repairs made to ADVANCED and/or ROYAL
OAKS HOMES, LLC by Plaintiff.
RESPONSE: Upon information and belief, none.
16. All notices of alleged defects made by Plaintiff to ROYAL OAKS
HOMES, LLC and/or ADVANCED.
RESPONSE: Pursuant to the CMO, Plaintiff has produced non-
privileged documents relating to the Subject Property as the same are
ordinarily maintained in the course of business. To the extent non-privileged
documents that are responsive to this request are within Plaintiff’s possession,
custody, or control, such documents were included in that production. If
documents were withheld on the basis of privilege, such documents were
identified on a contemporaneously produced privilege log.
17. Any other forensic reports, conditions assessments or housewrap
evaluations regarding the Project performed by any person at any time prior to the
contemplation of the instant litigation, including any ancillary photos, job files
and/or expert witness disclosure related thereto.
RESPONSE: Plaintiff objects to this request to the extent it seeks any
information protected by attorney-client privilege and/or the attorney work
product privilege. Plaintiff was not involved in the original construction of the
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Subject Property and, therefore, is not in possession of any inspection records
that occurred during that time. Notwithstanding, Plaintiff has produced its
experts’ reports in the expert disclosure pursuant to the operative CMO.
Plaintiff has produced its experts’ job files in accordance with the operative
CMO deadlines.
18. Any and all photographs or videos depicting or regarding interior
damages to the Property, whether taken prior or subsequent to contemplation of the
instant litigation.
RESPONSE: Plaintiff objects to this request to the extent it seeks any
information protected by attorney-client privilege and/or the attorney work
product privilege. Notwithstanding, Plaintiff has produced its experts’ reports
in the expert disclosure pursuant to the operative CMO. Plaintiff has produced
its experts’ job files in accordance with the operative CMO deadlines.
Further, pursuant to the CMO, Plaintiff has produced non-privileged
documents relating to the Subject Property as the same are ordinarily
maintained in the course of business. To the extent non-privileged documents
that are responsive to this request are within Plaintiff’s possession, custody, or
control, such documents were included in that production. If documents were
withheld on the basis of privilege, such documents were identified on a
contemporaneously produced privilege log.
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19. Any and all document evidencing reports of or repairs to sources or
suspected sources of water intrusion at the Project.
RESPONSE: Plaintiff objects to this request to the extent it seeks any
information protected by attorney-client privilege and/or the attorney work
product privilege. Notwithstanding, Plaintiff has produced its experts’ reports
in the expert disclosure pursuant to the operative CMO. Plaintiff has also
produced its experts’ job files in accordance with the operative CMO deadlines.
To the extent this request seeks information regarding regular
maintenance or temporary repairs, pursuant to the CMO, Plaintiff has
produced non-privileged documents relating to the Subject Property as the
same are ordinarily maintained in the course of business. To the extent non-
privileged documents that are responsive to this request are within Plaintiff’s
possession, custody, or control, such documents were included in that
production. If documents were withheld on the basis of privilege, such
documents were identified on a contemporaneously produced privilege log.
20. Any and all documents evincing repairs or maintenance performed on
or to the building envelope of the Project, including but not limited to repairs or
maintenance performed on or to the exterior walls, balconies, roofs, penetrations or
fenestrations, whether prior or subsequent to the contemplation of the instant
litigation.
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RESPONSE: Plaintiff objects to this request to the extent it seeks any
information protected by attorney-client privilege and/or the attorney work
product privilege. Notwithstanding, Plaintiff has produced its experts’ reports
in the expert disclosure pursuant to the operative CMO. Plaintiff has also
produced its experts’ job files in accordance with the operative CMO deadlines.
To the extent this request seeks information regarding regular
maintenance or temporary repairs, pursuant to the CMO, Plaintiff has
produced non-privileged documents relating to the Subject Property as the
same are ordinarily maintained in the course of business. To the extent non-
privileged documents that are responsive to this request are within Plaintiff’s
possession, custody, or control, such documents were included in that
production. If documents were withheld on the basis of privilege, such
documents were identified on a contemporaneously produced privilege log.
21. All indexes, file numbers or retrieval information concerning any of the
documents or materials involved in paragraphs 1 through 20 above.
RESPONSE: Plaintiff is not required to create a list of documents and/or
index of the same for the purpose of production. Additionally, Plaintiff objects
to this request to the extent it seeks any information protected by attorney-
client privilege and/or the attorney work product privilege. Notwithstanding,
Plaintiff has produced its experts’ reports in the expert disclosure pursuant to
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the operative CMO. Plaintiff has also produced its experts’ job files in
accordance with the operative CMO deadlines.
