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Filing # 66189489 E-Filed 01/05/2018 05:06:05 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR ORANGE COUNTY, FLORIDA
NEW PENN FINANCIAL, LLC D/B/A
SHELL POINT MORTGAGE SERVICING,
Plaintiff,
vs. Case No.: 2017-CA-004879-O
ROBERT J. CRAGER, et al.,
Defendants.
________________________________________/
DEFENDANT’S, CS TERRACES, LLC, AS TRUSTEE UNDER LAND TRUST
134B DATED JUNE 24, 2012, RESPONSES TO PLAINTIFF’S FIRST REQUEST
FOR PRODUCTION
COMES NOW, Defendant, CS TERRACES, LLC, AS TRUSTEE UNDER
LAND TRUST 134B DATED JUNE 24, 2012 hereby files its Responses to Plaintiff’s
First Request for Production as follows:
1. OBJECTION: OVERLY BROAD and UNDULY BURDENSOME.
Furthermore, the information sought should already be within Plaintiff’s
custody, possession, and control anyway, and is equally if not more available
to Plaintiff as Defendant, and as such, is sought for the purposes of harassing
and annoying Defendant.
2. OBJECTION: OVERLY BROAD and UNDULY BURDENSOME.
Furthermore, the information sought should already be within Plaintiff’s
custody, possession, and control anyway, and is equally if not more available
to Plaintiff as Defendant, and as such, is sought for the purposes of harassing
and annoying Defendant.
3. OBJECTION: OVERLY BROAD and UNDULY BURDENSOME.
Furthermore, the information sought should already be within Plaintiff’s
custody, possession, and control anyway, and is equally if not more available
to Plaintiff as Defendant, and as such, is sought for the purposes of harassing
and annoying Defendant.
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4. OBJECTION: OVERLY BROAD and UNDULY BURDENSOME.
Furthermore, the information sought should already be within Plaintiff’s
custody, possession, and control anyway, and is equally if not more available
to Plaintiff as Defendant, and as such, is sought for the purposes of harassing
and annoying Defendant.
5. OBJECTION: OVERLY BROAD and UNDULY BURDENSOME.
Furthermore, the information sought should already be within Plaintiff’s
custody, possession, and control anyway, and is equally if not more available
to Plaintiff as Defendant, and as such, is sought for the purposes of harassing
and annoying Defendant.
6. OBJECTION: IRRELEVANT and NOT REASONABLY CALCULATED
TO LEAD TO THE DISCOVERY OF ADMISSIBLE EVIDENCE.
Furthermore, the information sought should already be within Plaintiff’s
custody, possession, and control anyway, and is equally if not more available
to Plaintiff as Defendant, and as such, is sought for the purposes of harassing
and annoying Defendant.
7. The documents requested that are within Defendant’s possession, custody and
control shall be provided at a mutually agreeable time and place.
8. The documents requested that are within Defendant’s possession, custody and
control shall be provided at a mutually agreeable time and place.
9. The documents requested that are within Defendant’s possession, custody and
control shall be provided at a mutually agreeable time and place.
10. Not applicable. Defendant has yet to respond to Plaintiff’s Interrogatories.
11. The documents requested that are within Defendant’s possession, custody and
control shall be provided at a mutually agreeable time and place.
12. OBJECTION: OVERLY BROAD, UNDULY BURDENSOME
IRRELEVANT and NOT REASONABLY CALCULATED TO LEAD TO
THE DISCOVERY OF ADMISSIBLE EVIDENCE.
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13. OBJECTION: OVERLY BROAD, UNDULY BURDENSOME
IRRELEVANT and NOT REASONABLY CALCULATED TO LEAD TO
THE DISCOVERY OF ADMISSIBLE EVIDENCE.
14. Not applicable.
15. Not applicable.
16. Not applicable.
/s/ ANTHONY N. LEGENDRE, II, Esq.
ANTHONY N. LEGENDRE, II, Esq.
Fla. Bar No.: 67221
Primary E-mail: anthonylegendre@live.com
Secondary E-mail: Anthony@Law-Legends.com
Secondary E-mail: Ronald@Law-legends.com
Law Offices of Legendre & Legendre, PLLC
P.O. Box 948599
Maitland, FL 32794-8599
(407) 460-8525
CERTIFICATE OF SERVICE
I HEREBY CERTIFY, that a true and correct copy of the foregoing has been
furnished by email through the E-Portal to Plaintiff’s Attorneys this 5th day of January,
2018.
/s/ ANTHONY N. LEGENDRE, II, Esq.
ANTHONY N. LEGENDRE, II, Esq.
