FOWLER WHITE BURNETT P.A. • BRICKELL ARCH, 1395 BRICKELL AVENUE, 14TH FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200

 

PLAINTIFF'S FIRST REQUEST FOR PRODUCTION 

OF DOCUMENTS TO DEFENDANT, SIMON SHERMAN 

REQUESTED TO BE PROVIDED ON AN EXPEDITED BASIS 

Plaintiff, CONDOMINIUM ASSOCIATION OF PARKER PLAZA ESTATES, INC. , by 

and through undersigned counsel, hereby requests Defendant, SIMON SHERMAN, to produce the 

following within the time prescribed by the applicable Federal Rules of Civil Procedure or as 

ordered on an expedited basis by the Court pursuant to Plaintiff's Expedited Verified Rule 56(d) 

Motion for the Court to expedite discovery to be able to respond to Defendants' motion for 

summary judgment as follows: 

DEFINITIONS

1. The term "Action" shall mean the above-captioned action. 

2. The term "Complaint" shall mean the document titled First Amended Complaint, 

filed in this Court on November 17, 2022. 

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.

COMPOSITE EXHIBIT "A"

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FOWLER WHITE BURNETT P.A. • BRICKELL ARCH, 1395 BRICKELL AVENUE, 14TH FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200

3. The term "Sherman" "you," and/or "your" shall mean the Defendant, in the abovecaptioned action, Simon Sherman, and, where applicable, any of Sherman's agents, attorneys, 

employees, collaborators, fellow participants, assistants, predecessors, or successors. 

4. The term "Parker Plaza" shall mean the building located at 2030 S Ocean Dr., 

Hallandale Beach, Florida 33009. 

5. The term "Association" shall mean the Plaintiff, Condominium Association of 

Parker Plaza Estates, Inc. 

6. The term "IGOR" shall mean the group of individuals formed by Sherman and 

others who own or reside at Parker Plaza and refer to themselves as "Initiative Group of Owners 

and Residents". 

7. The term "Sherman Facebook Group" shall mean the Facebook group that Sherman 

and others created called "Parker Plaza Owners". 

8. The term "FREEDOM4PPA" shall mean the group of individuals who formed 

"Freedom for Parker Plaza Association", managed by Pavel Moreff. 

9. The term "Affidavit" shall mean the Affidavit of Simon Sherman in Support of 

Defendants' Motion for Summary Judgment filed in this Action on April 10, 2023 [ECF No. 39]. 

10. As used in these requests, (i) the terms “all,” “any,” and “each” shall each be 

construed as encompassing any and all, (ii) the connectives “and” and “or” shall be construed 

either disjunctively or conjunctively as necessary to bring within the scope of the discovery request 

all responses that might otherwise be construed to be outside of its scope, and (iii) the singular 

form of a noun or pronoun includes the plural form and vice versa. Additionally, regardless of the 

tense employed, all verbs shall be read as applying to the past, present and future as is necessary 

to make any paragraph more, rather than less, inclusive. 

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FOWLER WHITE BURNETT P.A. • BRICKELL ARCH, 1395 BRICKELL AVENUE, 14TH FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200

11. The term “concerning” and/or "relating to" shall mean, without limitation, relating 

to, referring to, describing, evidencing, regarding, consisting of, constituting, containing, 

mentioning, summarizing, listing, indicating, analyzing, explaining, supporting, undermining, 

contradicting, pertaining to, prepared in connection with, used in preparation for, or being in any 

way legally, logically, or factually connected with the matter discussed. 

12. The term “document” shall mean any printed, written, typed, recorded, transcribed, 

taped, photographic, or graphic matter, however produced or reproduced, including, but not limited 

to: any letter, correspondence, notation, or statement of any nature whatsoever between or among 

two or more persons, by or to whomever made, dialogues, discussions, e-mail, interviews, 

consultations, agreements, other understandings, or communication of any sort; film, print or 

negative of photograph; sound recording; video recording; note, notebook, diary, calendar, 

minutes, memorandum, contract, agreement, or any amendment thereto; telex, telegram, cable; 

summary, report or record of telephone conversation, voice mail or voice mail back-up, personal 

conversation, discussion, interview, meeting, conference, investigation, negotiation, act or 

activity; projection, work paper, or draft; computer or computer network output or input, hard or 