Further, pursuant to the CMO, Plaintiff has produced non-privileged
documents relating to the Subject Property as the same are ordinarily
maintained in the course of business. To the extent non-privileged documents
that are responsive to this request are within Plaintiff’s possession, custody, or
control, such documents were included in that production. If documents were
withheld on the basis of privilege, such documents were identified on a
contemporaneously produced privilege log.
DATED: May 5, 2023.
BALL JANIK LLP
By: /s/ Kasey L. Joyce
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
esmall@balljanik.com
jwidelitz@balljanik.com
ctribbey@balljanik.com
kjoyce@balljanik.com
dtodd@balljanik.com
cbetancourt@balljanik.com
bburton@balljanik.com
orlandodocket@balljanik.com
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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 5th day of May 2023.
/s/ Kasey L. Joyce, Esq.
Kasey L. Joyce, Esq.
SERVICE LIST
LUIS PRATS THAMIR A.R. KADDOURI, JR.
LANNIE D. HOUGH, JR. PENELOPE T. ROWLETT
JAMES MICHAEL WALLS BETH ANN TOBEY
ROBIN H. LEAVENGOOD Law Office of Thamir A.R. Kaddouri,
Carlton Fields, P.A. Jr. P.A.
4221 W. Boy Scout Boulevard 3220 West Cypress Street
Tampa, FL 33607-5780 Tampa, FL 33607
(813) 223-7000 (813) 879-5752
lprats@carltonfields.com thamir.kaddouri@tampalaw.org
lhough@carltonfields.com service@tampalaw.org
mwalls@carltonfields.com beth.tobey@tampalaw.org
rleavengood@carltonfields.com
mramos@carltonfields.com Counsel for Defendant, Imperial
nbonilla@carltonfields.com Building Corporation
ejohnson@carltonfields.com
krick@carltonfields.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.
(813) 265-1314 301 E. Pine Street, Suite 525
16
pse@psejd.com Orlando, FL 32801
(321) 558-7700
Counsel for Defendant, Hugh pkapsales@milnelawgroup.com
MacDonald Construction, Inc. (HMC) mefta@milnelawgroup.com
eservice@milnelawgroup.com
DENISE M. ANDERSON
ASHLEY M. MATTINGLY Counsel for Defendant, Weathermaster
Butler Weihmuller Katz Craig LLP Building Products, Inc.
400 N. Ashley Drive, Suite 2300
Tampa, FL 33602
(813) 281-1900
danderson@butler.legal
amattingly@butler.legal
krieck@butler.legal
rjorge@butler.legal
Co-Counsel for Defendant, Hugh
MacDonald Construction, Inc.
DENISE M. ANDERSON ANDREW E. HOLWAY
DAVID A. MERCER J. ROCCO CAFARO
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.legal (813) 221-3900
dmercer@butler.legal andrew.holway@hwhlaw.com
krieck@butler.legal derrick.calandra@hwhlaw.com
rjorge@butler.legal jill.kuty@hwhlaw.com
tbarry@butler.legal kathy.wernsing@hwhlaw.com
rocco.cafaro@hwhlaw.com
Counsel for Defendant, Don King’s tracy.coale@hwhlaw.com
Concrete, Inc.
Counsel for Defendant/Cross
Defendant, Weintraub Inspections &
Forensics, Inc. n/k/a Weintraub
Engineering and Inspections, Inc.
JAYNE ANN PITTMAN BRUCE R. CALDERON
NATALIE C. FISCHER ALICIA Z. GROSS
Conroy Simberg BARRI A. REISCH
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Two South Orange Avenue, Suite 300 Milber Makris Plousadis & Seiden,
Orlando, FL 32801 LLP
(407) 649-9797 1900 NW Corporate Blvd.
eserviceorl@conroysimberg.com East Tower, Suite 440
jpittman@conroysimberg.com Boca Raton, FL 33431
mmaitland@conroysimberg.com (561) 994-7310
nfischer@conroysimberg.com bcalderon@milbermakris.com
azgross@milbermakris.com
Counsel for Defendant, Advanced breisch@milbermakris.com
Wrapping and Concrete Solutions of kmcdowell@milbermakris.com
Central Florida, Inc. sskowronski@milbermakris.com
Counsel for Defendant/Cross-
Defendant, Brown + Company
Architecture, Inc.
JENNIFER MILLER BROOKS S. SCOTT ROSS
KIRA TSIRING Groelle & Salmon, P.A.
