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Filing # 78134493 E-Filed 09/19/2018 04:17:16 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
DOUGLAS BRANCH, CASE NO.: CACE-18-001790 (12)
Plaintiff, GENERAL JURISDICTION
v.
SOUTH FLORIDA LIGHTING TEAM LLC,
and the CITY OF FORT LAUDERDALE,
Defendants.
/
PLAINTIFF DOUGLAS BRANCH’S SECOND REQUESTS FOR PRODUCTION TO
DEFENDANT SOUTH FLORIDA LIGHTING TEA LLC
Plaintiff DOUGLAS BRANCH pursuant to Fla. R. Civ. P. 1.350, hereby requests Defendant
SOUTH FLORIDA LIGHTING TEAM LLC to produce the following:
DEFINITIONS AND INSTRUCTIONS
1. The terms “you,” “your” and “Defendant” means SOUTH FLORIDA LIGHTING
TEAM LLC, including any of its agents and all other persons acting or purporting to act on his
behalf. The term also includes the party's divisions, departments, subsidiaries, affiliates,
predecessors, present or former officers, directors, and includes any other person, acting or
purporting to act on its behalf.
2. The term “person” means any natural person, individual, proprietorship, partnership,
corporation, association, organization, joint venture, firm, other business enterprise, governmental
body, group of natural persons or other entity.
3. The term “document” means any written or graphic matter or other means of
preserving thought or expression and all tangible things from which information can be processed or
transcribed, including the originals and all nonidentical copies, whether different from the original by
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 9/19/2018 4:17:16 PM.****reason of any notation made on such copy or otherwise, including, but not limited to,
correspondence, memoranda, notes, messages, letters, telegrams, teletype, telefax, bulletins,
meetings or other communications, interoffice and intraoffice telephone calls, diaries, chronological
data, minutes, books, reports, studies, summaries, pamphlets, bulletins, printed matter, charts,
ledgers, invoices, worksheets, receipts, returns, computer printouts, prospectuses, financial
statements, schedules, affidavits, contracts, cancelled checks, statements, transcripts, statistics,
surveys, magazine or newspaper articles, releases (and any and all drafts, alterations and
modifications, changes and amendments of any of the foregoing), graphic or aural records or
representations of any kind (including without limitation photographs, microfiche, microfilm,
videotape, records and motion pictures) and electronic, mechanical or electric records or
representations of any kind (including without limitation tapes, cassettes, discs and records).
4. The term “all documents” means every document or group of documents as above
defined that are known to you or that can be located or discovered by reasonably diligent efforts.
5. The terms “refer” or “relate to” mean to make a statement about, discuss, describe,
reflect, constitute, identify, deal with, consist of, establish, comprise, list, evidence, substantiate or in
any way pertain, in whole or in part, to the subject.
6. The term “entity? means any natural person, individual, general or limited
partnership, corporation, association, organization, joint venture, firm or other business enterprise,
governmental body, group of natural persons or other entity.
7. As used herein the singular shall include the plural, the plural shall include the
singular, and the masculine, feminine and neuter shall include each of the other genders.
Leifer Law Firm
1200 North Federal Highway, Suite 320, Boca Raton, FL 33432
Phone: (561) 395-8055; Fax: (561) 395-8057
28. When producing the documents, please keep all documents segregated by the file in
which the documents are contained and indicate the name of the file in which the documents are
contained, and the name of the documents being produced.
9. In the event such file(s) or document(s) has (have) been removed for the purposes of
this action or for some other purpose, please state the name and address of the person who removed
the file, the title of the file and each subfile, if any, maintained within the file, and the present
location of the file.
10. Any request for production of a document shall be deemed to require production of
each and every such thing executed, created, prepared, received or in effect at any time to the present,
or during any other indicated period of time.
ll. Any and all documents produced pursuant to this request must be segregated and
identified as being responsive to a specified numbered request.
12. If you choose to withhold any documents from production for inspection and copying
(on the basis of privilege or otherwise), please provide a Privilege Log, identifying each document
withheld and provide its date, number of pages, author, recipient(s), a brief description of its subject
matter, and your basis for withholding the document from production.
13. The term “Subject Holiday Ornament” references the object which fell on Plaintiff's
head and body as described in the Amended Complaint.
ITEMS REQUESTED
1. Any and all training materials, including but not limited to handbooks, manuals,
pictures, videos, and guides, pertaining to the installation of the Subject Holiday Ornament, or
similar objects, in effect at the time in effect at the time of the accident.