floppy disc, e-mail, magnetic and/or optical medias, archived or back up data on any of these 

medias, and documents that have been deleted but are recoverable from any of these medias; 

opinion or report of consultant; request, order, invoice or bill of lading; analysis, diagram, map, 

index, sketch, drawing, plan, chart, manual, brochure, pamphlet, advertisement, circular, 

newspaper or magazine clipping, press release; receipt, journal, ledger, schedule, bill, or voucher; 

financial statement, statement of account, bank statement, checkbook, stubs, or register, canceled 

check, deposit slip, charge slip, tax return (income or other), requisition; file, study, graph, 

tabulation, and any and all other writings and recordings of whatever nature, whether signed or 

Case 0:22-cv-61638-WPD Document 58-1 Entered on FLSD Docket 09/01/2023 Page 3 of 23
 CASE NO. 22-61638-CIV-DIMITROULEAS 

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FOWLER WHITE BURNETT P.A. • BRICKELL ARCH, 1395 BRICKELL AVENUE, 14TH FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200

unsigned or transcribed, and any other data compilation from which information can be obtained, 

translated, if necessary, by the respondent through detection devices into reasonably usable form; 

or other tangible things which constitute or contain matters within the scope of the Florida Rules 

of Civil Procedure, and which are within the possession, custody, or control of you or any past or 

present agent, employee, consultant, attorney, or any other person acting on your behalf. The term 

“document” also includes the file, folder, tabs, and labels attached to or containing any document. 

Any document with any marks such as initials, comments, or notations of any kind is not deemed 

to be identical to one without such marks and is a separate document within the meaning of this 

term. 

13. When referring to a person, “identify” shall mean to give, to the extent known, the 

person’s full name, present or last known address, and when referring to a natural person, 

additionally, the present or last known place of employment. Once a person has been identified in 

accordance with this subparagraph, only the name of that person need be listed in response to 

subsequent discovery requesting the identification of that person. 

14. When referring to documents, “identify” shall mean to give, to the extent known, 

the (i) type of document; (ii) general subject matter; (iii) date of the document; and (iv) author(s), 

addressee(s) and recipient(s). 

15. The term “including” shall mean “including, but not limited to” so as to require the 

broadest possible inclusion. 

10. The term “person” shall mean an individual, corporation, partnership, trust, 

association, company, organization, or any form of a business or commercial entity. 

INSTRUCTIONS 

1. You are requested to produce all responsive documents in your possession, custody, 

or control, wherever located, including, without limitation, those in the custody of your affiliates, 

Case 0:22-cv-61638-WPD Document 58-1 Entered on FLSD Docket 09/01/2023 Page 4 of 23
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FOWLER WHITE BURNETT P.A. • BRICKELL ARCH, 1395 BRICKELL AVENUE, 14TH FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200

subsidiaries, parent corporations, predecessors, or successor entities and all of their respective 

current or former directors, officers, employees, agents, attorneys, advisors, and representatives, 

or other person acting or purporting to act on its or their behalf, or acted or purported to act, on its 

or their behalf. A document is deemed to be in your possession, custody, or control if it is in your 

physical custody or if it is in the physical custody of any other person or entity and you: (a) own 

such document in whole or in part; (b) have a right, by contract, statute, or otherwise, to use, 

inspect, examine, or copy such document on any terms; (c) have an understanding, express or 

implied, that you may use, inspect, examine, or copy such document on any terms; or (d) as a 

practical matter, have been able to use, inspect, examine, or copy such document when you sought 

to do so. 

2. If a privilege is claimed in response to any item number of this request, you are to 

provide a Privilege Log, setting forth the identity of the document for which such privilege is 

claimed, the type of document, the general subject matter of the document, the name of all 

individuals or entities listed or mentioned in such document, the date it was generated, the 

individual or entity that produced, generated, or composed the document, and the names of all 

person or entities that received a copy of the document. Notwithstanding the assertion of any 

privilege or other protection, any requested document that contains any responsive, non-privileged 

or non-protected information shall be produced, but that portion of the document for which the 

privilege or other protection is asserted may be redacted, provided that the redacted portion is 

identified and described consistently according to the requirements listed above. 

3. If there are no documents responsive to any particular request, you are to state so 

in writing. 