Hamilton, Miller & Birthisel, LLP 1715 N. Westshore Blvd., Suite 320
150 Southeast Second Avenue, Suite Tampa, FL 33607
1200 (813) 849-7200
Miami, FL 33131-2332 gstcourtdocs@gspalaw.com
(305) 379-3686 sross@gspalaw.com
jmiller@hamiltonmillerlaw.com cebanks@gspalaw.com
ktsiring@hamiltonmillerlaw.com mcoleman@gspalaw.com
jcasaccio@hamiltonmillerlaw.com
Counsel for Third-Party Defendant,
Counsel for Defendant/Cross- Helberg Enterprises, LLC
Defendant, TGK Stucco, Inc.
VICKI LAMBERT ANDREW T. MARSHALL
ALEC MASSON SARA W. MAPES
Luks, Santaniello, Petrillo & Cohen Hamilton, Price & Marshall, P.A.
201 S. Orange Avenue, Suite 400 2400 Manatee Ave. W.
Orlando, FL 32801 Bradenton, FL 34205
(407) 540-9170 (941) 748-0550
luksorl-pleadings@ls-law.com andrew@hamiltonpricelaw.com
amason@insurancedefense.net sara@hamiltonpricelaw.com
jpestonit@insurancedefense.net nancy@hamiltonpricelaw.com
kelsey@hamiltonpricelaw.com
atmservice@hamiltonpricelaw.com
18
Counsel for Third-Party Defendant,
Casey Hawkins Glass, Inc. Counsel for Third-Party Defendant,
T&M Construction of Sanford, Inc.
PHILLIP S. HOWELL
BRENDEN C. COLLINS WILLIAM M. WOODS
Galloway, Johnson, Tompkins, Burr & JOSEPH M. CLINE
Smith, P.L.C. 100 S. Missouri Avenue, Suite 201
400 N. Ashley Dr., Suite 1000 Clearwater, Fl 33756
Tampa, FL 33602 (727) 799-1229, Ext. 4072
(813) 977-1200 wwoods@willwoodslaw.com
tampaservice@gallowaylawfirm.com josephc@willwoodslaw.com
phowell@gallowaylawfirm.com marital@willwoodslaw.com
bcollinsl@gallowaylawfirm.com pleadings@willwoodslaw.com
Counsel for Third-Party Defendant, Counsel for Third-Party Defendants,
Casey Hawkins Glass, Inc. T & M Construction of Sanford, Inc.
and All Glass Installation Corp.
JOSEPH L. ZOLLNER COLE J. COPERTINO
Law Office of Christopher Norris JAMES MICHAEL MOORHEAD
PO Box 7217 Wright, Fulford, Moorhead & Brown,
London, KY 40742 P.A.
(904) 346-5422 505 Maitland Avenue, Suite 1000
floridacdlegalmail@libertymutual.com Altamonte Springs, FL 32701
joseph.zollner@libertymutual.com (407) 425-0234
ccopertino@wfmblaw.com
Counsel for Third-Party Defendant, cbraungart@wfmblaw.com
Lios Concrete Corp mmoorhead@wfmblaw.com
jgarcia@wfmblaw.com
Counsel for Third-Party Defendant,
Well Hung Windows & Doors
MONAL O. ZIPPER CHESLEY G. MOODY, JR.
JENNIFE SHIPPOLE MAI M. LE
Law Office of Jennifer L. Shippole Moody & Graf, P.A.
14050 NW 14th Street, Suite 180 1101 N. Lake Destiny Road, Suite 200
Sunrise, FL 33323 Maitland, FL 32751
(954) 417-3066 Ext. 4645 (407) 755-6900
jlspleadings@fednat.com cmoody@moodygraf.com
mzipper@fednat.com mle@moodygraf.com
jshippole@fednat.com kbraund@moodygraf.com
19
iperera@moodygraf.com
Counsel for Third-Party Defendant,
Atlantic Concrete Systems, Inc. Counsel for Premier Plastering of
Central Florida, Inc. Withdrew for
Premier Plastering only 3.4.2022 &
Defendant/Cross-Defendant, Wolf’s
Irrigation & Landscaping, Inc.
JERRILYNN HADLEY WAYNE M. ALDER
TODD M. LADAUCEUR Fisher Broyles, LLP
Galloway, Johnson, Tompkins, Burr 7668 N. W. 125th Way
and Smith, PLC Pompano Beach, FL 33076
118 E. Garden Street (954) 603-6174
Pensacola, FL 32502 wayne.alder@fisherbroyles.com
(850) 436-7000 wmalder@bellsouthnet.com
tmlconstruction@gallowaylawfirm.com
Counsel for Third-Party Defendant,
Counsel for Third-Party Defendant E.R.O. Construction, Inc. and Well
Hobbit Windows, LLC Done Windows, Inc.
