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Filing # 103926155 E-Filed 02/26/2020 11:15:02 AM
IN THE CIRCUIT COURT IN AND FOR BROWARD COUNTY, FLORIDA
PAUL RODRIGUEZ, CASE NO. CACE-19-021427 Div: 02
Plaintiff,
v.
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
PLAINTIFF'S RESPONSE TO REQUEST FOR PRODUCTION
Florida Bar #218261
COMES NOW, Plaintiff and hereby file this response to the Request for Production, and
would state:
1. Objection: overly broad and unduly burdensome. Furthermore, this request seeks
documents equally available to Defendant. Notwithstanding said objection and
without waiving same, any and all documents responsive to this request in Plaintiffs’
possession are attached herein.
2. Objection: overly broad and unduly burdensome. Furthermore, this request seeks
documents equally available to Defendant. Notwithstanding said objection and
without waiving same, any and all documents responsive to this request in Plaintiffs’
possession are attached herein.
3. Any and all documents responsive to this request in Plaintiffs’ possession are
attached herein.
4. To the best of Plaintiffs knowledge and belief, none.
5. Objection: this request secks documents equally available to Defendant.
Notwithstanding said objection and without waiving same, any and all documents
responsive to this request in Plaintiffs’ possession are attached herein.
6. To the best of Plaintiff's knowledge and belief, none.
7. To the best of Plaintiff's knowledge and belief, none.
8. Any and all documents responsive to this request in Plaintiffs’ possession are
attached herein.
[ono _+d
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/26/2020 11:15:02 AM.****10.
ll.
12,
13.
14,
15.
16,
17.
18.
19.
20.
Objection: this request seeks documents equally available to Defendant.
Notwithstanding said objection and without waiving same, any and all documents
responsive to this request in Plaintiffs’ possession are attached herein.
Objection: attorney-client and work-production privileged. Notwithstanding said
claims of privilege and without waiving same, Petitioner and his counsel have not
yet made any decisions regarding who they may call as an expert witness at
trial. However, they do reserve their right to make that decision if and as
necessary and further reserve the right to maintain their claims of privilege unless
and until required to divulge expert (consulting/non-testifying) witness
information by trial order or other order of the court and/or Florida law.
Any and all documents responsive to this request in Plaintiffs’ possession are
attached herein.
To the best of Plaintiffs knowledge and belief, none.
Objection: this request is vague. Furthermore, work product and attorney-client
privileged. Notwithstanding said claims of privilege and without waiving same,
any and all documents responsive to this request in Plaintiffs’ possession are
attached herein.
Any and all documents responsive to this request in Plaintiffs’ possession are
attached herein.
To the best of Plaintiff's knowledge and belief, none.
Objection: work product and attorney-client privileged. Notwithstanding said
claims of privilege and without waiving same, please be advised that neither
Plaintiffs, nor their counsel, have made any decisions at this point regarding what
they may produce at trial. However, Plaintiffs reserve the right to supplement this
response as necessary or as required pursuant to the Florida Rules of Civil
Procedure, as well as any local rules or Orders of the Court.
Objection: this request is overly broad, not reasonably limited in time and scope,
and not reasonably calculated to lead to admissible evidence. Notwithstanding
said objections and without waiving same, Plaintiff does not recall the names and
addresses of the entities with which they have had any homeowners insurance
coverage insuring the property for the past ten (10) years but Citizens Property
Insurance Corporation.
To the best of Plaintiffs knowledge and belief, none.
To the best of Plaintiff's knowledge and belief, none.
Objection: this request is not limited in time and scope. Notwithstanding said
objection and without waiving same, to the best of Plaintiff's knowledge and21,
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35,
belief, any and all documents responsive to this request in Plaintiffs’ possession
are attached herein.
To the best of Plaintiff's knowledge and belief, none.
Any and all documents responsive to this request in Plaintiffs’ possession are
attached herein.
Objection: this request is overly broad and unduly burdensome. Notwithstanding
said objections and without waiving same, none.
Objection; this request is irrelevant, overly broad, unduly burdensome, harassing,
not reasonably limited in time and not reasonably calculated to lead to admissible
evidence. Notwithstanding said objections and without waiving same, any and all
documents responsive to this request in Plaintiffs’ possession are attached herein.
Objection; this request is irrelevant, overly broad, unduly burdensome, harassing,
not reasonably limited in time and not reasonably calculated to lead to admissible
evidence. Notwithstanding said objections and without waiving same, none.
Objection: this request is irrelevant and not reasonably calculated to lead to
admissible evidence.
Any and all documents responsive to this request in Plaintiffs’ possession are
attached herein.
To the best of Plaintiff's knowledge and belief, none.
Objection: this request is overly broad and unduly burdensome. Notwithstanding
said objections and without waiving same, any and all documents responsive to
this request in Plaintiffs’ possession are attached herein.
