Preview
Filing # 111439118 E-Filed 08/07/2020 10:23:56 AM
IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
ANGEL LEON AND MARLEN LEON,
Plaintiff(s),
v.
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant. Case No.: 50-2020-CA-006669 XXXX-MB (AO)
PLAINTIFFS’ RESPONSE TO DEFENDANT’S FIRST REQUEST FOR PRODUCTION
Plaintiffs, ANGEL LEON AND MARLEN LEON, by and through the undersigned attorneys,
pursuant to Fla. R. Civ. P. 1.350, hereby respond to Defendant’s Request for Production (the
“Requests”) and state as follows:
GENERAL OBJECTIONS
1. Plaintiffs object to the Requests to the extent that they purport to create obligations
beyond those imposed by the Florida Rules of Civil Procedure.
2. Plaintiffs object to the production of “any and all” documents to the extent that
Defendant seeks to require Plaintiffs to do more than use reasonable diligence to locate responsive
and non-privileged or non-protected documents based on an examination of those files that may
reasonably be expected to yield such documents, on the grounds that such requests are vague,
ambiguous, overly broad, unduly burdensome, oppressive, vexatious, and seek the production of
irrelevant materials and documents.
3. Plaintiffs object to the Requests to the extent that they seek information protected by
various privileges of confidentiality, including the attorney-client privilege and the work product
doctrine, or any other privilege or immunity provided under Florida law.
*** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 08/07/2020 10:23:56 AM ***Leon v. Universal
Case No.: 50-2020-CA-006669 XXXX-MB (AO)
4. These General Objections shall be deemed applicable to and continuing with respect
to the Responses set forth herein. The General Objections asserted above are hereby incorporated
into the Responses. The Responses may repeat a General Objection for emphasis or for some other
reason. Such General Objections are not waived, nor in any way limited, by the Responses.
REQUESTS AND SPECIFIC RESPONSES
1. To the extent such documents exist and are in the possession of Plaintiffs, they have
been attached hereto as Exhibit “A” and incorporated into this response by reference.
2. To the extent such documents exist and are in the possession of Plaintiffs, they have
been attached hereto as Exhibit “A” and incorporated into this response by reference.
3. To the extent such documents exist and are in the possession of Plaintiffs, they have
been attached hereto as Exhibit “A” and incorporated into this response by reference.
4. To the extent such documents exist and are in the possession of Plaintiffs, they have
been attached hereto as Exhibit “A” and incorporated into this response by reference.
5. To the extent such documents exist and are in the possession of Plaintiffs, they have
been attached hereto as Exhibit “A” and incorporated into this response by reference.
6. To the extent such documents exist and are in the possession of Plaintiffs, they have
been attached hereto as Exhibit “A” and incorporated into this response by reference.
7. To the extent such documents exist and are in the possession of Plaintiffs, they have
been attached hereto as Exhibit “A” and incorporated into this response by reference.
8. To the extent such documents exist and are in the possession of Plaintiffs, they have
been attached hereto as Exhibit “A” and incorporated into this response by reference.
9. To the extent such documents exist and are in the possession of Plaintiffs, they have
been attached hereto as Exhibit “A” and incorporated into this response by reference.
10. To the extent such documents exist and are in the possession of Plaintiffs, they have
been attached hereto as Exhibit “A” and incorporated into this response by reference.
11. To the extent such documents exist and are in the possession of Plaintiffs, they have
been attached hereto as Exhibit “A” and incorporated into this response by reference.
12. To the extent such documents exist and are in the possession of Plaintiffs, they have
been attached hereto as Exhibit “A” and incorporated into this response by reference.Leon v. Universal
Case No.: 50-2020-CA-006669 XXXX-MB (AO)
13. To the extent such documents exist and are in the possession of Plaintiffs, they have
been attached hereto as Exhibit “A” and incorporated into this response by reference.
14. To the extent such documents exist and are in the possession of Plaintiffs, they have
been attached hereto as Exhibit “A” and incorporated into this response by reference.
15. To the extent such documents exist and are in the possession of Plaintiffs, they have
been attached hereto as Exhibit “A” and incorporated into this response by reference.
16. To the extent such documents exist and are in the possession of Plaintiffs, they have
been attached hereto as Exhibit “A” and incorporated into this response by reference.