SHAUN M. QUINN
JACKELINE RODRIGUEZ
Hamilton, Miller & Birthisel, LLP
150 S.E. 2nd Avenue, Suite 1200
Miami, FL 33131
(305) 379-3686
squinn@hamiltonmillerlaw.com
jrodriguez@hamiltonmiller.com
Counsel for Defendant/ Cross-
Defendant, Premier Plastering of
Central Florida, Inc.
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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Preview
Filing # 172513444 E-Filed 05/05/2023 10:10:39 AM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION, INC., a Florida not for profit corporation, Plaintiff, Case No.: 2020-CA-002942 v. 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, 1 Defendants. ___________________________________/ ROYAL OAKS HOME, LLC., Cross-Claimant, v. 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, 2 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, v. E.R.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/CROSS-DEFENDANT ADVANCED WRAPPING AND CONCRETE SOLUTIONS OF CENTRAL FLORIDA, INC.’S FIRST REQUEST FOR PRODUCTION 3 Plaintiff, VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION, INC. (hereinafter “Plaintiff”) hereby responds to Defendant/Cross-Defendant ADVANCED WRAPPING AND CONCRETE SOLUTIONS OF CENTRAL FLORIDA, INC.’s (hereinafter “Defendant”) First Request for Production. RESPONSE TO FIRST REQUEST FOR PRODUCTION OF DOCUMENTS 1. All maintenance records for the townhomes and common areas of townhome community known as Villas at Emerald Lake located Kissimmee, in O County, Florida (the “Property”). RESPONSE: Pursuant to the CMO, Plaintiff has produced (and will supplement the same) non-privileged documents relating to the Subject Property as the same are ordinarily maintained in the course of business. To the extent non-privileged documents that are responsive to this request are within Plaintiff’s possession, custody, or control, such documents were included in that production. If documents were withheld on the basis of privilege, such documents were identified on a contemporaneously produced privilege log. 2. All reports as to the inspection, observation, evaluation or testing of the Property. RESPONSE: Plaintiff objects to this request to the extent it seeks 4 information protected by attorney-client privilege and/or the attorney work product doctrine. Notwithstanding, Plaintiff has produced its experts’ reports in the expert disclosure pursuant to the operative CMO. Plaintiff has produced its experts’ job files in accordance with the operative CMO deadlines. 3. All consultants and experts reports rendered before, during and/or after construction, not limited to geotechnical reports, subsurface condition reports, building envelope conditions reports and structural reports. RESPONSE: Plaintiff objects to this request to the extent it seeks information protected by attorney-client privilege and/or the attorney work product doctrine. Further, Plaintiff was not involved in the original construction, neither before nor during the same. As such, it is not in the possession of any reports created during those times, if any. Notwithstanding, Plaintiff has produced its experts’ reports in the expert disclosure pursuant to the operative CMO. Plaintiff has also produced its experts’ job files in accordance with the operative CMO deadlines. 4. All documents showing ADVANCED knew or should have known of any condition alleged in the Complaint. RESPONSE: Plaintiff has produced its experts’ reports in the expert disclosure pursuant to the operative CMO. Plaintiff has also produced its experts’ job files in accordance with the operative CMO deadlines. 5 5. All document showing repairs performed by ADVANCED at the Property. RESPONSE: Upon information and belief, none. 6. Any and all documents and/or lists of contractors who have performed work or services on the Property. RESPONSE: Plaintiff states that it was not involved in the original construction. Notwithstanding, to the extent this request seeks information regarding regular maintenance or temporary repairs, pursuant to the CMO, Plaintiff has produced (and will supplement the same) non-privileged documents relating to the Subject Property as the same are ordinarily maintained in the course of business. To the extent non-privileged documents that are responsive to this request are within Plaintiff’s possession, custody, or control, such documents were included in that production. If documents were withheld on the basis of privilege, such documents were identified on a contemporaneously produced privilege log. 7. Any and all lists of employees (with addresses and phone numbers) who have worked at the Property for you. RESPONSE: Plaintiff is not required to create a list for the purposes