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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 # 118403143 E-Filed 12/17/2020 03:17:45 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 PLAINTIFF, VILLAS AT EMERALD LAKE HOMEOWNERS
ASSOCIATION, 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 Product to Plaintiff, Villas at Emerald Lake Homeowners
Association, Inc. to be responded to within thirty (30) days from the date of service.

FIRST REQUEST TO PRODUCE TO PLAINTIFF, VILLAS AT EMERALD
LAKE HOMEOWNERS ASSOCIATION, 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 Plaintiff, Villas at Emerald Lake Homeowners

Association, Inc.

REQUESTS

1. All communication between you and Imperial, and all non-privileged
communication between you and any other person, firm or entity, relating in any way to
work performed by Imperial on the Subject Property.

2. All documentation relating to complaints about the work performed by
Imperial on the Subject Property.

3. All quotations, bids for quotes, invitations to bid, or other documentation
containing actual or estimated prices or costs of repair work at the Subject Property.

4. All quotations, bids, and invoices for any repairs or remediation for defects
or damages arising from or attributed to Imperial’s work on the Subject Property.5. All quotations, bids, and invoices for any repairs or remediation for defects
or damages related to the framing of the Subject Property.

6. All quotations, bids, and invoices for any repairs or remediation for defects
or damages related to water damage at the Subject Property.

7. All contracts, proposals, subcontracts, agreements, assignments, change
orders (approved or not), field orders, work orders, requests for quotations, and other
documents which relate to the design, development, construction and/or materials for the
work performed by Imperial on the Subject Property.

8. All photographs, videos, or drawings of the work performed on the Subject
Property from the time of construction to the present, including any areas that you
contend have been defectively constructed, or in need of repair or remediation.

9. All photographs, videos, or drawings of the framing of the Subject
Property.

10. All photographs, videos, or drawings of any type of water damage to the
Subject Property.

11. All architectural plans, structural plans, surveys, site, plat and shop
drawings, working drawings, and other documents involving work of any nature on the
Subject Property from the time of construction to the present.

12. All documents showing any inspection of the Subject Property, including,
without limitation, all non-privileged inspection reports, analyses, reports, memoranda,
and other documents concerning inspection-related visits, regarding or involving work at
the subject property from the time of construction to the present.

13. All documentation and photographs of the location of each alleged code
violation for which you contend Imperial is responsible.14. All documentation and photographs showing the location of each alleged

code violation.

15. All documentation and photographs showing damage to personal property
other than the property you contend to be the subject of the code violation(s).

CERTIFICATE OF SERVICE

THEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished this day of December 17, 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,
LLCWY 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.: 1008538

LAW OFFICE OF THAMIR A. R.
KADDOURL 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