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Filing # 118783022 E-Filed 12/28/2020 04:05:29 PM
IN THE CIRCUIT COURT OF
THE NINTH JUDICIAL
CIRCUIT IN AND FOR
ORANGE COUNTY, FLORIDA
DIANA K. WINKLER and CASE NO.: 2018-CA-006581-O
MICHAEL J. WINKLER,
Plaintiffs,
v.
CHRISTOPHER P. HANCOCK;
LUXUS LEGAL, LLC; HANCOCK
& ASSOCIATES, P.A.;
ANDREA A. MCCREARY;
MICHAEL E. MORRIS; LAW OFFICE
OF MICHAEL E. MORRIS, P.A.;
HYATT LEGAL PLANS OF FLORIDA, INC.;
JENNIFER ENGLERT; and THE ORLANDO
LAW GROUP,
Defendants.
__________________________________/
DEFENDANT THE ORLANDO LAW GROUP’S RESPONSES TO
PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION OF DOCUMENTS
Defendant, The Orlando Law Group (hereinafter “Defendant”), pursuant to Florida
Rules of Civil Procedure, Rule 1.350, hereby responds to Plaintiffs’ First Request for
Production of Documents served with the Complaint as follows:
PRELIMINARY STATEMENT
These responses have been prepared pursuant to a reasonably diligent inquiry for the
information requested. They reflect information obtained by Defendant pursuant to a reasonably
diligent inquiry conducted in connection with these discovery requests in those areas where
information is expected to be found. To the extent that any of these Requests purport to require
more, DEFENDANT objects on the grounds that they impose an undue burden or expense.
The information provided in these responses is based upon such information as is
reasonably available to Defendant, and Defendant expressly reserves the right, without assuming
any duty not required by the Florida Rules of Civil Procedure or order of this Court, to revise,
correct, add to, or clarify any of these responses when and if additional information or
documentation comes to its attention.
Whether responding to each Request by answer or objection, Defendant does not concede
the relevance, materiality or admissibility as evidence for any purpose of any of these Requests,
the responses thereto or the subject matter to which they refer.
Defendant reserves the right to supplement or amend these objections and responses upon,
among other things: further investigation; discovery of additional facts; discovery of persons with
knowledge of relevant information; developments in this action or any other proceedings.
GENERAL OBJECTIONS
Without in any way limiting the Preliminary Statement set forth above, Defendant asserts
the following General Objections to all of the Requests, which objections are hereby incorporated
by reference into each of Defendant’s specific answers and/or objections. Defendant’s specific
answers and/or objections, which Defendant expressly reserves the right to amend, supplement,
and/or correct, are submitted subject to and without waiver of these General Objections.
1. Defendant objects to the Requests to the extent Plaintiffs seek information,
documents, or responses relating to matters that are not raised in the pleadings, claims or defenses
on the grounds that the information is not relevant to this action and not reasonably calculated to
lead to the discovery of admissible evidence. Rule 1.280, Florida Rules of Civil Procedure, states
in pertinent part: “Parties may obtain discovery regarding any matter, not privileged, that is
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relevant to the subject matter of the pending action, whether it relates to the claim or defense of
the party seeking discovery or the claim or defense of any other party, including the existence,
description, nature, custody, condition, and location of any books, documents, or other tangible
things and the identity and location of persons having knowledge of any discoverable matter. It is
not ground for objection that the information sought will be inadmissible at the trial if the
information sought appears reasonably calculated to lead to the discovery of admissible
evidence.” (emphasis added).
2. Defendant objects to the Requests to the extent Plaintiffs seek information that is
not within its possession, custody, or control and/or is uniquely within the knowledge of Plaintiffs
or other third parties with knowledge relevant to this action.
3. Defendant objects to the Requests to the extent Plaintiffs seek information that is
vague, overbroad, unduly burdensome, oppressive, vexatious, or not reasonably calculated to lead
to the discovery of admissible evidence.