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FOWLER WHITE BURNETT P.A. • BRICKELL ARCH, 1395 BRICKELL AVENUE, 14TH FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200

4. If you object to any request, state in full the basis for your objection. If you object 

to part of a request, specify the portion of the request to which you object and answer so much of 

the request as is not objectionable. 

5. Where any copy of any document whose production is sought herein, whether a 

draft or final version, is not identical to any other copy thereof, by reason of alterations, notes, 

comments, initials, underscoring, indication of routing, or other material contained thereon or 

attached thereto, all such non-identical copies are to be produced separately. 

6. If any document requested herein was formerly in your possession, custody, or 

control (or that of your representative or affiliate) and has been lost or destroyed or otherwise 

disposed of, you are requested to submit in lieu of any such document a written statement (a) 

describing in detail the nature of the document and its contents, (b) identifying the person(s) who 

prepared or authored the document and, if applicable, the person(s) to whom the document was 

sent, (c) specifying the date on which the document was prepared or transmitted, and (d) specifying 

the date on which the document was lost or destroyed and, if destroyed, the conditions of and 

reasons for such destruction and the person(s) requesting and performing the destruction. 

7. A request for any document shall be deemed to include a request for any and all 

transmittal sheets, cover letters, originals, non-identical copies, exhibits, enclosures, or 

attachments to such document, in addition to the document in its full and unexpurgated form. 

8. Where only a portion of a document relates or refers to the subject indicated, the 

entire document is to be produced nevertheless, along with all attachments, appendices, and 

exhibits. 

9. Each document produced in response to the requests below should be clearly 

categorized to indicate to which of the requests set forth herein it is responsive. Responses to this 

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FOWLER WHITE BURNETT P.A. • BRICKELL ARCH, 1395 BRICKELL AVENUE, 14TH FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200

request for production of documents shall be submitted in a form so that the response follows the 

retyped request for production of documents to which it applies. 

10. All documents shall be produced in the manner they are kept in the ordinary course 

of business and in their original file folders with any identifying labels, file markings, or similar 

identifying features. Documents attached to each other should not be separated. The name of the 

file from which a document was produced, the identity of the person from whose file the document 

was produced, and the identity of the present custodian of that file shall be set forth. 

11. Documents created or stored electronically must be produced in their original 

electronic format, with the original metadata intact, and not printed to paper or PDF. All 

electronically stored information (“ESI”) shall be produced in electronic form (the “production 

set”). Each document will have its own unique identifier (“Bates number”), which must be 

consistently formatted across the production, comprising of an alpha prefix and a fixed length 

number of digits (e.g., “PREFIX0000001”). 

12. The relevant period is the time period between August 2019 to the present. 

PLAINTIFF'S FIRST REQUEST FOR 

PRODUCTION OF DOCUMENTS TO DEFENDANT, SIMON SHERMAN 

1. All communications disseminated from "Parker Plaza" 

pploudspeaker@gmail.com. 

2. All communications disseminated from ssherm@unmc.edu related to the 

Association. 

3. All communications disseminated from s.sherman2030@gmail.com related to the 

Association. 

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 CASE NO. 22-61638-CIV-DIMITROULEAS 

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FOWLER WHITE BURNETT P.A. • BRICKELL ARCH, 1395 BRICKELL AVENUE, 14TH FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200

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. 

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 said fictitious name. 

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. 

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

account of which you are the organizer or promoter relating in any way to the Parker Plaza or its 

Association. 

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. 

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

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

the Association. 

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

related to the Association. 

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 CASE NO. 22-61638-CIV-DIMITROULEAS 

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FOWLER WHITE BURNETT P.A. • BRICKELL ARCH, 1395 BRICKELL AVENUE, 14TH FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200

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. 

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. 

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

the management of funds by the Association. 

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. 

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

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

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". 

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

"Currently, violations with online voting continue". 

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

"Malicious Property Tax Evader...." 

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

Association by South Florida Property Owners Consulting, LLC ("SPOC") 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. 

Case 0:22-cv-61638-WPD Document 58-1 Entered on FLSD Docket 09/01/2023 Page 9 of 23
 CASE NO. 22-61638-CIV-DIMITROULEAS 

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FOWLER WHITE BURNETT P.A. • BRICKELL ARCH, 1395 BRICKELL AVENUE, 14TH FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200

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

Association. 