Fla. Bar No.: 67221
Primary E-mail: anthonylegendre@live.com
Secondary E-mail: Anthony@Law-Legends.com
Secondary E-mail: Ronald@Law-legends.com
Law Offices of Legendre & Legendre, PLLC
P.O. Box 948599
Maitland, FL 32794-8599
(407) 460-8525
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Filing # 66189489 E-Filed 01/05/2018 05:06:05 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA NEW PENN FINANCIAL, LLC D/B/A SHELL POINT MORTGAGE SERVICING, Plaintiff, vs. Case No.: 2017-CA-004879-O ROBERT J. CRAGER, et al., Defendants. ________________________________________/ DEFENDANT’S, CS TERRACES, LLC, AS TRUSTEE UNDER LAND TRUST 134B DATED JUNE 24, 2012, RESPONSES TO PLAINTIFF’S FIRST REQUEST FOR PRODUCTION COMES NOW, Defendant, CS TERRACES, LLC, AS TRUSTEE UNDER LAND TRUST 134B DATED JUNE 24, 2012 hereby files its Responses to Plaintiff’s First Request for Production as follows: 1. OBJECTION: OVERLY BROAD and UNDULY BURDENSOME. Furthermore, the information sought should already be within Plaintiff’s custody, possession, and control anyway, and is equally if not more available to Plaintiff as Defendant, and as such, is sought for the purposes of harassing and annoying Defendant. 2. OBJECTION: OVERLY BROAD and UNDULY BURDENSOME. Furthermore, the information sought should already be within Plaintiff’s custody, possession, and control anyway, and is equally if not more available to Plaintiff as Defendant, and as such, is sought for the purposes of harassing and annoying Defendant. 3. OBJECTION: OVERLY BROAD and UNDULY BURDENSOME. Furthermore, the information sought should already be within Plaintiff’s custody, possession, and control anyway, and is equally if not more available to Plaintiff as Defendant, and as such, is sought for the purposes of harassing and annoying Defendant. 1 4. OBJECTION: OVERLY BROAD and UNDULY BURDENSOME. Furthermore, the information sought should already be within Plaintiff’s custody, possession, and control anyway, and is equally if not more available to Plaintiff as Defendant, and as such, is sought for the purposes of harassing and annoying Defendant. 5. OBJECTION: OVERLY BROAD and UNDULY BURDENSOME. Furthermore, the information sought should already be within Plaintiff’s custody, possession, and control anyway, and is equally if not more available to Plaintiff as Defendant, and as such, is sought for the purposes of harassing and annoying Defendant. 6. OBJECTION: IRRELEVANT and NOT REASONABLY CALCULATED TO LEAD TO THE DISCOVERY OF ADMISSIBLE EVIDENCE. Furthermore, the information sought should already be within Plaintiff’s custody, possession, and control anyway, and is equally if not more available to Plaintiff as Defendant, and as such, is sought for the purposes of harassing and annoying Defendant. 7. The documents requested that are within Defendant’s possession, custody and control shall be provided at a mutually agreeable time and place. 8. The documents requested that are within Defendant’s possession, custody and control shall be provided at a mutually agreeable time and place. 9. The documents requested that are within Defendant’s possession, custody and control shall be provided at a mutually agreeable time and place. 10. Not applicable. Defendant has yet to respond to Plaintiff’s Interrogatories. 11. The documents requested that are within Defendant’s possession, custody and control shall be provided at a mutually agreeable time and place. 12. OBJECTION: OVERLY BROAD, UNDULY BURDENSOME IRRELEVANT and NOT REASONABLY CALCULATED TO LEAD TO THE DISCOVERY OF ADMISSIBLE EVIDENCE. 2 13. OBJECTION: OVERLY BROAD, UNDULY BURDENSOME IRRELEVANT and NOT REASONABLY CALCULATED TO LEAD TO THE DISCOVERY OF ADMISSIBLE EVIDENCE. 14. Not applicable. 15. Not applicable. 16. Not applicable. /s/ ANTHONY N. LEGENDRE, II, Esq. ANTHONY N. LEGENDRE, II, Esq. Fla. Bar No.: 67221 Primary E-mail: anthonylegendre@live.com Secondary E-mail: Anthony@Law-Legends.com Secondary E-mail: Ronald@Law-legends.com Law Offices of Legendre & Legendre, PLLC P.O. Box 948599 Maitland, FL 32794-8599 (407) 460-8525 CERTIFICATE OF SERVICE I HEREBY CERTIFY, that a true and correct copy of the foregoing has been furnished by email through the E-Portal to Plaintiff’s Attorneys this 5th day of January, 2018. /s/ ANTHONY N. LEGENDRE, II, Esq. ANTHONY N. LEGENDRE, II, Esq. Fla. Bar No.: 67221 Primary E-mail: anthonylegendre@live.com Secondary E-mail: Anthony@Law-Legends.com Secondary E-mail: Ronald@Law-legends.com Law Offices of Legendre & Legendre, PLLC P.O. Box 948599 Maitland, FL 32794-8599 (407) 460-8525 3