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, SIMON SHERMAN’S, RESPONSES AND OBJECTIONS

TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF 

DOCUMENTS REQUESTED TO BE PROVIDED ON AN EXPEDITED 

BASIS

 Defendant, SIMON SHERMAN (“Sherman”), 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. Sherman objects to the Document Request to the extent it seeks 

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

EXHIBIT "B"

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2. Sherman 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. Sherman 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. Sherman 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. Sherman 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. Sherman 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. Sherman 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. Sherman is providing this Response based upon terms as they are commonly 

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

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

with expanded definitions or instructions.

9. Sherman 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 

Sherman, 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. 

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

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

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

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

REQUESTS FOR PRODUCTION

1. All communications disseminated from "Parker Plaza"

pploudspeaker@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 abovereferenced 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 ssherm@unmc.edu 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. This email address has been Mr. Sherman’s personal and/or work 

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email for approximately thirty (30) years. He could have emailed his wife about getting 

their car from the Association parking lot, and such would be responsive this Request.

3. All communications disseminated from ssherm@unmc.edu 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. This email address has been Mr. Sherman’s personal email 

address for years. He could have emailed his wife about getting their car from the 

Association parking lot, and such would be responsive this Request.

4. All Facebook Posts posted in the Sherman Facebook Group by "Parker Plaza" 

pploudspeaker@gmail.com, ssherm@unmc.edu, s.sherman2030@gmail.com, or any other 

account you own or manage. 

Response: Responsive documents are being produced contemporaneously herewith at 

Bates 1 through 840. 

5. All documents relating to the proper publication and registration, and the ownership 

and authorization to use the fictitious name PARKER PLAZA ESTATES and all instances of use 

of use of said fictitious name.

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

6. All documents reflecting all communications, including emails, letters, and social 

media posts, sent by Sherman with the display name PARKER PLAZA to the members and 

nonmembers of the Association including but not limited to any communication in response from 

members that received said communications who indicated being confused as to whether the 

communications with the display name PARKER PLAZA were sent on behalf of the Association 

or not. 

Response: Responsive documents are being produced contemporaneously herewith at 

Bates 1 through 840. 

7. All email communications disseminated regarding any "GoFundMe" page or 

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account of which you are the organizer or promoter 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.

8. All Facebook Posts posted in the Sherman Facebook Group regarding any 

"GoFundMe" page of which you are the organizer or promoter relating in any way to the Parker 

Plaza or its Association. 

Response: See Response No. 7.

9. 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. By way of example, in 2010, Mr. Sherman could have posted on 

social media that he lives in the building managed by the Association. 

10. 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. 

11. 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. 

12. 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" or its registration.

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

13. All documents and communications where the fictitious name of "PARKER 

PLAZA ESTATES", registered with the State of Florida Department of State, has been used in any 

way. 

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

14. All documents evidencing your claims that there have been or are irregularities in 

the management of funds by the Association. 

Response: Responsive documents are being produced contemporaneously herewith at 

Bates 1 through 840. 

15. All documents evidencing your claims 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. 

16. All documents evidencing and supporting your claim that there is corruption by the 

Association, any Director, the management, vendors or contractors. 

Response: Responsive documents are being produced contemporaneously herewith at 

Bates 1 through 840. 

17. All documents evidencing and supporting your claim in your Affidavit that, "While 

I served on the Board, I discovered that some of the conduct of the Association was not in 

compliance with our governing documents and Chapter 718". 

Response: Responsive documents are being produced contemporaneously herewith at 

Bates 1 through 840. 

18. All documents evidencing and supporting your claim in your Affidavit that, 

"Currently, violations with online voting continue". 

Response: Responsive documents are being produced contemporaneously herewith at 

Bates 1 through 840. 

19. All documents evidencing and supporting your claim that Michael Fagan is a 

"Malicious Property Tax Evader...." 

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Response: Responsive documents are being produced contemporaneously herewith at 

Bates 1 through 840. 

20. All documents related to the collection of funds for the investigation of the

Association by South Florida Property Owners Consulting, LLC ("S") and C&G Financial 

Group ("C&G"), the investigation by SPOC and C&G, the report or reports and the 

dissemination of the conclusions reached by SPOC and C&G to members or non-members of 

the Association. 

Response: Mr. Sherman objects to the portion of this Request that relates to the “collection 

of funds” as such is not relevant to any party’s claim or defense. Documents responsive to the 

balance of this Request are being produced contemporaneously herewith at Bates 1 through 840. 

21. All documents related to the collection of funds for any investigation of the 

Association. 

Response: This Request is not relevant to any party’s claim or defense. 

Dated: July 5, 2024 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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