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Filing # 93085573 E-Filed 07/24/2019 02:27:05 PM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL ACTION
IRIS BEAUGRAND, individually and as
POA for Heidrun Riedner,
Plaintiff,
v. CASE NO: 2017 CA 181
ROBERT O’TOOLE,
Defendant.
/
PLAINTIFF’S THIRD REQUEST FOR
PRODUCTION OF DOCUMENTS TO DEFENDANT.
Defendant, ROBERT O’TOOLE, by and through his undersigned counsel and pursuant to
Fla. R. Civ. P. 1.350, requests Plaintiff to produce for inspection and copying on or before thirty
(30) days after service of this Request upon it, at the Law offices of Steele T. Williams, P.A., 1381
McAnsh Square, Sarasota, Florida 34236, all documents in the possession, custody and control of
the Plaintiff, or otherwise available to Plaintiff, which are responsive to the Request contained in the
numbered paragraphs below.
INSTRUCTIONS AND DEFINITIONS
1, If any document herein requested was formerly in the possession, custody or control of
Plaintiff and has been lost or destroyed, Plaintiff is requested to submit in lieu of each document a
written statement which:
a. Describes in detail the nature of the document and its contents;
b. Identifies the person who prepared or authored the document and, if
applicable, the person to whom the document was sent;
c. Specifies the date on which the document was prepared or transmitted or both;
d. Specifies, if possible, the date on which the document was lost or destroyed,and if destroyed, the conditions of or reasons for such destruction and the person requesting and
performing the destruction.
If any documents otherwise required to be produced by this Request are withheld,
Plaintiff shall identify the document by stating its date, author, recipients and the reasons for
withholding.
2) Asused herein, the following words shall be held to have the following meaning:
i) “Document” shall mean any written or graphic matter or other means of
preserving thought or expressions and all tangible things from which information can be processed
or transcribed, including the originals and all non-identified copies, whether different from the
original by reason of any notation made on such copy or otherwise, including, but not limited to,
correspondence, memoranda, notes, messages, letters, telegrams, teletypes, telefax, bulletins,
meetings or other communications, inter-office and intra-office telephone calls, diaries,
chronological date, minutes, books, reports, studies, summaries, pamphlets, bulletins, printed
matter, charts, invoices, work sheets, receipts, returns, computer print-outs, prospectuses, financial
statements, schedules, affidavits, contracts, security agreements, financing statements, Promissory
Notes, Mortgages, canceled checks, statements, transcripts, statistics, surveys, magazine or
newspaper articles, releases (and any and all drafts, alterations and modifications, changes and
amendments of any of the foregoing), graphic or other oral records or representations of any kind
(including without limitation photographs, microfiche, microfilm, video tape, records and motion
pictures), and electronic, mechanical or electric records or representations of any kind (including
without limitation tapes, cassettes, discs and records).
2|Pa
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«DOCUMENTS REQUESTED
1. All documents which you contend support any of your affirmative defenses in this matter.
2. All documents which you contend support any of your causes of action asserted in your
counterclaim in this matter.
3. All documents pertaining to your maintenance or costs associated with 808 East 1°‘ Street,
Englewood, FL 34223.
4, All copies of any anti-fraud provisions of duly promulgated regulations of the Federal Housing
Finance Agency (FHFA) and 12 U.S.C. Section 4642 you rely on in this matter.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been sent
via Email to Bret Clark, Esq. attorney for Robert O’Toole on this 24" day of July, 2019.
Steele T. Williams, P.A.
Pineapple Place
1381 McAnsh Square
Sarasota, FL 34236-5620
Ph: (941)378-1800
Email: Steele TWilliams@comeast.net
Website: SteeleWilliams.com
/s/ Steele T. Williams
FBN: 079995
3|Page
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Filing # 93085573 E-Filed 07/24/2019 02:27:05 PM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL ACTION IRIS BEAUGRAND, individually and as POA for Heidrun Riedner, Plaintiff, v. CASE NO: 2017 CA 181 ROBERT O’TOOLE, Defendant. / PLAINTIFF’S THIRD REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT. Defendant, ROBERT O’TOOLE, by and through his undersigned counsel and pursuant to Fla. R. Civ. P. 1.350, requests Plaintiff to produce for inspection and copying on or before thirty (30) days after service of this Request upon it, at the Law offices of Steele T. Williams, P.A., 1381 McAnsh Square, Sarasota, Florida 34236, all documents in the possession, custody and control of the Plaintiff, or otherwise available to Plaintiff, which are responsive to the Request contained in the numbered paragraphs below. INSTRUCTIONS AND DEFINITIONS 1, If any document herein requested was formerly in the possession, custody or control of Plaintiff and has been lost or destroyed, Plaintiff is requested to submit in lieu of each document a written statement which: a. Describes in detail the nature of the document and its contents; b. Identifies the person who prepared or authored the document and, if applicable, the person to whom the document was sent; c. Specifies the date on which the document was prepared or transmitted or both; d. Specifies, if possible, the date on which the document was lost or destroyed,and if destroyed, the conditions of or reasons for such destruction and the person requesting and performing the destruction. If any documents otherwise required to be produced by this Request are withheld, Plaintiff shall identify the document by stating its date, author, recipients and the reasons for withholding. 2) Asused herein, the following words shall be held to have the following meaning: i) “Document” shall mean any written or graphic matter or other means of preserving thought or expressions and all tangible things from which information can be processed or transcribed, including the originals and all non-identified copies, whether different from the original by reason of any notation made on such copy or otherwise, including, but not limited to, correspondence, memoranda, notes, messages, letters, telegrams, teletypes, telefax, bulletins, meetings or other communications, inter-office and intra-office telephone calls, diaries, chronological date, minutes, books, reports, studies, summaries, pamphlets, bulletins, printed matter, charts, invoices, work sheets, receipts, returns, computer print-outs, prospectuses, financial statements, schedules, affidavits, contracts, security agreements, financing statements, Promissory Notes, Mortgages, canceled checks, statements, transcripts, statistics, surveys, magazine or newspaper articles, releases (and any and all drafts, alterations and modifications, changes and amendments of any of the foregoing), graphic or other oral records or representations of any kind (including without limitation photographs, microfiche, microfilm, video tape, records and motion pictures), and electronic, mechanical or electric records or representations of any kind (including without limitation tapes, cassettes, discs and records). 2|Pa oe «DOCUMENTS REQUESTED 1. All documents which you contend support any of your affirmative defenses in this matter. 2. All documents which you contend support any of your causes of action asserted in your counterclaim in this matter. 3. All documents pertaining to your maintenance or costs associated with 808 East 1°‘ Street, Englewood, FL 34223. 4, All copies of any anti-fraud provisions of duly promulgated regulations of the Federal Housing Finance Agency (FHFA) and 12 U.S.C. Section 4642 you rely on in this matter. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been sent via Email to Bret Clark, Esq. attorney for Robert O’Toole on this 24" day of July, 2019. Steele T. Williams, P.A. Pineapple Place 1381 McAnsh Square Sarasota, FL 34236-5620 Ph: (941)378-1800 Email: Steele TWilliams@comeast.net Website: SteeleWilliams.com /s/ Steele T. Williams FBN: 079995 3|Page