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  • VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION INC vs. ROYAL OAK HOMES LLC CONSTRUCTION DEFECT-OTHER NEGLIGENCE document preview
  • VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION INC vs. ROYAL OAK HOMES LLC CONSTRUCTION DEFECT-OTHER NEGLIGENCE document preview
  • VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION INC vs. ROYAL OAK HOMES LLC CONSTRUCTION DEFECT-OTHER NEGLIGENCE document preview
  • VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION INC vs. ROYAL OAK HOMES LLC CONSTRUCTION DEFECT-OTHER NEGLIGENCE document preview
  • VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION INC vs. ROYAL OAK HOMES LLC CONSTRUCTION DEFECT-OTHER NEGLIGENCE document preview
  • VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION INC vs. ROYAL OAK HOMES LLC CONSTRUCTION DEFECT-OTHER NEGLIGENCE document preview
  • VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION INC vs. ROYAL OAK HOMES LLC CONSTRUCTION DEFECT-OTHER NEGLIGENCE document preview
  • VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION INC vs. ROYAL OAK HOMES LLC CONSTRUCTION DEFECT-OTHER NEGLIGENCE document preview 
						
                                
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                                Filing # 125529804 E-Filed 04/23/2021 04:30:43 PM

IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY, FLORIDA

VILLAS AT EMERALD LAKE HOMEOWNERS
ASSOCIATION, INC., a Florida not for profit
corporation,

Plaintiff,
v. CASE NO.: 2020-CA-002942-ON

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;

Defendants.
/

 

ROYAL OAK HOMES, LLC, a Florida limited
liability company;

Crossclaim Plaintiff,
v.
ADVANCED WRAPPING AND CONCRETE

SOLUTIONS OF CENTRAL FLORIDA, INC., a
Florida corporation; DON KING’S CONCRETE,

125856614.1 1INC., 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.
f

DEFENDANT, ROYAL OAK HOMES, LLC
NOTICE OF TAKING DEPOSITION DUCES TECUM

Defendants, ROYAL OAK HOMES, LLC (“Royal Oak”), through the undersigned

counsel, will take the following deposition:

Deponent: Felix Martin
Date: June 15-16, 2021
Time: 9:30 a.m.

Location: Via Zoom Video Conference (Link below to be used both days)

https://us02web.zoom.us/j/84387116581 2pwd=Z1UzbjZGaV V aRHE1LOWwvSC9nQVRgZ209

Meeting ID: 843 8711 6581
Passcode: 157883

This deposition will be conducted upon oral examination, pursuant to Rule 1.390 of the

Florida Rules of Civil Procedure, before a Notary Public of the office of Legal Realtime

Reporting, Inc., or before some other officer authorized by law to administer oaths.

125856614.1 2Per Section 2.1 and 4.2 of the Case Management Order (“CMO”) the Deponent(s)’s
expert job file shall be provided to all parties twenty (20) days prior to the deposition and the
Deponent(s) shall bring to or have with them at the deposition the documents and items listed in
Exhibit “A” hereto.

This deposition is being taken for the purpose of discovery, for use as evidence and for
such other uses and purposes as are permitted under the Florida Rules of Civil Procedure and other

applicable law. Oral examination will continue from day-to-day until completed.

/s/ James Michael Walls
James Michael Walls
Florida Bar No. 706272
Lannie D. Hough Jr.
Florida Bar No. 149470
Robin H. Leavengood
Florida Bar No. 0547751
Brian C. Porter

Florida Bar No, 120282
CARLTON FIELDS, P.A.
4221 W. Boy Scout Boulevard
Tampa, FL 33607-5780
Telephone: (813) 223-7000
Facsimile: (813) 229-4133
lhough@carltonfields.com

   
 

rleavengood@carltonfields.com
brosa@carltonfields.com
mwalls@carltonfields.com
bporter@carltonfields.com
jeostello@carltonfields.com

Attorneys for Defendant, Royal Oak Homes, LLC

 

  

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on April 23, 2021, the foregoing was electronically filed with
the Clerk of the Court by using the E-filing Portal, which will electronically serve this document
to all registered counsel of record.

/s/James Michael Walls
Attorney

125856614.1 3EXHIBIT A

The Witness is requested to bring the documents listed below, that relate to any review,
analysis, inspection, or evaluation of the Villas at Emerald Lake Homeowners Association, Inc.

project:

10.

11.

125856614.1

Your current curriculum vitae or resume.

All reports, correspondence, written information, and all other documents furnished
to you or acquired by you in connection with or relating to your engagement as an
expert witness in this case.

All reports, correspondence, and other documents, including but not limited to, all
photographs, measurements, calculations, models and model results, and all other
documentation of engineering or construction analyses prepared by you or for you
in connection with or relating to your opinion(s) or conclusion(s) in this case.

All letters, correspondence, written communications, and all other documents
relating to any oral communication between you and any party to this case, or the
attorney or any individual acting on behalf of that party, relating to this case.

All depositions, reports, correspondence, information, and all other documents
received or reviewed by you in connection with the development of any opinion or
conclusion reached by you or any other person in this case.

All depositions, reports, correspondence, written information, photographs, and all
other documents relating to any opinion developed by you or any other person in
this case.

All reports, books, treatises, articles, publications, periodicals, literature, cases,
depositions, schedules, information, and all other documents you relied upon in
developing your opinion(s) or conclusion(s) in this case.

All reports, books, treatises, articles, publications, periodicals, literature, cases,
depositions, information and all other documents you referred to or consulted in
developing any opinion(s) or conclusion(s) in this case.

A list identifying other cases over the last five years in which you have testified as
an expert witness, whether by deposition or at trial.

All correspondence, communications, contracts, agreements, invoices, statements,
and all other documents relating to your scope of employment in this case.

All correspondence, communications, contracts, agreements, invoices, statements,
and all other documents relating to your compensation for services rendered by you
in this case.