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Filing # 59444835 E-Filed 07/24/2017 10:19:08 PM
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT IN AND
FOR ORANGE COUNTY, FLORIDA
CASE NO.: 2017-CA-4797
ILER DALEGRAND &
CHRISTINE DALEGRAND,
Plaintiffs,
v.
SECURITY FIRST
INSURANCE COMPANY,
Defendant.
_______________________________/
DEFENDANT’S RESPONSE TO PLAINTIFFS’ FIRST REQUEST
FOR PRODUCTION TO DEFENDANT
COMES NOW, Defendant, SECURITY FIRST INSURANCE COMPANY (“SFIC”),
by and through undersigned counsel and pursuant to Florida Rule of Civil Procedure
1.350, hereby responds to Plaintiffs’ First Request for Production to Defendant, and states
as follows:
GENERAL OBJECTIONS
1. SFIC objects to the production of any and all documents to the extent Plaintiffs’
requests contravene the attorney-client privilege, the work-product doctrine, the Florida
Rules of Civil Procedure, or any other applicable privilege, doctrine, or rule.
2. SFIC objects to the production of any and all documents to the extent Plaintiffs’
requests are overbroad, unduly burdensome, or oppressive.
Page 1
COLE, SCOTT & KISSANE, P.A.
TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX
CASE NO.: 2017-CA-4797
3. SFIC objects to the production of any and all documents to the extent the
documents sought are neither relevant nor calculated to lead to the discovery of SFIC
objects to the production of any and all documents to the extent the documents sought
are not within the possession, custody, or control of SFIC or its agents.
5. SFIC does not waive its right to object to the relevancy, authenticity,
competency, or admissibility of any documents which have been or will be produced in
response to any request in Plaintiffs’ Request to Produce.
6. SFIC reserves the right to supplement these responses as appropriate.
7. SFIC objects to Plaintiffs’ “Instructions” (regarding descriptions of privileged
documents) as overbroad and unduly burdensome. SFIC will provide a Privilege Log,
describing items determined to be otherwise discoverable, that complies with Rule
1.280(b)(6) of the Florida Rules of Civil Procedure and applicable case law, describing
“the nature of the documents, communications, or things not produced or disclosed in a
manner that, without revealing information itself privileged or protected, will enable other
parties to assess the applicability of the privilege or protection.”
8. SFIC objects to the discovery of any information to the extent that it seeks
confidential and private information regarding individuals who are not parties to this
lawsuit.
RESPONSES TO PLAINTIFFS’ REQUEST FOR PRODUCTION
1. Any and all insurance policies ever issued by the Defendant to the Plaintiff,
including all declaration pages, applications, addenda and riders.
Response: Security First Insurance Company objects to this Request
as the documents sought are shielded from discovery by the work
Page 2
COLE, SCOTT & KISSANE, P.A.
TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX
CASE NO.: 2017-CA-4797
product doctrine. Security First Insurance Company objects to this
Request as it seeks documents related to claims handling which are
not discoverable in a first party cause of action. United Servs. Auto.
Ass'n v. Kindl, 49 So. 3d 807, 808 (Fla. 5th DCA 2010); Seminole Cas.
Ins. Co. v. Mastrominas, 6 So. 3d 1256, 1258 (Fla. 2d DCA 2009); State
Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995);
State Farm Florida Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003). Notwithstanding this objection, Defendant is producing a
certified copy of the Policy, declarations, endorsement details,
notices, and checklist of coverages.
2. Any and all correspondence between you and Plaintiff or anyone acting on
the Plaintiffs behalf.
Response: Defendant is producing Letter dated December 28, 2016;
Letter dated January 2, 2017
3. Any and all written or recorded statements of the Plaintiff, its agents, and/or
representatives.
Response: Defendant is producing a recorded statement of Mr. Chris
Dalegrand, taken on December 30, 2016.
4. Any and all statements taken by the Defendant of any witness with regards
to any fact Any and all photographs and/or video of the Plaintiffs property and/or its
contents.
Response: Security First Insurance Company objects to this Request
as the documents sought are shielded from discovery by the work
product doctrine. Security First Insurance Company objects to this
Request as it seeks documents related to claims handling which are
not discoverable in a first party cause of action. United Servs. Auto.