Objection: overly broad, unduly burdensome, not reasonably limited in time or
scope. Notwithstanding said objections and without waving same, any and all
documents responsive to this request in Plaintiffs’ possession are attached herein.
Objection: overly broad, unduly burdensome, not reasonably limited in time or
scope. Notwithstanding said objections and without waving same, none in
Plaintiffs possession.
Objection: overly broad, unduly burdensome, not reasonably limited in time or
scope. Notwithstanding said objections and without waving same, none in
Plaintiff's possession.
To the best of Plaintiff's knowledge and belief, none.
Objection: this request may impinge upon Plaintiff's work-product privilege.
Notwithstanding said objections and without waving same, none.
Objection: overly broad, unduly burdensome and not reasonably limited in time
and scope. Additionally, this request may impinge upon Plaintiffs work-product
mrprivilege. Notwithstanding said objections and without waving same, any and all
non-privileged documents responsive to this request in Plaintiffs’ possession are
attached herein.
36. To the best of Plaintiff's knowledge and belief, none.
37. Objection; this request seeks information that is equally available to Defendant as
a matter of public records. Notwithstanding said objections and without waving
same, to the best of Plaintiff's knowledge and belief, none.
38. Objection; this request seeks information that is equally available to Defendant as a
matter of public records. Notwithstanding said objections and without waving same,
to the best of Plaintiffs knowledge and belief, none.
39. Any and all responsive documents in Plaintiff's possession, custody or control is
attached herein.
40. Any and ail responsive documents in Plaintiff’s possession, custody or control is
attached herein.
[CERTIFICATE OF SERVICE IS LOCATED ON THE FOLLOWING PAGE]
[oorCERTIFICATE OF SERVICE
WE HEREBY CERTIFY that on this___ 26th day of __February _, 2020, a true and
correct copy of the foregoing was emailed electronically filed and served through the Florida Court’s
E-Filing Portal to: Lyndsay D. Fichtenbaum, of GOEDE, ADAMCZYK, DEBOEST & CROSS,
PLLC, 4800 N. Federal Highway, Suite 307D, Boca Raton, Florda, 334131, at
Ifichtenbaum@gadclaw; bblotz@gadclaw.
DUBOFF LAW FIRM
ATTORNEY FOR PLAINTIFF
680 NE 127 STREET
NORTH MIAMI, FLORIDA 33161
TELEPHONE (305) 899-0085
FAX No. (305) 899-0091
cv
By;
TH R. DUBOFF
DUBOFF
Preview
Filing # 103926155 E-Filed 02/26/2020 11:15:02 AM IN THE CIRCUIT COURT IN AND FOR BROWARD COUNTY, FLORIDA PAUL RODRIGUEZ, CASE NO. CACE-19-021427 Div: 02 Plaintiff, v. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. PLAINTIFF'S RESPONSE TO REQUEST FOR PRODUCTION Florida Bar #218261 COMES NOW, Plaintiff and hereby file this response to the Request for Production, and would state: 1. Objection: overly broad and unduly burdensome. Furthermore, this request seeks documents equally available to Defendant. Notwithstanding said objection and without waiving same, any and all documents responsive to this request in Plaintiffs’ possession are attached herein. 2. Objection: overly broad and unduly burdensome. Furthermore, this request seeks documents equally available to Defendant. Notwithstanding said objection and without waiving same, any and all documents responsive to this request in Plaintiffs’ possession are attached herein. 3. Any and all documents responsive to this request in Plaintiffs’ possession are attached herein. 4. To the best of Plaintiffs knowledge and belief, none. 5. Objection: this request secks documents equally available to Defendant. Notwithstanding said objection and without waiving same, any and all documents responsive to this request in Plaintiffs’ possession are attached herein. 6. To the best of Plaintiff's knowledge and belief, none. 7. To the best of Plaintiff's knowledge and belief, none. 8. Any and all documents responsive to this request in Plaintiffs’ possession are attached herein. [ono _+d *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/26/2020 11:15:02 AM.****10. ll. 12, 13. 14, 15. 16, 17. 18. 19. 20. Objection: this request seeks documents equally available to Defendant. Notwithstanding said objection and without waiving same, any and all documents responsive to this request in Plaintiffs’ possession are attached herein. Objection: attorney-client and work-production privileged. Notwithstanding said claims of privilege and without waiving same, Petitioner and his counsel have not yet made any decisions regarding who they may call as an expert witness at trial. However, they do reserve their right to make that decision if and as necessary and further reserve the right to maintain their claims of privilege unless and until required to divulge expert (consulting/non-testifying) witness information by trial order or other order of the court and/or Florida law. Any and all documents responsive to this request in Plaintiffs’ possession are attached herein. To the best of Plaintiffs knowledge and belief, none. Objection: this request is vague. Furthermore, work product and attorney-client privileged. Notwithstanding said claims of privilege and without waiving same, any and all documents responsive to this request in