 

Case 0:22-cv-61638-WPD Document 58-1 Entered on FLSD Docket 09/01/2023 Page 10 of 23
 CASE NO. 22-61638-CIV-DIMITROULEAS 

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FOWLER WHITE BURNETT P.A. • BRICKELL ARCH, 1395 BRICKELL AVENUE, 14TH FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200

Respectfully submitted,

/s/ Luis S. Konski

 Luis S. Konski 

Fla. Bar No. 207837 

Email: lkonski@fowler-white.com 

Daniel A. Milian, Esq. 

Fla. Bar No. 74803 

Email: dmilian@fowler-white.com 

Ana E. Tovar 

Fla. Bar No. 1008100 

Email: atovar@fowler-white.com 

FOWLER WHITE BURNETT, P.A. 

Brickell Arch, Fourteenth Floor 

1395 Brickell Avenue 

Miami, Florida 33131 

Telephone: (305) 789-9200 

Facsimile: (305) 789-9201

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FOWLER WHITE BURNETT P.A. • BRICKELL ARCH, 1395 BRICKELL AVENUE, 14TH FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200

CERTIFICATE OF SERVICE 

 I HEREBY CERTIFY that on May 22, 2023, the foregoing document was electronically 

served upon: Richard S. Lubliner, Esq., Lubliner Law, PLLC, Counsel for Defendants, 1645 Palm 

Beach Lakes Boulevard, Suite 1200, West Palm Beach, Florida 33401, rich@lubliner-law.com, 

carolina@lubliner-law.com. 

/s/ Luis S. Konski

Luis S. Konski

Case 0:22-cv-61638-WPD Document 58-1 Entered on FLSD Docket 09/01/2023 Page 12 of 23
FOWLER WHITE BURNETT P.A. • BRICKELL ARCH, 1395 BRICKELL AVENUE, 14TH FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200

 

PLAINTIFF'S FIRST REQUEST FOR PRODUCTION 

OF DOCUMENTS TO DEFENDANT, PAVEL MOREFF 

REQUESTED TO BE PROVIDED ON AN EXPEDITED BASIS 

Plaintiff, CONDOMINIUM ASSOCIATION OF PARKER PLAZA ESTATES, INC., by 

and through undersigned counsel, hereby requests Defendant, PAVEL MOREFF, to produce the 

following within the time prescribed by the applicable Federal Rules of Civil Procedure or as 

ordered on an expedited basis by the Court pursuant to Plaintiff's Expedited Verified Rule 56(d) 

Motion for the Court to expedite discovery to be able to respond to Defendants' motion for 

summary judgment as follows: 

DEFINITIONS

1. The term "Action" shall mean the above-captioned action. 

2. The term "Complaint" shall mean the document titled First Amended Complaint, 

filed in this Court on November 17, 2022. 

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.

Case 0:22-cv-61638-WPD Document 58-1 Entered on FLSD Docket 09/01/2023 Page 13 of 23
 CASE NO. 22-61638-CIV-DIMITROULEAS 

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FOWLER WHITE BURNETT P.A. • BRICKELL ARCH, 1395 BRICKELL AVENUE, 14TH FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200

3. The term "Moreff" "you," and/or "your" shall mean the Defendant, in the abovecaptioned action, Pavel Moreff, and, where applicable, any of Moreff's agents, attorneys, 

employees, collaborators, fellow participants, assistants, predecessors, or successors. 

4. The term "Sherman" shall mean co-defendant in this Action, Simon Sherman. 

5. The term "Parker Plaza" shall mean the building located at 2030 S Ocean Dr., 

Hallandale Beach, Florida 33009. 

6. The term "Association" shall mean the Plaintiff, Condominium Association of 

Parker Plaza Estates, Inc. 

7. The term "IGOR" shall mean the group of individuals formed by Simon Sherman 

and others who own or reside at Parker Plaza and refer to themselves as "Initiative Group of 

Owners and Residents". 

8. The term "Sherman Facebook Group" shall mean the Facebook group that Sherman 

and others created called "Parker Plaza Owners". 

9. The term "FREEDOM4PPA" shall mean the Facebook page and group of 

individuals who formed "Freedom for Parker Plaza Association", and is managed by you. 

