Preview
Filing # 34543376 E-Filed 11/17/2015 12:58:30 PM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT, IN
AND FOR BROWARD COUNTY,
FLORIDA
BENJAMIN EDELL AND REBECCA EDELL,
Plaintiffs, CASE NO.: CACE-15-013539 Division:21
v.
HERITAGE PROPERTY AND CASUALTY INSURANCE COMPANY,
Defendant.
/
PLAINTIFFS’ RESPONSES TO DEFENDANT’S REQUEST FOR PRODUCTION
COME NOW the Plaintiffs, BENJAMIN EDELL and REBECCA EDELL, by and
through undersigned counsel, and hereby file this Responses to Defendant’s Request for
Production which was served on September 15, 2015, and state as follows:
1. None.
2. Objection, overly broad, irrelevant, and not reasonably calculated to lead to the discovery
of admissible evidence.
3. None.
4. See attached.
5. Objection, overly broad, unduly burdensome, and not reasonably calculated to lead to the
discovery of admissible evidence. Notwithstanding the foregoing objection, documents
responsive to this request, if any, will be provided under separate cover.
6. See attached.
7. None.
8. None.
1
DAVID Low & ASSOCIATES, P.A. * 20195 N.E. 16™ PLACE, SECOND FLOOR * MIAMI, FLORIDA 33179
(T) (305) 935-8986 ¢ (F) (305) 675-2685
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 11/17/2015 12:58:30 PM.****11.
12.
13.
14.
15.
16.
17.
See attached.
None currently in Plaintiff's possession. Discovery is ongoing.
None currently in Plaintiff's possession. Documents responsive to this request, if any, will
be provided under separate cover.
See attached.
See attached.
None.
Objection, overly broad and unduly burdensome, moreover Defendant is requesting
documents which are equally available to Defendant.
Objection, overly broad, unduly burdensome, irrelevant, and not reasonably calculated to
lead to the discovery of admissible evidence.
None.
Objection, overly broad, vague, and ambiguous, moreover Defendant is requesting
documents which are equally available to Defendant.
[SPACE INTENTIONALLY LEFT BLANK]
2
DAVID Low & ASSOCIATES, P.A. * 20195 N.E. 16™ PLACE, SECOND FLOOR * MIAMI, FLORIDA 33179
(T) (305) 935-8986 ¢ (F) (305) 675-2685CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served
electronically via the E-Portal on Glenn H. Malin, Esq., Peterson Bernard, Attorneys for the
Defendant, at gmalini@fil-law.com and jguarente@ftl-law.com, on the 17th day of November,
2015.
Respectfully submitted,
DAVID LOW & ASSOCIATES, P.A.
20195 N.E. 16" Place, Second Place
Miami, Florida 33179
Tel.: (305) 935-8986
Fax: (305) 675-2685
E-Service Email: eservice@davidlowpa.com
Non-Service Email:awinston@davidlowpa.com
By: /s/ Amanda Winston
DAVID LOW, ESQ.
Florida Bar No.: 67957
AMANDA WINSTON, ESQ.
Florida Bar No.: 115644
3
DAVID Low & ASSOCIATES, P.A. * 20195 N.E. 16™ PLACE, SECOND FLOOR * MIAMI, FLORIDA 33179
(T) (305) 935-8986 ¢ (F) (305) 675-2685
Preview
Filing # 34543376 E-Filed 11/17/2015 12:58:30 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA BENJAMIN EDELL AND REBECCA EDELL, Plaintiffs, CASE NO.: CACE-15-013539 Division:21 v. HERITAGE PROPERTY AND CASUALTY INSURANCE COMPANY, Defendant. / PLAINTIFFS’ RESPONSES TO DEFENDANT’S REQUEST FOR PRODUCTION COME NOW the Plaintiffs, BENJAMIN EDELL and REBECCA EDELL, by and through undersigned counsel, and hereby file this Responses to Defendant’s Request for Production which was served on September 15, 2015, and state as follows: 1. None. 2. Objection, overly broad, irrelevant, and not reasonably calculated to lead to the discovery of admissible evidence. 3. None. 4. See attached. 5. Objection, overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. Notwithstanding the foregoing objection, documents responsive to this request, if any, will be provided under separate cover. 6. See attached. 7. None. 8. None. 1 DAVID Low & ASSOCIATES, P.A. * 20195 N.E. 16™ PLACE, SECOND FLOOR * MIAMI, FLORIDA 33179 (T) (305) 935-8986 ¢ (F) (305) 675-2685 *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 11/17/2015 12:58:30 PM.****11. 12. 13. 14. 15. 16. 17. See attached. None currently in Plaintiff's possession. Discovery is ongoing. None currently in Plaintiff's possession. Documents responsive to this request, if any, will be provided under separate cover. See attached. See attached. None. Objection, overly broad and unduly burdensome, moreover Defendant is requesting documents which are equally available to Defendant. Objection, overly broad, unduly burdensome, irrelevant, and not reasonably calculated to lead to the discovery of admissible evidence. None. Objection, overly broad, vague, and ambiguous, moreover Defendant is requesting documents which are equally available to Defendant. [SPACE INTENTIONALLY LEFT BLANK] 2 DAVID Low & ASSOCIATES, P.A. * 20195 N.E. 16™ PLACE, SECOND FLOOR * MIAMI, FLORIDA 33179 (T) (305) 935-8986 ¢ (F) (305) 675-2685CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served electronically via the E-Portal on Glenn H. Malin, Esq., Peterson Bernard, Attorneys for the Defendant, at gmalini@fil-law.com and jguarente@ftl-law.com, on the 17th day of November, 2015. Respectfully submitted, DAVID LOW & ASSOCIATES, P.A. 20195 N.E. 16" Place, Second Place Miami, Florida 33179 Tel.: (305) 935-8986 Fax: (305) 675-2685 E-Service Email: eservice@davidlowpa.com Non-Service Email:awinston@davidlowpa.com By: /s/ Amanda Winston DAVID LOW, ESQ. Florida Bar No.: 67957 AMANDA WINSTON, ESQ. Florida Bar No.: 115644 3 DAVID Low & ASSOCIATES, P.A. * 20195 N.E. 16™ PLACE, SECOND FLOOR * MIAMI, FLORIDA 33179 (T) (305) 935-8986 ¢ (F) (305) 675-2685