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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 # 118776693 E-Filed 12/28/2020 03:10:09 PM

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

VILLAS AT EMERALD LAKE
HOMEOWNERS ASSOCIATION, INC.,
a Florida not for profit corporation, Case No.: 2020-CA-2942-ON

Plaintiff,

ve

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
IRRIGATIONS & LANDSCAPING, INC., a
Florida corporation;

SUMMERPARK HOMES, INC., a Florida
corporation; BROWN+COMPANY
ARCHITECTURE, INC., a Florida corporation;

Defendants,
/

DEFENDANT, IMPERIAL BUILDING CORPORATION’S FIRST REQUEST TO
PRODUCE TO DEFENDANT, WEATHERMASTER BUILDING PRODUCTS,
INC.COMES NOW, Defendant, Imperial Building Corporation (“Imperial”), by and
through its undersigned counsel, and pursuant to Florida Rule of Civil Procedure 1.350,
hereby files it First Request to Produce to Defendant, Weathermaster Building Products,
Inc., to be responded to within thirty (30) days from the date of service.

FIRST REQUEST TO PRODUCE TO DEFENDANT,
WEATHERMASTER BUILDING PRODUCTS, INC.

DEFINITIONS
1. The term “Subject Property” refers to the real property and buildings encompassed
in Villas at Emerald Lake, Kissimmee, Florida, 34744.
2. The term “you’ or “your” refers to Defendant, Weathermaster Building Products,

Inc.

 

1. All communications between and among you, the Plaintiff, the other Defendants,
the subcontractors, the material men and equipment suppliers, the field
representatives, consultants, local building authorities, insurance companies, or
any other person, firm, or entity, relating in any way to work performed on the
Subject Property.

2. All documents reflecting the names of any person or entity who performed work
on the Subject Property, including all subcontractors, materialmen, and equipment
suppliers.

3. All contracts, proposals, subcontracts, agreements, assignments, change orders
(approved or not), work orders, and other documents which relate to the design,
development, construction and/or materials for the design, development and/or
construction of the Subject Property.. All requests for information, interpretation, or clarification, of any conflicts in the
contracts, documents, plans and/or specifications for the work performed on the
Subject Property.

. All architectural, structural, site, and manufacturers, and other similar
specifications of the Subject Property, including original issues, revisions, and “as
built” conditions.

. All sketches, photographs, videotape recordings, or other visual or oral recordings
or communications of, or related to, to the Subject Property.

. All inspection reports, analyses, reports, memoranda, and other documents
concerning visits or inspections, whether prepared prior to, during, or after
construction, that relate to the Subject Property.

. All documents, inspection reports, or correspondence sent or delivered to, or
received from, all building department (county or city), or other municipal boards,
private inspectors, or other governmental agencies with respect to the design
and/or construction of the Subject Property.

. All contracts between you and Plaintiff, or the other parties in this lawsuit relating
to the Subject Property.

10. Any and all invoices related to the Subject Project.

11. All documents, bids, and estimates, sent or received from any person for warranty

work or repair work on the Subject Property.

12. All correspondence, contracts, bids, estimates, change orders, billings, checks and

check stubs, showing any amounts incurred or expended to repair, remediate
and/or correct allegedly defective work on the Subject Property.

13. All documents or communications related to any work performed on the framing

system of the Subject Property.14. If you have an opinion as to either Imperials’ quality of workmanship on the
Subject Property or its quality of workmanship on any other project, please
provide documentation that supports the same.CERTIFICATE OF SERVICE

THEREBY CERTIFY that a true and correct copy of the foregoing has been

furnished this day of December 28, 2020, via electronic mail to:

 

Phillip E. Joseph, Esquire

Evan J. Small, Esquire

Jeffrey A. Widelitz, Esquire
Nicholas B. Vargo, Esquire

Ball Janik, LLP

201 E. Pine Street, Suite 600
Orlando, FL 32801
pjoseph@balljanik.com
esmall@balljanik.com
jwidelitz@balljanik.com
nvargo@balljanik.com
ypalmer@balljanik.com
mwise@balljanik.com
orlandodocket@balljanik.com
Counsel for Plaintiff, Villas at Emerald
Lake Homeowners Association, Inc.

Lannie D. Hough Jr., Esquire

Robin Leavengood, Esquire

Carlton Fields

4221 W. Boy Scout Blvd, Suite 1000
Tampa, Florida 33607
lhough@carltonfields.com
nbonilla@carltonfields.com
rleavengood@carltonfields.com
brosa@carltonfields.com
vwilliams@carltonfields.com
Counsel for Defendant, Royal Oak Homes,
LLC

 

Paul Sidney Elliott, Esquire
P.O. Box 274204

Tampa, FL 33688-4204
pse@psejd.com

Counsel for Hugh MacDonald
Construction, Inc.

 

 

Peter J. Kapsales, Esquire

Margaret M. Efta, Esquire

Milne Law Group, P.A.

301 E. Pine Street, Suite 525
Orlando, FL 32801
pkapsales@milnelawgroup.com
mefta@milnelawgroup.com
eservice@milnelawgroup.com
Counsel for Weathermaster Building
Products, Inc.

 

WY Thamtr AR. Kaddourt, Jr.

 

THAMIR A.R. KADDOURL, JR.
Florida Bar No.: 0186600
PENELOPE T. ROWLETT
Florida Bar No.: 0120979

BETH ANN TOBEY

Florida Bar No.: 1008538LAW OFFICE OF THAMIR A. R.
KADDOURI JR., P.A.

3220 West Cypress Street

Tampa, Florida 33607

(813) 879-5752 Tel; (813) 879-5707 Facsimile
THAMIR.KADDOURI@TAMPALAW.ORG;
SERVICE@TAMPALAW.ORG;

Counsel for Defendant, Imperial Building
Corporation