of production. Notwithstanding, Plaintiff is a Board consisting of volunteers. It does not have direct employees. If this request seeks information related to community association management companies or repair and/or maintenance 6 contractors, Plaintiff has produced (and will supplement the same) non- privileged documents relating to the Subject Property as the same are ordinarily maintained in the course of business. To the extent non-privileged documents that are responsive to this request are within Plaintiff’s possession, custody, or control, such documents were included in that production. If documents were withheld on the basis of privilege, such documents were identified on a contemporaneously produced privilege log. 8. Copies of any and all photographs of the Property. RESPONSE: Plaintiff objects to this request to the extent it seeks any information protected by attorney-client privilege and/or the attorney work product privilege. Notwithstanding, Plaintiff has produced its experts’ reports in the expert disclosure pursuant to the operative CMO. Plaintiff has also produced its experts’ job files in accordance with the operative CMO deadlines. Further, pursuant to the CMO, Plaintiff has produced non-privileged documents relating to the Subject Property as the same are ordinarily maintained in the course of business. To the extent non-privileged documents that are responsive to this request are within Plaintiff’s possession, custody, or control, such documents were included in that production. If documents were withheld on the basis of privilege, such documents were identified on a contemporaneously produced privilege log. 7 9. Any and all videotapes depicting any areas of the Property exhibiting alleged construction defects at the Project. RESPONSE: Plaintiff objects to this request to the extent it seeks any information protected by attorney-client privilege and/or the attorney work product privilege. Notwithstanding, Plaintiff has produced its experts’ reports in the expert disclosure pursuant to the operative CMO. Plaintiff has also produced its experts’ job files in accordance with the operative CMO deadlines. Further, pursuant to the CMO, Plaintiff has produced non-privileged documents relating to the Subject Property as the same are ordinarily maintained in the course of business. To the extent non-privileged documents that are responsive to this request are within Plaintiff’s possession, custody, or control, such documents were included in that production. If documents were withheld on the basis of privilege, such documents were identified on a contemporaneously produced privilege log. 10. Any and all documents stating qualification and/or opinions of any expert or consultant retained by you. RESPONSE: Plaintiff objects to this request to the extent it seeks any information protected by attorney-client privilege and/or the attorney work product privilege. Notwithstanding, Plaintiff has produced its experts’ reports in the expert disclosure pursuant to the operative CMO. Plaintiff has also 8 produced its experts’ job files in accordance with the operative CMO deadlines. 11. Any and all correspondence, memorandum and notes to any consultant or contractor, regarding conditions of the Property. RESPONSE: Plaintiff objects to this request to the extent it seeks any information protected by attorney-client privilege and/or the attorney work product privilege. Notwithstanding, Plaintiff has produced its experts’ reports in the expert disclosure pursuant to the operative CMO. Plaintiff has also produced its experts’ job files in accordance with the operative CMO deadlines. 12. Any and all estimates for the alleged damage and/or remediation at the Property. RESPONSE: Plaintiff has produced its experts’ reports in the expert disclosure pursuant to the operative CMO. Plaintiff has also produced its experts’ job files in accordance with the operative CMO deadlines. To the extent this request seeks information regarding regular maintenance or temporary repairs, pursuant to the CMO, Plaintiff has produced (and will supplement the same) non-privileged documents relating to the Subject Property as the same are ordinarily maintained in the course of business. To the extent non-privileged documents that are responsive to this request are within Plaintiff’s possession, custody, or control, such documents were included in that production. If documents were withheld on the basis of 9 privilege, such documents were identified on a contemporaneously produced privilege log. 13. Any witness statements/affidavits. RESPONSE: Plaintiff objects to this request to the extent it seeks any information protected by attorney-client