Preview
Filing # 65665814 E-Filed 12/20/2017 04:36:30 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR ORANGE COUNTY, FLORIDA
CASE NUMBER: 2017-CA-004941-O
PARC SOLEIL VACATION OWNERS
ASSOCIATION, INC., a Florida non-profit
corporation,
Plaintiff,
v.
RICK SINGH, as Property Appraiser;
SCOTT RANDOLPH, as Tax Collector;
and LEON M. BIEGALSKI, as Executive
Director of the Florida Department of Revenue,
Defendants.
/
DEFENDANT, RICK SINGH’S, RESPONSE TO PLAINTIFF’S
FIRST REQUEST FOR PRODUCTION
Defendant, RICK SINGH, as Orange County Property Appraiser (“OCPA”), by counsel
and pursuant to Florida Rule of Civil Procedure 1.350, hereby serves his Response to the First
Request for Production of Plaintiff, PARC SOLEIL VACATION OWNERS ASSOCIATION,
INC., and states as follows:
GENERAL OBJECTIONS
1. OCPA objects to the Request’s Definitions and Instructions to the extent they
purport to require OCPA to take any actions not required or contemplated by the Florida Rules of
Civil Procedure.
RESPONSE TO DOCUMENT REQUESTS
1. To the extent such documents exist and are in OCPA’s possession, custody or
control, OCPA will produce such documents at a mutually convenient date and location.
2. None at this time other than the applicable Florida Statutes and case law.
3. To the extent such documents exist and are in OCPA’s possession, custody, or
control, OCPA will produce such documents at a mutually convenient date and location.
4. To the extent such documents exist and are in OCPA’s possession, custody, or
control, OCPA will produce such documents at a mutually convenient date and location.
5. To the extent such documents exist and are in OCPA’s possession, custody, or
control, OCPA will produce such documents at a mutually convenient date and location.
6. None.
7. Objection: To the extent this request seeks information relating to properties other
than the property that is the subject of this action, it requests documents that are irrelevant and not
reasonably calculated to lead to the discovery of admissible evidence. Such documents also may
contain confidential and proprietary information of other timeshare developers. To the extent such
documents relating to the subject property exist and are in OCPA’s possession, custody, or control,
OCPA will produce such documents at a mutually convenient date and location.
8. To the extent such documents exist and are in OCPA’s possession, custody, or
control, OCPA will produce such documents at a mutually convenient date and location.
9. To the extent such documents exist and are in OCPA’s possession, custody, or
control, OCPA will produce such documents at a mutually convenient date and location.
10. Objection: This request is vague and ambiguous such that OCPA does not
understand the nature and scope of the requested documents and cannot, therefore, frame a response
to it.
11. To the extent such documents exist and are in OCPA’s possession, custody, or
control, OCPA will produce such documents at a mutually convenient date and location.
12. None.
2
13. To the extent such documents exist and are in OCPA’s possession, custody, or
control, OCPA will produce such documents at a mutually convenient date and location.
14. To the extent such documents exist and are in OCPA’s possession, custody, or
control, OCPA will produce such documents at a mutually convenient date and location.
15. Objection: Work product and attorney/client privilege.
16. To the extent such documents exist and are in OCPA’s possession, custody, or
control, OCPA will produce such documents at a mutually convenient date and location.
17. To the extent such documents exist and are in OCPA’s possession, custody, or
control, OCPA will produce such documents at a mutually convenient date and location.
18. To the extent such documents exist and are in OCPA’s possession, custody, or
control, OCPA will produce such documents at a mutually convenient date and location.
19. To the extent such documents exist and are in OCPA’s possession, custody, or
control, OCPA will produce such documents at a mutually convenient date and location.
20. To the extent such documents exist and are in OCPA’s possession, custody, or
control, OCPA will produce such documents at a mutually convenient date and location.
21. To the extent such documents exist and are in OCPA’s possession, custody, or
control, OCPA will produce such documents at a mutually convenient date and location.
22. To the extent such documents exist and are in OCPA’s possession, custody, or
control, OCPA will produce such documents at a mutually convenient date and location.
23. Objection: The word “studies” is not defined and is vague and confusing such that
OCPA cannot understand and formulate a response to this request.
24. None.
25. None.
3
26. To the extent such documents exist and are in OCPA’s possession, custody, or
control, OCPA will produce such documents at a mutually convenient date and location.
27. Objection: Attorney/client privilege and work product.
28. To the extent such documents exist and are in OCPA’s possession, custody, or
control, OCPA will produce such documents at a mutually convenient date and location.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
e-mail on December 20, 2017, to: ROBERT E.V. KELLEY, JR., Hill, Ward & Henderson, P.A.,
101 E. Kennedy Blvd., Suite 3700, Tampa FL 33601 at rob.kelley@hwhlaw.com and
relitrevk@hwhlaw.com, STEVEN R. BECHTEL, Mateer & Harbert, P.A., 225 East Robinson
Street, Suite 600, Orlando, FL 32801 at sbechtel@mateerharbert.com and
phouck@mateerharbert.com; and RANDI E. DINCHER, Office of the Attorney General,
Revenue Litigation Bureau, PL-01, The Capitol, Tallahassee, FL 32399-1050 at
randi.dincher@myfloridalegal.com, lorann.jennings@myfloridalegal.com, and
jon.annette@myfloridalegal.com.
/s/ Kenneth P. Hazouri
KENNETH P. HAZOURI, B.C.S.