17. To the extent such documents exist and are in the possession of Plaintiffs, they have
been attached hereto as Exhibit “A” and incorporated into this response by reference.
18. To the extent such documents exist and are in the possession of Plaintiffs, they have
been attached hereto as Exhibit “A” and incorporated into this response by reference.
19. To the extent such documents exist and are in the possession of Plaintiffs, they have
been attached hereto as Exhibit “A” and incorporated into this response by reference.
20. To the extent such documents exist and are in the possession of Plaintiffs, they have
been attached hereto as Exhibit “A” and incorporated into this response by reference.
21. To the extent such documents exist and are in the possession of Plaintiffs, they have
been attached hereto as Exhibit “A” and incorporated into this response by reference.
22. To the extent such documents exist and are in the possession of Plaintiffs, they have
been attached hereto as Exhibit “A” and incorporated into this response by reference.
23. To the extent such documents exist and are in the possession of Plaintiffs, they have
been attached hereto as Exhibit “A” and incorporated into this response by reference.
24. To the extent such documents exist and are in the possession of Plaintiffs, they have
been attached hereto as Exhibit “A” and incorporated into this response by reference.Leon v. Universal
Case No.: 50-2020-CA-006669 XXXX-MB (AO)
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on August 7, 2020, a true and correct copy of the foregoing has
been served via e-service upon Joseph, Ashley, Esq., Universal Property & Casualty Insurance
Company, at the following e-mail address(es): upciserviceO2@universalproperty.com;
sr0327@universalproperty.com; aj0709@universalproperty.com.
Respectfully submitted,
LEVY & PARTNERS, PLLC
Attorneys for Plaintiff
3230 Stirling Road, Suite 1
Hollywood, Florida 33021
(954) 727-8570 - Telephone
holly@lawlp.com - E-Mail
maritza@lawlp.com - Secondary Service
By: /s/ Holly K. Miller
HOLLY K. MILLER, ESQ.
Florida Bar No.: 40185
ELY R. LEVY, ESQ.
Florida Bar No.: 15452Leon v. Universal
Case No.: 50-2020-CA-006669 XXXX-MB (AO)
EXHIBIT “A”
Responsive Documents will be emailed separately
to the Designated email addresses on file
Preview
Filing # 111439118 E-Filed 08/07/2020 10:23:56 AM IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA ANGEL LEON AND MARLEN LEON, Plaintiff(s), v. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. Case No.: 50-2020-CA-006669 XXXX-MB (AO) PLAINTIFFS’ RESPONSE TO DEFENDANT’S FIRST REQUEST FOR PRODUCTION Plaintiffs, ANGEL LEON AND MARLEN LEON, by and through the undersigned attorneys, pursuant to Fla. R. Civ. P. 1.350, hereby respond to Defendant’s Request for Production (the “Requests”) and state as follows: GENERAL OBJECTIONS 1. Plaintiffs object to the Requests to the extent that they purport to create obligations beyond those imposed by the Florida Rules of Civil Procedure. 2. Plaintiffs object to the production of “any and all” documents to the extent that Defendant seeks to require Plaintiffs to do more than use reasonable diligence to locate responsive and non-privileged or non-protected documents based on an examination of those files that may reasonably be expected to yield such documents, on the grounds that such requests are vague, ambiguous, overly broad, unduly burdensome, oppressive, vexatious, and seek the production of irrelevant materials and documents. 3. Plaintiffs object to the Requests to the extent that they seek information protected by various privileges of confidentiality, including the attorney-client privilege and the work product doctrine, or any other privilege or immunity provided under Florida law. *** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 08/07/2020 10:23:56 AM ***Leon v. Universal Case No.: 50-2020-CA-006669 XXXX-MB (AO) 4. These General Objections shall be deemed applicable to and continuing with respect to the Responses set forth herein. The General Objections asserted above are hereby incorporated into the Responses. The Responses may repeat a General Objection for emphasis or for some other reason. Such General Objections are not waived, nor in any way limited, by the Responses. REQUESTS AND SPECIFIC RESPONSES 1. To the extent such documents exist and are in the possession of Plaintiffs, they have been attached hereto as Exhibit “A” and incorporated into this response by reference. 2. To the extent such documents exist and are in the possession of Plaintiffs, they have been attached hereto as Exhibit “A” and incorporated into this response by reference. 