4. Defendant objects generally to each and every Request to the extent it calls for
information that is protected from disclosure by any applicable privilege or protection from
discovery including, but not limited to, the attorney-client and/or work product privileges. In
addition, certain of the documents requested may be otherwise confidential or contain
commercially sensitive information and will be provided by Defendant only upon and conditioned
upon the prior entry of, and subject to, an appropriate protective order.
5. Defendant objects generally to the Requests, including their definitions and
instructions, to the extent that they seek to impose burdens or duties upon Defendant that are
greater than are required by the Florida Rules of Civil Procedure and/or applicable law.
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6. Defendant objects generally to each and every Request to the extent the response
thereto would cause undue burden, undue expense, and/or oppression.
7. Defendant’s decision to provide responses to the Requests and/or to provide
documents pursuant to same, notwithstanding the objectionable nature of the Requests themselves,
should not be construed as, and is not: (a) an admission that the material is relevant; (b) a waiver
of the General Objections, or the specific objections asserted in response to the Requests; or (c) an
agreement that requests for similar responses and documents will be treated in a similar manner.
8. Defendant reserves the right to object to the use of any document produced in
response to the Requests, or the subject matter thereof, on any ground in any further proceeding in
this action, including, but not limited to, the trial of this action, and in any other action or
proceeding.
9. Defendant objects generally to the Requests to the extent they fail to describe the
information or documents sought with reasonable particularity such that Defendant must speculate
as to the information or documents sought.
10. Defendant objects generally to the Requests to the extent they purport to require
Defendant to search the files of third parties, on the grounds that such Requests are overly broad
or unduly burdensome. Defendant also objects to the Requests to the extent they purport to require
Defendant to provide information or produce documents in the possession or custody of third
parties, on the grounds that such Requests seek information that is neither relevant to the subject
matter of this litigation, nor reasonably calculated to lead to the discovery of admissible evidence.
RESPONSES AND OBJECTIONS TO SPECIFIC REQUESTS
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Without in any way limiting the Preliminary Statement and General Objections set forth
above, Defendant asserts these additional, specific objections and responses to the correspondingly
numbered Requests:
REQUEST NO. 1: Any communications, inclusive of texts and e-mails,
exchanged between you and Hyatt Legal since becoming a part of their network prior to
your filing of a Notice of Withdrawal in the Old Case which involved the Winklers.
RESPONSE: Any and all documents responsive to this request, which are
within the possession and control of Defendant will be made available for
inspection and copying at a mutually agreeable time and location.
REQUEST NO. 2: Any communications, inclusive of texts and e-mails,
exchanged between you and Hyatt Legal since becoming a part of their network on and
after your filing of a Notice of Withdrawal in the Old Case which involved the Winklers.
RESPONSE: Any and all documents responsive to this request, which are
within the possession and control of Defendant will be made available for
inspection and copying at a mutually agreeable time and location.
REQUEST NO. 3: Any written contract and agreement entered into by and
between you and/or your law firm and Hyatt that then allowed you to represent the
Winklers in the Old Case.
RESPONSE: Defendant is not in possession of any documents which would
be responsive to this request.
REQUEST NO. 4: Any communications, inclusive of texts and e-mail, exchanged
between you and Hancock, relating to the Old Case which involved the Winklers and/or
this case.
RESPONSE: Any and all documents responsive to this request, which are
within the possession and control of Defendant will be made available for
inspection and copying at a mutually agreeable time and location.
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REQUEST NO. 5: Any communications, inclusive of texts and e-mail, exchanged
between you and Morris, relating to the foreclosure matter involving the Winklers and/or
this case.
RESPONSE: Defendant is not in possession of any documents which would
be responsive to this request.
REQUEST NO. 6: Any communications, inclusive of texts and e-mail, exchanged
between you and McCreary, relating to the Old Case which involved the Winklers and/or
this case.
RESPONSE: Defendant is not in possession of any documents which would
be responsive to this request.
REQUEST NO. 7: Any communications, inclusive of texts and e-mail, exchanged
between you and any other person or entity relating in any way to the Winklers.