Board Certified in Appellate Practice
Florida Bar Number 019800
Primary E-Mail: khazouri@dsklawgroup.com
Secondary E-Mail: lquezada@dsklawgroup.com
de Beaubien, Simmons, Knight,
Mantzaris & Neal, LLP
332 North Magnolia Avenue
Orlando, Florida 32801
Telephone: (407) 422-2454
Attorneys for Rick Singh
4
Preview
Filing # 65665814 E-Filed 12/20/2017 04:36:30 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CASE NUMBER: 2017-CA-004941-O PARC SOLEIL VACATION OWNERS ASSOCIATION, INC., a Florida non-profit corporation, Plaintiff, v. RICK SINGH, as Property Appraiser; SCOTT RANDOLPH, as Tax Collector; and LEON M. BIEGALSKI, as Executive Director of the Florida Department of Revenue, Defendants. / DEFENDANT, RICK SINGH’S, RESPONSE TO PLAINTIFF’S FIRST REQUEST FOR PRODUCTION Defendant, RICK SINGH, as Orange County Property Appraiser (“OCPA”), by counsel and pursuant to Florida Rule of Civil Procedure 1.350, hereby serves his Response to the First Request for Production of Plaintiff, PARC SOLEIL VACATION OWNERS ASSOCIATION, INC., and states as follows: GENERAL OBJECTIONS 1. OCPA objects to the Request’s Definitions and Instructions to the extent they purport to require OCPA to take any actions not required or contemplated by the Florida Rules of Civil Procedure. RESPONSE TO DOCUMENT REQUESTS 1. To the extent such documents exist and are in OCPA’s possession, custody or control, OCPA will produce such documents at a mutually convenient date and location. 2. None at this time other than the applicable Florida Statutes and case law. 3. To the extent such documents exist and are in OCPA’s possession, custody, or control, OCPA will produce such documents at a mutually convenient date and location. 4. To the extent such documents exist and are in OCPA’s possession, custody, or control, OCPA will produce such documents at a mutually convenient date and location. 5. To the extent such documents exist and are in OCPA’s possession, custody, or control, OCPA will produce such documents at a mutually convenient date and location. 6. None. 7. Objection: To the extent this request seeks information relating to properties other than the property that is the subject of this action, it requests documents that are irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. Such documents also may contain confidential and proprietary information of other timeshare developers. To the extent such documents relating to the subject property exist and are in OCPA’s possession, custody, or control, OCPA will produce such documents at a mutually convenient date and location. 8. To the extent such documents exist and are in OCPA’s possession, custody, or control, OCPA will produce such documents at a mutually convenient date and location. 9. To the extent such documents exist and are in OCPA’s possession, custody, or control, OCPA will produce such documents at a mutually convenient date and location. 10. Objection: This request is vague and ambiguous such that OCPA does not understand the nature and scope of the requested documents and cannot, therefore, frame a response to it. 11. To the extent such documents exist and are in OCPA’s possession, custody, or control, OCPA will produce such documents at a mutually convenient date and location. 12. None. 2 13. To the extent such documents exist and are in OCPA’s possession, custody, or control, OCPA will produce such documents at a mutually convenient date and location. 14. To the extent such documents exist and are in OCPA’s possession, custody, or control, OCPA will produce such documents at a mutually convenient date and location. 15. Objection: Work product and attorney/client privilege. 16. To the extent such documents exist and are in OCPA’s possession, custody, or control, OCPA will produce such documents at a mutually convenient date and location. 17. To the extent such documents exist and are in OCPA’s possession, custody, or control, OCPA will produce such documents at a mutually convenient date and location. 18. To the extent such documents exist and are in OCPA’s possession, custody, or control, OCPA will produce such documents at a mutually convenient date and location. 19. To the extent such documents exist and are in OCPA’s possession, custody, or control, OCPA will produce such documents at a mutually convenient date and location. 20. To the extent such documents exist and are in OCPA’s possession, custody, or control, OCPA will produce such documents at a mutually convenient date and location. 21. To the extent such documents exist and are in OCPA’s possession, custody, or control, OCPA will produce such documents at a mutually convenient date and location. 22. To the extent such documents exist and are in OCPA’s possession, custody, or control, OCPA will produce such documents at a mutually convenient date and location. 23. Objection: The word “studies” is not defined and is vague and confusing such that OCPA cannot understand and formulate a response to this request. 24. None. 25. None. 3 26. To the extent such documents exist and are in OCPA’s possession, custody, or control, OCPA will produce such documents at a mutually convenient date and location. 27. Objection: Attorney/client privilege and work product. 28. To the extent such documents exist and are in OCPA’s possession, custody, or control, OCPA will produce such documents at a mutually convenient date and location. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by e-mail on December 20, 2017, to: ROBERT E.V. KELLEY, JR., Hill, Ward & Henderson, P.A., 101 E. Kennedy Blvd., Suite 3700, Tampa FL 33601 at rob.kelley@hwhlaw.com and relitrevk@hwhlaw.com, STEVEN R. BECHTEL, Mateer & Harbert, P.A., 225 East Robinson Street, Suite 600, Orlando, FL 32801 at sbechtel@mateerharbert.com and phouck@mateerharbert.com; and RANDI E. DINCHER, Office of the Attorney General, Revenue Litigation Bureau, PL-01, The Capitol, Tallahassee, FL 32399-1050 at randi.dincher@myfloridalegal.com, lorann.jennings@myfloridalegal.com, and jon.annette@myfloridalegal.com. /s/ Kenneth P. Hazouri KENNETH P. HAZOURI, B.C.S. Board Certified in Appellate Practice Florida Bar Number 019800 Primary E-Mail: khazouri@dsklawgroup.com Secondary E-Mail: lquezada@dsklawgroup.com de Beaubien, Simmons, Knight, Mantzaris & Neal, LLP 332 North Magnolia Avenue Orlando, Florida 32801 Telephone: (407) 422-2454 Attorneys for Rick Singh 4