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Filing # 126480406 E-Filed 05/10/2021 01:18:38 PM
IN THE CIRCUIT COURT OF THE 9™ JUDICIAL
CIRCUIT IN AND FOR OSCEOLA COUNTY,
FLORIDA
CASE NO.: 2020-CA-002942-ON
VILLAS AT EMERALD LAKE
HOMEONWERS ASSOCIATION, INC., a
Florida not for profit corporation,
Plaintiff,
Vv.
ROYAL OAK HOMES, LLC, a Florida
limited liability company; ADVANCED
WRAPPING AND CONCRETE
SOLUTIONS OF CENTRAL FLORIDA,
INC., a Florida corporation; DON KING’S
CONCRETE, INC., a Florida corporation;
HUGH MACDONALD
CONSTRUCTION, INC., a Florida
corporation; IMPERIAL BUILDING
CORPORATION, a Florida corporation;
PREMIER PLASTERING OF CENTRAL
FLORIDA, INC. n/k/a TGK STUCCO,
INC., a Florida corporation;
WEATHERMASTER BUILDING
PRODUCTS, INC., a Florida corporation;
WEINTRAUB INSPECTIONS &
FORENSICS, INC. n/k/a WEINTRAUB
ENGINEERING AND INSPECTIONS,
INC, a Florida corporation; THE
DIMILLO GROUP, LLC, a Florida limited
liability company; WOLF’S IRRIGATION
& LANDSCAPING, INC., A Florida
corporation; SUMMERPARK HOMES,
INC., a Florida corporation; BROWN +
COMPANY ARCHITECTURE, INC., a
Florida corporation;
Defendant.
ROYAL OAK HOMES, LLC, a Florida
limited liability company;Crossclaim Plaintiff,
Vv.
ADVANCED WRAPPING AND
CONCRETE SOLUTION OF CENTRAL
FLORIDA, INC., a Florida corporation;
DON KING’S CONCRETE, INC., a Florida
corporation; HUGH MACDONALD
CONSTRUCTION, INC., a Florida
corporation; IMPERIAL BUILDING
CORPORATION, a Florida corporation;
PREMIER PLASTERING OF CENTRAL
FLORIDA, INC. n/k/a TGK STUCCO,
INC., a Florida corporation;
WEATHERMASTER BUILDING
PRODUCTS, INC., a Florida corporation;
WEINTRAUB INSPECTIONS &
FORENSICS, INC. n/k/a WEINTRAUB
ENGINEERING AND INSPECTIONS,
INC., a Florida corporation; WOLF'S
IRRIGATION & LANDSCAPING, INC., a
Florida corporation, BROWN+ COMPANY
ARCHITECTURE, INC., a Florida
corporation;
Crossclaim Defendants.
BROWN+COMPANY ARCHITECTURE, INC."S RESPONSES TO_
PLAINTIFF’S FIRST REQUEST FOR PRODUCTION
Pursuant to the VILLAS AT EMERALD LAKE HOMEONWERS ASSOCIATION,
INC.’s (the “Association”) First Request for Production, Defendant BROWN + COMPANY
ARCHITECTURE, INC. (“Brown”) hereby serves its response to the Association’s First
Request for Production and states as follows:
GENERAL OBJECTIONS:
By producing the documents requested, Brown does not: (a) admit that those
documents (or related documents) are properly discoverable; (b) waive any objections theymight otherwise make to the production or introduction at trial of such documents; or (c)
admit that the documents are admissible at trial.
The process of discovery is ongoing, and Brown reserves the right to supplement,
amend, or correct all or any part of the response provided here.
DOCUMENTS TO BE PRODUCED
1, Any and all documents that refer or relate to the Project, including, without
limitation, any document generated, transmitted, received or maintained by you that refers to the
development, design, construction, management, ownership, conversion, repair, marketing, and
sale of the Project and/or the individual townhouse units contained in the Project.
RESPONSE: Objection. Brown objects to this Request as vague and overly broad.
Specifically, Brown objects to the Phrases “Any and all documents” and “refer or
relate to the Project” as vague, insufficiently specific, and too expansive to allow
Brown to reasonably identify documents that may be responsive to this request.
Brown further objects to this Request to the extent that it seeks documents or
information protected from disclosure by the attorney client privilege and
attorney work product doctrines. Subject to and without waiving the objections, to
the extent that Brown is in possession of any responsive documents, Brown will
produce same in accordance with the April 9, 2021 Court Order 4¥ 3.1 & 3.3.
2. Any and all documents that constitute, refer, or relate to communications about the
Subject Property to or from any owner, officer, director, member, manager, employee, agent or
representative of any of the following:
a. ROYAL OAK HOMES, LLC
b. ADVANCED WRAPPING AND CONCRETE SOLUTIONS OF CENTRAL
FLORIDA, INC.
c. DON KING’S CONCRETE, INC.
d. HUGH MACDONALD CONSTRUCTION, INC.
e. IMPERIAL BUILDING CORPORATION
f. PREMIER PLASTERING OF CENTRAL FLORIDA, INC. n/k/a TGK STUCCO,
INC.
g. WEATHERMASTER BUILDING PRODUCTS, INC.h. WEINTRAUB INSPECTIONS & FORENSICS, INC. n/k/a WEINTRAUB
ENGINEERING & INSPECTIONS, INC.
i. THE DIMILLO GROUP, LLC
j.. WOLF’S IRRIGATION & LANDSCAPING, INC.
k. SUMMERPARK HOMES, INC.
RESPONSE: Objection to Request 2, and all its subparts as vague and overly broad.
Specifically, Brown objects to the Phrases “Any and all documents” and “refer or
relate to communications about the Subject Property” as extremely vague,
insufficiently specific, not defined, and too expansive to allow Brown to reasonably
identify documents that may be responsive to this request. Brown further objects
to this Request to the extent that it seeks documents or information protected from
disclosure by the attorney client privilege and attorney work product doctrines.
Subject to and without waiving the objections, to the extent that Brown is in
possession of any responsive documents, Brown will produce same in accordance
with the April 9, 2021 Court Order ¥[{ 3.1 & 3.3.
3. All contracts or modifications to contracts related to the design of the Project.
RESPONSE: Objection. Brown objects to this Request as vague and overly broad.
Specifically, Brown objects to the Phrases “All contracts or modifications to
contracts” and “related to the design and construction of the Project” as extremely
vague, insufficiently specific, and too expansive to allow Brown to reasonably
identify documents that may be responsive to this request. Brown was a design
professional as to this Project only and would have only had copies of its own
contracts and modifications, not “All contracts and modifications”. Brown further
objects to this Request to the extent that it seeks documents or information
protected from disclosure by the attorney client privilege and attorney work
product doctrines. Subject to and without waiving the objections, to the extent that
Brown is in possession of any responsive documents, Brown will produce same in
accordance with the April 9, 2021 Court Order {[f 3.1 & 3.3.
4. All notices of commencement permit applications, permits, County inspection
records, and certificates of occupancy.
RESPONSE: To the extent Brown is in possession of any relevant, non-privileged
and non-confidential documents, responsive to this request, Brown will produce
same in accordance with the April 9, 2021 Court Order § 3.1 & 3.3.
5. All documents signed by a public entity relating to the Project including, but not
limited to, inspection reports, and permit requirement documents.
RESPONSE: Objection. Brown objects to this Request as vague, overbroad, andunduly burdensome as the Request is not limited in time or scope of the claims alleged
in this litigation. Additionally, the phrase “public entity” is insufficiently specific and
too expansive to allow Brown to reasonably identify “All documents” that may be
responsive to this request. Brown also objects to the extent that this Request seeks
documents protected from disclosure by the attorney-client privilege and the work
product doctrine. Subject to and without waiving the objections, to the Brown is in
possession of any responsive documents, Brown will produce same in accordance
with the April 9, 2021 Court Order ¥[{ 3.1 & 3.3.
6. All plans (including permit plans, construction plans, and as-built plans),
specifications, or other such documents related to the design of the Project.
RESPONSE: Objection. Brown objects to this Request as vague and overly broad.
Specifically, Brown objects to the phrase “or other such documents related to the
design of the Project” as extremely vague, and too expansive to allow Brown to
reasonably identify documents that may be responsive to this request. Brown
further objects to this Request to the extent that it seeks documents or information
protected from disclosure by the attorney client privilege and attorney work
product doctrines. Subject to and without waiving the objections, to the extent that
Brown is in possession of any responsive documents, Brown will produce same in
accordance with the April 9, 2021 Court Order f 3.1 & 3.3.
7. All documents in your possession, custody, or control relating to payment for the
design or construction of the Project.
RESPONSE: Objection. Brown objects to this Request as vague, overbroad, and
unduly burdensome as the Request is not limited in time or scope. Additionally,
the phrase “relating to payment” is insufficiently specific and too expansive to
allow Brown to reasonably identify “All documents” that may be responsive to this
request. Brown also objects to the extent that this Request seeks documents
protected from disclosure by the attorney-client privilege and the work product
doctrine. Subject to and without waiving the objections, to the extent Brown is in
possession of any responsive documents, Brown will produce same in accordance
with the April 9, 2021 Court Order [§ 3.1 & 3.3.
8. All documents relating to daily, weekly, or monthly progress reports or similar
reports memorializing the progress of the planning, design, or construction of the Project.
RESPONSE: To the extent Brown is in possession of any relevant, non-privileged
and non-confidential documents, Brown will produce same in accordance with the
April 9, 2021 Court Order 4 3.1 & 3.3.
9. All field memos, field reports, or other documents relating to the status of the
planning, design, or construction of the Project.