Leifer Law Firm
1200 North Federal Highway, Suite 320, Boca Raton, FL 33432
Phone: (561) 395-8055; Fax: (561) 395-8057
32. Any and all meeting minutes and/or any documents documenting any safety meetings
relating to the installation of the Subject Holiday Ornament, or similar objects, for the six months
before the accident referenced in the Amended Complaint.
3. Any and all meeting minutes and/or any documents documenting any safety meetings
relating to the installation of the Subject Holiday Ornament, or similar objects, for the six months
accident the accident referenced in the Amended Complaint.
4. Any and all meeting minutes and/or any documents documenting any safety meetings
relating to the accident referenced in the Amended Complaint.
5. The work order, purchase order, and invoice relating to the installation of Subject
Holiday Ornament.
6. With respect to each individual named in the list you produced in response to
Plaintiff's First Request for Production, attached hereto as Exhibit A, please provide the individual’s
clock-in and clock-out reports or documents from December 9, 2015 through December 15, 2015.
7. With respect to each individual named in the list you produced in response to
Plaintiffs First Request for Production, attached hereto as Exhibit A, please provide the individual’s
employee file.
8. With respect to each individual named in the list you produced in response to
Plaintiffs First Request for Production, attached hereto as Exhibit A, please provide documents
showing the individual last known contact information (address, telephone numbers, and e-mail
addresses).
9. Any and all documents that support your contention that the City of Fort Lauderdale is
Leifer Law Firm
1200 North Federal Highway, Suite 320, Boca Raton, FL 33432
Phone: (561) 395-8055; Fax: (561) 395-8057
4responsible for the accident referenced in the Amended Complaint, as stated in your Eight
Affirmative Defense to the Amended Complaint.
10. Any and all documents that support your contention that Altek Engineering is
responsible for the accident referenced in the Amended Complaint, as stated in your Eight
Affirmative Defense to the Amended Complaint.
ll. Any and all documents and correspondence you received, sent, or exchanged with
Altek Engineering that in any way relate to the holiday decorations which were installed by you in
2015 in the City of Fort Lauderdale (which include the Subject Holiday Ornament).
12. Any executed addendum, extensions, or renewals of the Agreement for Holiday Light
Display Services you executed with the City of Fort Lauderdale on October 13, 2014.
13. Exhibits B, C, and D to the Agreement for Holiday Light Display Services you
executed with the City of Fort Lauderdale on October 13, 2014.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served on this 19th
day of September, 2018, to all parties listed in the E-Portal Service system. The certificate is taken as
prima facie proof of such service in compliance with Fla. R. Jud. Admin. 2.516.
LEIFER LAW FIRM
Attorneys for Plaintiff
1200 North Federal Highway
Suite 320
Boca Raton, FL 33432
(561) 395-8055
(561) 395-8057 (fax)
By: /s/ Fernando Ramirez.
Fernando Ramirez, Esq.
Fla, Bar No. 78376
framirez@
com
samantha@leiferlaw.com
Leifer Law Firm
1200 North Federal Highway, Suite 320, Boca Raton, FL 33432
Phone: (561) 395-8055; Fax: (561) 395-8057
5Name
DIAZ, IRENE A
NUNEZ, LUIZ J
GARCIA, JEUDY
BELFOR, BOOKERTEE
HALL, DAVON P
ALVAREZ-CRUZ, PEDRO F
IWYCHE, SABRINA D
OROURKE, JOHN
MENDEZ, LISSETTE V
KENDRICK, RICKY
POWELL, TRACEY
MYLES, NICOLE
DEATON, SONIA C
BEAUMARD, SOLANGE
DAVIS, MIGEL
CURIEL, KENNY
ARISTILDE, RICHARD
HOLLIE, ANTWONE
ANDREWS, III, DAN C
VITAL, MARIE Y
GONZALEZ, RAUL
LAW, ADRIAN
DIAZ, ERNESTO E
FERNANDEZ, MARIO D
ROBERT, JEFFREY
MELO, LARONZ M
QUINTANA, ROBERT A
BALL, JULIUS
BROOKS, KEON J
ICENIA, ERIK D
ENRIQUEZ, OSCAR J
THORNTON, JAMES F
BLAISE, ALAIN
BACON, AVIS D
JALEMAN, VANNER J
ROLLE, STEPHANIE
SIMMONS, ANTONIO