privilege and/or the attorney work product privilege. Plaintiff has produced non-privileged documents relating to the Subject Property as the same are ordinarily maintained in the course of business. To the extent non-privileged documents that are responsive to this request are within Plaintiff’s possession, custody, or control, such documents were included in that production. If documents were withheld on the basis of privilege, such documents were identified on a contemporaneously produced privilege log. 14. All settlement agreements, assignments, releases or other records or releases of any person or entity regardless of whether a lawsuit was initiated arising out of alleged construction defects at the Property, including, but not limited to, issues relating to design or inspection. RESPONSE: Plaintiff objects to this request to the extent it seeks any information protected by attorney-client privilege and/or the attorney work product privilege. Notwithstanding, any dismissals filed in this case, if any, are a matter of public record and such information can be discerned from the case 10 docket via the Osceola County Clerk of Court’s office. 15. All requests for repairs made to ADVANCED and/or ROYAL OAKS HOMES, LLC by Plaintiff. RESPONSE: Upon information and belief, none. 16. All notices of alleged defects made by Plaintiff to ROYAL OAKS HOMES, LLC and/or ADVANCED. RESPONSE: Pursuant to the CMO, Plaintiff has produced non- privileged documents relating to the Subject Property as the same are ordinarily maintained in the course of business. To the extent non-privileged documents that are responsive to this request are within Plaintiff’s possession, custody, or control, such documents were included in that production. If documents were withheld on the basis of privilege, such documents were identified on a contemporaneously produced privilege log. 17. Any other forensic reports, conditions assessments or housewrap evaluations regarding the Project performed by any person at any time prior to the contemplation of the instant litigation, including any ancillary photos, job files and/or expert witness disclosure related thereto. RESPONSE: Plaintiff objects to this request to the extent it seeks any information protected by attorney-client privilege and/or the attorney work product privilege. Plaintiff was not involved in the original construction of the 11 Subject Property and, therefore, is not in possession of any inspection records that occurred during that time. Notwithstanding, Plaintiff has produced its experts’ reports in the expert disclosure pursuant to the operative CMO. Plaintiff has produced its experts’ job files in accordance with the operative CMO deadlines. 18. Any and all photographs or videos depicting or regarding interior damages to the Property, whether taken prior or subsequent to contemplation of the instant litigation. RESPONSE: Plaintiff objects to this request to the extent it seeks any information protected by attorney-client privilege and/or the attorney work product privilege. Notwithstanding, Plaintiff has produced its experts’ reports in the expert disclosure pursuant to the operative CMO. Plaintiff has produced its experts’ job files in accordance with the operative CMO deadlines. Further, pursuant to the CMO, Plaintiff has produced non-privileged documents relating to the Subject Property as the same are ordinarily maintained in the course of business. To the extent non-privileged documents that are responsive to this request are within Plaintiff’s possession, custody, or control, such documents were included in that production. If documents were withheld on the basis of privilege, such documents were identified on a contemporaneously produced privilege log. 12 19. Any and all document evidencing reports of or repairs to sources or suspected sources of water intrusion at the Project. RESPONSE: Plaintiff objects to this request to the extent it seeks any information protected by attorney-client privilege and/or the attorney work product privilege. Notwithstanding, Plaintiff has produced its experts’ reports in the expert disclosure pursuant to the operative CMO. Plaintiff has also produced its experts’ job files in accordance with the operative CMO deadlines. To the extent this request seeks information regarding regular maintenance or temporary repairs, pursuant to the CMO, Plaintiff has produced non-privileged documents relating to the Subject Property as the same are ordinarily maintained in the course of business. To the extent non- privileged documents that are responsive to this request are within Plaintiff’s possession, custody, or control, such documents were included in that production. If documents were withheld on the basis of privilege, such documents were identified on a contemporaneously produced privilege log. 20. Any and all documents evincing repairs or maintenance performed on or to the building envelope of the Project, including but not limited to repairs or maintenance performed on or to the exterior walls, balconies, roofs, penetrations or fenestrations, whether prior or subsequent to the contemplation of the instant litigation. 