10. The term "Pavel's Affidavit" shall mean the Affidavit of Pavel Moreff in Support 

of Defendants' Motion for Summary Judgment filed in this Action on April 10, 2023, [ECF No. 

38]. 

11. As used in these requests, (i) the terms “all,” “any,” and “each” shall each be 

construed as encompassing any and all, (ii) the connectives “and” and “or” shall be construed 

either disjunctively or conjunctively as necessary to bring within the scope of the discovery request 

all responses that might otherwise be construed to be outside of its scope, and (iii) the singular 

form of a noun or pronoun includes the plural form and vice versa. Additionally, regardless of the 

Case 0:22-cv-61638-WPD Document 58-1 Entered on FLSD Docket 09/01/2023 Page 14 of 23
 CASE NO. 22-61638-CIV-DIMITROULEAS 

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FOWLER WHITE BURNETT P.A. • BRICKELL ARCH, 1395 BRICKELL AVENUE, 14TH FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200

tense employed, all verbs shall be read as applying to the past, present and future as is necessary 

to make any paragraph more, rather than less, inclusive. 

12. The term “concerning” and/or "relating to" shall mean, without limitation, relating 

to, referring to, describing, evidencing, regarding, consisting of, constituting, containing, 

mentioning, summarizing, listing, indicating, analyzing, explaining, supporting, undermining, 

contradicting, pertaining to, prepared in connection with, used in preparation for, or being in any 

way legally, logically, or factually connected with the matter discussed. 

13. The term “document” shall mean any printed, written, typed, recorded, transcribed, 

taped, photographic, or graphic matter, however produced or reproduced, including, but not limited 

to: any letter, correspondence, notation, or statement of any nature whatsoever between or among 

two or more persons, by or to whomever made, dialogues, discussions, e-mail, interviews, 

consultations, agreements, other understandings, or communication of any sort; film, print or 

negative of photograph; sound recording; video recording; note, notebook, diary, calendar, 

minutes, memorandum, contract, agreement, or any amendment thereto; telex, telegram, cable; 

summary, report or record of telephone conversation, voice mail or voice mail back-up, personal 

conversation, discussion, interview, meeting, conference, investigation, negotiation, act or 

activity; projection, work paper, or draft; computer or computer network output or input, hard or 

floppy disc, e-mail, magnetic and/or optical medias, archived or back up data on any of these 

medias, and documents that have been deleted but are recoverable from any of these medias; 

opinion or report of consultant; request, order, invoice or bill of lading; analysis, diagram, map, 

index, sketch, drawing, plan, chart, manual, brochure, pamphlet, advertisement, circular, 

newspaper or magazine clipping, press release; receipt, journal, ledger, schedule, bill, or voucher; 

financial statement, statement of account, bank statement, checkbook, stubs, or register, canceled 

Case 0:22-cv-61638-WPD Document 58-1 Entered on FLSD Docket 09/01/2023 Page 15 of 23
 CASE NO. 22-61638-CIV-DIMITROULEAS 

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FOWLER WHITE BURNETT P.A. • BRICKELL ARCH, 1395 BRICKELL AVENUE, 14TH FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200

check, deposit slip, charge slip, tax return (income or other), requisition; file, study, graph, 

tabulation, and any and all other writings and recordings of whatever nature, whether signed or 

unsigned or transcribed, and any other data compilation from which information can be obtained, 

translated, if necessary, by the respondent through detection devices into reasonably usable form; 

or other tangible things which constitute or contain matters within the scope of the Florida Rules 

of Civil Procedure, and which are within the possession, custody, or control of you or any past or 

present agent, employee, consultant, attorney, or any other person acting on your behalf. The term 

“document” also includes the file, folder, tabs, and labels attached to or containing any document. 

Any document with any marks such as initials, comments, or notations of any kind is not deemed 

to be identical to one without such marks and is a separate document within the meaning of this 

term. 

14. When referring to a person, “identify” shall mean to give, to the extent known, the 

person’s full name, present or last known address, and when referring to a natural person, 

additionally, the present or last known place of employment. Once a person has been identified in 

accordance with this subparagraph, only the name of that person need be listed in response to 

subsequent discovery requesting the identification of that person. 