ALVAREZ, FARAH
SIMMONS, ANTOINE B
REDMAN, NORMAN
DIAZ, ELADIO X
JONES, DAVID
JULIEN-AHYEE, DIRK L
EXHIBIT
AJANVIER, JEAN E
BLASH, DWIGHT
HERNANDEZ-MORENO, ALEXIS
PEREZ-JAIME, JORGE E
DESIRE, SEBETHIEW
PAUL, SHERRI
CHARLES, LOUIS M
FERNANDEZ, RONALD
BOHORQUEZ, LUZM
BOHORQUEZ, LUZ M
BOHORQUEZ, LUZ M
LOUIS, JERRY A
FLOREZ, CLEMENCIA
SAINTIL, THONISE
SAINTIL, THONISE
ACEVEDO, ALEXANDER
GUERRIER, MARLENE
PETERSON, JOSEPH
COMIN, CHRISTIAN
ISANTIESTEBAN, LEONEL
ISANTIESTEBAN, LEONEL
VAL, JUNIOR
BRIOSO, VICTOR A
PETITFRERE, FARIOLAN
COLASSAINT, WIENFRID
FERNANDEZ, MILVIA S
SANCHEZ, NORLING
COELHO, NICHOLAS W
JEANMARIE, WILHEM
ARCE, BENYI L
COLMENARES, WISMAR
NUNEZ, LUIZ J
BELFOR, BOOKERTEE
HALL, DAVON P
ALVAREZ-CRUZ, PEDRO F
OROURKE, JOHN
MENDEZ, LISSETTE V
HOWARD, DAUHRON
KENDRICK, RICKY
DEATON, SONIA C
BEAUMARD, SOLANGE
FERNANDEZ, MILVIA S
WALKER, ADAM E
SANCHEZ, NORLINGCURIEL, KENNY
ANDREWS, III, DAN C
VITAL, MARIE Y
GONZALEZ, RAUL
FERNANDEZ, MARIO D
ROBERT, JEFFREY
MELO, LARONZ M
BALL, JULIUS
ICENIA, ERIK D
ENRIQUEZ, OSCAR J
BLAISE, ALAIN
JALEMAN, VANNER J
SIMMONS, ANTONIO
REDMAN, NORMAN
JANVIER, JEAN E
HERNANDEZ-MORENO, ALEXIS
PEREZ-JAIME, JORGE E
PETITNORD, WILBY
CHARLES, LOUIS M
BOHORQUEZ, LUZ M
FLOREZ, CLEMENCIA
ACEVEDO, ALEXANDER
COMIN, CHRISTIAN
SANTIESTEBAN, LEONEL
VAL, JUNIOR
BRIOSO, VICTOR A
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Filing # 78134493 E-Filed 09/19/2018 04:17:16 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA DOUGLAS BRANCH, CASE NO.: CACE-18-001790 (12) Plaintiff, GENERAL JURISDICTION v. SOUTH FLORIDA LIGHTING TEAM LLC, and the CITY OF FORT LAUDERDALE, Defendants. / PLAINTIFF DOUGLAS BRANCH’S SECOND REQUESTS FOR PRODUCTION TO DEFENDANT SOUTH FLORIDA LIGHTING TEA LLC Plaintiff DOUGLAS BRANCH pursuant to Fla. R. Civ. P. 1.350, hereby requests Defendant SOUTH FLORIDA LIGHTING TEAM LLC to produce the following: DEFINITIONS AND INSTRUCTIONS 1. The terms “you,” “your” and “Defendant” means SOUTH FLORIDA LIGHTING TEAM LLC, including any of its agents and all other persons acting or purporting to act on his behalf. The term also includes the party's divisions, departments, subsidiaries, affiliates, predecessors, present or former officers, directors, and includes any other person, acting or purporting to act on its behalf. 2. The term “person” means any natural person, individual, proprietorship, partnership, corporation, association, organization, joint venture, firm, other business enterprise, governmental body, group of natural persons or other entity. 3. The term “document” means any written or graphic matter or other means of preserving thought or expression and all tangible things from which information can be processed or transcribed, including the originals and all nonidentical copies, whether different from the original by *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 9/19/2018 4:17:16 PM.****reason of any notation made on such copy or otherwise, including, but not limited to, correspondence, memoranda, notes, messages, letters, telegrams, teletype, telefax, bulletins, meetings or other communications, interoffice and intraoffice telephone calls, diaries, chronological data, minutes, books, reports, studies, summaries, pamphlets, bulletins, printed matter, charts, ledgers, invoices, worksheets, receipts, returns, computer printouts, prospectuses, financial statements, schedules, affidavits, contracts, cancelled checks, statements, transcripts, statistics, surveys, magazine or newspaper articles, releases (and any and all drafts, alterations and modifications, changes and amendments of any of the foregoing), graphic or aural records or representations of any kind (including without limitation photographs, microfiche, microfilm, videotape, records and motion pictures) and electronic, mechanical or electric records or representations of any kind (including without limitation tapes, cassettes, discs and records). 