RESPONSE: To the extent Brown is in possession of any relevant, non-privileged
and non-confidential documents, Brown will produce same in accordance with theApril 9, 2021 Court Order [§ 3.1 & 3.3.
10. All job diaries, notes, meeting minutes, or other similar documents related to the
design or construction of the Project.
RESPONSE: To the extent Brown is in possession of any relevant, non-privileged
and non-confidential documents, Brown will produce same in accordance with the
April 9, 2021 Court Order (3.1 & 3.3.
11. All timecards, time sheets or any other similar documents evidencing or relating to
the amount of time spent by your or any other person’s personnel performing work on the Project,
including, but not limited to, employees, principals, agents, independent contractors, sub-
consultants, and sub-subconsultants, relating to construction, maintenance, or remediation of the
Project.
RESPONSE: To the extent Brown is in possession of any relevant, non-privileged
and non-confidential documents, Brown will produce same in accordance with the
April 9, 2021 Court Order [§ 3.1 & 3.3.
12. All schedules, timelines, bar charts, critical path method analyses and other
documents relating to construction, maintenance, or remediation of the Project.
RESPONSE: None.
13. All analyses, conclusions, recommendations, correspondence, notes, reviews,
reports, working papers or any other documents, internal or otherwise, relating to any person’s
requests for time extensions, requests for information, claims, or requests for compensation related
to the Project.
RESPONSE: Objection. Brown objects to this Request as overbroad as the
Request is not limited in time or scope. Additionally, this Request is insufficiently
specific and too expansive to allow Brown to reasonably identify “All analyses,
conclusions, recommendations, correspondence, notes, review, reports, working
papers...” that may be responsive to this request. Brown also objects to the extent
that this Request seeks documents protected from disclosure by the attorney-client
privilege and the work product doctrine. Subject to and without waiving the
objections, to the extent Brown is in possession of any responsive documents, Brown
will produce same in accordance with the April 9, 2021 Court Order 7§ 3.1 & 3.3.
14. All memoranda, correspondence or any other documents, internal or otherwise,
prepared by or for Association or any other person regarding any alleged failure relating to the
construction, maintenance, or remediation of the Project.
RESPONSE: Objection. Brown objects to this Request as vague and ambiguous.
Specifically, Brown objects to the use of the phrase “failure relating to”. The use
of ‘failure relating to’ is capable of multiple interpretation and is not defined by
the Association. Brown cannot reasonably identify responsive documents to this
Request given the ambiguity of the Request as written. Brown further objects tothis Request to the extent that it seeks documents or information protected from
disclosure by the attorney client privilege and attorney work product doctrines.
Subject to and without waiving the objections, to the extent that Brown is in
possession of any responsive documents, Brown will produce same in accordance
with the April 9, 2021 Court Order [§ 3.1 & 3.3.
15. All contracts, purchase orders and other agreements and amendments thereto
relating to the Project including, but not limited to, all subcontracts and/or agreements and change
orders thereto.
RESPONSE: To the extent that Brown is in possession of any relevant, non-
privileged and non-confidential responsive documents, Brown will produce same
in accordance with the April 9, 2021 Court Order 4 3.1 & 3.3.
16. All Requests for Information or other similar documents received or responded to
by Association from any person or entity.
RESPONSE: To the extent that Brown is in possession of any relevant, non-privileged
and non-confidential documents responsive documents, Brown will produce same in
accordance with the April 9, 2021 Court Order ¢§ 3.1 & 3.3.
17. All Change Orders relating to the Project.
RESPONSE: To the extent Brown is in possession of any relevant, non-privileged
and non-confidential documents, Brown will produce same in accordance with the
April 9, 2021 Court Order (3.1 & 3.3.
18. All submittals and transmittals relating to the Project.
RESPONSE: To the extent Brown is in possession of any relevant, non-privileged
and non-confidential documents, Brown will produce same in accordance with the
April 9, 2021 Court Order (ff 3.1 & 3.3.19. All laboratory and testing reports on materials or work associated with the design
or construction of the Project.
RESPONSE: To the extent Brown is in possession of any relevant, non-privileged
and non-confidential documents, Brown will produce same in accordance with the
April 9, 2021 Court Order 7 3.1 & 3.3.
20. — All documents evidencing any changes or alterations in the design of the Project.
RESPONSE: Objection. Brown objects to this Request as vague, overbroad, and
unduly burdensome as the Request is not limited in time or scope. Additionally, Brown
objects to the Request as ambiguous and vague. Specifically, the phrase “changes or
alterations” is capable of multiple interpretation and is not defined by the
Association. Brown also objects to the extent that this Request seeks documents
protected from disclosure by the attorney-client privilege and the work product
doctrine. Subject to and without waiving the objections, to the extent it is in possession
of any responsive documents, Brown will produce same in accordance with the April
9, 2021 Court Order (ff 3.1 & 3.3.
21. All shop drawings, material submittals or installation procedures prepared by or
obtained by Association relating to the Project.
RESPONSE: To the extent Brown is in possession of any relevant, non-privileged
and non-confidential documents, Brown will produce same in accordance with the
April 9, 2021 Court Order (§ 3.1 & 3.3.
22. All manufacturers’ or suppliers’ instructions, standards, guidelines, brochures,
representations, warranties or other documents relating to the Project.
RESPONSE: To the extent Brown is in possession of any relevant, non-privileged
and non-confidential documents, Brown will produce same in accordance with the
April 9, 2021 Court Order 4 3.1 & 3.3.
23. All documents related to the inspection or testing of the Project design or
construction by any person or entity.
RESPONSE: Objection. Brown objects to this Request as vague, overbroad, and
unduly burdensome as the Request is not limited in time or scope. Additionally,
Brown objects to the Request as ambiguous and vague. Specifically, the phrase
“inspection or testing” is capable of multiple interpretation and is not defined by
the Association. Brown also objects to the extent that this Request seeks documents
protected from disclosure by the attorney-client privilege and the work product
doctrine. Subject to and without waiving the objections, to the extent Brown is in
possession of any relevant, non-privileged and non-confidential documents,
Brown will produce same in accordance with the April 9, 2021 Court Order {| 3.1
& 3.3.24. Laser color copies of any photographs which are in any manner related to the
subject matter of this Action.
RESPONSE: Objection. Brown objects to this Request as vague, overbroad, and unduly
burdensome as the Request is not limited in time or scope. Additionally, Brown objects
to the Request as ambiguous and vague. Specifically, the phrase “subject matter” is
capable of multiple interpretation and is not defined by the Association.
Furthermore, Brown objects to this Request as it seeks irrelevant information, not
reasonably calculated to lead to the discovery of relevant or admissible evidence.
Brown also objects to the extent that this Request seeks documents protected from
disclosure by the attorney-client privilege and the work product doctrine. Finally,
Brown objects to the request seeking to compel Brown to create documents,
specifically, ‘laser color copies’.
25. All videotapes which are in any manner related to the subject matter of this Action.
RESPONSE: Objection. Brown objects to this Request as vague, overbroad, and
unduly burdensome as the Request is not limited in time or scope. Additionally, Brown
objects to the Request as ambiguous and vague. Specifically, the phrase “subject
matter” is capable of multiple interpretation and is not defined by the Association.
Furthermore, Brown objects to this Request as it seeks irrelevant information, not
reasonably calculated to lead to the discovery of relevant or admissible evidence.
Brown also objects to the extent that this Request seeks documents protected from
disclosure by the attorney-client privilege and the work product doctrine. Subject to
and without waiving the objections, to the extent Brown is in possession of any
relevant, non-privileged and non-confidential documents, Brown will produce
same in accordance with the April 9, 2021 Court Order 4 3.1 & 3.3.
26. All movie footage whether in electronic or physical form related to the Project.
RESPONSE: Objection. Brown objects to this Request as vague, overbroad, and
unduly burdensome as the Request is not limited in time or scope. Additionally,
Brown objects to this Request as it seeks irrelevant information, not reasonably
calculated to lead to the discovery of relevant or admissible evidence. Brown also
objects to the extent that this Request seeks documents protected from disclosure
by the attorney-client privilege and the work product doctrine.
27. All punch lists or other similar documents relating to the design or construction of
the Project.
RESPONSE: To the extent Brown is in possession of any relevant, non-privileged
and non-confidential documents, Brown will produce same in accordance with the
April 9, 2021 Court Order §§ 3.1 & 3.3.
28. All documents and correspondence between the Plaintiff and any other party to this
Action relating to the design or construction of the Project (this request excludes correspondenceor other documents exchanged between counsel for the Parties).
RESPONSE: Objection. Brown objects to this Request as vague and overly broad.
Specifically, Brown objects to the Phrases “All contracts or modifications to
contracts” and “related to the design and construction of the Project” as extremely
vague, insufficiently specific, and too expansive to allow Brown to reasonably
identify documents that may be responsive to this request. Brown was a design
professional as to this Project only and would have only had copies of its own
contracts and modifications, not “All contracts and modifications”. Brown further
objects to this Request to the extent that it seeks documents or information
protected from disclosure by the attorney client privilege and attorney work
product doctrines. Subject to and without waiving the objections, to the extent that
Brown is in possession of any relevant, non-privileged and non-confidential
documents, Brown will produce same in accordance with the April 9, 2021 Court
Order Ff 3.1 & 3.3.
29. All documents reflecting any communication between and any renters, tenants,
guests, lessee’s, or any persons who reside or resided at the Project, as further described in
Plaintiff's complaint and is at issue in this litigation.
RESPONSE: None.
30. All correspondence or other documents between any other person, party or entity
relating to any alleged defects in the design or construction of the Project.