RESPONSE: Defendant objects to this request on the grounds that it is so
overly broad that it could be so widely construed so as to encompass attorney-
client communications or work product, including that containing mental
impressions of counsel. Without waiving said objections, any and all
documents responsive to this request, not subject to privilege, which are within
the possession and control of Defendant will be made available for inspection
and copying at a mutually agreeable time and location.
REQUEST NO. 8: Any communications, inclusive of texts and e-mail, exchanged
with opposing parties or their counsel in this case.
RESPONSE: Defendant objects to this request on the grounds that it is so
overly broad that it could be so widely construed so as to encompass attorney-
client communications or work product, including that containing mental
impressions of counsel. Without waiving said objections, any and all
documents responsive to this request, not subject to privilege, which are within
the possession and control of Defendant will be made available for inspection
and copying at a mutually agreeable time and location.
REQUEST NO. 9: A copy of your law firm’s litigation files, inclusive of
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communications with the opposing parties or their counsel and communications with the
court, judges, or the judicial assistants, as it relates to your handling of any matter for the
Winklers inclusive of the Old Case.
RESPONSE: Defendant objects to this request on the grounds that it is so
overly broad that it could be so widely construed so as to encompass attorney-
client communications or work product, including that containing mental
impressions of counsel. Without waiving said objections, any and all
documents responsive to this request, not subject to privilege, which are within
the possession and control of Defendant will be made available for inspection
and copying at a mutually agreeable time and location.
REQUEST NO. 10: Any documents you drafted and prepared and filed in the Old
Case involving Plaintiffs.
RESPONSE: Any and all documents responsive to this request, which are
within the possession and control of Defendant will be made available for
inspection and copying at a mutually agreeable time and location.
REQUEST NO. 11: Any Codes of Excellence executed at the request of Hyatt
Legal, similar in form to that which is attached as Exhibit “A.”
RESPONSE: Defendant is not in possession of any documents which would
be responsive to this request.
REQUEST NO. 12: Any documents or communications between Hyatt/Hyatt
Legal and you or your law firm relating to the vetting process that was prior to you
becoming one of the Hyatt attorneys in their network.
RESPONSE: Defendant is not in possession of any documents which would
be responsive to this request.
REQUEST NO. 13: Any documents or communications between Hyatt Legal and
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you or your law firm regarding your presentation of your credentials meeting the standards
in their Code of Excellence.
RESPONSE: Defendant is not in possession of any documents which would
be responsive to this request.
REQUEST NO. 14: Any other documents executed at the request of Hyatt Legal
that addressed the quality of your legal work.
RESPONSE: Defendant is not in possession of any documents which would
be responsive to this request.
REQUEST NO. 15: Any communications, inclusive of texts and e-mails,
exchanged between you and Hyatt Legal, relating to the Old Case and your representation
of the Winklers.
RESPONSE: Any and all documents responsive to this request, which are
within the possession and control of Defendant will be made available for
inspection and copying at a mutually agreeable time and location.
REQUEST NO. 16: Any communications, inclusive of texts and e-mails,
exchanged between you and Hyatt Legal, relating to this case.
RESPONSE: Defendant is not in possession of any documents which would
be responsive to this request.
REQUEST NO. 17: Any communications or documents, inclusive of texts and ex-
mails, exchanged between you and Hyatt/Hyatt Legal, relating to your termination as a
network attorney with Hyatt/Hyatt Legal or otherwise explaining why you ceased to be a
network attorney with Hyatt/Hyatt Legal.
RESPONSE: Defendant is not in possession of any documents which would
be responsive to this request.
REQUEST NO. 18: All documents upon which you intend to rely or did rely when
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preparing your answers to the First Set of Interrogatories served on you simultaneously
with this request.
RESPONSE: Any and all documents responsive to this request, which are
within the possession and control of Defendant will be made available for
inspection and copying at a mutually agreeable time and location.