4. The term “all documents” means every document or group of documents as above defined that are known to you or that can be located or discovered by reasonably diligent efforts. 5. The terms “refer” or “relate to” mean to make a statement about, discuss, describe, reflect, constitute, identify, deal with, consist of, establish, comprise, list, evidence, substantiate or in any way pertain, in whole or in part, to the subject. 6. The term “entity? means any natural person, individual, general or limited partnership, corporation, association, organization, joint venture, firm or other business enterprise, governmental body, group of natural persons or other entity. 7. As used herein the singular shall include the plural, the plural shall include the singular, and the masculine, feminine and neuter shall include each of the other genders. Leifer Law Firm 1200 North Federal Highway, Suite 320, Boca Raton, FL 33432 Phone: (561) 395-8055; Fax: (561) 395-8057 28. When producing the documents, please keep all documents segregated by the file in which the documents are contained and indicate the name of the file in which the documents are contained, and the name of the documents being produced. 9. In the event such file(s) or document(s) has (have) been removed for the purposes of this action or for some other purpose, please state the name and address of the person who removed the file, the title of the file and each subfile, if any, maintained within the file, and the present location of the file. 10. Any request for production of a document shall be deemed to require production of each and every such thing executed, created, prepared, received or in effect at any time to the present, or during any other indicated period of time. ll. Any and all documents produced pursuant to this request must be segregated and identified as being responsive to a specified numbered request. 12. If you choose to withhold any documents from production for inspection and copying (on the basis of privilege or otherwise), please provide a Privilege Log, identifying each document withheld and provide its date, number of pages, author, recipient(s), a brief description of its subject matter, and your basis for withholding the document from production. 13. The term “Subject Holiday Ornament” references the object which fell on Plaintiff's head and body as described in the Amended Complaint. ITEMS REQUESTED 1. Any and all training materials, including but not limited to handbooks, manuals, pictures, videos, and guides, pertaining to the installation of the Subject Holiday Ornament, or similar objects, in effect at the time in effect at the time of the accident. Leifer Law Firm 1200 North Federal Highway, Suite 320, Boca Raton, FL 33432 Phone: (561) 395-8055; Fax: (561) 395-8057 32. Any and all meeting minutes and/or any documents documenting any safety meetings relating to the installation of the Subject Holiday Ornament, or similar objects, for the six months before the accident referenced in the Amended Complaint. 3. Any and all meeting minutes and/or any documents documenting any safety meetings relating to the installation of the Subject Holiday Ornament, or similar objects, for the six months accident the accident referenced in the Amended Complaint. 4. Any and all meeting minutes and/or any documents documenting any safety meetings relating to the accident referenced in the Amended Complaint. 5. The work order, purchase order, and invoice relating to the installation of Subject Holiday Ornament. 6. With respect to each individual named in the list you produced in response to Plaintiff's First Request for Production, attached hereto as Exhibit A, please provide the individual’s clock-in and clock-out reports or documents from December 9, 2015 through December 15, 2015. 