Preview
*#4* FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 10/30/2019 9:46:00 AM.**#*
Filing # 92155208 E-Filed 07/08/2019 09:51:24 AM
IN THE CIRCUIT COURT FOR THE
11" JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CASE NO.: 18-038533-CA-01 *
15020 ASSOCIATES REALTY
Plaintiff, 49- 022885
vs.
CITIZENS PROPERTY INSURANCE
CORPORATION, a Florida Corporation,
Defendant,
DEFENDANT CITIZENS PROPERTY INSURANCE CORPORATION’S
RESPONSES TO PLAINTIFF’S REQUEST TO PRODUCE
COMES NOW, Defendant, CITIZENS PROPERTY INSURANCE CORPORATION, by
and through undersigned counsel, and pursuant to the applicable Florida Rules of Civil Procedure
hereby files its Response to Plaintiff's Request to Produce and states as follows:
1. All insurance policies that would inure to the benefit of the Plaintiff herein, together
with any declaration of coverage page, insurance application, endorsements, riders,
arid a sworn statement of a corporate officer of Defendant attesting to the coverage
and authenticity of the policy.
RESPONSE: See attached.
2. All non-privileged portions of the claim file with regard to this claim. For any items
withheld, please set forth the nature of the privilege or protection allowing you to withhold
the document, the date of the document, the drafter, recipient, the date upon which you
anticipated litigation, and a general description of the document.
RESPONSE: Objection. Vague, overly broad. Moreover, Defendant objects to this
request to the extent that it seeks information protected from discovery by the work
product and attorney-client privilege. See State Farm v. Valido, 662 So. 2d 1012 (Fla.
3d DCA 1995), Surf Drugs, Inc. v. Vermette, 236 So. 2d 108 (Fla. 1970), State Farm v.
Galmon, 835 So. 2d 389 (Fla. 2d DCA 2003). Without waiver of the foregoing, see
attached.*#4* FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 10/30/2019 9:46:00 AM.**#*
Copies of any and all forms, correspondence, or reports received by you or any of your
agents on your behalf concerning the Plaintiffs losses from anyone.
RESPONSE: Objection. Vague, overly broad, not limited in time and/or scope.
Moreover, Defendant objects to this request to the extent that it seeks information
protected from discovery by the work product and attorney-client privilege. See State
Farm y. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995), Surf Drugs, Inc. v. Vermette, 236
So. 2d 108 (Fla. 1970), State Farm v. Galmon, 835 So. 2d 389 (Fla. 2d DCA 2003).
Without waiver of the foregoing, see attached.
Any and all statements of any witnesses taken by Defendant with regard to any fact
relevant to any issue in this case.
RESPONSE: Objection. Vague and overbroad. Moreover, Defendant objects to this
request to the extent that it seeks information protected from discovery by the work
product privilege. Without waiver of the foregoing, none.
Any and all photographs in the Defendant's possession related to Plaintiffs claim in
their native digital format.
RESPONSE: Objection. Vague, overly broad. Moreover, Defendant objects to this
request to the extent that it seeks information protected from discovery by the work
product and attorney-client privilege. See State Farm v. Valido, 662 So. 2d 1012 (Fla.
3d DCA 1995), Surf Drugs, Inc. v. Vermette, 236 So. 2d 108 (Fla. 1970), State Farm v.
Galmon, 835 So. 2d 389 (Fla. 2d DCA 2003). Without waiver of the foregoing, see
attached.
All audio recordings and/or transcripts of any statement given by Plaintiff.
RESPONSE: Objection. Vague, overly broad, not limited in time and/or scope.
Moreover, Defendant objects to this request to the extent that it seeks information
protected from discovery by the work product and attorney-client privilege. See State
Farm v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995), Surf Drugs, Inc. v. Vermette, 236
So. 2d 108 (Fla. 1970), State Farm v. Galmon, 835 So. 2d 389 (Fla. 2d DCA 2003).
Without waiver of the foregoing, none.