15. When referring to documents, “identify” shall mean to give, to the extent known, 

the (i) type of document; (ii) general subject matter; (iii) date of the document; and (iv) author(s), 

addressee(s) and recipient(s). 

16. The term “including” shall mean “including, but not limited to” so as to require the 

broadest possible inclusion. 

10. The term “person” shall mean an individual, corporation, partnership, trust, 

association, company, organization, or any form of a business or commercial entity. 

Case 0:22-cv-61638-WPD Document 58-1 Entered on FLSD Docket 09/01/2023 Page 16 of 23
 CASE NO. 22-61638-CIV-DIMITROULEAS 

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FOWLER WHITE BURNETT P.A. • BRICKELL ARCH, 1395 BRICKELL AVENUE, 14TH FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200

INSTRUCTIONS 

1. You are requested to produce all responsive documents in your possession, custody, 

or control, wherever located, including, without limitation, those in the custody of your affiliates, 

subsidiaries, parent corporations, predecessors, or successor entities and all of their respective 

current or former directors, officers, employees, agents, attorneys, advisors, and representatives, 

or other person acting or purporting to act on its or their behalf, or acted or purported to act, on its 

or their behalf. A document is deemed to be in your possession, custody, or control if it is in your 

physical custody or if it is in the physical custody of any other person or entity and you: (a) own 

such document in whole or in part; (b) have a right, by contract, statute, or otherwise, to use, 

inspect, examine, or copy such document on any terms; (c) have an understanding, express or 

implied, that you may use, inspect, examine, or copy such document on any terms; or (d) as a 

practical matter, have been able to use, inspect, examine, or copy such document when you sought 

to do so. 

2. If a privilege is claimed in response to any item number of this request, you are to 

provide a Privilege Log, setting forth the identity of the document for which such privilege is 

claimed, the type of document, the general subject matter of the document, the name of all 

individuals or entities listed or mentioned in such document, the date it was generated, the 

individual or entity that produced, generated, or composed the document, and the names of all 

person or entities that received a copy of the document. Notwithstanding the assertion of any 

privilege or other protection, any requested document that contains any responsive, non-privileged 

or non-protected information shall be produced, but that portion of the document for which the 

privilege or other protection is asserted may be redacted, provided that the redacted portion is 

identified and described consistently according to the requirements listed above. 

Case 0:22-cv-61638-WPD Document 58-1 Entered on FLSD Docket 09/01/2023 Page 17 of 23
 CASE NO. 22-61638-CIV-DIMITROULEAS 

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FOWLER WHITE BURNETT P.A. • BRICKELL ARCH, 1395 BRICKELL AVENUE, 14TH FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200

3. If there are no documents responsive to any particular request, you are to state so 

in writing. 

4. If you object to any request, state in full the basis for your objection. If you object 

to part of a request, specify the portion of the request to which you object and answer so much of 

the request as is not objectionable. 

5. Where any copy of any document whose production is sought herein, whether a 

draft or final version, is not identical to any other copy thereof, by reason of alterations, notes, 

comments, initials, underscoring, indication of routing, or other material contained thereon or 

attached thereto, all such non-identical copies are to be produced separately. 

6. If any document requested herein was formerly in your possession, custody, or 

control (or that of your representative or affiliate) and has been lost or destroyed or otherwise 

disposed of, you are requested to submit in lieu of any such document a written statement (a) 

describing in detail the nature of the document and its contents, (b) identifying the person(s) who 

prepared or authored the document and, if applicable, the person(s) to whom the document was 

sent, (c) specifying the date on which the document was prepared or transmitted, and (d) specifying 

the date on which the document was lost or destroyed and, if destroyed, the conditions of and 

reasons for such destruction and the person(s) requesting and performing the destruction. 

7. A request for any document shall be deemed to include a request for any and all 

transmittal sheets, cover letters, originals, non-identical copies, exhibits, enclosures, or 

attachments to such document, in addition to the document in its full and unexpurgated form. 

8. Where only a portion of a document relates or refers to the subject indicated, the 

entire document is to be produced nevertheless, along with all attachments, appendices, and 

exhibits. 

