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Filing # 105497185 E-Filed 03/26/2020 03:44:32 PM
IN THE CIRCUIT COURT,
SEVENTEENTH JUDICIAL CIRCUIT, IN
AND FOR BROWARD COUNTY,
FLORIDA
CACE18-001274
WELLS FARGO BANK, N.A.,
Plaintiff,
vs.
BETTY MORALES, et al.,
Defendants.
/
PLAINTIFF’S RESPONSES TO DEFENDANT’S
FIRST REQUEST FOR PRODUCTION TO PLAINTIFF
Plaintiff, Wells Fargo Bank, N.A. (“Plaintiff”), by and through its undersigned counsel,
and pursuant to Florida Rule of Civil Procedure 1.350, hereby files this response to Defendant,
Betty Morales’s (“Defendant”) First Request for Production to Plaintiff.
PRELIMINARY STATEMENT
These responses have been prepared from documents obtained from expected and
reasonably available sources by Plaintiff through reasonably diligent inquiry. To the extent that
any of these requests purport to require more, however, Plaintiff objects to each of them on the
ground that it imposes undue burden or expense.
Plaintiff's Responses have been prepared in accordance with the Florida Rules of Civil
Procedure and pursuant to a reasonable and diligent investigation and search for documents and
information contained within the subject file maintained by Plaintiff, or its agent. Plaintiff states
that it and its servicers are very large entities which employ many employees across different
locations throughout the United States. Due to mergers, acquisitions, reorganizations, and various
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/26/2020 03:44:32 PM.****changes over time, employees often change jobs and relocate to different locations while other
employees retire or otherwise leave the company. Accordingly, Plaintiff does not represent that
these responses reflect a search of its entire organization. Rather, the scope of the investigation
conducted to locate responsive information has been reasonably focused on making inquiries to
those departments, groups, and employees most likely to be knowledgeable and have documents
related to the specific matters at issue concerning the subject loan, and to reviewing its systems
and records in which information related to such matters ordinarily would be expected to be
located. Plaintiff, if necessary and where appropriate, will supplement these responses should
additional documentation be located through further investigation or discovery. Plaintiff expressly
reserves the right, without assuming any duty of disclosure not required under the Florida Rules
of Civil Procedure or order of this Court, to revise, amend, correct, add or clarify any of these
responses if and when additional information or documentation comes to its attention.
When responding to each request, Plaintiff does not concede the evidentiary relevance,
materiality, or admissibility of any of these production requests, or the subject matter to which
they relate. By submitting these responses, Plaintiff does not adopt the purported definitions of
words and phrases contained in the Requests to the extent that they are vague and ambiguous or
are inconsistent with either (i) the definition set forth by Plaintiff in its responses or (ii) the ordinary
and customary meaning of such words and phrases.RESPONSES
Without in any way limiting the force or application of the Preliminary Statement, Plaintiff
asserts these specific responses:
Request No.1; Copy of all exhibits you intend to use or may use at trial.
Response: Plaintiff objects to this request as it is premature as there is no trial date currently
set and Plaintiff will comply with all mandated deadlines provided by the Court or Case
Management Report.
Dated March 26, 2020 Respectfully Submitted,
McGUIREWOODS LLP
By___/s/ Brian A. Wolf
Jason R. Bowyer, Esq.
Florida Bar No. 0693731
Primary E-Mail: jbowyer@mcguirewoods.com
Secondary E-Mail: fladmin@mcguirewoods.com
Brian A. Wolf, Esq.
Florida Bar No. 0092610
Primary E-Mail: bwolf@mcguirewoods.com
Secondary E-Mail: flservice@mcguirewoods.com
50 N. Laura Street, Suite 3300
Jacksonville, Florida 32202
(904) 798-3200
(904) 798-3207 (fax)
Attorneys for Plaintiff Wells Fargo Bank, N.A.CERTIFICATE OF SERVICE
THEREBY CERTIFY that a copy of the foregoing has been furnished by Email on March
26, 2020 to the following:
VIA EMAIL
Matthew Marks, Esq.
Brock & Scott, PLLC
1501 NW 49th St., Suite 200
Fort Lauderdale, FL 33309
FLCourtDocs@brockandscott.com
Attorneys for Plaintiff
Bruce K. Herman, Esq.
The Herman Law Group, P.A.
3020 NE 32nd Ave., Suite 226
Ft. Lauderdale, FL 33308
service@thlglaw.com
Attorney for Defendant, Betty Morales
Mark F. Booth, Esq.
Rogers, Morris Ziegler, LLP
1401 E. Broward Blvd. Suite 300
Ft. Lauderdale, FL 33301
MEFBooth@rmzlaw.com
Susan@rmzlaw.com
Attorneys for Defendants, Scott A. Raben and Betty Morales
Tamar Duffner Shendell, Esq.