WADSWORTH MARGREY & DIXON, LLP
261 N.E. 1* Street, 5* Floor, Miami, Florida 33132 - Telephone: 305-777-1000, Facsimile: 305-777-100110.
*#4* FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 10/30/2019 9:46:00 AM.****
Copies of all IRS Forms 1099 from Defendant to any consultants who examined
Plaintiffs home (whether engineers, contractors or roofers) for past 5-years for the
evaluation of claims submitted to Defendant by Defendant's insureds.
RESPONSE: Objection. Vague, overly broad. Moreover, Defendant objects to this
request to the extent that it seeks information protected from discovery by the work
product and attorney-client privilege. See State Farm v. Valido, 662 So. 2d 1012 (Fla.
3d DCA 1995), Surf Drugs, Inc. v. Vermette, 236 So. 2d 108 (Fla. 1970), State Farm v.
Galmon, 835 So. 2d 389 (Fla. 2d DCA 2003).
All reports in your possession that support Defendant's contention that any of Plaintiff's
stated damages are not covered or proper.
RESPONSE: Objection. Vague, overly broad. Moreover, Defendant objects to this
request to the extent that it seeks information protected from discovery by the work
product and attorney-client privilege. See State Farm v. Valido, 662 So. 2d 1012 (Fla.
3d DCA 1995), Surf Drugs, Inc. v. Vermette, 236 So. 2d 108 (Fla. 1970), State Farm v.
Galmon, 835 So. 2d 389 (Fla. 2d DCA 2003). Without waiver of the foregoing, see
attached.
The complete underwriting file with regard to Defendant's issuance of insurance on the
subject risk, and all renewals. This request shali include, but not be limited to, all
underwriting files referring or relating in any way to the policy at issue in this action,
including the file folders in which the underwriting documents are kept -and drafts of all
documents in the file.
RESPONSE: See attached.
All documents or evidence identified by you in your responses to Plaintiffs First Set
of Interrogatories.
RESPONSE: Defendant has requested Plaintiff to provide a copy of the
interrogatories so as to allow this Defendant to formally prepare a response to same.
Without waiver of the foregoing and subject to State Farm v. Valido, 662 So. 2d 1012
(Fla. 3d DCA 1995), Surf Drugs, Inc. v. Vermette, 236 So. 2d 108 (Fla. 1970), State
Farm v. Galmon, 835 So. 2d 389 (Fla. 2d DCA 2003), see attached.
WADSWORTH MARGREY & DIXON, LLP
261 N.E. 1* Street, 5 Floor, Miami, Florida 33132 - Telephone: 305-777-1000, Facsimile: 305-777-10011.
12.
13.
14.
+" FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 10/30/2019 9:46:00 AM.****
The electronic diary, including the electronic and paper notes made by Defendant's
claims personnel, contractors, and third party adjusters / adjusting firms relating to
Plaintiffs claims.
RESPONSE: Objection. Vague, overly broad. Moreover, Defendant objects to this
request to the extent that it seeks information protected from discovery by the work
product and attorney-client privilege. See State Farm v. Valido, 662 So. 2d 1012 (Fla.
3d DCA 1995), Surf Drugs, Inc. v. Vermette, 236 So. 2d 108 (Fla. 1970), State Farm v.
Galmon, 835 So. 2d 389 (Fla. 2d DCA 2003).
All adjusting reports, estimates, and appraisals concerning Plaintiffs underlying
claims.
RESPONSE: Objection. Vague, overly broad. Moreover, Defendant objects to this
request to the extent that it seeks information protected from discovery by the work
product and attorney-client privilege. See State Farm v. Valido, 662 So. 2d 1012 (Fla.
3d DCA 1995), Surf Drugs, Inc. v. Vermette, 236 So. 2d 108 (Fla. 1970), State Farm v.
Galmon, 835 So. 2d 389 (Fla. 2d DCA 2003). Without waiver of the foregoing, see
attached.
The engineering and mold reports prepared concerning Plaintiffs underlying claim.