Case 0:22-cv-61638-WPD Document 58-1 Entered on FLSD Docket 09/01/2023 Page 18 of 23
 CASE NO. 22-61638-CIV-DIMITROULEAS 

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FOWLER WHITE BURNETT P.A. • BRICKELL ARCH, 1395 BRICKELL AVENUE, 14TH FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200

9. Each document produced in response to the requests below should be clearly 

categorized to indicate to which of the requests set forth herein it is responsive. Responses to this 

request for production of documents shall be submitted in a form so that the response follows the 

retyped request for production of documents to which it applies. 

10. All documents shall be produced in the manner they are kept in the ordinary course 

of business and in their original file folders with any identifying labels, file markings, or similar 

identifying features. Documents attached to each other should not be separated. The name of the 

file from which a document was produced, the identity of the person from whose file the document 

was produced, and the identity of the present custodian of that file shall be set forth. 

11. Documents created or stored electronically must be produced in their original 

electronic format, with the original metadata intact, and not printed to paper or PDF. All 

electronically stored information (“ESI”) shall be produced in electronic form (the “production 

set”). Each document will have its own unique identifier (“Bates number”), which must be 

consistently formatted across the production, comprising of an alpha prefix and a fixed length 

number of digits (e.g., “PREFIX0000001”). 

12. The relevant period is the time period between August 2019 to the present. 

PLAINTIFF'S FIRST REQUEST FOR 

PRODUCTION OF DOCUMENTS TO DEFENDANT, SIMON SHERMAN 

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

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

Association. 

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. 

Case 0:22-cv-61638-WPD Document 58-1 Entered on FLSD Docket 09/01/2023 Page 19 of 23
 CASE NO. 22-61638-CIV-DIMITROULEAS 

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FOWLER WHITE BURNETT P.A. • BRICKELL ARCH, 1395 BRICKELL AVENUE, 14TH FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200

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. 

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

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

the Association. 

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

related to the Association. 

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". 

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. 

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. 

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. 

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, 

Case 0:22-cv-61638-WPD Document 58-1 Entered on FLSD Docket 09/01/2023 Page 20 of 23
 CASE NO. 22-61638-CIV-DIMITROULEAS 

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FOWLER WHITE BURNETT P.A. • BRICKELL ARCH, 1395 BRICKELL AVENUE, 14TH FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200

nor approved at a duly noticed Board meeting, in derogation of Chapter 718 of the Florida Statutes, 

and the Association's governing documents". 

 

Case 0:22-cv-61638-WPD Document 58-1 Entered on FLSD Docket 09/01/2023 Page 21 of 23
 CASE NO. 22-61638-CIV-DIMITROULEAS 

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FOWLER WHITE BURNETT P.A. • BRICKELL ARCH, 1395 BRICKELL AVENUE, 14TH FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200

Respectfully submitted,

/s/ Luis S. Konski

 Luis S. Konski 

Fla. Bar No. 207837 

Email: lkonski@fowler-white.com 

Daniel A. Milian, Esq. 

Fla. Bar No. 74803 

Email: dmilian@fowler-white.com 

Ana E. Tovar 

Fla. Bar No. 1008100 

Email: atovar@fowler-white.com 

Joseph R. Englander 

Fla. Bar No. 935565 

Email: jenglander@fowler-white.com 

FOWLER WHITE BURNETT, P.A. 

Brickell Arch, Fourteenth Floor 

1395 Brickell Avenue 

Miami, Florida 33131 

Telephone: (305) 789-9200 

Facsimile: (305) 789-9201

Case 0:22-cv-61638-WPD Document 58-1 Entered on FLSD Docket 09/01/2023 Page 22 of 23
 CASE NO. 22-61638-CIV-DIMITROULEAS 

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FOWLER WHITE BURNETT P.A. • BRICKELL ARCH, 1395 BRICKELL AVENUE, 14TH FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200

CERTIFICATE OF SERVICE 

 I HEREBY CERTIFY that on May 22, 2023, the foregoing document was electronically 

served upon: Richard S. Lubliner, Esq., Lubliner Law, PLLC, Counsel for Defendants, 1645 Palm 

Beach Lakes Boulevard, Suite 1200, West Palm Beach, Florida 33401, rich@lubliner-law.com, 

carolina@lubliner-law.com. 

/s/ Luis S. Konski

Luis S. Konski

Case 0:22-cv-61638-WPD Document 58-1 Entered on FLSD Docket 09/01/2023 Page 23 of 23