RESPONSE: Objection. Brown objects to the extent that this Request seeks
confidential documents and communications protected from disclosure by the
attorney-client privilege and the work product doctrine.
31. All documents involving any evaluation, investigation, study, or analysis of alleged
defects in the design or construction of the Project.
RESPONSE: Objection. Brown objects to the extent that this Request seeks
confidential documents protected from disclosure by the attorney-client privilege and
the work product doctrine.
32. All documents, correspondence or tangible materials in your possession, custody,
or control relating in any way to any defects and deficiencies being alleged to exist at the Project
in this Action.
RESPONSE: Objection. Brown objects to the extent that this Request seeks
confidential documents protected from disclosure by the attorney-client privilege and
the work product doctrine.33. All documents evidence the identity, qualifications and/or opinions of any expert
retained by you or your counsel to provide testimony in this Action.
RESPONSE: Objection. Brown objects to this Request as premature. This matter is in
the early stages of discovery and Brown has not engaged a testifying or consulting
expert at this time. As such, there are no responsive documents. Brown reserves the
right to disclose experts and associated expert materials in accordance with applicable
Florida Statutes, Florida Rules of Civil Procedure, Florida Rules of Discovery and any
Court Order(s) governing expert discovery and disclosures.
34. All expert witness reports for those experts you intend to call at the time of trial.
RESPONSE: Objection. Brown objects to this Request as premature. This matter is
in the early stages of discovery and Brown has not engaged a testifying or consulting
expert at this time. As such, there are no responsive documents. Brown reserves the
right to disclose experts and associated expert materials in accordance with applicable
Florida Statutes, Florida Rules of Civil Procedure, Florida Rules of Discovery and any
Court Order(s) governing expert discovery and disclosures.
35. Any correspondence, report, analysis or any other documents produced by any
expert or outside consultant related to the Project.
RESPONSE: Objection. Brown objects to this Request as premature. This matter is in
the early stages of discovery and Brown has not engaged a testifying or consulting
expert at this time. Brown reserves the right to disclose experts and associated expert
materials in accordance with applicable Florida Statutes, Florida Rules of Civil
Procedure, Florida Rules of Discovery and any Court Order(s) governing expert
discovery and disclosures.
36. All documents, invoices, cancelled checks, quotes, estimates, timecards, payroll
reports and any other documents evidencing damages incurred by you or any other person in the
remediation of the work performed on the Project.
RESPONSE: Objection. Brown objects to this Request as vague and ambiguous.
Specifically, Brown objects to the use of the phrase “damages”. The use of
‘damages’ is capable of multiple interpretation because the Association does not
define ‘damages, and Brown has not alleged any damages of any kind. Brown
further objects to the Request as overbroad, as the Request also seeks documents
as to ‘other damages’ incurred ‘in the remediation of the work’, meanwhile
Brown’s scope of services does not include ‘remediation’.
37. All statements from any person or entity related to the Project or this Action.
RESPONSE: Objection. Brown objects to this Request as vague and overly broad.
Specifically, Brown objects to the phrase “All recorded statements from any
person or entity .. .” as the Request is too vague, non-specific, and expansive toallow Brown to reasonably identify documents that may be responsive to this
request. Brown further objects to this Request to the extent that it seeks
documents or information protected from disclosure by the attorney client
privilege and attorney work product doctrines. Furthermore, Brown objects to
the use of ‘Action’ as it is capable of multiple interpretation because the
Association does not define ‘Action’. Subject to and without waiving the objections,
to the extent that Brown is in possession of any relevant, non-privileged and non-
confidential documents, Brown will produce same in accordance with the April 9,
2021 Court Order [f 3.1 & 3.3.
38. All documents related to insurance coverage relating to the claims asserted in the
Complaint (including, but not limited to, insurance policies, certificates of insurance,
correspondence between you and any insurer, correspondence between you and your insurance
agent and/or broker, etc.).
RESPONSE: Objection. Brown objects to this Request as it seeks irrelevant
information, not reasonably calculated to lead to the discovery of relevant or
admissible evidence. Brown further objects to this Request to the extent that it
seeks documents or information protected from disclosure by the attorney client
privilege and attorney work product doctrines. Subject to and without waiving the
objections, to the extent that Brown is in possession of any relevant, non-privileged
and non-confidential documents, Brown will produce same in accordance with the
April 9, 2021 Court Order 4 3.1 & 3.3.
39. Any and all information related to e-mail, including but not limited to current,
backed-up and archived programs, accounts, unified messaging, server-based e-mail, Web-based
e-mail, dial-up e-mail, usernames and addresses, domain names and addresses, e-mail messages,
attachments, manual and automated mailing lists and mailing list addresses for all executives,
employees, staff and personnel who participated in the Project.
RESPONSE: Objection. Brown objects to this Request as vague and overly broad.
Specifically, Brown objects to the phrase “Any and all information related to e-
mail. . .” and “including but not limited to current, backed-up and archived
programs, accounts, unified messaging, server-based e-mail, Web-based e-mail,
dial-up e-mail, usernames and addresses, domain names and addresses, . . .” as the
Request is too vague, non-specific, and expansive to allow Brown to reasonably
identify documents that may be responsive to this request. Additionally, Brown
objects to this Request as vague, overbroad, and unduly burdensome as the Request
is not limited in time or scope. Additionally, Brown objects to this Request as it
seeks irrelevant information, not reasonably calculated to lead to the discovery of
relevant or admissible evidence. Brown also objects to the extent that this Request
seeks documents protected from disclosure by the attorney-client privilege and the
work product doctrine.
40. All documents related to any estimates, offers, bids, or any invitations for offers
relating to any remediation efforts related to your allegations regarding the Project.RESPONSE: Objection. Brown objects to this Request as vague and ambiguous.
Specifically, Brown objects to the use of the phrase “your allegations”. Brown has
not asserted any allegations against others at this time, therefore this Request is
vague, ambiguous, and capable of multiple interpretations. Brown further objects
to the Request as overbroad, as the Request also seeks all documents as ‘relating
to any remediation efforts’, meanwhile Brown’s scope of work does not include
‘remediation’. Subject to and without waiving the objections, to the extent that
Brown is in possession of any relevant, non-privileged and non-confidential
documents, Brown will produce same in accordance with the April 9, 2021 Court
Order Ff 3.1 & 3.3.
41. All blank forms prepared or used by you or any other person relating to the
construction, maintenance, or remediation of the Project.
RESPONSE: Objection. Brown objects to this Request as it seeks irrelevant
information, not reasonably calculated to lead to the discovery of relevant or
admissible evidence. Additionally, Brown objects to this Request as vague, and
ambiguous. Specifically, Brown objects to the use of the phrase “used by you and
any other person” which is capable of multiple interpretations. Brown also objects
to the uses of “relating to the construction, maintenance, or remediation”, which
is also capable of multiple interpretations. Brown further objects to the Request
as overbroad, as the Request also seeks all documents not only to multiple persons
that are unidentified but also pertaining to multiple broad stages of the Project.
42. All documents showing, reflecting or indicating staffing by you or any other person
related to the Project.
RESPONSE: Objection. Brown objects to this Request as vague and ambiguous.
Specifically, Brown objects to the use of the phrase “staffing” which is capable of
multiple interpretations, and the Association does not define the term.
43. All documents concerning quality control procedures, supervision, coordination,
orders or opinions of the Association, or any contractor, subcontractor, project manager or any
other person related to the Project and within the custody of Association.
RESPONSE: Objection. Brown objects to this Request as vague, the phrase “order”,
and “opinions” is insufficiently specific and too expansive to allow Brown to reasonably
identify “All documents” that may be responsive to this request.
44. A list or log identifying those documents withheld from production in response to
any objections you or your attorneys have or may have to any other requests herein.
RESPONSE: To the extent Brown is in possession of any relevant, privileged, or
confidential documents, Brown will produce a privilege log in accordance with the
Florida Rules of Civil Procedure and the April 9, 2021 Court Order 4 3.1 & 3.3.45. All contents of change order files including correspondence and notes among any
architects, engineers, contractors, subcontractors, suppliers or specialists relating to construction,
maintenance, or remediation of the Project.
RESPONSE: Objection. Brown objects to this Request as vague, overbroad, and
unduly burdensome as the Request is not limited in time, scope of the claims, or as to
any party involved or alleged to be involved in this litigation. Additionally, the phrase
“All contents of change order files including correspondence and notes” is
insufficiently specific and “among any architects, engineers, contractors,
subcontractors, suppliers or specialists” too expansive to allow Brown to reasonably
identify “All contents” that may be responsive to this request. Brown also objects to
the extent that this Request seeks documents protected from disclosure by the
attorney-client privilege and the work product doctrine. Subject to and without
waiving the objections, to the extent that Brown is in possession of any relevant,
non-privileged and non-confidential documents, Brown will produce same in
accordance with the April 9, 2021 Court Order 4 3.1 & 3.3.
46. All documents related to any destructive testing or any samples collected from the
Property that are in your custody or control.
RESPONSE: Objection. Brown objects to this Request as overbroad as the Request is
not limited in time or scope.
47. All photographs and videos pertaining to construction, maintenance, or remediation
of the Project.
RESPONSE: Objection. Brown objects to this Request as overbroad as the Request is
not limited in time or scope.
48. All photographs related to damages asserted by any party to this litigation.
RESPONSE: Objection. Brown objects to this Request as vague, and ambiguous.
Specifically, Brown objects to the use of the phrase “damages asserted by any
party” which is not only capable of multiple interpretations, but also lacks any
specificity necessary to identify responsive documents to the Request. Brown
further objects to the Request as overbroad, as the Request also seeks all
documents not only from all sources, all of which are unidentified, but also
pertaining to multiple asserted damages.