Ass'n v. Kindl, 49 So. 3d 807, 808 (Fla. 5th DCA 2010); Seminole Cas.
Ins. Co. v. Mastrominas, 6 So. 3d 1256, 1258 (Fla. 2d DCA 2009); State
Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995);
State Farm Florida Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003). Notwithstanding this objection, see Response to #3.
5. Any and all photographs and/or video of the Plaintiff’s property and/or its
Page 3
COLE, SCOTT & KISSANE, P.A.
TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX
CASE NO.: 2017-CA-4797
contents.
Response: Security First Insurance Company objects to this Request
as the documents sought are shielded from discovery by the work
product doctrine and the attorney client privilege. Security First
Insurance Company objects to this Request as it seeks documents
related to claims handling which are not discoverable in a first party
cause of action. United Servs. Auto. Ass'n v. Kindl, 49 So. 3d 807, 808
(Fla. 5th DCA 2010); Seminole Cas. Ins. Co. v. Mastrominas, 6 So. 3d
1256, 1258 (Fla. 2d DCA 2009); State Farm Fire & Cas. Co. v. Valido,
662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Florida Ins. Co. v.
Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003). See Defendant’s Privilege
Log.
6. Any and all proof of loss forms, statements, notices of claim and/or any
other documents, submitted by the Plaintiff pertaining to its claims that are the subject of
this litigation.
Response: None is Defendant’s possession, custody, or control.
7. Any and all appraisals, estimates, or other documents pertaining to the
value of Plaintiff s claim.
Response: Security First Insurance Company objects to this Request
as the documents sought are shielded from discovery by the work
product doctrine and the attorney client privilege. Security First
Insurance Company objects to this Request as it seeks documents
related to claims handling which are not discoverable in a first party
cause of action. United Servs. Auto. Ass'n v. Kindl, 49 So. 3d 807, 808
(Fla. 5th DCA 2010); Seminole Cas. Ins. Co. v. Mastrominas, 6 So. 3d
1256, 1258 (Fla. 2d DCA 2009); State Farm Fire & Cas. Co. v. Valido,
662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Florida Ins. Co. v.
Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003). See Defendant’s Privilege
Log.
8. Any and all surveillance reports, claim history reports, or other investigative
reports prepared by you or on your behalf with regard to the Plaintiff or Plaintiffs claim.
Response: Security First Insurance Company objects to this Request
as the documents sought are shielded from discovery by the work
Page 4
COLE, SCOTT & KISSANE, P.A.
TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX
CASE NO.: 2017-CA-4797
product doctrine and the attorney client privilege. Security First
Insurance Company objects to this Request as it seeks documents
related to claims handling which are not discoverable in a first party
cause of action. United Servs. Auto. Ass'n v. Kindl, 49 So. 3d 807, 808
(Fla. 5th DCA 2010); Seminole Cas. Ins. Co. v. Mastrominas, 6 So. 3d
1256, 1258 (Fla. 2d DCA 2009); State Farm Fire & Cas. Co. v. Valido,
662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Florida Ins. Co. v.
Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003). See Defendant’s Privilege
Log.
9. Plaintiffs entire underwriting file with Defendant, along with any other
materials used by Defendant in determining the Plaintiffs insurable limit(s) of liability.
Response: Security First Insurance Company objects to this Request
as the documents sought are shielded from discovery by the work
product doctrine and the attorney client privilege. Security First
Insurance Company objects to this Request as it seeks documents
related to claims handling which are not discoverable in a first party
cause of action. United Servs. Auto. Ass'n v. Kindl, 49 So. 3d 807, 808
(Fla. 5th DCA 2010); Seminole Cas. Ins. Co. v. Mastrominas, 6 So. 3d
1256, 1258 (Fla. 2d DCA 2009); State Farm Fire & Cas. Co. v. Valido,
662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Florida Ins. Co. v.
Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003). See Defendant’s Privilege
Log and Policy, which speak for themselves.
10. Defendant’s underwriting guidelines in effect when issuing the subject
policy of insurance to Plaintiff. All underwriting guidelines in effect from date of issuance
of the policy through the date.