RESPONSE: Objection. Vague, overly broad. Moreover, Defendant objects to this
request to the extent that it seeks information protected from discovery by the work
product and attorney-client privilege. See State Farm v. Valido, 662 So. 2d 1012 (Fla.
3d DCA 1995), Surf Drugs, Inc. v. Vermette, 236 So. 2d 108 (Fla. 1970), State Farm y.
Galmon, 835 So. 2d 389 (Fla. 2d DCA 2003). Without waiver of the foregoing, see
attached.
The field notes, measurements and file maintained by the adjuster(s) and engineers
who physically inspected the subject property.
RESPONSE: Objection. Vague, overly broad. Moreover, Defendant objects to this
request to the extent that it seeks information protected from discovery by the work
product and attorney-client privilege. See State Farm v. Valido, 662 So. 2d 1012 (Fla.
3d DCA 1995), Surf Drugs, Inc. v. Vermette, 236 So. 2d 108 (Fla. 1970), State Farm v.
Galmon, 835 So. 2d 389 (Fla. 2d DCA 2003). Without waiver of the foregoing, see
attached,
WADSWORTH MARGREY & DIXON, LLP
261 N.E. 1* Street, 5" Floor, Miami, Florida 33132 - Telephone: 305-777-1000, Facsimile: 305-777-100115.
16.
17.
18.
19.
*#4* FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 10/30/2019 9:46:00 AM.**#*
The emails, instant messages, text messages, and internal correspondence pertaining to
Plaintiff's underlying claim.
RESPONSE: Objection. Vague, overly broad. Moreover, Defendant objects to this
request to the extent that it seeks information protected from discovery by the work
product and attorney-client privilege. See State Farm v. Valido, 662 So. 2d 1012 (Fla.
3d DCA 1995), Surf Drugs, Inc. v. Vermette, 236 So. 2d 108 (Fla. 1970), State Farm v.
Galmon, 835 So. 2d 389 (Fla. 2d DCA 2003).
Any emails, correspondence, or documentation provided to you by Plaintiff or any agent,
representative, or public adjuster of Plaintiff regarding the underlying claim.
RESPONSE: Broad, vague. Without waiver of the foregoing, see attached.
The documents reflecting reserves applied to the subject claim.
RESPONSE: Objection. Vague, overly broad. Moreover, Defendant objects to this
request to the extent that it seeks information protected from discovery by the work
product and attorney-client privilege. See State Farm v. Valido, 662 So. 2d 1012 (Fla.
3d DCA 1995), Surf Drugs, Inc. v. Vermette, 236 So. 2d 108 (Fla. 1970), State Farm v.
Galmon, 835 So. 2d 389 (Fla. 2d DCA 2003). Without waiver of the foregoing, see
copy of policy attached.
All evidence upon which your affirmative defenses rely.
RESPONSE: Objection. Vague, over broad, unduly burdensome. Moreover,
Defendant objects to this request to the extent that it seeks information protected
from discovery by the work product privilege. Without waiver of the foregoing, see
attached. -
All evidence upon which you rely in support of your denial that you are in breach of
contract, as alleged in the Complaint.
RESPONSE: Objection. Vague, over broad, unduly burdensome. Moreover,
Defendant objects to this request to the extent that it seeks information protected
from discovery by the work product privilege. Without waiver of the foregoing, see
attached.
WADSWORTH MARGREY & DIXON, LLP
261 N.E. 1* Street, 5“ Floor, Miami, Florida 33132 - Telephone: 305-777-1000, Facsimile: 305-777-1001*#** FILED: BROWARD COUNTY, FL Brenda D, Forman, CLERK 10/30/2019 9:46:00 AM.****
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY a true copy of the foregoing was provided via email to:
jparrish@forthepeople.com Joe Parrish Jr., Esq. Morgan & Morgan, P.A., 30338 Overseas
Highway Unit 7 Big Pine Key, FL 33043 on July 8, 2019.