7. With respect to each individual named in the list you produced in response to Plaintiffs First Request for Production, attached hereto as Exhibit A, please provide the individual’s employee file. 8. With respect to each individual named in the list you produced in response to Plaintiffs First Request for Production, attached hereto as Exhibit A, please provide documents showing the individual last known contact information (address, telephone numbers, and e-mail addresses). 9. Any and all documents that support your contention that the City of Fort Lauderdale is Leifer Law Firm 1200 North Federal Highway, Suite 320, Boca Raton, FL 33432 Phone: (561) 395-8055; Fax: (561) 395-8057 4responsible for the accident referenced in the Amended Complaint, as stated in your Eight Affirmative Defense to the Amended Complaint. 10. Any and all documents that support your contention that Altek Engineering is responsible for the accident referenced in the Amended Complaint, as stated in your Eight Affirmative Defense to the Amended Complaint. ll. Any and all documents and correspondence you received, sent, or exchanged with Altek Engineering that in any way relate to the holiday decorations which were installed by you in 2015 in the City of Fort Lauderdale (which include the Subject Holiday Ornament). 12. Any executed addendum, extensions, or renewals of the Agreement for Holiday Light Display Services you executed with the City of Fort Lauderdale on October 13, 2014. 13. Exhibits B, C, and D to the Agreement for Holiday Light Display Services you executed with the City of Fort Lauderdale on October 13, 2014. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served on this 19th day of September, 2018, to all parties listed in the E-Portal Service system. The certificate is taken as prima facie proof of such service in compliance with Fla. R. Jud. Admin. 2.516. LEIFER LAW FIRM Attorneys for Plaintiff 1200 North Federal Highway Suite 320 Boca Raton, FL 33432 (561) 395-8055 (561) 395-8057 (fax) By: /s/ Fernando Ramirez. Fernando Ramirez, Esq. Fla, Bar No. 78376 framirez@ com samantha@leiferlaw.com Leifer Law Firm 1200 North Federal Highway, Suite 320, Boca Raton, FL 33432 Phone: (561) 395-8055; Fax: (561) 395-8057 5Name DIAZ, IRENE A NUNEZ, LUIZ J GARCIA, JEUDY BELFOR, BOOKERTEE HALL, DAVON P ALVAREZ-CRUZ, PEDRO F IWYCHE, SABRINA D OROURKE, JOHN MENDEZ, LISSETTE V KENDRICK, RICKY POWELL, TRACEY MYLES, NICOLE DEATON, SONIA C BEAUMARD, SOLANGE DAVIS, MIGEL CURIEL, KENNY ARISTILDE, RICHARD HOLLIE, ANTWONE ANDREWS, III, DAN C VITAL, MARIE Y GONZALEZ, RAUL LAW, ADRIAN DIAZ, ERNESTO E FERNANDEZ, MARIO D ROBERT, JEFFREY MELO, LARONZ M QUINTANA, ROBERT A BALL, JULIUS BROOKS, KEON J ICENIA, ERIK D ENRIQUEZ, OSCAR J THORNTON, JAMES F BLAISE, ALAIN BACON, AVIS D JALEMAN, VANNER J ROLLE, STEPHANIE SIMMONS, ANTONIO ALVAREZ, FARAH SIMMONS, ANTOINE B REDMAN, NORMAN DIAZ, ELADIO X JONES, DAVID JULIEN-AHYEE, DIRK L EXHIBIT AJANVIER, JEAN E BLASH, DWIGHT HERNANDEZ-MORENO, ALEXIS PEREZ-JAIME, JORGE E DESIRE, SEBETHIEW PAUL, SHERRI CHARLES, LOUIS M FERNANDEZ, RONALD BOHORQUEZ, LUZM BOHORQUEZ, LUZ M BOHORQUEZ, LUZ M LOUIS, JERRY A FLOREZ, CLEMENCIA SAINTIL, THONISE SAINTIL, THONISE ACEVEDO, ALEXANDER GUERRIER, MARLENE PETERSON, JOSEPH COMIN, CHRISTIAN ISANTIESTEBAN, LEONEL ISANTIESTEBAN, LEONEL VAL, JUNIOR BRIOSO, VICTOR A PETITFRERE, FARIOLAN COLASSAINT, WIENFRID FERNANDEZ, MILVIA S SANCHEZ, NORLING COELHO, NICHOLAS W JEANMARIE, WILHEM ARCE, BENYI L COLMENARES, WISMAR NUNEZ, LUIZ J BELFOR, BOOKERTEE HALL, DAVON P ALVAREZ-CRUZ, PEDRO F OROURKE, JOHN MENDEZ, LISSETTE V HOWARD, DAUHRON KENDRICK, RICKY DEATON, SONIA C BEAUMARD, SOLANGE FERNANDEZ, MILVIA S WALKER, ADAM E SANCHEZ, NORLINGCURIEL, KENNY ANDREWS, III, DAN C VITAL, MARIE Y GONZALEZ, RAUL FERNANDEZ, MARIO D ROBERT, JEFFREY MELO, LARONZ M BALL, JULIUS ICENIA, ERIK D ENRIQUEZ, OSCAR J BLAISE, ALAIN JALEMAN, VANNER J SIMMONS, ANTONIO REDMAN, NORMAN JANVIER, JEAN E HERNANDEZ-MORENO, ALEXIS PEREZ-JAIME, JORGE E PETITNORD, WILBY CHARLES, LOUIS M BOHORQUEZ, LUZ M FLOREZ, CLEMENCIA ACEVEDO, ALEXANDER COMIN, CHRISTIAN SANTIESTEBAN, LEONEL VAL, JUNIOR BRIOSO, VICTOR A