3. To the extent such documents exist and are in the possession of Plaintiffs, they have been attached hereto as Exhibit “A” and incorporated into this response by reference. 4. To the extent such documents exist and are in the possession of Plaintiffs, they have been attached hereto as Exhibit “A” and incorporated into this response by reference. 5. To the extent such documents exist and are in the possession of Plaintiffs, they have been attached hereto as Exhibit “A” and incorporated into this response by reference. 6. To the extent such documents exist and are in the possession of Plaintiffs, they have been attached hereto as Exhibit “A” and incorporated into this response by reference. 7. To the extent such documents exist and are in the possession of Plaintiffs, they have been attached hereto as Exhibit “A” and incorporated into this response by reference. 8. To the extent such documents exist and are in the possession of Plaintiffs, they have been attached hereto as Exhibit “A” and incorporated into this response by reference. 9. To the extent such documents exist and are in the possession of Plaintiffs, they have been attached hereto as Exhibit “A” and incorporated into this response by reference. 10. To the extent such documents exist and are in the possession of Plaintiffs, they have been attached hereto as Exhibit “A” and incorporated into this response by reference. 11. To the extent such documents exist and are in the possession of Plaintiffs, they have been attached hereto as Exhibit “A” and incorporated into this response by reference. 12. To the extent such documents exist and are in the possession of Plaintiffs, they have been attached hereto as Exhibit “A” and incorporated into this response by reference.Leon v. Universal Case No.: 50-2020-CA-006669 XXXX-MB (AO) 13. To the extent such documents exist and are in the possession of Plaintiffs, they have been attached hereto as Exhibit “A” and incorporated into this response by reference. 14. To the extent such documents exist and are in the possession of Plaintiffs, they have been attached hereto as Exhibit “A” and incorporated into this response by reference. 15. To the extent such documents exist and are in the possession of Plaintiffs, they have been attached hereto as Exhibit “A” and incorporated into this response by reference. 16. To the extent such documents exist and are in the possession of Plaintiffs, they have been attached hereto as Exhibit “A” and incorporated into this response by reference. 17. To the extent such documents exist and are in the possession of Plaintiffs, they have been attached hereto as Exhibit “A” and incorporated into this response by reference. 18. To the extent such documents exist and are in the possession of Plaintiffs, they have been attached hereto as Exhibit “A” and incorporated into this response by reference. 19. To the extent such documents exist and are in the possession of Plaintiffs, they have been attached hereto as Exhibit “A” and incorporated into this response by reference. 20. To the extent such documents exist and are in the possession of Plaintiffs, they have been attached hereto as Exhibit “A” and incorporated into this response by reference. 21. To the extent such documents exist and are in the possession of Plaintiffs, they have been attached hereto as Exhibit “A” and incorporated into this response by reference. 22. To the extent such documents exist and are in the possession of Plaintiffs, they have been attached hereto as Exhibit “A” and incorporated into this response by reference. 23. To the extent such documents exist and are in the possession of Plaintiffs, they have been attached hereto as Exhibit “A” and incorporated into this response by reference. 24. To the extent such documents exist and are in the possession of Plaintiffs, they have been attached hereto as Exhibit “A” and incorporated into this response by reference.Leon v. Universal Case No.: 50-2020-CA-006669 XXXX-MB (AO) CERTIFICATE OF SERVICE I HEREBY CERTIFY that on August 7, 2020, a true and correct copy of the foregoing has been served via e-service upon Joseph, Ashley, Esq., Universal Property & Casualty Insurance Company, at the following e-mail address(es): upciserviceO2@universalproperty.com; sr0327@universalproperty.com; aj0709@universalproperty.com. Respectfully submitted, LEVY & PARTNERS, PLLC Attorneys for Plaintiff 3230 Stirling Road, Suite 1 Hollywood, Florida 33021 (954) 727-8570 - Telephone holly@lawlp.com - E-Mail maritza@lawlp.com - Secondary Service By: /s/ Holly K. Miller HOLLY K. MILLER, ESQ. Florida Bar No.: 40185 ELY R. LEVY, ESQ. Florida Bar No.: 15452Leon v. Universal Case No.: 50-2020-CA-006669 XXXX-MB (AO) EXHIBIT “A” Responsive Documents will be emailed separately to the Designated email addresses on file