Plaintiffs’ possession are attached herein. Any and all documents responsive to this request in Plaintiffs’ possession are attached herein. To the best of Plaintiff's knowledge and belief, none. Objection: work product and attorney-client privileged. Notwithstanding said claims of privilege and without waiving same, please be advised that neither Plaintiffs, nor their counsel, have made any decisions at this point regarding what they may produce at trial. However, Plaintiffs reserve the right to supplement this response as necessary or as required pursuant to the Florida Rules of Civil Procedure, as well as any local rules or Orders of the Court. Objection: this request is overly broad, not reasonably limited in time and scope, and not reasonably calculated to lead to admissible evidence. Notwithstanding said objections and without waiving same, Plaintiff does not recall the names and addresses of the entities with which they have had any homeowners insurance coverage insuring the property for the past ten (10) years but Citizens Property Insurance Corporation. To the best of Plaintiffs knowledge and belief, none. To the best of Plaintiff's knowledge and belief, none. Objection: this request is not limited in time and scope. Notwithstanding said objection and without waiving same, to the best of Plaintiff's knowledge and21, 22. 23. 24. 25. 26. 27. 28. 29. 30. 31. 32. 33. 34. 35, belief, any and all documents responsive to this request in Plaintiffs’ possession are attached herein. To the best of Plaintiff's knowledge and belief, none. Any and all documents responsive to this request in Plaintiffs’ possession are attached herein. Objection: this request is overly broad and unduly burdensome. Notwithstanding said objections and without waiving same, none. Objection; this request is irrelevant, overly broad, unduly burdensome, harassing, not reasonably limited in time and not reasonably calculated to lead to admissible evidence. Notwithstanding said objections and without waiving same, any and all documents responsive to this request in Plaintiffs’ possession are attached herein. Objection; this request is irrelevant, overly broad, unduly burdensome, harassing, not reasonably limited in time and not reasonably calculated to lead to admissible evidence. Notwithstanding said objections and without waiving same, none. Objection: this request is irrelevant and not reasonably calculated to lead to admissible evidence. Any and all documents responsive to this request in Plaintiffs’ possession are attached herein. To the best of Plaintiff's knowledge and belief, none. Objection: this request is overly broad and unduly burdensome. Notwithstanding said objections and without waiving same, any and all documents responsive to this request in Plaintiffs’ possession are attached herein. Objection: overly broad, unduly burdensome, not reasonably limited in time or scope. Notwithstanding said objections and without waving same, any and all documents responsive to this request in Plaintiffs’ possession are attached herein. Objection: overly broad, unduly burdensome, not reasonably limited in time or scope. Notwithstanding said objections and without waving same, none in Plaintiffs possession. Objection: overly broad, unduly burdensome, not reasonably limited in time or scope. Notwithstanding said objections and without waving same, none in Plaintiff's possession. To the best of Plaintiff's knowledge and belief, none. Objection: this request may impinge upon Plaintiff's work-product privilege. Notwithstanding said objections and without waving same, none. Objection: overly broad, unduly burdensome and not reasonably limited in time and scope. Additionally, this request may impinge upon Plaintiffs work-product mrprivilege. Notwithstanding said objections and without waving same, any and all non-privileged documents responsive to this request in Plaintiffs’ possession are attached herein. 36. To the best of Plaintiff's knowledge and belief, none. 37. Objection; this request seeks information that is equally available to Defendant as a matter of public records. Notwithstanding said objections and without waving same, to the best of Plaintiff's knowledge and belief, none. 38. Objection; this request seeks information that is equally available to Defendant as a matter of public records. Notwithstanding said objections and without waving same, to the best of Plaintiffs knowledge and belief, none. 39. Any and all responsive documents in Plaintiff's possession, custody or control is attached herein. 40. Any and ail responsive documents in Plaintiff’s possession, custody or control is attached herein. [CERTIFICATE OF SERVICE IS LOCATED ON THE FOLLOWING PAGE] [oorCERTIFICATE OF SERVICE WE HEREBY CERTIFY that on this___ 26th day of __February _, 2020, a true and correct copy of the foregoing was emailed electronically filed and served through the Florida Court’s E-Filing Portal to: Lyndsay D. Fichtenbaum, of GOEDE, ADAMCZYK, DEBOEST & CROSS, PLLC, 4800 N. Federal Highway, Suite 307D, Boca Raton, Florda, 334131, at Ifichtenbaum@gadclaw; bblotz@gadclaw. DUBOFF LAW FIRM ATTORNEY FOR PLAINTIFF 680 NE 127 STREET NORTH MIAMI, FLORIDA 33161 TELEPHONE (305) 899-0085 FAX No. (305) 899-0091 cv By; TH R. DUBOFF DUBOFF