UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

Fort Lauderdale Division 

 Case No. 22-61638-CIV-DIMITROULEAS 

 

CONDOMINIUM ASSOCIATION OF 

PARKER PLAZA ESTATES, INC., 

Plaintiff, 

v. 

PAVEL MOREFF and SIMON 

SHERMAN, 

 

Defendants. 

DEFENDANT, PAVEL MOREFF’S, RESPONSES AND OBJECTIONS TO 

PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS 

REQUESTED TO BE PROVIDED ON AN EXPEDITED BASIS

 Defendant, PAVEL MOREFF (“Moreff”), by and through undersigned counsel, hereby 

objects and responds to Plaintiff, CONDOMINIUM ASSOCIATION OF PARKER PLAZA 

ESTATES, INC.’s (“Plaintiff”), First Request for Production of Documents Requested to be 

Provided on an Expedited Basis (the “Document Request”), and states as follows:

GENERAL OBJECTIONS

1. Moreff objects to the Document Request to the extent it seeks 

documents/information not in his possession, custody or control.

EXHIBIT "C"

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2. Moreff objects to the Document Request to the extent it seeks 

documents/information which are publicly or otherwise available and/or uniquely or equally 

available from third parties, including Plaintiff.

3. Moreff objects to the Document Request insofar as it seeks documents/information 

that do not specifically refer to the events which are the subject matter of this litigation.

4. Moreff objects to the Document Request to the extent it seeks 

documents/information prepared in anticipation of litigation, protected by the attorney-client 

privilege, the work-product privilege, and any other privilege, protection, or immunity applicable 

under the governing law.

5. Moreff objects to the Document Request to the extent it is overly broad, unduly 

burdensome, oppressive, and/or seek documents/information that are not relevant to the issues in 

this proceeding, or reasonably calculated to lead to the discovery of admissible evidence.

6. Moreff objects to the Document Request to the extent it contains any express or 

implied assumptions of fact or law concerning matters at issue in this litigation.

7. Moreff does not waive their right to object, on any and all grounds, to (1) the 

evidentiary use of the information contained in this Response; and (2) discovery requests relating 

to this Response.

8. Moreff is providing this Response based upon terms as they are commonly 

understood, and consistent with the Federal Rules Civil Procedure. Defendant objects to, and will 

refrain from, extending or modifying any words employed in the Document Request to comport 

with expanded definitions or instructions.

9. Moreff submits his responses and objections without conceding the relevancy or 

materiality of the subject matter of any request or of any document, or that any responsive 

materials exist.

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10. The inadvertent production or disclosure of any privileged documents or 

information shall not constitute or be deemed a waiver of any applicable privilege with respect to 

such document (or the contents or subject matter thereof) or with respect to any such other 

document or discovery now or hereafter requested or provided.

11. This Response has been prepared on the basis of information now known to 

Moreff, and the objections and responses contained herein are made without waiving any further 

objections to, or admitting the relevancy or materiality of, any of the information requested. 

Moreff’s investigation, discovery, and preparation for this proceeding are continuing, and this 

Response is being provided without prejudice to Moreff’s right to introduce or object to the 

discovery of any documents, facts, or information discovered after the date hereof.

12. Moreff reserves the right to supplement/amend this Response.

REQUESTS FOR PRODUCTION

1. All communications disseminated from freedom4ppa@gmail.com. 

Response: This Request is overly broad and unduly burdensome. It does not contain a 

timeframe, nor does it define what documents “disseminated” from the above email 

address are related to, or regarding. By way of example, someone could have sent an email 

from the above-referenced email address asking his wife what time dinner was, or who

won the Miami Dolphins’ football game, and such documents would be responsive to this 

impermissible fishing expedition. This Request is also objected to because is not relevant 

to any party’s claim or defense. As noted above, an email could have been “disseminated” 

from the above email address about any topic whatsoever, at any time.

2. All communications disseminated from pmoreff.pp@gmail.com related to the 

Association. 

Response: Responsive documents are being produced contemporaneously herewith at 

Bates 1 through 840.

3. All Facebook Posts posted in the Sherman Facebook 

Group by freedom4ppa@gmail.com, pmoreff.pp@gmail.com, or any other account you own or 

manage. 

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Response: Responsive documents are being produced contemporaneously herewith at 

Bates 1 through 840.

4. All email communications disseminated regarding any "GoFundMe" page of which 

Simon Sherman is the promoter or organizer relating in any way to the Parker Plaza or its 

Association. 

Response: Any email communications regarding any “GoFundMe” page or account has 

nothing to do with any party’s claim or defense and, is therefore, not relevant. 

5. All social media posts and messages by you related in any way to the Association. 

Response: This Request is overly broad and unduly burdensome. It does not contain a 

timeframe. Moreover, the phrase “related to the Association” is not narrowly tailored, 

which also results in this Request as being objectionable because it is not relevant to any 

party’s claim or defense. 

6. All documents and communications between you and IGOR in any way related to the 

Association. 

Response: This Request is overly broad and unduly burdensome. It does not contain a 

timeframe. Moreover, the phrase “related to the Association” is not narrowly tailored, 

which also results in this Request as being objectionable because it is not relevant to any 

party’s claim or defense. 

7. All documents and communications between you and FREEDOM4PPA in any way 

related to the Association. 

Response: This Request is overly broad and unduly burdensome. It does not contain a 

timeframe. Moreover, the phrase “related to the Association” is not narrowly tailored, 

which also results in this Request as being objectionable because it is not relevant to any 

party’s claim or defense. 

8. All documents and communications between you and Vlad Gorny or Big Apple 

Services LLC, with an owner address of 2030 S. Ocean Drive, Apt. 1106, Hallandale 

Beach, Florida 33009, related to the fictitious name of "PARKER PLAZA ESTATES". 

Response: No such documents are in Mr. Moreff’s possession, custody, or control.

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9. All documents evidencing your claim that any Director, the management, vendors or 

contractors of the Association have engaged in irregularities in the management of 

funds of the Association. 

Response: Responsive documents are being produced contemporaneously herewith at 

Bates 1 through 840.

10. All documents evidencing your claim that any Director, the management, vendors or 

contractors of the Association have engaged in criminal mismanagement of the 

Association. 

Response: Responsive documents are being produced contemporaneously herewith at 

Bates 1 through 840.

11. All documents evidencing and supporting your claim that any Director, the 

management, vendors or contractors of the Association have engaged in corruption by 

the Association. 

Response: Responsive documents are being produced contemporaneously herewith at 

Bates 1 through 840.

12. Any and all documents evidencing the misconduct of Association as alleged in your 

Affidavit that, "Surprisingly, the proposal, agreement and contract differ significantly 

in technical and budgetary aspects from each other which were not disclosed to 

members of the Association, nor approved at a duly noticed Board meeting, in 

derogation of Chapter 718 of the Florida Statutes, and the Association's governing 

documents". s

Response: Responsive documents are being produced contemporaneously herewith at 

Bates 1 through 840.

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Dated: July 5, 2023 Respectfully submitted,

LUBLINER LAW PLLC

1645 Palm Beach Lakes Boulevard, Suite 1200

West Palm Beach, Florida 33401

Telephone: (561) 207-2018

Facsimile: (561) 584-7227

rich@lubliner-law.com

carolina@lubliner-law.com 

 By: /s/ Richard S. Lubliner 

Richard S. Lubliner, Esquire 

FBN 47741

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