CERTIFICATE OF SERVICE
I hereby certify that on December 28, 2020, a true and correct copy of the foregoing
was filed with the Clerk of Court using the Florida Courts E-Filing Portal, which will serve
a copy via e-mail on the following: T. SCOTT TUFTS, ESQUIRE, (stufs@cplspa.com;
ecasado@cplspa.com; courtefilings@cplspa.com), CPLS, P.A. (Attorneys for Plaintiffs);
CHRISTOPHER P. HANCOCK, ESQUIRE & HANCOCK & ASSOCIATES, P.A.,
(chancock@luxuslegal.com), (Attorneys for Defendants); DAMON I. WEISS,
ESQUIRE, (amccreary@wgworl.com), Weiss, Gruner, Barclay & Barnett, (Attorneys for
Andrea McCreary, Esquire); and JOHN E. MEAGHER, ESQUIRE and JEFFREY M.
LANDAU, ESQUIRE, (jlandau@shutts.com), Shutts & Bowen LLP, (Attorneys for Hyatt
Legal Plans of Florida, Inc.).
I further hereby certify on December 28, 2020, that a copy hereof has been furnished
by electronic mail to:: T. SCOTT TUFTS, ESQUIRE, (stufs@cplspa.com;
ecasado@cplspa.com; courtefilings@cplspa.com), CPLS, P.A. (Attorneys for Plaintiffs);
CHRISTOPHER P. HANCOCK, ESQUIRE & HANCOCK & ASSOCIATES, P.A.,
(chancock@luxuslegal.com), (Defendants); DAMON I. WEISS, ESQUIRE,
(amccreary@wgworl.com), Weiss, Gruner, Barclay & Barnett, (Attorneys for Andrea
McCreary, Esquire); and JOHN E. MEAGHER, ESQUIRE and JEFFREY M.
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LANDAU, ESQUIRE, (jlandau@shutts.com), Shutts & Bowen LLP, (Attorneys for Hyatt
Legal Plans of Florida, Inc.).
/s/ Sean M. McDonough
SEAN M. McDONOUGH, ESQUIRE
Florida Bar No. 896446
sean.mcdonough@wilsonelser.com
A. DONALD SCOTT, JR., ESQUIRE
Florida Bar No.110432
a.donald.scottjr@wilsonelser.com
Wilson Elser Moskowitz Edelman & Dicker LLP
111 North Orange Avenue, Suite 1200
Orlando, Florida 32801
407-203-7599—Phone
407-648-1376—Facsimile
Attorneys for Defendants,
Jennifer Englert and The Orlando Law Group
SMM:ajc
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Preview
Filing # 118783022 E-Filed 12/28/2020 04:05:29 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA DIANA K. WINKLER and CASE NO.: 2018-CA-006581-O MICHAEL J. WINKLER, Plaintiffs, v. CHRISTOPHER P. HANCOCK; LUXUS LEGAL, LLC; HANCOCK & ASSOCIATES, P.A.; ANDREA A. MCCREARY; MICHAEL E. MORRIS; LAW OFFICE OF MICHAEL E. MORRIS, P.A.; HYATT LEGAL PLANS OF FLORIDA, INC.; JENNIFER ENGLERT; and THE ORLANDO LAW GROUP, Defendants. __________________________________/ DEFENDANT THE ORLANDO LAW GROUP’S RESPONSES TO PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION OF DOCUMENTS Defendant, The Orlando Law Group (hereinafter “Defendant”), pursuant to Florida Rules of Civil Procedure, Rule 1.350, hereby responds to Plaintiffs’ First Request for Production of Documents served with the Complaint as follows: PRELIMINARY STATEMENT These responses have been prepared pursuant to a reasonably diligent inquiry for the information requested. They reflect information obtained by Defendant pursuant to a reasonably diligent inquiry conducted in connection with these discovery requests in those areas where information is expected to be found. To the extent that any of these Requests purport to require more, DEFENDANT objects on the grounds that they impose an undue burden or expense. The information provided in these responses is based upon such information as is reasonably available to Defendant, and Defendant expressly reserves the right, without assuming any duty not required by the Florida Rules of Civil Procedure or order of this Court, to revise, correct, add to, or clarify any of these responses when and if additional information or documentation comes to its attention. Whether responding to each Request by answer or objection, Defendant does not concede the relevance, materiality or admissibility as evidence for any purpose of any of these Requests, the responses thereto or the subject matter to which they refer. Defendant reserves the right to supplement or amend these objections and responses upon, among other things: further investigation; discovery of additional facts; discovery of persons with knowledge of relevant information; developments in this action or any other proceedings. GENERAL OBJECTIONS Without in any way limiting the Preliminary Statement set forth above, Defendant asserts the following General Objections to all of the Requests, which objections are hereby incorporated by reference into each of Defendant’s specific answers and/or objections. Defendant’s specific answers and/or objections, which Defendant expressly reserves the right to amend, supplement, and/or correct, are submitted subject to and without waiver of these General Objections. 