Filing# 85652817 E-Filed 02/28/2019 12:01:33 PM

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT

IN AND FOR PALM BEACH COUNTY, FLORIDA

Case No.: 50-2017-CA-004532-XXXX-MB (AI)

OAKS AT BOCA RATON PROPERTY OWNERS

ASSOCIATION, INC.,
Plaintiff,
vs.

LAURENCE S. SCHNEIDER,
STEPHANIE L. SCHNEIDER,

Defendants.
I

DEFENDANTS LAURENCE S. SCHNEIDER AND ST.E ~ ~IE L. SCHNEIDER'S

FIRST REQUEST FOR THE PRODUCTIO 0F ~ UMENTS TO
PLAINTIFF OAKS AT BOCA RATON PROPER'[¥ 0WNERS ASSOCIATION, INC.

of Civil Procedure 1.3 50, requests that Plai1 ift Oa s f Boca Raton Property Owners Association,

Inc., produce the following docume wi~ in 3'0 days of the date of service hereof at Wyman

Legal Solutions, 955 NW 17th Av

DEFINITIONS

'l\.ssol:. , ''You," or ''Your" means Plaintiff Oaks at Boca Raton Property

affilia es any partnership or joint venture to which it may be a party, and its employees, agents,

offic~ directors, representatives, consultants, accountants, and attorneys, including any person

who served in any such capacity at any time during the relevant time period specified herein.

2. The term "document" means any book, paper, record, or other data or data compilations, whether

written, typed, printed, electronically stored, recorded, or graphic of any kind or description,

WYMAN LEGAL SOLUTIONS • 955 NW 17'" AVENUE, SUITE C •DELRAY BEACH, FL 33445 • (561) 361-8700

FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 02/28/2019 12:01 :33 PM
including originals, non-identical copies, and drafts, and includes all materials within the scope of

Rule l.350(a). The term "document" refers to any document now or at any time in the possession,

custody, or control of the producing party.

3. A person is deemed in "control" of a document ifhe has ownership, possession, or custody of a

document, or the right or ability to secure a document or a copy thereof from any person or public

or private entity with physical possession of the document.

other form of public, private, or legal entity and includes all of tha

5. The "Action" shall mean this proceeding, captione oca Raton Property Owners

Association, Inc. v. Laurence S. Schneider, 5020 l 7CA004532XXXXMBAI,

currently pending in the Palm Beach Coun ,'\

instruction, publication,

contact, discussion, report, o ctronic, or recorded oral exchange between two or more

persons.

a logically or factually connected with the matter.

8. The terms "a m" and "or" shall be construed either conjunctively or disjunctively as necessary
to b. · ~ t in the scope of the request any document, electronically stored information (ESI), or

thing th t might otherwise fall outside its scope.

9. The terms "all," "any," or "each" encompass any and all of the matter discussed.

10. The use of singular form includes plural, and vice versa.

11. The use of present tense includes past tense, and vice versa.

WYMAN LEGAL SOLUTIONS• 955 NW 17'" AVENUE, SUITE C • DELRAY BEACH, FL33445 • (561)361-8700
12. All other capitalized terms used herein shall have the meanings provided for in the Pleadings

in this Action.

INSTRUCTIONS

1. All documents must be produced as they are kept in the usual course of busi~ th any

identifying labels, file markings, or similar identifying features, or shall be orga 1ze~ ana'iabeled

to correspond to the categories requested herein.

2. You must produce electronically stored information (ESI) in its ori

metadata intact. For example:

a. Documents created using Microsoft Word must be prod

b. Emails must be produced as .msg or .pst files.

3. Unless otherwise stated herein, the r~ an tii:ye period for all requested documents,

information, and things is the period comm~'a°}g January 1, 2015 up to and including the date of
y

your response.

things in your possession, cust0 y, or control, or in the possession, custody, or control of your

employees, predecessors successors, subsidiaries, divisions, affiliates, partners, joint venturers,

d to the physical location of such documents.

