Party Discovery: VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION INC vs. ROYAL OAK HOMES LLC

On May 20, 170 a Party Discovery was filed involving a dispute between Don King'S Concrete Inc., Weathermaster Building Products Inc. A Florida Corporation, Villas At Emerald Lake Homeowners Association Inc, and Advanced Wrapping And Concrete Solutions Of Centra, Brown And Company Architecture Inc, Don Kings Concrete Inc, Hugh Macdonald Construction Inc, Imperial Building Corporation, Premier Plastering Of Central Florida Inc N K A Tg, Royal Oak Homes Llc, Summerpark Homes Inc, Tgk Stucco Inc, The Dimillo Group Llc, Weathermaster Building Products Inc, Weintraub Inspections And Forensics Inc, Wolfs Irrigation And Landscaping Inc, All Glass Installation Corp. A Florida Corporation, Atlantic Concrete Systems, Inc., Casey Hawkins Glass Inc. A Florida Corporation, Dean Nesbit Llc A Florida Limited Liability Company, E.R.O. Construction Inc., Helberg Enterprises, Llc, Hobbit Windows Llc A Florida Limited Liability Company, Lios Concrete Corp., T&M Construction Of Sanford Inc. A Florida Corporation, Well Done Windows Inc. A Florida Corporation, Well Hung Windows & Doors, Llc, for CIRCUIT CIVIL in the District Court of Osceola County.

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Filing # 148322195 E-Filed 04/25/2022 02:40:45 PM

2046032
IN THE CIRCUIT COURT OF THE 9TH JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY, FLORIDA

CASE NO. 2020-CA-002942-ON

VILLAS AT EMERALD LAKE HOMEOWNERS
ASSOCIATION, INC., a Florida Not for Profit
Corporation,

Plaintiff,

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; and BROWN+COMPANY
ARCHITECTURE, INC., a Florida corporation;

Defendants.
________________________________________/

ROYAL OAK HOMES, LLC, a Florida limited
Liability company,

Crossclaim Plaintiff,

v.
CASE NO. 2020-CA-002942-ON

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;

Crossclaim Defendants.
_______________________________________/

WEATHERMASTER BUILDING PRODUCTS,
INC., a Florida corporation, and DON KING'S
CONCRETE, INC.,

Third-Party Plaintiff,

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;
WELL HUNG WINDOWS & DOORS, LLC, a Florida
limited liability company; LIOS CONCRETE
CORP.; E.R.O. CONSTRUCTION, INC. and
ATLANTIC CONCRETE SYSTEMS, INC.

Third-Party Defendants.

2
CASE NO. 2020-CA-002942-ON

DEFEENDANT, ADVANCED WRAPPING AND CONCRETE SOLUTIONS OF
CENTRAL FLORIDA, INC.’S RESPONSE TO DEFENDANT, BROWN+ COMPANY
ARCHITECTURE, INC.’S FIRST REQUEST TO PRODUCE

Defendant, ADVANCED WRAPPING AND CONCRETE SOLUTIONS OF

CENTRAL FLORIDA, INC. (“ADVANCED”) by and through the undersigned attorneys,

responds to the Request to Produce filed by Defendant, BROWN+COMPANY

ARCHITECTURE, INC. (“BROWN”) dated February 22, 2022, as follows:

GENERAL OBJECTIONS

The following general objections apply to BROWN’s requests in their entirety and

should be read to apply to each and every one of the First Request for Production.

A. ADVANCED objects to all document requests to the extent that they seek

communications, information and/or matters exempted from discovery by the

attorney/client privilege, the attorney work product privilege, the investigative privilege,

the joint defense party communications exemption, and/or any other privilege or

exemption from discovery.

B. ADVANCED objects to all document requests to the extent that they seek

matters beyond the scope of admissible discovery in this matter or to the extent that they

attempt to impose any duty, obligation, and/or burden other than as imposed by American

Arbitration Rules of Procedure.

C. ADVANCED reserves the right to challenge the competency, relevancy,

materiality and admissibility, or to object on any ground, to the use of information or

identification of documents set forth herein in any subsequent proceeding or at the

hearing on this matter.

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CASE NO. 2020-CA-002942-ON

D. ADVANCED objects to the use of the term “any and all documents” as

rendering BROWN’s requests impermissibly, vague, ambiguous, overly broad and unduly

burdensome.

E. ADVANCED states that the assertion of the same, similar or additional

objections, or the provision of partial answers in response to any request, does not

constitute or imply waiver of any of ADVANCED’S general objections.

DOCUMENTS TO BE PRODUCED

1. Any and all contracts you entered into related to the Project.