1. Defendant objects to the Requests to the extent Plaintiffs seek information, documents, or responses relating to matters that are not raised in the pleadings, claims or defenses on the grounds that the information is not relevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Rule 1.280, Florida Rules of Civil Procedure, states in pertinent part: “Parties may obtain discovery regarding any matter, not privileged, that is 2 relevant to the subject matter of the pending action, whether it relates to the claim or defense of the party seeking discovery or the claim or defense of any other party, including the existence, description, nature, custody, condition, and location of any books, documents, or other tangible things and the identity and location of persons having knowledge of any discoverable matter. It is not ground for objection that the information sought will be inadmissible at the trial if the information sought appears reasonably calculated to lead to the discovery of admissible evidence.” (emphasis added). 2. Defendant objects to the Requests to the extent Plaintiffs seek information that is not within its possession, custody, or control and/or is uniquely within the knowledge of Plaintiffs or other third parties with knowledge relevant to this action. 3. Defendant objects to the Requests to the extent Plaintiffs seek information that is vague, overbroad, unduly burdensome, oppressive, vexatious, or not reasonably calculated to lead to the discovery of admissible evidence. 4. Defendant objects generally to each and every Request to the extent it calls for information that is protected from disclosure by any applicable privilege or protection from discovery including, but not limited to, the attorney-client and/or work product privileges. In addition, certain of the documents requested may be otherwise confidential or contain commercially sensitive information and will be provided by Defendant only upon and conditioned upon the prior entry of, and subject to, an appropriate protective order. 5. Defendant objects generally to the Requests, including their definitions and instructions, to the extent that they seek to impose burdens or duties upon Defendant that are greater than are required by the Florida Rules of Civil Procedure and/or applicable law. 3 6. Defendant objects generally to each and every Request to the extent the response thereto would cause undue burden, undue expense, and/or oppression. 7. Defendant’s decision to provide responses to the Requests and/or to provide documents pursuant to same, notwithstanding the objectionable nature of the Requests themselves, should not be construed as, and is not: (a) an admission that the material is relevant; (b) a waiver of the General Objections, or the specific objections asserted in response to the Requests; or (c) an agreement that requests for similar responses and documents will be treated in a similar manner. 8. Defendant reserves the right to object to the use of any document produced in response to the Requests, or the subject matter thereof, on any ground in any further proceeding in this action, including, but not limited to, the trial of this action, and in any other action or proceeding. 9. Defendant objects generally to the Requests to the extent they fail to describe the information or documents sought with reasonable particularity such that Defendant must speculate as to the information or documents sought. 10. Defendant objects generally to the Requests to the extent they purport to require Defendant to search the files of third parties, on the grounds that such Requests are overly broad or unduly burdensome. Defendant also objects to the Requests to the extent they purport to require Defendant to provide information or produce documents in the possession or custody of third parties, on the grounds that such Requests seek information that is neither relevant to the subject matter of this litigation, nor reasonably calculated to lead to the discovery of admissible evidence. RESPONSES AND OBJECTIONS TO SPECIFIC REQUESTS 4 Without in any way limiting the Preliminary Statement and General Objections set forth above, Defendant asserts these additional, specific objections and responses to the correspondingly numbered Requests: REQUEST NO. 1: Any communications, inclusive of texts and e-mails, exchanged between you and Hyatt Legal since becoming a part of their network prior to your filing of a Notice of Withdrawal in the Old Case which involved the Winklers. RESPONSE: Any and all documents responsive to this request, which are within the possession and control of Defendant will be made available for inspection and copying at a mutually agreeable time and location. REQUEST NO. 2: Any communications, inclusive of texts and e-mails, exchanged between you and Hyatt Legal since becoming a part of their network on and after your filing of a Notice of Withdrawal in the Old Case which involved the Winklers. RESPONSE: Any and all documents responsive to this request, which are within the possession and control of Defendant will be made available for inspection and copying at a mutually agreeable time and location. REQUEST NO. 3: Any written contract and agreement entered into by and between you and/or your law firm and Hyatt that then allowed you to represent the Winklers in the Old Case. RESPONSE: Defendant is not in possession of any documents which would be responsive to this request. REQUEST NO. 4: Any communications, inclusive of texts and e-mail, exchanged between you and Hancock, relating to the Old Case which involved the Winklers and/or this case. RESPONSE: Any and all documents responsive to this request, which are within the possession and control of Defendant will be made available for inspection and copying at a mutually agreeable time and location. 5 REQUEST NO. 5: Any communications, inclusive of texts and e-mail, exchanged between you and Morris, relating to the foreclosure matter involving the Winklers and/or this case. RESPONSE: Defendant is not in possession of any documents which would be responsive to this request. REQUEST NO. 6: Any communications, inclusive of texts and e-mail, exchanged between you and McCreary, relating to the Old Case which involved the Winklers and/or this case. RESPONSE: Defendant is not in possession of any documents which would be responsive to this request. REQUEST NO. 7: Any communications, inclusive of texts and e-mail, exchanged between you and any other person or entity relating in any way to the Winklers. RESPONSE: Defendant objects to this request on the grounds that it is so overly broad that it could be so widely construed so as to encompass attorney- client communications or work product, including that containing mental impressions of counsel. Without waiving said objections, any and all documents responsive to this request, not subject to privilege, which are within the possession and control of Defendant will be made available for inspection and copying at a mutually agreeable time and location. REQUEST NO. 8: Any communications, inclusive of texts and e-mail, exchanged with opposing parties or their counsel in this case. RESPONSE: Defendant objects to this request on the grounds that it is so overly broad that it could be so widely construed so as to encompass attorney- client communications or work product, including that containing mental impressions of counsel. Without waiving said objections, any and all documents responsive to this request, not subject to privilege, which are within the possession and control of Defendant will be made available for inspection and copying at a mutually agreeable time and location. REQUEST NO. 9: A copy of your law firm’s litigation files, inclusive of 6 communications with the opposing parties or their counsel and communications with the court, judges, or the judicial assistants, as it relates to your handling of any matter for the Winklers inclusive of the Old Case. RESPONSE: Defendant objects to this request on the grounds that it is so overly broad that it could be so widely construed so as to encompass attorney- client communications or work product, including that containing mental impressions of counsel. Without waiving said objections, any and all documents responsive to this request, not subject to privilege, which are within the possession and control of Defendant will be made available for inspection and copying at a mutually agreeable time and location. REQUEST NO. 10: Any documents you drafted and prepared and filed in the Old Case involving Plaintiffs. RESPONSE: Any and all documents responsive to this