49, All statements and interviews with persons associated with the design,
construction, or remediation of the Project.
RESPONSE: Objection. Brown objects to this Request as vague, overbroad, and unduly
burdensome as the Request is not limited in time or scope. Additionally, Brown objects
to the Request as ambiguous and vague. Specifically, the phrase “statements”, and
“interviews” are capable of multiple interpretation, and are not defined by theAssociation. Additionally, the Request lacks all necessary specificity to allow
identification of responsive documents as there are no indications of which persons
were “associated with the design, construction, or remediation”.
50. All documents upon which you intend to rely to establish proof of claims,
damages or refutation of claims in this Action.
RESPONSE: Objection. Brown objects to this Request as vague and overly broad.
Specifically, Brown objects to the phrase “All documents upon which you intend
to rely to establish . . . refutation of claims in this Action” as the Request is too
vague, non-specific, and expansive to allow Brown to reasonably identify
documents that may be responsive to this request. Brown further objects to this
Request to the extent that it seeks documents or information protected from
disclosure by the attorney client privilege and attorney work product doctrines.
Furthermore, Brown objects to the use of ‘Action’ as it is capable of multiple
interpretation, and the Association does not define it. Subject to and without
waiving the objections, to the extent that Brown is in possession of any relevant,
non-privileged and non-confidential documents, Brown will produce same in
accordance with the April 9, 2021 Court Order 4 3.1 & 3.3.
51. A copy of all warranty documents, including extended warranty documents,
relating to the Project.
RESPONSE: To the extent Brown is in possession of any relevant, non-privileged
and non-confidential documents, Brown will produce same in accordance with the
April 9, 2021 Court Order §§ 3.1 & 3.3.
52. All written notices provided by or to you or any other person relating to the defects
alleged in this Action.
RESPONSE: Objection. Brown objects to this Request as vague, overbroad, and
unduly burdensome as the Request is not limited in time, scope, scope of the claims
being noticed, or as to any person or persons who have either received or sent “written
notices”. Additionally, the phrase “written notices” is insufficiently specific, and too
expansive to allow Brown to reasonably identify “written notices” that may be
responsive to this Request. Furthermore, Brown objects to the use of ‘Action’ as it is
capable of multiple interpretations, and the Association does not define ‘Action’.
53. A copy of all building codes, ASTM procedures or any other industry standard
for which you allege any person failed to comply it its work relating to construction, maintenance,
or remediation of the Project.
RESPONSE: Objection. Brown objects to this Request as premature. This matter is in
the early stages of discovery and Brown has not engaged a testifying or consulting
expert at this time. As such, there are no building codes, ASTM procedures, or industry
standards identified at this time. Brown reserves the right to disclose experts and
associated expert materials in accordance with applicable Florida Statutes, Florida
Rules of Civil Procedure, Florida Rules of Discovery and any Court Order(s) governingexpert discovery and disclosures. Additionally, Brown objects to this Request as
ambiguous and vague, as Brown has not asserted any affirmative claims at this time.
54. All settlement agreements or liquidation agreements between you and any other person
relating to the construction, maintenance, or remediation of the Project.
RESPONSE: Objection. Brown objects to this Request as it seeks irrelevant
information, not reasonably calculated to lead to the discovery of relevant or
admissible evidence.
55. All documents evidencing bids and proposals submitted by any entity to correct the
alleged construction defects asserted by Plaintiff.
RESPONSE: Objection. Brown objects to this Request as vague and ambiguous.
Specifically, Brown objects to the use of the phrase “alleged construction defects
asserted by you”. Brown has not asserted any allegations of construction defects
at this time; therefore, this Request is vague, ambiguous, and capable of multiple
interpretations. Brown further objects to the Request as overbroad, as the Request
also seeks all documents of certain delineated types “submitted by any entity”, not
just documents submitted by Brown.
56. A copy of the specifications and standards received by you or from any other
person which pertain to the Project’s design, construction, or remediation.
RESPONSE: Objection. Brown objects to this Request as vague and ambiguous.
Specifically, Brown objects to the use of the phrase “specifications and standards”
which are capable of multiple interpretations and the Association does not define
the terms. Additionally, the Request does not specify which set of “specifications
and standards” is being talked about in the request or what trade the requested
“specifications and standards” concern.CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been electronically
served via the Florida E-Filing Portal to counsel of record for the parties on the attached Service List,
this 10th day of May, 2021.
MILBER MAKRIS PLOUSADIS & SEIDEN, LLP Attorneys for
Defendant, Brown + Company Architecture, Inc.
1900 NW Corporate Blvd., East Tower, Suite 440 Boca Raton,
Florida 33431
bealderon@milbermakris.com
dhill@milbermakris.com
acreech@milbermakris.com
Telephone: 561-994-7310
Facsimile: (561) 994-7313
By: _S:/ Audra R. Creech
Bruce R. Calderon
Florida Bar No. 50448
D. Bryan Hill
Florida Bar No. 113687
Audra R. Creech
Florida Bar No. 122373SERVICE LIST
Phillip E. Joseph, Esq.
Evan J. Small, Esq.
Jeffrey A. Widelitz Esq.
Nicholas B. Vargo, Esq.
Ball Janik, LLP
201 East Pine Street — Suite 600
Orlando, FL 32801
pjoseph@balljanik.com
esmall@balljanik.com
nvargo@ballianik.om
asmith@balljanik.com
ypalmer@balljanik.com
cbetancourt@balljanik.com
mwise@balljanik.com
dmiksell@balljanik.com
orlandodocket@balljanik.com
Counsel for Plaintiff, Villas at Emerald
Lake Homeowners Association, Inc.
James Michael Walls, Esq.
Bryan C. Porter, Esq.
Carlton Fields, P.A.
4221 W. Boy Scout Boulevard
Tampa, FL 33607-5780
mwalls@ecarltonfields.com
bporter@carltonfields.com
jcostello@carltonfields.com
Counsel for Defendant, Royal Oak Homes, LLC
Thamir A. R. Kaddouri, Jr., Esq.
Law Office Of Thamir A.R. Kaddouri, Jr., P.A.
3220 West Cypress Street
Tampa, FL 33607
Counsel for Defendant, Imperial Building Corporation
Paul Sidney Elliott, Esq.
P. O. Box 274204
Tampa, FL 33688-4204
pse@pseid.com
Counsel for Defendant, Hugh MacDonald Construction, Inc. (HMC)Peter J. Kapsales, Esq.
Margaret M. Efta, Esq.
Milne Law Group, P.A.
301 East Pine Street — Suite 525
Orlando, FL 32801
pkapsales@milnelawgroup.com
mefia@milnelawgroup.com
eservice@milnelawgroup.com
Counsel for Defendant, Weathermaster Building Products, Inc.
Denise M. Anderson, Esq.
Kate F. Gaset, Esq.
Butler Weihmuller Katz Craig LLP
400 North Ashley Drive — Suite 2300
Tampa, FL 33602
danderson@butler.Jegal
kgaset(@pbutler.legal
krieck@butler legal
rjorge@butler legal
dwhite@butler.legal
Counsel for Defendants, Don King’s Concrete, Inc. and Hugh MacDonald Construction, Inc.
Jayne Ann Pittman, Esq.
Natalie C. Fischer, Esq.
Conroy Simberg
Two South Orange Avenue — Suite 300
Orlando, FL 32801
eserviceorl@conroysimberg.com
jpittman@conroysimberg.com
nfischer@conroysimberg.com
mmaitland@conroysimberg.com
Counsel for Defendant, Advanced Wrapping and Concrete Solutions
Of Central Florida, Inc.
Eric J. Netcher, Esq.
Walker, Revels, Greninger & Netcher, PLLC
189 South Orange Avenue - Suite 1830
Orlando, FL 32801
enetcher@wrgn-law.com
hpaymayesh@wrgn-law.com
Counsel for Third-Party Defendant, All Glass Installation Corp.S. Scott Ross, Esq.
Groelle & Salmon, P.A.
1715 N. Westshore Boulevard - Suite 320
Tampa, FL 33607
gstcourtdocs@gspalaw.com
sross@gspalaw.com
cebanks@gspalaw.com
meoleman@gspalaw.com
Counsel for Third-Party Defendant, Helberg Enterprises, LLC
Cole J. Copertino, Esq.
Wright, Fulford, Moorhead & Brown, P.A.
505 Maitland Avenue - Suite 1000
Altamonte Springs, FL 32701
ccopertino@wfimblaw.com
cbraungart@wfmblaw.com
lwilliams@wfmblaw.com
Counsel for Third-Party Defendant, Well Hung Windows & Doors, LLC
Alec Masson
Luks, Santaniello, Petrillo & Cohen
201 South Orange Avenue — Suite 400
Orlando, FL 32801
luksorl@pleadings@LS-Law.com
AMasson@insurancedefense.net
JPestonit@insurancedefense.net
Counsel for Third-Party Defendant, Casey Hawkins Glass, Inc.
Phillip S. Howell, Esq.
Kyle R. McNeal, Esq.
Galloway, Johnson, Tompkins, Burr & Smith, P.L.C.
400 N. Ashley Drive — Suite 1000
Tampa, FL 33602
tampaservice@gallowaylawfirm.com
phowell@gallowaylawfirm.com
kmeneal@gallowaylawfirm.com
Counsel for Third-Party Defendant, Casey Hawkins Glass, Inc.Andrew T. Marshall, Esq.
Hamilton, Price & Marshall, P.A.
