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Filing # 64000476 E-Filed 11/09/2017 01:53:49 PM
IN THE CIRCUIT COURT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
LISE BAPTISTE, CASE NO.: 2017-14299 CA 01
Plaintiff(s),
vs.
CITIZENS PROPERTY
INSURANCE CORPORATION,
Defendant.
/
DEFENDANT’S MOTION TO COMPEL
PLAINTIFF’S RESPONSES TO DISCOVERY
COMES NOW the Defendant, CITIZENS PROPERTY INSURANCE CORPORATION,
by and through the undersigned counsel, and hereby moves this Honorable Court to enter an Order
compelling the Plaintiff, Lise Baptiste, to respond to Defendant’s discovery requests propounded
upon Plaintiff on August 23, 2017, and as grounds therefore states as follows:
1, Defendant served its First Request for Production and First set of Interrogatories
upon Plaintiff on August 23, 2017.
2. Plaintiff's responses to Defendant’s discovery requests were due on or about the
September 22, 2017.
3. On September28, 2018, Defendant forwarded a good faith letter attempting to resolve
this matter. See good faith letter attached as exhibit “A”.
4. As of the filing of this Motion, the Plaintiff has failed to respond to Defendant’s
discovery requests although they seek relevant, material information on issuesraised by the pleadings; are reasonably calculated to lead to the discovery of
admissible evidence; and are in complete conformity with the applicable rules.
5. As Plaintiff has failed to respond to Defendant’s amicable attempt to resolve this
matter, any objections Plaintiff may have had to the aforementioned discovery
have been waived.
WHEREFORE, Defendant moves this Honorable Court to enter an Order compelling the
Plaintiff to respond to Defendant’s Request for Production and Notice of Serving Interrogatories,
and grant any other relief this Court deems just and proper.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was e-mailed this
9" day of November, 2017 to all counsel on the attached service list.
Kubicki Draper, PA
25 West Flagler Street, Penthouse
Miami, Florida 33130
Direct Line: (305) 982-6735
CW-KD@Kubickidraper.com
SRG@kubickidraper.com
BY:_/s/ Sarah R. Goldberg
SARAH R. GOLDBERG, ESQ.
Florida Bar No. 92085SERVICE LIST
Peter Mineo, Esq.
The Mineo Salcedo Law Firm, P.A.
5400 S. University Drive, Suite 502
Davie, Florida 3328
pjmineo@mineolaw.comExhibit ALAW OFFICES
KUBICKI 25 West Flagler Street, Penthouse ¢ Miami, Florida 33130
(305) 374-1212 © (305) 374-7846 Fax
Miami ¢ Key Wesc ¢ Ft. Lauderdale * West Palm Beach * Ft. Myers ¢ Naples * Tampa
Orlando * Ocala ¢ Jacksonville * Tallahassee * Pensacola
Founded 1963 www.kubickidraper.com
Direct Line: 305-982-6735
Direct Email: srg@kubickidraper.com
September 28, 2017
VIA EMAIL
Peter Mineo, Esq.
The Mineo Salcedo Law Firm, P.A.
5400 S. University Drive, Suite 502
Davie, Florida 3328
Pjmineo@mineolaw.com
Re: Lise Baptiste #2 v. Citizens
Claim No.: 001-00-084680
Our File No.: 092808
Dear Mr. Mineo,
This letter is to bring to your attention that we have not received Plaintiff’ s responses
to Defendant’s initial Request for Production and Interrogatories dated August 23, 2017,
which were due on September 22, 2017.
Please provide the responses to said outstanding discovery to our office within the
next three (3) days to avoid the necessity of filing any future Motion to Compel with the
Court.
If, by chance, these documents have already been forwarded to our attention, please
contact me immediately so that I may properly document our file.
If you should have any questions, please do not hesitate to contact the undersigned.
Sincerely,
* z
Sarah R. Goldberg,
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Filing # 64000476 E-Filed 11/09/2017 01:53:49 PM IN THE CIRCUIT COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA LISE BAPTISTE, CASE NO.: 2017-14299 CA 01 Plaintiff(s), vs. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. / DEFENDANT’S MOTION TO COMPEL PLAINTIFF’S RESPONSES TO DISCOVERY COMES NOW the Defendant, CITIZENS PROPERTY INSURANCE CORPORATION, by and through the undersigned counsel, and hereby moves this Honorable Court to enter an Order compelling the Plaintiff, Lise Baptiste, to respond to Defendant’s discovery requests propounded upon Plaintiff on August 23, 2017, and as grounds therefore states as follows: 1, Defendant served its First Request for Production and First set of Interrogatories upon Plaintiff on August 23, 2017. 2. Plaintiff's responses to Defendant’s discovery requests were due on or about the September 22, 2017. 3. On September28, 2018, Defendant forwarded a good faith letter attempting to resolve this matter. See good faith letter attached as exhibit “A”. 4. As of the filing of this Motion, the Plaintiff has failed to respond to Defendant’s discovery requests although they seek relevant, material information on issuesraised by the pleadings; are reasonably calculated to lead to the discovery of admissible evidence; and are in complete conformity with the applicable rules. 5. As Plaintiff has failed to respond to Defendant’s amicable attempt to resolve this matter, any objections Plaintiff may have had to the aforementioned discovery have been waived. WHEREFORE, Defendant moves this Honorable Court to enter an Order compelling the Plaintiff to respond to Defendant’s Request for Production and Notice of Serving Interrogatories, and grant any other relief this Court deems just and proper. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was e-mailed this 9" day of November, 2017 to all counsel on the attached service list. Kubicki Draper, PA 25 West Flagler Street, Penthouse Miami, Florida 33130 Direct Line: (305) 982-6735 CW-KD@Kubickidraper.com SRG@kubickidraper.com BY:_/s/ Sarah R. Goldberg SARAH R. GOLDBERG, ESQ. Florida Bar No. 92085SERVICE LIST Peter Mineo, Esq. The Mineo Salcedo Law Firm, P.A. 5400 S. University Drive, Suite 502 Davie, Florida 3328 pjmineo@mineolaw.comExhibit ALAW OFFICES KUBICKI 25 West Flagler Street, Penthouse ¢ Miami, Florida 33130 (305) 374-1212 © (305) 374-7846 Fax Miami ¢ Key Wesc ¢ Ft. Lauderdale * West Palm Beach * Ft. Myers ¢ Naples * Tampa Orlando * Ocala ¢ Jacksonville * Tallahassee * Pensacola Founded 1963 www.kubickidraper.com Direct Line: 305-982-6735 Direct Email: srg@kubickidraper.com September 28, 2017 VIA EMAIL Peter Mineo, Esq. The Mineo Salcedo Law Firm, P.A. 5400 S. University Drive, Suite 502 Davie, Florida 3328 Pjmineo@mineolaw.com Re: Lise Baptiste #2 v. Citizens Claim No.: 001-00-084680 Our File No.: 092808 Dear Mr. Mineo, This letter is to bring to your attention that we have not received Plaintiff’ s responses to Defendant’s initial Request for Production and Interrogatories dated August 23, 2017, which were due on September 22, 2017. Please provide the responses to said outstanding discovery to our office within the next three (3) days to avoid the necessity of filing any future Motion to Compel with the Court. If, by chance, these documents have already been forwarded to our attention, please contact me immediately so that I may properly document our file. If you should have any questions, please do not hesitate to contact the undersigned. Sincerely, * z Sarah R. Goldberg,