13 RESPONSE: Plaintiff objects to this request to the extent it seeks any information protected by attorney-client privilege and/or the attorney work product privilege. Notwithstanding, Plaintiff has produced its experts’ reports in the expert disclosure pursuant to the operative CMO. Plaintiff has also produced its experts’ job files in accordance with the operative CMO deadlines. To the extent this request seeks information regarding regular maintenance or temporary repairs, pursuant to the CMO, Plaintiff has produced non-privileged documents relating to the Subject Property as the same are ordinarily maintained in the course of business. To the extent non- privileged documents that are responsive to this request are within Plaintiff’s possession, custody, or control, such documents were included in that production. If documents were withheld on the basis of privilege, such documents were identified on a contemporaneously produced privilege log. 21. All indexes, file numbers or retrieval information concerning any of the documents or materials involved in paragraphs 1 through 20 above. RESPONSE: Plaintiff is not required to create a list of documents and/or index of the same for the purpose of production. Additionally, Plaintiff objects to this request to the extent it seeks any information protected by attorney- client privilege and/or the attorney work product privilege. Notwithstanding, Plaintiff has produced its experts’ reports in the expert disclosure pursuant to 14 the operative CMO. Plaintiff has also produced its experts’ job files in accordance with the operative CMO deadlines. Further, pursuant to the CMO, Plaintiff has produced non-privileged documents relating to the Subject Property as the same are ordinarily maintained in the course of business. To the extent non-privileged documents that are responsive to this request are within Plaintiff’s possession, custody, or control, such documents were included in that production. If documents were withheld on the basis of privilege, such documents were identified on a contemporaneously produced privilege log. DATED: May 5, 2023. BALL JANIK LLP By: /s/ Kasey L. Joyce 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 esmall@balljanik.com jwidelitz@balljanik.com ctribbey@balljanik.com kjoyce@balljanik.com dtodd@balljanik.com cbetancourt@balljanik.com bburton@balljanik.com orlandodocket@balljanik.com 15 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 5th day of May 2023. /s/ Kasey L. Joyce, Esq. Kasey L. Joyce, Esq. SERVICE LIST LUIS PRATS THAMIR A.R. KADDOURI, JR. LANNIE D. HOUGH, JR. PENELOPE T. ROWLETT JAMES MICHAEL WALLS BETH ANN TOBEY ROBIN H. LEAVENGOOD Law Office of Thamir A.R. Kaddouri, Carlton Fields, P.A. Jr. P.A. 4221 W. Boy Scout Boulevard 3220 West Cypress Street Tampa, FL 33607-5780 Tampa, FL 33607 (813) 223-7000 (813) 879-5752 lprats@carltonfields.com thamir.kaddouri@tampalaw.org lhough@carltonfields.com service@tampalaw.org mwalls@carltonfields.com beth.tobey@tampalaw.org rleavengood@carltonfields.com mramos@carltonfields.com Counsel for Defendant, Imperial nbonilla@carltonfields.com Building Corporation ejohnson@carltonfields.com krick@carltonfields.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. (813) 265-1314 301 E. Pine Street, Suite 525 16 pse@psejd.com Orlando, FL 32801 (321) 558-7700 Counsel for Defendant, Hugh pkapsales@milnelawgroup.com MacDonald Construction, Inc. (HMC) mefta@milnelawgroup.com eservice@milnelawgroup.com DENISE M. ANDERSON ASHLEY M. MATTINGLY Counsel for Defendant, Weathermaster Butler Weihmuller Katz Craig LLP Building Products, Inc. 400 N. Ashley Drive, Suite 2300 Tampa, FL 33602 (813) 281-1900 danderson@butler.legal amattingly@butler.legal krieck@butler.legal rjorge@butler.legal Co-Counsel for Defendant, Hugh MacDonald Construction, Inc. DENISE M. ANDERSON ANDREW E. HOLWAY DAVID A. MERCER J. ROCCO CAFARO 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.legal (813) 221-3900 dmercer@butler.legal andrew.holway@hwhlaw.com krieck@butler.legal derrick.calandra@hwhlaw.com rjorge@butler.legal jill.kuty@hwhlaw.com tbarry@butler.legal kathy.wernsing@hwhlaw.com rocco.cafaro@hwhlaw.com Counsel for Defendant, Don King’s tracy.coale@hwhlaw.com Concrete, Inc. Counsel for Defendant/Cross Defendant, Weintraub Inspections & Forensics, Inc. n/k/a Weintraub Engineering and Inspections, Inc. JAYNE ANN PITTMAN BRUCE R. CALDERON NATALIE C. FISCHER ALICIA Z. GROSS Conroy Simberg BARRI A. REISCH 17 Two South Orange Avenue, Suite 300 Milber Makris Plousadis & Seiden, Orlando, FL 32801 LLP (407) 649-9797 1900 NW Corporate Blvd. eserviceorl@conroysimberg.com East Tower, Suite 440 jpittman@conroysimberg.com Boca Raton, FL 33431 mmaitland@conroysimberg.com (561) 994-7310 nfischer@conroysimberg.com bcalderon@milbermakris.com azgross@milbermakris.com Counsel for Defendant, Advanced breisch@milbermakris.com Wrapping and Concrete Solutions of kmcdowell@milbermakris.com Central Florida, Inc. sskowronski@milbermakris.com Counsel for Defendant/Cross- Defendant, Brown + Company Architecture, Inc. JENNIFER MILLER BROOKS S. SCOTT ROSS KIRA TSIRING Groelle & Salmon, P.A. Hamilton, Miller & Birthisel, LLP 1715 N. Westshore Blvd., Suite 320 150 Southeast Second Avenue, Suite Tampa, FL 33607 1200 (813) 849-7200 Miami, FL 33131-2332 gstcourtdocs@gspalaw.com (305) 379-3686 sross@gspalaw.com jmiller@hamiltonmillerlaw.com cebanks@gspalaw.com ktsiring@hamiltonmillerlaw.com mcoleman@gspalaw.com jcasaccio@hamiltonmillerlaw.com Counsel for Third-Party Defendant, Counsel for Defendant/Cross- Helberg Enterprises, LLC Defendant, TGK Stucco, Inc. VICKI LAMBERT ANDREW T. MARSHALL ALEC MASSON SARA W. MAPES Luks, Santaniello, Petrillo & Cohen Hamilton, Price & Marshall, P.A. 201 S. Orange Avenue, Suite 400 2400 Manatee Ave. W. Orlando, FL 32801 Bradenton, FL 34205 (407) 540-9170 (941) 748-0550 luksorl-pleadings@ls-law.com andrew@hamiltonpricelaw.com amason@insurancedefense.net sara@hamiltonpricelaw.com jpestonit@insurancedefense.net nancy@hamiltonpricelaw.com kelsey@hamiltonpricelaw.com atmservice@hamiltonpricelaw.com 18 Counsel for Third-Party Defendant, Casey Hawkins Glass, Inc. Counsel for Third-Party Defendant, T&M Construction of Sanford, Inc. PHILLIP S. HOWELL BRENDEN C. COLLINS WILLIAM M. WOODS Galloway, Johnson, Tompkins, Burr & JOSEPH M. CLINE Smith, P.L.C. 100 S. Missouri Avenue, Suite 201 400 N. Ashley Dr., Suite 1000 Clearwater, Fl 33756 Tampa, FL 33602 (727) 799-1229, Ext. 4072 (813) 977-1200 wwoods@willwoodslaw.com tampaservice@gallowaylawfirm.com josephc@willwoodslaw.com phowell@gallowaylawfirm.com marital@willwoodslaw.com bcollinsl@gallowaylawfirm.com pleadings@willwoodslaw.com Counsel for Third-Party Defendant, Counsel for Third-Party Defendants, Casey Hawkins Glass, Inc. T & M Construction of Sanford, Inc. and All Glass Installation Corp. JOSEPH L. ZOLLNER COLE J. COPERTINO Law Office of Christopher Norris JAMES MICHAEL MOORHEAD PO Box 7217 Wright, Fulford, Moorhead & Brown, London, KY 40742 P.A. (904) 346-5422 505 Maitland Avenue, Suite 1000 floridacdlegalmail@libertymutual.com Altamonte Springs, FL 32701 joseph.zollner@libertymutual.com (407) 425-0234 ccopertino@wfmblaw.com Counsel for Third-Party Defendant, cbraungart@wfmblaw.com Lios Concrete Corp mmoorhead@wfmblaw.com jgarcia@wfmblaw.com Counsel for Third-Party Defendant, Well Hung Windows & Doors MONAL O. ZIPPER CHESLEY G. MOODY, JR. JENNIFE SHIPPOLE MAI M. LE Law Office of Jennifer L. Shippole Moody & Graf, P.A. 14050 NW 14th Street, Suite 180 1101 N. Lake Destiny Road, Suite 200 Sunrise, FL 33323 Maitland, FL 32751 (954) 417-3066 Ext. 4645 (407) 755-6900 jlspleadings@fednat.com cmoody@moodygraf.com mzipper@fednat.com mle@moodygraf.com jshippole@fednat.com kbraund@moodygraf.com 19 iperera@moodygraf.com Counsel for Third-Party Defendant, Atlantic Concrete Systems, Inc. Counsel for Premier Plastering of Central Florida, Inc. Withdrew for Premier Plastering only 3.4.2022 & Defendant/Cross-Defendant, Wolf’s Irrigation & Landscaping, Inc. JERRILYNN HADLEY WAYNE M. ALDER TODD M. LADAUCEUR Fisher Broyles, LLP Galloway, Johnson, Tompkins, Burr 7668 N. W. 125th Way and Smith, PLC Pompano Beach, FL 33076 118 E. Garden Street (954) 603-6174 Pensacola, FL 32502 wayne.alder@fisherbroyles.com (850) 436-7000 wmalder@bellsouthnet.com tmlconstruction@gallowaylawfirm.com Counsel for Third-Party Defendant, Counsel for Third-Party Defendant E.R.O. Construction, Inc. and Well Hobbit Windows, LLC Done Windows, Inc. SHAUN M. QUINN JACKELINE RODRIGUEZ Hamilton, Miller & Birthisel, LLP 150 S.E. 2nd Avenue, Suite 1200 Miami, FL 33131 (305) 379-3686 squinn@hamiltonmillerlaw.com jrodriguez@hamiltonmiller.com Counsel for Defendant/ Cross- Defendant, Premier Plastering of Central Florida, Inc. UNREPRESENTED PARTIES Expert Painting & Pressure Washing, Inc. c/o Richard C. Bates, Registered Agent 3631 Late Morning Cir. Kissimmee, FL 34744 20