2400 Manatee Avenue West
Bradenton, FL 34205
Andrew@hamiltonpricelaw.com
Nancy@hamiltonpricelaw.com
Kelsey@hamiltonpricelaw.com
Counsel for T&M Construction of Sanford, Inc.
Andrew E. Holway, Esq.
Timothy C. Ford, Esq.
Hill Ward Henderson, P.A.
101 East Kennedy Boulevard
Suite 3700
Tampa, FL 33602
Andrew. holway@hwhlaw.com
Tim.ford@hwhlaw.com
Kathy.wernsing@hwhlaw.com
Tracy.coale@hghlaw.com
Derrick.calandra@hghlaw.com
Counsel for Weintraub Inspections
Joseph L. Zollner
Law Office of Christopher J. Norris
PO Box 7217
London, KY 40742
FloridaCDLegalMail@LibertyMutual.com
Joseph.Zollner@LibertyMutual.com
Preview
Filing # 126480406 E-Filed 05/10/2021 01:18:38 PM IN THE CIRCUIT COURT OF THE 9™ JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO.: 2020-CA-002942-ON VILLAS AT EMERALD LAKE HOMEONWERS ASSOCIATION, INC., a Florida not for profit corporation, Plaintiff, Vv. ROYAL OAK HOMES, LLC, a Florida limited liability company; ADVANCED WRAPPING AND CONCRETE SOLUTIONS OF CENTRAL FLORIDA, INC., a Florida corporation; DON KING’S CONCRETE, INC., a Florida corporation; HUGH MACDONALD CONSTRUCTION, INC., a Florida corporation; IMPERIAL BUILDING CORPORATION, a Florida corporation; PREMIER PLASTERING OF CENTRAL FLORIDA, INC. n/k/a TGK STUCCO, INC., a Florida corporation; WEATHERMASTER BUILDING PRODUCTS, INC., a Florida corporation; WEINTRAUB INSPECTIONS & FORENSICS, INC. n/k/a WEINTRAUB ENGINEERING AND INSPECTIONS, INC, a Florida corporation; THE DIMILLO GROUP, LLC, a Florida limited liability company; WOLF’S IRRIGATION & LANDSCAPING, INC., A Florida corporation; SUMMERPARK HOMES, INC., a Florida corporation; BROWN + COMPANY ARCHITECTURE, INC., a Florida corporation; Defendant. ROYAL OAK HOMES, LLC, a Florida limited liability company;Crossclaim Plaintiff, Vv. ADVANCED WRAPPING AND CONCRETE SOLUTION OF CENTRAL FLORIDA, INC., a Florida corporation; DON KING’S CONCRETE, INC., a Florida corporation; HUGH MACDONALD CONSTRUCTION, INC., a Florida corporation; IMPERIAL BUILDING CORPORATION, a Florida corporation; PREMIER PLASTERING OF CENTRAL FLORIDA, INC. n/k/a TGK STUCCO, INC., a Florida corporation; WEATHERMASTER BUILDING PRODUCTS, INC., a Florida corporation; WEINTRAUB INSPECTIONS & FORENSICS, INC. n/k/a WEINTRAUB ENGINEERING AND INSPECTIONS, INC., a Florida corporation; WOLF'S IRRIGATION & LANDSCAPING, INC., a Florida corporation, BROWN+ COMPANY ARCHITECTURE, INC., a Florida corporation; Crossclaim Defendants. BROWN+COMPANY ARCHITECTURE, INC."S RESPONSES TO_ PLAINTIFF’S FIRST REQUEST FOR PRODUCTION Pursuant to the VILLAS AT EMERALD LAKE HOMEONWERS ASSOCIATION, INC.’s (the “Association”) First Request for Production, Defendant BROWN + COMPANY ARCHITECTURE, INC. (“Brown”) hereby serves its response to the Association’s First Request for Production and states as follows: GENERAL OBJECTIONS: By producing the documents requested, Brown does not: (a) admit that those documents (or related documents) are properly discoverable; (b) waive any objections theymight otherwise make to the production or introduction at trial of such documents; or (c) admit that the documents are admissible at trial. The process of discovery is ongoing, and Brown reserves the right to supplement, amend, or correct all or any part of the response provided here. DOCUMENTS TO BE PRODUCED 1, Any and all documents that refer or relate to the Project, including, without limitation, any document generated, transmitted, received or maintained by you that refers to the development, design, construction, management, ownership, conversion, repair, marketing, and sale of the Project and/or the individual townhouse units contained in the Project. RESPONSE: Objection. Brown objects to this Request as vague and overly broad. Specifically, Brown objects to the Phrases “Any and all documents” and “refer or relate to the Project” as vague, insufficiently specific, and too expansive to allow Brown to reasonably identify documents that may be responsive to this request. Brown further objects to this Request to the extent that it seeks documents or information protected from disclosure by the attorney client privilege and attorney work product doctrines. Subject to and without waiving the objections, to the extent that Brown is in possession of any responsive documents, Brown will produce same in accordance with the April 9, 2021 Court Order 4¥ 3.1 & 3.3. 2. Any and all documents that constitute, refer, or relate to communications about the Subject Property to or from any owner, officer, director, member, manager, employee, agent or representative of any of the following: a. ROYAL OAK HOMES, LLC b. ADVANCED WRAPPING AND CONCRETE SOLUTIONS OF CENTRAL FLORIDA, INC. c. DON KING’S CONCRETE, INC. d. HUGH MACDONALD CONSTRUCTION, INC. e. IMPERIAL BUILDING CORPORATION f. PREMIER PLASTERING OF CENTRAL FLORIDA, INC. n/k/a TGK STUCCO, INC. g. WEATHERMASTER BUILDING PRODUCTS, INC.h. WEINTRAUB INSPECTIONS & FORENSICS, INC. n/k/a WEINTRAUB ENGINEERING & INSPECTIONS, INC. i. THE DIMILLO GROUP, LLC j.. WOLF’S IRRIGATION & LANDSCAPING, INC. k. SUMMERPARK HOMES, INC. RESPONSE: Objection to Request 2, and all its subparts as vague and overly broad. Specifically, Brown objects to the Phrases “Any and all documents” and “refer or relate to communications about the Subject Property” as extremely vague, insufficiently specific, not defined, and too expansive to allow Brown to reasonably identify documents that may be responsive to this request. Brown further objects to this Request to the extent that it seeks documents or information protected from disclosure by the attorney client privilege and attorney work product doctrines. Subject to and without waiving the objections, to the extent that Brown is in possession of any responsive documents, Brown will produce same in accordance with the April 9, 2021 Court Order ¥[{ 3.1 & 3.3. 3. All contracts or modifications to contracts related to the design of the Project. RESPONSE: Objection. Brown objects to this Request as vague and overly broad. Specifically, Brown objects to the Phrases “All contracts or modifications to contracts” and “related to the design and construction of the Project” as extremely vague, insufficiently specific, and too expansive to allow Brown to reasonably identify documents that may be responsive to this request. Brown was a design professional as to this Project only and would have only had copies of its own contracts and modifications, not “All contracts and modifications”. Brown further objects to this Request to the extent that it seeks documents or information protected from disclosure by the attorney client privilege and attorney work product doctrines. Subject to and without waiving the objections, to the extent that Brown is in possession of any responsive documents, Brown will produce same in accordance with the April 9, 2021 Court Order {[f 3.1 & 3.3. 4. All notices of commencement permit applications, permits, County inspection records, and certificates of occupancy. RESPONSE: To the extent Brown is in possession of any relevant, non-privileged and non-confidential documents, responsive to this request, Brown will produce same in accordance with the April 9, 2021 Court Order § 3.1 & 3.3. 5. All documents signed by a public entity relating to the Project including, but not limited to, inspection reports, and permit requirement documents. RESPONSE: Objection. Brown objects to this Request as vague, overbroad, andunduly burdensome as the Request is not limited in time or scope of the claims alleged in this litigation. Additionally, the phrase “public entity” is insufficiently specific and too expansive to allow Brown to reasonably identify “All documents” that may be responsive to this request. Brown also objects to the extent that this Request seeks documents protected from disclosure by the attorney-client privilege and the work product doctrine. Subject to and without waiving the objections, to the Brown is in possession of any responsive documents, Brown will produce same in accordance with the April 9, 2021 Court Order ¥[{ 3.1 & 3.3. 6. All plans (including permit plans, construction plans, and as-built plans), specifications, or other such documents related to the design of the Project. RESPONSE: Objection. Brown objects to this Request as vague and overly broad. Specifically, Brown objects to the phrase “or other such documents related to the design of the Project” as extremely vague, and too expansive to allow Brown to reasonably identify documents that may be responsive to this request. Brown further objects to this Request to the extent that it seeks documents or information protected from disclosure by the attorney client privilege and attorney work product doctrines. Subject to and without waiving the objections, to the extent that Brown is in possession of any responsive documents, Brown will produce same in accordance with the April 9, 2021 Court Order f 3.1 & 3.3. 7. All documents in your possession, custody, or control relating to payment for the design or construction of the Project. RESPONSE: Objection. Brown objects to this Request as vague, overbroad, and unduly burdensome as the Request is not limited in time or scope. Additionally, the phrase “relating to payment” is insufficiently specific and too expansive to allow Brown to reasonably identify “All documents” that may be responsive to this request. Brown also objects to the extent that this Request seeks documents protected from disclosure by the attorney-client privilege and the work product doctrine. Subject to and without waiving the objections, to the extent Brown is in possession of any responsive documents, Brown will produce same in accordance with the April 9, 2021 Court Order [§ 3.1 & 3.3. 8. All documents relating to daily, weekly, or monthly progress reports or similar reports memorializing the progress of the planning, design, or construction of the Project. RESPONSE: To the extent Brown is in possession of any relevant, non-privileged and non-confidential documents, Brown will produce same in accordance with the April 9, 2021 Court Order 4 3.1 & 3.3. 9. All field memos, field reports, or other documents relating to the status of the planning, design, or construction of the Project. RESPONSE: To the extent Brown is in possession of any relevant, non-privileged and non-confidential documents, Brown will produce same in accordance with theApril 9, 2021 Court Order [§ 3.1 & 3.3. 10. All job diaries, notes, meeting minutes, or other similar documents related to the design or construction of the Project. RESPONSE: To the extent Brown is in possession of any relevant, non-privileged and non-confidential documents, Brown will produce same in accordance with the April 9, 2021 Court Order (3.1 & 3.3. 