WADSWORTH, MARGREY & DIXON, LLP
Attorneys for Defendant
261 NE 1 Street, 5" Floor
Miami, FL 33132
(305) 777-1000 Telephone
(305) 777-1001 Facsimile
By: //Elizabeth Gonzalez
Elizabeth Gonzalez
Florida Bar No.: 58702
E-mail: eg@wmd-law.org
Christopher W. Wadsworth
Florida Bar No.: 78026
E-mail: cw@cmd-law.org,
Secondary: pleadings@wmd-law.org
WADSWORTH MARGREY & DIXON, LLP
261 NLE. 1* Street, 5 Floor, Miami, Florida 33132 - Telephone: 305-777-1000, Facsimile: 305-777-1001
Preview
*#4* FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 10/30/2019 9:46:00 AM.**#* Filing # 92155208 E-Filed 07/08/2019 09:51:24 AM IN THE CIRCUIT COURT FOR THE 11" JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NO.: 18-038533-CA-01 * 15020 ASSOCIATES REALTY Plaintiff, 49- 022885 vs. CITIZENS PROPERTY INSURANCE CORPORATION, a Florida Corporation, Defendant, DEFENDANT CITIZENS PROPERTY INSURANCE CORPORATION’S RESPONSES TO PLAINTIFF’S REQUEST TO PRODUCE COMES NOW, Defendant, CITIZENS PROPERTY INSURANCE CORPORATION, by and through undersigned counsel, and pursuant to the applicable Florida Rules of Civil Procedure hereby files its Response to Plaintiff's Request to Produce and states as follows: 1. All insurance policies that would inure to the benefit of the Plaintiff herein, together with any declaration of coverage page, insurance application, endorsements, riders, arid a sworn statement of a corporate officer of Defendant attesting to the coverage and authenticity of the policy. RESPONSE: See attached. 2. All non-privileged portions of the claim file with regard to this claim. For any items withheld, please set forth the nature of the privilege or protection allowing you to withhold the document, the date of the document, the drafter, recipient, the date upon which you anticipated litigation, and a general description of the document. RESPONSE: Objection. Vague, overly broad. Moreover, Defendant objects to this request to the extent that it seeks information protected from discovery by the work product and attorney-client privilege. See State Farm v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995), Surf Drugs, Inc. v. Vermette, 236 So. 2d 108 (Fla. 1970), State Farm v. Galmon, 835 So. 2d 389 (Fla. 2d DCA 2003). Without waiver of the foregoing, see attached.*#4* FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 10/30/2019 9:46:00 AM.**#* Copies of any and all forms, correspondence, or reports received by you or any of your agents on your behalf concerning the Plaintiffs losses from anyone. RESPONSE: Objection. Vague, overly broad, not limited in time and/or scope. Moreover, Defendant objects to this request to the extent that it seeks information protected from discovery by the work product and attorney-client privilege. See State Farm y. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995), Surf Drugs, Inc. v. Vermette, 236 So. 2d 108 (Fla. 1970), State Farm v. Galmon, 835 So. 2d 389 (Fla. 2d DCA 2003). Without waiver of the foregoing, see attached. Any and all statements of any witnesses taken by Defendant with regard to any fact relevant to any issue in this case. RESPONSE: Objection. Vague and overbroad. Moreover, Defendant objects to this request to the extent that it seeks information protected from discovery by the work product privilege. Without waiver of the foregoing, none. Any and all photographs in the Defendant's possession related to Plaintiffs claim in their native digital format. RESPONSE: Objection. Vague, overly broad. Moreover, Defendant objects to this request to the extent that it seeks information protected from discovery by the work product and attorney-client privilege. See State Farm v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995), Surf Drugs, Inc. v. Vermette, 236 So. 2d 108 (Fla. 1970), State Farm v. Galmon, 835 So. 2d 389 (Fla. 2d DCA 2003). Without waiver of the foregoing, see attached. All audio recordings and/or transcripts of any statement given by Plaintiff. RESPONSE: Objection. Vague, overly broad, not limited in time and/or scope. Moreover, Defendant objects to this request to the extent that it seeks information protected from discovery by the work product and attorney-client privilege. See State Farm v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995), Surf Drugs, Inc. v. Vermette, 236 So. 2d 108 (Fla. 1970), State Farm v. Galmon, 835 So. 2d 389 (Fla. 2d DCA 2003). Without waiver of the foregoing, none. WADSWORTH MARGREY & DIXON, LLP 261 N.E. 1* Street, 5* Floor, Miami, Florida 33132 - Telephone: 305-777-1000, Facsimile: 305-777-100110. *#4* FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 10/30/2019 9:46:00 AM.