Response: Security First Insurance Company objects to this Request
as the documents sought are shielded from discovery by the work
product doctrine and the attorney client privilege. Security First
Insurance Company objects to this Request as it seeks documents
related to claims handling which are not discoverable in a first party
cause of action. United Servs. Auto. Ass'n v. Kindl, 49 So. 3d 807, 808
(Fla. 5th DCA 2010); Seminole Cas. Ins. Co. v. Mastrominas, 6 So. 3d
1256, 1258 (Fla. 2d DCA 2009); State Farm Fire & Cas. Co. v. Valido,
662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Florida Ins. Co. v.
Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003). See Defendant’s Privilege
Log.
Page 5
COLE, SCOTT & KISSANE, P.A.
TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX
CASE NO.: 2017-CA-4797
11. All underwriting guidelines in effect from date of issuance of the policy
through the date [sic]
Response: Security First Insurance Company objects to this Request
as the documents sought are shielded from discovery by the work
product doctrine and the attorney client privilege. Security First
Insurance Company objects to this Request as it seeks documents
related to claims handling which are not discoverable in a first party
cause of action. United Servs. Auto. Ass'n v. Kindl, 49 So. 3d 807, 808
(Fla. 5th DCA 2010); Seminole Cas. Ins. Co. v. Mastrominas, 6 So. 3d
1256, 1258 (Fla. 2d DCA 2009); State Farm Fire & Cas. Co. v. Valido,
662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Florida Ins. Co. v.
Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003). See Defendant’s Privilege
Log.
[CERTIFICATE OF SERVICE ON FOLLOWING PAGE]
Page 6
COLE, SCOTT & KISSANE, P.A.
TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX
CASE NO.: 2017-CA-4797
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 24th day of July, 2017, a true and correct copy of
the foregoing was filed with the Clerk of Orange County by using the Florida Courts e-
Filing Portal, which will send an automatic e-mail message to the following parties
registered with the e-Filing Portal system: E. Terrell Matthews, Esq., Rogatinsky &
Matthews, P.A., 3113 Stirling Road, Suite 103, Fort Lauderdale, FL 33312,
rogatinskyfirm@gmail.com.
COLE, SCOTT & KISSANE, P.A.
Counsel for Defendant
Tower Place, Suite 400
1900 Summit Tower Boulevard
Orlando, Florida 32810
Telephone (407) 775-3517
Facsimile (321) 972-0099
Primary e-mail: bartley.vickers@csklegal.com
Secondary e-mail: randy.bock@csklegal.com
Tertiary e-mail:
kristina.moorhead@csklegal.com
By: s/ Randy A. Bock
BARTLEY G. VICKERS
Florida Bar No.: 27187
RANDY A. BOCK
Florida Bar No.: 89773
0504.0587-00/6896000
Page 7
COLE, SCOTT & KISSANE, P.A.
TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX
Preview
Filing # 59444835 E-Filed 07/24/2017 10:19:08 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CASE NO.: 2017-CA-4797 ILER DALEGRAND & CHRISTINE DALEGRAND, Plaintiffs, v. SECURITY FIRST INSURANCE COMPANY, Defendant. _______________________________/ DEFENDANT’S RESPONSE TO PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION TO DEFENDANT COMES NOW, Defendant, SECURITY FIRST INSURANCE COMPANY (“SFIC”), by and through undersigned counsel and pursuant to Florida Rule of Civil Procedure 1.350, hereby responds to Plaintiffs’ First Request for Production to Defendant, and states as follows: GENERAL OBJECTIONS 1. SFIC objects to the production of any and all documents to the extent Plaintiffs’ requests contravene the attorney-client privilege, the work-product doctrine, the Florida Rules of Civil Procedure, or any other applicable privilege, doctrine, or rule. 2. SFIC objects to the production of any and all documents to the extent Plaintiffs’ requests are overbroad, unduly burdensome, or oppressive. Page 1 COLE, SCOTT & KISSANE, P.A. TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX CASE NO.: 2017-CA-4797 3. SFIC objects to the production of any and all documents to the extent the documents sought are neither relevant nor calculated to lead to the discovery of SFIC objects to the production of any and all documents to the extent the documents sought are not within the possession, custody, or control of SFIC or its agents. 5. SFIC does not waive its right to object to the relevancy, authenticity, competency, or admissibility of any documents which have been or will be produced in response to any request in Plaintiffs’ Request to Produce. 6. SFIC reserves the right to supplement these responses as appropriate. 