request, which are within the possession and control of Defendant will be made available for inspection and copying at a mutually agreeable time and location. REQUEST NO. 11: Any Codes of Excellence executed at the request of Hyatt Legal, similar in form to that which is attached as Exhibit “A.” RESPONSE: Defendant is not in possession of any documents which would be responsive to this request. REQUEST NO. 12: Any documents or communications between Hyatt/Hyatt Legal and you or your law firm relating to the vetting process that was prior to you becoming one of the Hyatt attorneys in their network. RESPONSE: Defendant is not in possession of any documents which would be responsive to this request. REQUEST NO. 13: Any documents or communications between Hyatt Legal and 7 you or your law firm regarding your presentation of your credentials meeting the standards in their Code of Excellence. RESPONSE: Defendant is not in possession of any documents which would be responsive to this request. REQUEST NO. 14: Any other documents executed at the request of Hyatt Legal that addressed the quality of your legal work. RESPONSE: Defendant is not in possession of any documents which would be responsive to this request. REQUEST NO. 15: Any communications, inclusive of texts and e-mails, exchanged between you and Hyatt Legal, relating to the Old Case and your representation of the Winklers. RESPONSE: Any and all documents responsive to this request, which are within the possession and control of Defendant will be made available for inspection and copying at a mutually agreeable time and location. REQUEST NO. 16: Any communications, inclusive of texts and e-mails, exchanged between you and Hyatt Legal, relating to this case. RESPONSE: Defendant is not in possession of any documents which would be responsive to this request. REQUEST NO. 17: Any communications or documents, inclusive of texts and ex- mails, exchanged between you and Hyatt/Hyatt Legal, relating to your termination as a network attorney with Hyatt/Hyatt Legal or otherwise explaining why you ceased to be a network attorney with Hyatt/Hyatt Legal. RESPONSE: Defendant is not in possession of any documents which would be responsive to this request. REQUEST NO. 18: All documents upon which you intend to rely or did rely when 8 preparing your answers to the First Set of Interrogatories served on you simultaneously with this request. RESPONSE: Any and all documents responsive to this request, which are within the possession and control of Defendant will be made available for inspection and copying at a mutually agreeable time and location. CERTIFICATE OF SERVICE I hereby certify that on December 28, 2020, a true and correct copy of the foregoing was filed with the Clerk of Court using the Florida Courts E-Filing Portal, which will serve a copy via e-mail on the following: T. SCOTT TUFTS, ESQUIRE, (stufs@cplspa.com; ecasado@cplspa.com; courtefilings@cplspa.com), CPLS, P.A. (Attorneys for Plaintiffs); CHRISTOPHER P. HANCOCK, ESQUIRE & HANCOCK & ASSOCIATES, P.A., (chancock@luxuslegal.com), (Attorneys for Defendants); DAMON I. WEISS, ESQUIRE, (amccreary@wgworl.com), Weiss, Gruner, Barclay & Barnett, (Attorneys for Andrea McCreary, Esquire); and JOHN E. MEAGHER, ESQUIRE and JEFFREY M. LANDAU, ESQUIRE, (jlandau@shutts.com), Shutts & Bowen LLP, (Attorneys for Hyatt Legal Plans of Florida, Inc.). I further hereby certify on December 28, 2020, that a copy hereof has been furnished by electronic mail to:: T. SCOTT TUFTS, ESQUIRE, (stufs@cplspa.com; ecasado@cplspa.com; courtefilings@cplspa.com), CPLS, P.A. (Attorneys for Plaintiffs); CHRISTOPHER P. HANCOCK, ESQUIRE & HANCOCK & ASSOCIATES, P.A., (chancock@luxuslegal.com), (Defendants); DAMON I. WEISS, ESQUIRE, (amccreary@wgworl.com), Weiss, Gruner, Barclay & Barnett, (Attorneys for Andrea McCreary, Esquire); and JOHN E. MEAGHER, ESQUIRE and JEFFREY M. 9 LANDAU, ESQUIRE, (jlandau@shutts.com), Shutts & Bowen LLP, (Attorneys for Hyatt Legal Plans of Florida, Inc.). /s/ Sean M. McDonough SEAN M. McDONOUGH, ESQUIRE Florida Bar No. 896446 sean.mcdonough@wilsonelser.com A. DONALD SCOTT, JR., ESQUIRE Florida Bar No.110432 a.donald.scottjr@wilsonelser.com Wilson Elser Moskowitz Edelman & Dicker LLP 111 North Orange Avenue, Suite 1200 Orlando, Florida 32801 407-203-7599—Phone 407-648-1376—Facsimile Attorneys for Defendants, Jennifer Englert and The Orlando Law Group SMM:ajc 10