5. In e~ oncling to these requests, include documents, information, or things obtained on your

behalf by your counsel, employees, agents, or any other persons acting on your behalf. If your

response is that the requested item is not within your possession or custody, describe in detail the

unsuccessful efforts you made to locate each such item. If your response is that the requested item

is not under your control, identify who has the control and the location of each requested item.

WYMAN LEGAL SOLUTIONS• 955 NW 17'" AVENUE, SUITE C • DELRAY BEACH, FL33445 • (561)361-8700
6. If any document, information, or tangible thing was, but no longer is, in your possession,

custody, or control, or in existence, include a statement:

a. identifying the item;

b. describing where the item is now;

c. identifying who has control of the item;

d. describing how the item became lost or destroyed or was transferred; and

e. identifying each of those persons responsible for or having knowledge o · estruction,

or transfer of the requested item from your possession, custody, or control.

7. Each request contemplates production of all documents in th€ir entirety. If a portion of a

document is responsive to one or more requests, the docum n s l He produced in its entirety.

8. If any document or other requested information is hole or in part, by a claim of

privilege, such as attorney-client privilege, work: Rroduct octrine, or trade secret, the producing

party shall set forth separately with respect ,o

a. the ground of confidentiality claim .

b. each and every basis under wh

c. the type of document;

f. other in 0rmatton to enable an assessment of the applicability of the privilege or protection as

req1¥i..,.~ .,;:;..J~..:.. a Rule of Civil Procedure l .28O(b )( 6).

9. To the extent you assert that a document contains information that should be protected from

disclosure (based on the attorney-client privilege, work product doctrine, or another protection),

and non-privileged information, the non-privileged portions of the item must be produced. For

each such document, indicate the portion of the document withheld by stamping the words

WYMAN LEGAL SOLUTIONS• 955 NW 17'" AVENUE, SUITE C • DELRAY BEACH, FL33445 • (561)361-8700
"MATERIAL REDACTED" on the document in an appropriate location that does not obscure the

remaining text.

10. If there are no documents, information, or tangible things in response to any particular request,

or if you withhold any responsive information, you shall state so in writing.

DOCUMENTS REQUESTED -s,,4

:::::r::~:e:l~:~::::. received by you ill respoIBe to c;cument requesffi or
REQUEST NO. 2: All documents referred to or quoted in the

REQUEST NO. 4: All documents that [PROD RTY] will or may introduce as evidence

at trial in this action.

-....._ CERTIFICATE OF SERVICE

ER¥"F'Y that a copy of the foregoing has been served via the Florida Court's

WYMAN LEGAL SOLUTIONS• 955 NW 17'" AVENUE, SUITE C • DELRAY BEACH, FL33445 • (561)361-8700
 RESPECTFULLY SUBMITTED,
WYMAN LEGAL SOLUTIONS
955 NW 17rn A VENUE, SUITE C
DELRAY BEACH, FL 33445
P: (561) 361-8700

SA-
F: (561) 361-8899

BY: Isl Andrew D. Wyman, Esq.

ANDREW D. WYMAN, ESQ.
FLORIDA STATE BARNO.: 3260 ,fl
ANDY@WYMANLEGALSOLUTL0NS.CSO
ATTORNEY FOR DEFENDA)i>fS
LAURENCE S. SCHNEIDER)
STEPHANIE L. SCl:INEIDER:1

SERVIC

ALEKSANDRA NOVAKOVICH, Esq. ~

Attorney for Plaintiff
SACHS, SAX CAPLAN ~
6111 Broken Sound Parkway NW
~~
Boca Raton, FL 33487
foreclosure@ssclawfirm.comG '
agonzalez@ssclawfirm.com
v
crestivo@ssclawfirm.com

~~
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WYMAN LEGAL SOLUTIONS• 955 NW 17m AVENUE, SUITE C • DELRAY BEACH, FL 33445 • (561) 361-8700