Shendell & Associates, PA
5340 North Federal Highway, Suite 201
service@shendell-law.com
Attorneys for Brook Field Gardens North No. 2
Association, Inc., and Brook Field Gardens
North Master Association, Inc.
/s/ Brian A. Wolf
Attomey
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Filing # 105497185 E-Filed 03/26/2020 03:44:32 PM IN THE CIRCUIT COURT, SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CACE18-001274 WELLS FARGO BANK, N.A., Plaintiff, vs. BETTY MORALES, et al., Defendants. / PLAINTIFF’S RESPONSES TO DEFENDANT’S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF Plaintiff, Wells Fargo Bank, N.A. (“Plaintiff”), by and through its undersigned counsel, and pursuant to Florida Rule of Civil Procedure 1.350, hereby files this response to Defendant, Betty Morales’s (“Defendant”) First Request for Production to Plaintiff. PRELIMINARY STATEMENT These responses have been prepared from documents obtained from expected and reasonably available sources by Plaintiff through reasonably diligent inquiry. To the extent that any of these requests purport to require more, however, Plaintiff objects to each of them on the ground that it imposes undue burden or expense. Plaintiff's Responses have been prepared in accordance with the Florida Rules of Civil Procedure and pursuant to a reasonable and diligent investigation and search for documents and information contained within the subject file maintained by Plaintiff, or its agent. Plaintiff states that it and its servicers are very large entities which employ many employees across different locations throughout the United States. Due to mergers, acquisitions, reorganizations, and various *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/26/2020 03:44:32 PM.****changes over time, employees often change jobs and relocate to different locations while other employees retire or otherwise leave the company. Accordingly, Plaintiff does not represent that these responses reflect a search of its entire organization. Rather, the scope of the investigation conducted to locate responsive information has been reasonably focused on making inquiries to those departments, groups, and employees most likely to be knowledgeable and have documents related to the specific matters at issue concerning the subject loan, and to reviewing its systems and records in which information related to such matters ordinarily would be expected to be located. Plaintiff, if necessary and where appropriate, will supplement these responses should additional documentation be located through further investigation or discovery. Plaintiff expressly reserves the right, without assuming any duty of disclosure not required under the Florida Rules of Civil Procedure or order of this Court, to revise, amend, correct, add or clarify any of these responses if and when additional information or documentation comes to its attention. When responding to each request, Plaintiff does not concede the evidentiary relevance, materiality, or admissibility of any of these production requests, or the subject matter to which they relate. By submitting these responses, Plaintiff does not adopt the purported definitions of words and phrases contained in the Requests to the extent that they are vague and ambiguous or are inconsistent with either (i) the definition set forth by Plaintiff in its responses or (ii) the ordinary and customary meaning of such words and phrases.RESPONSES Without in any way limiting the force or application of the Preliminary Statement, Plaintiff asserts these specific responses: Request No.1; Copy of all exhibits you intend to use or may use at trial. Response: Plaintiff objects to this request as it is premature as there is no trial date currently set and Plaintiff will comply with all mandated deadlines provided by the Court or Case Management Report. Dated March 26, 2020 Respectfully Submitted, McGUIREWOODS LLP By___/s/ Brian A. Wolf Jason R. Bowyer, Esq. Florida Bar No. 0693731 Primary E-Mail: jbowyer@mcguirewoods.com Secondary E-Mail: fladmin@mcguirewoods.com Brian A. Wolf, Esq. Florida Bar No. 0092610 Primary E-Mail: bwolf@mcguirewoods.com Secondary E-Mail: flservice@mcguirewoods.com 50 N. Laura Street, Suite 3300 Jacksonville, Florida 32202 (904) 798-3200 (904) 798-3207 (fax) Attorneys for Plaintiff Wells Fargo Bank, N.A.CERTIFICATE OF SERVICE THEREBY CERTIFY that a copy of the foregoing has been furnished by Email on March 26, 2020 to the following: VIA EMAIL Matthew Marks, Esq. Brock & Scott, PLLC 1501 NW 49th St., Suite 200 Fort Lauderdale, FL 33309 FLCourtDocs@brockandscott.com Attorneys for Plaintiff Bruce K. Herman, Esq. The Herman Law Group, P.A. 3020 NE 32nd Ave., Suite 226 Ft. Lauderdale, FL 33308 service@thlglaw.com Attorney for Defendant, Betty Morales Mark F. Booth, Esq. Rogers, Morris Ziegler, LLP 1401 E. Broward Blvd. Suite 300 Ft. Lauderdale, FL 33301 MEFBooth@rmzlaw.com Susan@rmzlaw.com Attorneys for Defendants, Scott A. Raben and Betty Morales Tamar Duffner Shendell, Esq. Shendell & Associates, PA 5340 North Federal Highway, Suite 201 service@shendell-law.com Attorneys for Brook Field Gardens North No. 2 Association, Inc., and Brook Field Gardens North Master Association, Inc. /s/ Brian A. Wolf Attomey