**** Copies of all IRS Forms 1099 from Defendant to any consultants who examined Plaintiffs home (whether engineers, contractors or roofers) for past 5-years for the evaluation of claims submitted to Defendant by Defendant's insureds. RESPONSE: Objection. Vague, overly broad. Moreover, Defendant objects to this request to the extent that it seeks information protected from discovery by the work product and attorney-client privilege. See State Farm v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995), Surf Drugs, Inc. v. Vermette, 236 So. 2d 108 (Fla. 1970), State Farm v. Galmon, 835 So. 2d 389 (Fla. 2d DCA 2003). All reports in your possession that support Defendant's contention that any of Plaintiff's stated damages are not covered or proper. RESPONSE: Objection. Vague, overly broad. Moreover, Defendant objects to this request to the extent that it seeks information protected from discovery by the work product and attorney-client privilege. See State Farm v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995), Surf Drugs, Inc. v. Vermette, 236 So. 2d 108 (Fla. 1970), State Farm v. Galmon, 835 So. 2d 389 (Fla. 2d DCA 2003). Without waiver of the foregoing, see attached. The complete underwriting file with regard to Defendant's issuance of insurance on the subject risk, and all renewals. This request shali include, but not be limited to, all underwriting files referring or relating in any way to the policy at issue in this action, including the file folders in which the underwriting documents are kept -and drafts of all documents in the file. RESPONSE: See attached. All documents or evidence identified by you in your responses to Plaintiffs First Set of Interrogatories. RESPONSE: Defendant has requested Plaintiff to provide a copy of the interrogatories so as to allow this Defendant to formally prepare a response to same. Without waiver of the foregoing and subject to State Farm v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995), Surf Drugs, Inc. v. Vermette, 236 So. 2d 108 (Fla. 1970), State Farm v. Galmon, 835 So. 2d 389 (Fla. 2d DCA 2003), see attached. WADSWORTH MARGREY & DIXON, LLP 261 N.E. 1* Street, 5 Floor, Miami, Florida 33132 - Telephone: 305-777-1000, Facsimile: 305-777-10011. 12. 13. 14. +" FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 10/30/2019 9:46:00 AM.**** The electronic diary, including the electronic and paper notes made by Defendant's claims personnel, contractors, and third party adjusters / adjusting firms relating to Plaintiffs claims. RESPONSE: Objection. Vague, overly broad. Moreover, Defendant objects to this request to the extent that it seeks information protected from discovery by the work product and attorney-client privilege. See State Farm v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995), Surf Drugs, Inc. v. Vermette, 236 So. 2d 108 (Fla. 1970), State Farm v. Galmon, 835 So. 2d 389 (Fla. 2d DCA 2003). All adjusting reports, estimates, and appraisals concerning Plaintiffs underlying claims. RESPONSE: Objection. Vague, overly broad. Moreover, Defendant objects to this request to the extent that it seeks information protected from discovery by the work product and attorney-client privilege. See State Farm v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995), Surf Drugs, Inc. v. Vermette, 236 So. 2d 108 (Fla. 1970), State Farm v. Galmon, 835 So. 2d 389 (Fla. 2d DCA 2003). Without waiver of the foregoing, see attached. The engineering and mold reports prepared concerning Plaintiffs underlying claim. RESPONSE: Objection. Vague, overly broad. Moreover, Defendant objects to this request to the extent that it seeks information protected from discovery by the work product and attorney-client privilege. See State Farm v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995), Surf Drugs, Inc. v. Vermette, 236 So. 2d 108 (Fla. 1970), State Farm y. Galmon, 835 So. 2d 389 (Fla. 2d DCA 2003). Without waiver of the foregoing, see attached. The field notes, measurements and file maintained by the adjuster(s) and engineers who physically inspected the subject property. RESPONSE: Objection. Vague, overly broad. Moreover, Defendant objects to this request to the extent that it seeks information protected from discovery by the work product and attorney-client privilege. See State Farm v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995), Surf Drugs, Inc. v. Vermette, 236 So. 2d 108 (Fla. 1970), State Farm v. Galmon, 835 So. 2d 389 (Fla. 2d DCA 2003). Without waiver of the foregoing, see attached, WADSWORTH MARGREY & DIXON, LLP 261 N.E. 1* Street, 5" Floor, Miami, Florida 33132 - Telephone: 305-777-1000, Facsimile: 305-777-100115. 16. 17. 18. 19. *#4* FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 10/30/2019 9:46:00 AM.**#* The emails, instant messages, text messages, and internal correspondence pertaining to Plaintiff's underlying claim. RESPONSE: Objection. Vague, overly broad. Moreover, Defendant objects to this request to the extent that it seeks information protected from discovery by the work product and attorney-client privilege. See State Farm v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995), Surf Drugs, Inc. v. Vermette, 236 So. 2d 108 (Fla. 1970), State Farm v. Galmon, 835 So. 2d 389 (Fla. 2d DCA 2003). Any emails, correspondence, or documentation provided to you by Plaintiff or any agent, representative, or public adjuster of Plaintiff regarding the underlying claim. RESPONSE: Broad, vague. Without waiver of the foregoing, see attached. The documents reflecting reserves applied to the subject claim. RESPONSE: Objection. Vague, overly broad. Moreover, Defendant objects to this request to the extent that it seeks information protected from discovery by the work product and attorney-client privilege. See State Farm v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995), Surf Drugs, Inc. v. Vermette, 236 So. 2d 108 (Fla. 1970), State Farm v. Galmon, 835 So. 2d 389 (Fla. 2d DCA 2003). Without waiver of the foregoing, see copy of policy attached. All evidence upon which your affirmative defenses rely. RESPONSE: Objection. Vague, over broad, unduly burdensome. Moreover, Defendant objects to this request to the extent that it seeks information protected from discovery by the work product privilege. Without waiver of the foregoing, see attached. - All evidence upon which you rely in support of your denial that you are in breach of contract, as alleged in the Complaint. RESPONSE: Objection. Vague, over broad, unduly burdensome. Moreover, Defendant objects to this request to the extent that it seeks information protected from discovery by the work product privilege. Without waiver of the foregoing, see attached. WADSWORTH MARGREY & DIXON, LLP 261 N.E. 1* Street, 5“ Floor, Miami, Florida 33132 - Telephone: 305-777-1000, Facsimile: 305-777-1001*#** FILED: BROWARD COUNTY, FL Brenda D, Forman, CLERK 10/30/2019 9:46:00 AM.**** CERTIFICATE OF SERVICE WE HEREBY CERTIFY a true copy of the foregoing was provided via email to: jparrish@forthepeople.com Joe Parrish Jr., Esq. Morgan & Morgan, P.A., 30338 Overseas Highway Unit 7 Big Pine Key, FL 33043 on July 8, 2019. WADSWORTH, MARGREY & DIXON, LLP Attorneys for Defendant 261 NE 1 Street, 5" Floor Miami, FL 33132 (305) 777-1000 Telephone (305) 777-1001 Facsimile By: //Elizabeth Gonzalez Elizabeth Gonzalez Florida Bar No.: 58702 E-mail: eg@wmd-law.org Christopher W. Wadsworth Florida Bar No.: 78026 E-mail: cw@cmd-law.org, Secondary: pleadings@wmd-law.org WADSWORTH MARGREY & DIXON, LLP 261 NLE. 1* Street, 5 Floor, Miami, Florida 33132 - Telephone: 305-777-1000, Facsimile: 305-777-1001