7. SFIC objects to Plaintiffs’ “Instructions” (regarding descriptions of privileged documents) as overbroad and unduly burdensome. SFIC will provide a Privilege Log, describing items determined to be otherwise discoverable, that complies with Rule 1.280(b)(6) of the Florida Rules of Civil Procedure and applicable case law, describing “the nature of the documents, communications, or things not produced or disclosed in a manner that, without revealing information itself privileged or protected, will enable other parties to assess the applicability of the privilege or protection.” 8. SFIC objects to the discovery of any information to the extent that it seeks confidential and private information regarding individuals who are not parties to this lawsuit. RESPONSES TO PLAINTIFFS’ REQUEST FOR PRODUCTION 1. Any and all insurance policies ever issued by the Defendant to the Plaintiff, including all declaration pages, applications, addenda and riders. Response: Security First Insurance Company objects to this Request as the documents sought are shielded from discovery by the work Page 2 COLE, SCOTT & KISSANE, P.A. TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX CASE NO.: 2017-CA-4797 product doctrine. Security First Insurance Company objects to this Request as it seeks documents related to claims handling which are not discoverable in a first party cause of action. United Servs. Auto. Ass'n v. Kindl, 49 So. 3d 807, 808 (Fla. 5th DCA 2010); Seminole Cas. Ins. Co. v. Mastrominas, 6 So. 3d 1256, 1258 (Fla. 2d DCA 2009); State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Florida Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003). Notwithstanding this objection, Defendant is producing a certified copy of the Policy, declarations, endorsement details, notices, and checklist of coverages. 2. Any and all correspondence between you and Plaintiff or anyone acting on the Plaintiffs behalf. Response: Defendant is producing Letter dated December 28, 2016; Letter dated January 2, 2017 3. Any and all written or recorded statements of the Plaintiff, its agents, and/or representatives. Response: Defendant is producing a recorded statement of Mr. Chris Dalegrand, taken on December 30, 2016. 4. Any and all statements taken by the Defendant of any witness with regards to any fact Any and all photographs and/or video of the Plaintiffs property and/or its contents. Response: Security First Insurance Company objects to this Request as the documents sought are shielded from discovery by the work product doctrine. Security First Insurance Company objects to this Request as it seeks documents related to claims handling which are not discoverable in a first party cause of action. United Servs. Auto. Ass'n v. Kindl, 49 So. 3d 807, 808 (Fla. 5th DCA 2010); Seminole Cas. Ins. Co. v. Mastrominas, 6 So. 3d 1256, 1258 (Fla. 2d DCA 2009); State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Florida Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003). Notwithstanding this objection, see Response to #3. 5. Any and all photographs and/or video of the Plaintiff’s property and/or its Page 3 COLE, SCOTT & KISSANE, P.A. TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX CASE NO.: 2017-CA-4797 contents. Response: Security First Insurance Company objects to this Request as the documents sought are shielded from discovery by the work product doctrine and the attorney client privilege. Security First Insurance Company objects to this Request as it seeks documents related to claims handling which are not discoverable in a first party cause of action. United Servs. Auto. Ass'n v. Kindl, 49 So. 3d 807, 808 (Fla. 5th DCA 2010); Seminole Cas. Ins. Co. v. Mastrominas, 6 So. 3d 1256, 1258 (Fla. 2d DCA 2009); State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Florida Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003). See Defendant’s Privilege Log. 6. Any and all proof of loss forms, statements, notices of claim and/or any other documents, submitted by the Plaintiff pertaining to its claims that are the subject of this litigation. Response: None is Defendant’s possession, custody, or control. 7. Any and all appraisals, estimates, or other documents pertaining to the value of Plaintiff s claim. Response: Security First Insurance Company objects to this Request as the documents sought are shielded from discovery by the work product doctrine and the attorney client privilege. Security First Insurance Company objects to this Request as it seeks documents related to claims handling which are not discoverable in a first party cause of action. United Servs. Auto. Ass'n v. Kindl, 49 So. 3d 807, 808 (Fla. 5th DCA 2010); Seminole Cas. Ins. Co. v. Mastrominas, 6 So. 3d 1256, 1258 (Fla. 2d DCA 2009); State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Florida Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003). See