11. All timecards, time sheets or any other similar documents evidencing or relating to the amount of time spent by your or any other person’s personnel performing work on the Project, including, but not limited to, employees, principals, agents, independent contractors, sub- consultants, and sub-subconsultants, relating to construction, maintenance, or remediation of the Project. RESPONSE: To the extent Brown is in possession of any relevant, non-privileged and non-confidential documents, Brown will produce same in accordance with the April 9, 2021 Court Order [§ 3.1 & 3.3. 12. All schedules, timelines, bar charts, critical path method analyses and other documents relating to construction, maintenance, or remediation of the Project. RESPONSE: None. 13. All analyses, conclusions, recommendations, correspondence, notes, reviews, reports, working papers or any other documents, internal or otherwise, relating to any person’s requests for time extensions, requests for information, claims, or requests for compensation related to the Project. RESPONSE: Objection. Brown objects to this Request as overbroad as the Request is not limited in time or scope. Additionally, this Request is insufficiently specific and too expansive to allow Brown to reasonably identify “All analyses, conclusions, recommendations, correspondence, notes, review, reports, working papers...” that may be responsive to this request. Brown also objects to the extent that this Request seeks documents protected from disclosure by the attorney-client privilege and the work product doctrine. Subject to and without waiving the objections, to the extent Brown is in possession of any responsive documents, Brown will produce same in accordance with the April 9, 2021 Court Order 7§ 3.1 & 3.3. 14. All memoranda, correspondence or any other documents, internal or otherwise, prepared by or for Association or any other person regarding any alleged failure relating to the construction, maintenance, or remediation of the Project. RESPONSE: Objection. Brown objects to this Request as vague and ambiguous. Specifically, Brown objects to the use of the phrase “failure relating to”. The use of ‘failure relating to’ is capable of multiple interpretation and is not defined by the Association. Brown cannot reasonably identify responsive documents to this Request given the ambiguity of the Request as written. Brown further objects tothis Request to the extent that it seeks documents or information protected from disclosure by the attorney client privilege and attorney work product doctrines. Subject to and without waiving the objections, to the extent that Brown is in possession of any responsive documents, Brown will produce same in accordance with the April 9, 2021 Court Order [§ 3.1 & 3.3. 15. All contracts, purchase orders and other agreements and amendments thereto relating to the Project including, but not limited to, all subcontracts and/or agreements and change orders thereto. RESPONSE: To the extent that Brown is in possession of any relevant, non- privileged and non-confidential responsive documents, Brown will produce same in accordance with the April 9, 2021 Court Order 4 3.1 & 3.3. 16. All Requests for Information or other similar documents received or responded to by Association from any person or entity. RESPONSE: To the extent that Brown is in possession of any relevant, non-privileged and non-confidential documents responsive documents, Brown will produce same in accordance with the April 9, 2021 Court Order ¢§ 3.1 & 3.3. 17. All Change Orders relating to the Project. RESPONSE: To the extent Brown is in possession of any relevant, non-privileged and non-confidential documents, Brown will produce same in accordance with the April 9, 2021 Court Order (3.1 & 3.3. 18. All submittals and transmittals relating to the Project. RESPONSE: To the extent Brown is in possession of any relevant, non-privileged and non-confidential documents, Brown will produce same in accordance with the April 9, 2021 Court Order (ff 3.1 & 3.3.19. All laboratory and testing reports on materials or work associated with the design or construction of the Project. RESPONSE: To the extent Brown is in possession of any relevant, non-privileged and non-confidential documents, Brown will produce same in accordance with the April 9, 2021 Court Order 7 3.1 & 3.3. 20. — All documents evidencing any changes or alterations in the design of the Project. RESPONSE: Objection. Brown objects to this Request as vague, overbroad, and unduly burdensome as the Request is not limited in time or scope. Additionally, Brown objects to the Request as ambiguous and vague. Specifically, the phrase “changes or alterations” is capable of multiple interpretation and is not defined by the Association. Brown also objects to the extent that this Request seeks documents protected from disclosure by the attorney-client privilege and the work product doctrine. Subject to and without waiving the objections, to the extent it is in possession of any responsive documents, Brown will produce same in accordance with the April 9, 2021 Court Order (ff 3.1 & 3.3. 21. All shop drawings, material submittals or installation procedures prepared by or obtained by Association relating to the Project. RESPONSE: To the extent Brown is in possession of any relevant, non-privileged and non-confidential documents, Brown will produce same in accordance with the April 9, 2021 Court Order (§ 3.1 & 3.3. 22. All manufacturers’ or suppliers’ instructions, standards, guidelines, brochures, representations, warranties or other documents relating to the Project. RESPONSE: To the extent Brown is in possession of any relevant, non-privileged and non-confidential documents, Brown will produce same in accordance with the April 9, 2021 Court Order 4 3.1 & 3.3. 23. All documents related to the inspection or testing of the Project design or construction by any person or entity. RESPONSE: Objection. Brown objects to this Request as vague, overbroad, and unduly burdensome as the Request is not limited in time or scope. Additionally, Brown objects to the Request as ambiguous and vague. Specifically, the phrase “inspection or testing” is capable of multiple interpretation and is not defined by the Association. Brown also objects to the extent that this Request seeks documents protected from disclosure by the attorney-client privilege and the work product doctrine. Subject to and without waiving the objections, to the extent Brown is in possession of any relevant, non-privileged and non-confidential documents, Brown will produce same in accordance with the April 9, 2021 Court Order {| 3.1 & 3.3.24. Laser color copies of any photographs which are in any manner related to the subject matter of this Action. RESPONSE: Objection. Brown objects to this Request as vague, overbroad, and unduly burdensome as the Request is not limited in time or scope. Additionally, Brown objects to the Request as ambiguous and vague. Specifically, the phrase “subject matter” is capable of multiple interpretation and is not defined by the Association. Furthermore, Brown objects to this Request as it seeks irrelevant information, not reasonably calculated to lead to the discovery of relevant or admissible evidence. Brown also objects to the extent that this Request seeks documents protected from disclosure by the attorney-client privilege and the work product doctrine. Finally, Brown objects to the request seeking to compel Brown to create documents, specifically, ‘laser color copies’. 25. All videotapes which are in any manner related to the subject matter of this Action. RESPONSE: Objection. Brown objects to this Request as vague, overbroad, and unduly burdensome as the Request is not limited in time or scope. Additionally, Brown objects to the Request as ambiguous and vague. Specifically, the phrase “subject matter” is capable of multiple interpretation and is not defined by the Association. Furthermore, Brown objects to this Request as it seeks irrelevant information, not reasonably calculated to lead to the discovery of relevant or admissible evidence. Brown also objects to the extent that this Request seeks documents protected from disclosure by the attorney-client privilege and the work product doctrine. Subject to and without waiving the objections, to the extent Brown is in possession of any relevant, non-privileged and non-confidential documents, Brown will produce same in accordance with the April 9, 2021 Court Order 4 3.1 & 3.3. 26. All movie footage whether in electronic or physical form related to the Project. RESPONSE: Objection. Brown objects to this Request as vague, overbroad, and unduly burdensome as the Request is not limited in time or scope. Additionally, Brown objects to this Request as it seeks irrelevant information, not reasonably calculated to lead to the discovery of relevant or admissible evidence. Brown also objects to the extent that this Request seeks documents protected from disclosure by the attorney-client privilege and the work product doctrine. 27. All punch lists or other similar documents relating to the design or construction of the Project. RESPONSE: To the extent Brown is in possession of any relevant, non-privileged and non-confidential documents, Brown will produce same in accordance with the April 9, 2021 Court Order §§ 3.1 & 3.3. 28. All documents and correspondence between the Plaintiff and any other party to this Action relating to the design or construction of the Project (this request excludes correspondenceor other documents exchanged between counsel for the Parties). RESPONSE: Objection. Brown objects to this Request as vague and overly broad. Specifically, Brown objects to the Phrases “All contracts or modifications to contracts” and “related to the design and construction of the Project” as extremely vague, insufficiently specific, and too expansive to allow Brown to reasonably identify documents that may be responsive to this request. Brown was a design professional as to this Project only and would have only had copies of its own contracts and modifications, not “All contracts and modifications”. Brown further objects to this Request to the extent that it seeks documents or information protected from disclosure by the attorney client privilege and attorney work product doctrines. Subject to and without waiving the objections, to the extent that Brown is in possession of any relevant, non-privileged and non-confidential documents, Brown will produce same in accordance with the April 9, 2021 Court Order Ff 3.1 & 3.3. 29. All documents reflecting any communication between and any renters, tenants, guests, lessee’s, or any persons who reside or resided at the Project, as further described in Plaintiff's complaint and is at issue in this litigation. RESPONSE: None. 30. All correspondence or other documents between any other person, party or entity relating to any alleged defects in the design or construction of the Project. RESPONSE: Objection. Brown objects to the extent that this Request seeks confidential documents and communications protected from disclosure by the attorney-client privilege and the work product doctrine. 31. All documents involving any evaluation, investigation, study, or analysis of alleged defects in the design or construction of the Project. RESPONSE: Objection. Brown objects to the extent that this Request seeks confidential documents protected from disclosure by the attorney-client privilege and the work product doctrine. 32. All documents, correspondence or tangible materials in your possession, custody, or control relating in any way to any defects and deficiencies being alleged to exist at the Project in this Action. RESPONSE: Objection. Brown objects to the extent that this Request seeks confidential documents protected from disclosure by the attorney-client privilege and the work product doctrine.33. All documents evidence the identity, qualifications and/or opinions of any expert retained by you or your counsel to provide testimony in this Action. RESPONSE: Objection. Brown objects to this Request as premature. This matter is in the early stages of discovery and Brown has not engaged a testifying or consulting expert at this time. As such, there are no responsive documents. Brown reserves the right to disclose experts and associated expert materials in accordance with applicable Florida Statutes, Florida Rules of Civil Procedure, Florida Rules of Discovery and any Court Order(s) governing expert discovery and disclosures. 34. All expert witness reports for those experts you intend to call at the time of trial. RESPONSE: Objection. Brown objects to this Request as premature. This matter is in the early stages of discovery and Brown has not engaged a testifying or consulting expert at this time. As such, there are no responsive documents. Brown reserves the right to disclose experts and associated expert materials in accordance with applicable Florida Statutes, Florida Rules of Civil Procedure, Florida Rules of Discovery and any Court Order(s) governing expert discovery and disclosures. 35. Any correspondence, report, analysis or any other documents produced by any expert or outside consultant related to the Project. RESPONSE: Objection. Brown objects to this Request as premature. This matter is in the early stages of discovery and Brown has not engaged a testifying or consulting expert at this time. Brown reserves the right to disclose experts and associated expert materials in accordance with applicable Florida Statutes, Florida Rules of Civil Procedure, Florida Rules of Discovery and any Court Order(s) governing expert discovery and disclosures. 36. All documents, invoices, cancelled checks, quotes, estimates, timecards, payroll reports and any other documents evidencing damages incurred by you or any other person in the remediation of the work performed on the Project. RESPONSE: Objection. Brown objects to this Request as vague and ambiguous. Specifically, Brown objects to the use of the phrase “damages”. The use of ‘damages’ is capable of multiple interpretation because the Association does not define ‘damages, and Brown has not alleged any damages of any kind. Brown further objects to the Request as overbroad, as the Request also seeks documents as to ‘other damages’ incurred ‘in the remediation of the work’, meanwhile Brown’s scope of services does not include ‘remediation’. 37. All statements from any person or entity related to the Project or this Action. RESPONSE: Objection. Brown objects to this Request as vague and overly broad. Specifically, Brown objects to the phrase “All recorded statements from any person or entity .. .” as the Request is too vague, non-specific, and expansive toallow Brown to reasonably identify documents that may be responsive to this request. Brown further objects to this Request to the extent that it seeks documents or information protected from disclosure by the attorney client privilege and attorney work product doctrines. Furthermore, Brown objects to the use of ‘Action’ as it is capable of multiple interpretation because the Association does not define ‘Action’. Subject to and without waiving the objections, to the extent that Brown is in possession of any relevant, non-privileged and non- confidential documents, Brown will produce same in accordance with the April 9, 2021 Court Order [f 3.1 & 3.3. 38. All documents related to insurance coverage relating to the claims asserted in the Complaint (including, but not limited to, insurance policies, certificates of insurance, correspondence between you and any insurer, correspondence between you and your insurance agent and/or broker, etc.). RESPONSE: Objection. Brown objects to this Request as it seeks irrelevant information, not reasonably calculated to lead to the discovery of relevant or admissible evidence. Brown further objects to this Request to the extent that it seeks documents or information protected from disclosure by the attorney client privilege and attorney work product doctrines. Subject to and without waiving the objections, to the extent that Brown is in possession of any relevant, non-privileged and non-confidential documents, Brown will produce same in accordance with the April 9, 2021 Court Order 4 3.1 & 3.3. 39. Any and all information related to e-mail, including but not limited to current, backed-up and archived programs, accounts, unified messaging, server-based e-mail, Web-based e-mail, dial-up e-mail, usernames and addresses, domain names and addresses, e-mail messages, attachments, manual and automated mailing lists and mailing list addresses for all executives, employees, staff and personnel who participated in the Project. RESPONSE: Objection. Brown objects to this Request as vague and overly broad. Specifically, Brown objects to the phrase “Any and all information related to e- mail. . .” and “including but not limited to current, backed-up and archived programs, accounts, unified messaging, server-based e-mail, Web-based e-mail, dial-up e-mail, usernames and addresses, domain names and addresses, . . .” as the Request is too vague, non-specific, and expansive to allow Brown to reasonably identify documents that may be responsive to this request. Additionally, Brown objects to this Request as vague, overbroad, and unduly burdensome as the Request is not limited in time or scope. Additionally, Brown objects to this Request as it seeks irrelevant information, not reasonably calculated to lead to the discovery of relevant or admissible evidence. Brown also objects to the extent that this Request seeks documents protected from disclosure by the attorney-client privilege and the work product doctrine. 40. All documents related to any estimates, offers, bids, or any invitations for offers relating to any remediation efforts related to your allegations regarding the Project.RESPONSE: Objection. Brown objects to this Request as vague and ambiguous. Specifically, Brown objects to the use of the phrase “your allegations”. Brown has not asserted any allegations against others at this time, therefore this Request is vague, ambiguous, and capable of multiple interpretations. Brown further objects to the Request as overbroad, as the Request also seeks all documents as ‘relating to any remediation efforts’, meanwhile Brown’s scope of work does not include ‘remediation’. Subject to and without waiving the objections, to the extent that Brown is in possession of any relevant, non-privileged and non-confidential documents, Brown will produce same in accordance with the April 9, 2021 Court Order Ff 3.1 & 3.3. 41. All blank forms prepared or used by you or any other person relating to the construction, maintenance, or remediation of the Project. RESPONSE: Objection. Brown objects to this Request as it seeks irrelevant information, not reasonably calculated to lead to the discovery of relevant or admissible evidence. Additionally, Brown objects to this Request as vague, and ambiguous. Specifically, Brown objects to the use of the phrase “used by you and any other person” which is capable of multiple interpretations. Brown also objects to the uses of “relating to the construction, maintenance, or remediation”, which is also capable of multiple interpretations. Brown further objects to the Request as overbroad, as the Request also seeks all documents not only to multiple persons that are unidentified but also pertaining to multiple broad stages of the Project. 42. All documents showing, reflecting or indicating staffing by you or any other person related to the Project. RESPONSE: Objection. Brown objects to this Request as vague and ambiguous. Specifically, Brown objects to the use of the phrase “staffing” which is capable of multiple interpretations, and the Association does not define the term. 43. All documents concerning quality control procedures, supervision, coordination, orders or opinions of the Association, or any contractor, subcontractor, project manager or any other person related to the Project and within the custody of Association. RESPONSE: Objection. Brown objects to this Request as vague, the phrase “order”, and “opinions” is insufficiently specific and too expansive to allow Brown to reasonably identify “All documents” that may be responsive to this request. 44. A list or log identifying those documents withheld from production in response to any objections you or your attorneys have or may have to any other requests herein. RESPONSE: To the extent Brown is in possession of any relevant, privileged, or confidential documents, Brown will produce a privilege log in accordance with the Florida Rules of Civil Procedure and the April 9, 2021 Court Order 4 3.1 & 3.3.45. All contents of change order files including correspondence and notes among any architects, engineers, contractors, subcontractors, suppliers or specialists relating to construction, maintenance, or remediation of the Project. RESPONSE: Objection. Brown objects to this Request as vague, overbroad, and unduly burdensome as the Request is not limited in time, scope of the claims, or as to any party involved or alleged to be involved in this litigation. Additionally, the phrase “All contents of change order files including correspondence and notes” is insufficiently specific and “among any architects, engineers, contractors, subcontractors, suppliers or specialists” too expansive to allow Brown to reasonably identify “All contents” that may be responsive to this request. Brown also objects to the extent that this Request seeks documents protected from disclosure by the attorney-client privilege and the work product doctrine. Subject to and without waiving the objections, to the extent that Brown is in possession of any relevant, non-privileged and non-confidential documents, Brown will produce same in accordance with the April 9, 2021 Court Order 4 3.1 & 3.3. 46. All documents related to any destructive testing or any samples collected from the Property that are in your custody or control. RESPONSE: Objection. Brown objects to this Request as overbroad as the Request is not limited in time or scope. 47. All photographs and videos pertaining to construction, maintenance, or remediation of the Project. RESPONSE: Objection. Brown objects to this Request as overbroad as the Request is not limited in time or scope. 48. All photographs related to damages asserted by any party to this litigation. RESPONSE: Objection. Brown objects to this Request as vague, and ambiguous. Specifically, Brown objects to the use of the phrase “damages asserted by any party” which is not only capable of multiple interpretations, but also lacks any specificity necessary to identify responsive documents to the Request. Brown further objects to the Request as overbroad, as the Request also seeks all documents not only from all sources, all of which are unidentified, but also pertaining to multiple asserted damages. 49, All statements and interviews with persons associated with the design, construction, or remediation of the Project. RESPONSE: Objection. Brown objects to this Request as vague, overbroad, and unduly burdensome as the Request is not limited in time or scope. Additionally, Brown objects to the Request as ambiguous and vague. Specifically, the phrase “statements”, and “interviews” are capable of multiple interpretation, and are not defined by theAssociation. Additionally, the Request lacks all necessary specificity to allow identification of responsive documents as there are no indications of which persons were “associated with the design, construction, or remediation”. 50. All documents upon which you intend to rely to establish proof of claims, damages or refutation of claims in this Action. RESPONSE: Objection. Brown objects to this Request as vague and overly broad. Specifically, Brown objects to the phrase “All documents upon which you intend to rely to establish . . . refutation of claims in this Action” as the Request is too vague, non-specific, and expansive to allow Brown to reasonably identify documents that may be responsive to this request. Brown further objects to this Request to the extent that it seeks documents or information protected from disclosure by the attorney client privilege and attorney work product doctrines. Furthermore, Brown objects to the use of ‘Action’ as it is capable of multiple interpretation, and the Association does not define it. Subject to and without waiving the objections, to the extent that Brown is in possession of any relevant, non-privileged and non-confidential documents, Brown will produce same in accordance with the April 9, 2021 Court Order 4 3.1 & 3.3. 51. A copy of all warranty documents, including extended warranty documents, relating to the Project. RESPONSE: To the extent Brown is in possession of any relevant, non-privileged and non-confidential documents, Brown will produce same in accordance with the April 9, 2021 Court Order §§ 3.1 & 3.3. 52. All written notices provided by or to you or any other person relating to the defects alleged in this Action. RESPONSE: Objection. Brown objects to this Request as vague, overbroad, and unduly burdensome as the Request is not limited in time, scope, scope of the claims being noticed, or as to any person or persons who have either received or sent “written notices”. Additionally, the phrase “written notices” is insufficiently specific, and too expansive to allow Brown to reasonably identify “written notices” that may be responsive to this Request. Furthermore, Brown objects to the use of ‘Action’ as it is capable of multiple interpretations, and the Association does not define ‘Action’. 53. A copy of all building codes, ASTM procedures or any other industry standard for which you allege any person failed to comply it its work relating to construction, maintenance, or remediation of the Project. RESPONSE: Objection. Brown objects to this Request as premature. This matter is in the early stages of discovery and Brown has not engaged a testifying or consulting expert at this time. As such, there are no building codes, ASTM procedures, or industry standards identified at this time. Brown reserves the right to disclose experts and associated expert materials in accordance with applicable Florida Statutes, Florida Rules of Civil Procedure, Florida Rules of Discovery and any Court Order(s) governingexpert discovery and disclosures. Additionally, Brown objects to this Request as ambiguous and vague, as Brown has not asserted any affirmative claims at this time. 54. All settlement agreements or liquidation agreements between you and any other person relating to the construction, maintenance, or remediation of the Project. RESPONSE: Objection. Brown objects to this Request as it seeks irrelevant information, not reasonably calculated to lead to the discovery of relevant or admissible evidence. 55. All documents evidencing bids and proposals submitted by any entity to correct the alleged construction defects asserted by Plaintiff. RESPONSE: Objection. Brown objects to this Request as vague and ambiguous. Specifically, Brown objects to the use of the phrase “alleged construction defects asserted by you”. Brown has not asserted any allegations of construction defects at this time; therefore, this Request is vague, ambiguous, and capable of multiple interpretations. Brown further objects to the Request as overbroad, as the Request also seeks all documents of certain delineated types “submitted by any entity”, not just documents submitted by Brown. 56. A copy of the specifications and standards received by you or from any other person which pertain to the Project’s design, construction, or remediation. RESPONSE: Objection. Brown objects to this Request as vague and ambiguous. Specifically, Brown objects to the use of the phrase “specifications and standards” which are capable of multiple interpretations and the Association does not define the terms. Additionally, the Request does not specify which set of “specifications and standards” is being talked about in the request or what trade the requested “specifications and standards” concern.CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been electronically served via the Florida E-Filing Portal to counsel of record for the parties on the attached Service List, this 10th day of May, 2021. MILBER MAKRIS PLOUSADIS & SEIDEN, LLP Attorneys for Defendant, Brown + Company Architecture, Inc. 1900 NW Corporate Blvd., East Tower, Suite 440 Boca Raton, Florida 33431 bealderon@milbermakris.com dhill@milbermakris.com acreech@milbermakris.com Telephone: 561-994-7310 Facsimile: (561) 994-7313 By: _S:/ Audra R. Creech Bruce R. Calderon Florida Bar No. 50448 D. Bryan Hill Florida Bar No. 113687 Audra R. Creech Florida Bar No. 122373SERVICE LIST Phillip E. Joseph, Esq. Evan J. Small, Esq. Jeffrey A. Widelitz Esq. Nicholas B. Vargo, Esq. Ball Janik, LLP 201 East Pine Street — Suite 600 Orlando, FL 32801 pjoseph@balljanik.com esmall@balljanik.com nvargo@ballianik.om asmith@balljanik.com ypalmer@balljanik.com cbetancourt@balljanik.com mwise@balljanik.com dmiksell@balljanik.com orlandodocket@balljanik.com Counsel for Plaintiff, Villas at Emerald Lake Homeowners Association, Inc. James Michael Walls, Esq. Bryan C. Porter, Esq. Carlton Fields, P.A. 4221 W. Boy Scout Boulevard Tampa, FL 33607-5780 mwalls@ecarltonfields.com bporter@carltonfields.com jcostello@carltonfields.com Counsel for Defendant, Royal Oak Homes, LLC Thamir A. R. Kaddouri, Jr., Esq. Law Office Of Thamir A.R. Kaddouri, Jr., P.A. 3220 West Cypress Street Tampa, FL 33607 Counsel for Defendant, Imperial Building Corporation Paul Sidney Elliott, Esq. P. O. Box 274204 Tampa, FL 33688-4204 pse@pseid.com Counsel for Defendant, Hugh MacDonald Construction, Inc. (HMC)Peter J. Kapsales, Esq. Margaret M. Efta, Esq. Milne Law Group, P.A. 301 East Pine Street — Suite 525 Orlando, FL 32801 pkapsales@milnelawgroup.com mefia@milnelawgroup.com eservice@milnelawgroup.com Counsel for Defendant, Weathermaster Building Products, Inc. Denise M. Anderson, Esq. Kate F. Gaset, Esq. Butler Weihmuller Katz Craig LLP 400 North Ashley Drive — Suite 2300 Tampa, FL 33602 danderson@butler.Jegal kgaset(@pbutler.legal krieck@butler legal rjorge@butler legal dwhite@butler.legal Counsel for Defendants, Don King’s Concrete, Inc. and Hugh MacDonald Construction, Inc. Jayne Ann Pittman, Esq. Natalie C. Fischer, Esq. Conroy Simberg Two South Orange Avenue — Suite 300 Orlando, FL 32801 eserviceorl@conroysimberg.com jpittman@conroysimberg.com nfischer@conroysimberg.com mmaitland@conroysimberg.com Counsel for Defendant, Advanced Wrapping and Concrete Solutions Of Central Florida, Inc. Eric J. Netcher, Esq. Walker, Revels, Greninger & Netcher, PLLC 189 South Orange Avenue - Suite 1830 Orlando, FL 32801 enetcher@wrgn-law.com hpaymayesh@wrgn-law.com Counsel for Third-Party Defendant, All Glass Installation Corp.S. Scott Ross, Esq. Groelle & Salmon, P.A. 1715 N. Westshore Boulevard - Suite 320 Tampa, FL 33607 gstcourtdocs@gspalaw.com sross@gspalaw.com cebanks@gspalaw.com meoleman@gspalaw.com Counsel for Third-Party Defendant, Helberg Enterprises, LLC Cole J. Copertino, Esq. Wright, Fulford, Moorhead & Brown, P.A. 505 Maitland Avenue - Suite 1000 Altamonte Springs, FL 32701 ccopertino@wfimblaw.com cbraungart@wfmblaw.com lwilliams@wfmblaw.com Counsel for Third-Party Defendant, Well Hung Windows & Doors, LLC Alec Masson Luks, Santaniello, Petrillo & Cohen 201 South Orange Avenue — Suite 400 Orlando, FL 32801 luksorl@pleadings@LS-Law.com AMasson@insurancedefense.net JPestonit@insurancedefense.net Counsel for Third-Party Defendant, Casey Hawkins Glass, Inc. Phillip S. Howell, Esq. Kyle R. McNeal, Esq. Galloway, Johnson, Tompkins, Burr & Smith, P.L.C. 400 N. Ashley Drive — Suite 1000 Tampa, FL 33602 tampaservice@gallowaylawfirm.com phowell@gallowaylawfirm.com kmeneal@gallowaylawfirm.com Counsel for Third-Party Defendant, Casey Hawkins Glass, Inc.Andrew T. Marshall, Esq. Hamilton, Price & Marshall, P.A. 2400 Manatee Avenue West Bradenton, FL 34205 Andrew@hamiltonpricelaw.com Nancy@hamiltonpricelaw.com Kelsey@hamiltonpricelaw.com Counsel for T&M Construction of Sanford, Inc. Andrew E. Holway, Esq. Timothy C. Ford, Esq. Hill Ward Henderson, P.A. 101 East Kennedy Boulevard Suite 3700 Tampa, FL 33602 Andrew. holway@hwhlaw.com Tim.ford@hwhlaw.com Kathy.wernsing@hwhlaw.com Tracy.coale@hghlaw.com Derrick.calandra@hghlaw.com Counsel for Weintraub Inspections Joseph L. Zollner Law Office of Christopher J. Norris PO Box 7217 London, KY 40742 FloridaCDLegalMail@LibertyMutual.com Joseph.Zollner@LibertyMutual.com