Defendant’s Privilege Log. 8. Any and all surveillance reports, claim history reports, or other investigative reports prepared by you or on your behalf with regard to the Plaintiff or Plaintiffs claim. Response: Security First Insurance Company objects to this Request as the documents sought are shielded from discovery by the work Page 4 COLE, SCOTT & KISSANE, P.A. TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX CASE NO.: 2017-CA-4797 product doctrine and the attorney client privilege. Security First Insurance Company objects to this Request as it seeks documents related to claims handling which are not discoverable in a first party cause of action. United Servs. Auto. Ass'n v. Kindl, 49 So. 3d 807, 808 (Fla. 5th DCA 2010); Seminole Cas. Ins. Co. v. Mastrominas, 6 So. 3d 1256, 1258 (Fla. 2d DCA 2009); State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Florida Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003). See Defendant’s Privilege Log. 9. Plaintiffs entire underwriting file with Defendant, along with any other materials used by Defendant in determining the Plaintiffs insurable limit(s) of liability. Response: Security First Insurance Company objects to this Request as the documents sought are shielded from discovery by the work product doctrine and the attorney client privilege. Security First Insurance Company objects to this Request as it seeks documents related to claims handling which are not discoverable in a first party cause of action. United Servs. Auto. Ass'n v. Kindl, 49 So. 3d 807, 808 (Fla. 5th DCA 2010); Seminole Cas. Ins. Co. v. Mastrominas, 6 So. 3d 1256, 1258 (Fla. 2d DCA 2009); State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Florida Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003). See Defendant’s Privilege Log and Policy, which speak for themselves. 10. Defendant’s underwriting guidelines in effect when issuing the subject policy of insurance to Plaintiff. All underwriting guidelines in effect from date of issuance of the policy through the date. Response: Security First Insurance Company objects to this Request as the documents sought are shielded from discovery by the work product doctrine and the attorney client privilege. Security First Insurance Company objects to this Request as it seeks documents related to claims handling which are not discoverable in a first party cause of action. United Servs. Auto. Ass'n v. Kindl, 49 So. 3d 807, 808 (Fla. 5th DCA 2010); Seminole Cas. Ins. Co. v. Mastrominas, 6 So. 3d 1256, 1258 (Fla. 2d DCA 2009); State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Florida Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003). See Defendant’s Privilege Log. Page 5 COLE, SCOTT & KISSANE, P.A. TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX CASE NO.: 2017-CA-4797 11. All underwriting guidelines in effect from date of issuance of the policy through the date [sic] Response: Security First Insurance Company objects to this Request as the documents sought are shielded from discovery by the work product doctrine and the attorney client privilege. Security First Insurance Company objects to this Request as it seeks documents related to claims handling which are not discoverable in a first party cause of action. United Servs. Auto. Ass'n v. Kindl, 49 So. 3d 807, 808 (Fla. 5th DCA 2010); Seminole Cas. Ins. Co. v. Mastrominas, 6 So. 3d 1256, 1258 (Fla. 2d DCA 2009); State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Florida Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003). See Defendant’s Privilege Log. [CERTIFICATE OF SERVICE ON FOLLOWING PAGE] Page 6 COLE, SCOTT & KISSANE, P.A. TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX CASE NO.: 2017-CA-4797 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 24th day of July, 2017, a true and correct copy of the foregoing was filed with the Clerk of Orange County by using the Florida Courts e- Filing Portal, which will send an automatic e-mail message to the following parties registered with the e-Filing Portal system: E. Terrell Matthews, Esq., Rogatinsky & Matthews, P.A., 3113 Stirling Road, Suite 103, Fort Lauderdale, FL 33312, rogatinskyfirm@gmail.com. COLE, SCOTT & KISSANE, P.A. Counsel for Defendant Tower Place, Suite 400 1900 Summit Tower Boulevard Orlando, Florida 32810 Telephone (407) 775-3517 Facsimile (321) 972-0099 Primary e-mail: bartley.vickers@csklegal.com Secondary e-mail: randy.bock@csklegal.com Tertiary e-mail: kristina.moorhead@csklegal.com By: s/ Randy A. Bock BARTLEY G. VICKERS Florida Bar No.: 27187 RANDY A. BOCK Florida Bar No.: 89773 0504.0587-00/6896000 Page 7 COLE, SCOTT & KISSANE, P.A. TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX