UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

 Case No.: 18-16248-BKC-MAM 

IN RE: Chapter 7 Proceeding

CHANCE & ANTHEM, LLC,

Debtor.

 /

ROBERT C. FURR, not individually but 

as Chapter 7 Trustee of the estate of the 

Debtor, Chance & Anthem, LLC,

Plaintiff.

v. Adv. Proc. No.: 19-01301-BKC-MAM-A

ADVANCED AVIONICS, LLC,

Defendant.

 /

DEFENDANT’S, ADVANCED AVIONICS, LLC, RESPONSE TO

PLAINTIFF’S, ROBERT C. FURR, AS TRUSTEE, FIRST

REQUEST FOR PRODUCTION OF DOCUMENTS

Defendant, Advanced Avionics, LLC, (hereinafter referred to as “Plaintiff”) by 

and through its undersigned attorney responds to Plaintiff’s, Robert C. Furr, as Trustee,

(hereinafter referred to as “Plaintiff”) First Request for Production of Documents served 

upon Defendant, as follows:

GENERAL OBJECTIONS

The following general objections are hereby incorporated into each of the specific 

responses and objections set forth below:

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1. The Defendant objects to the requests, in particular any special instructions, 

to the extent they purport to impose obligations beyond those set forth in the Florida 

Rules of Civil Procedure.

2. The Defendant objects to the Plaintiff’s requests to the extent it calls for the 

production of documents that are otherwise in Plaintiff’s possession, custody, and/or 

control that are equally available to Plaintiff and/or Plaintiff’s access to the documents 

sought is superior to that of the Defendant, and/or at a minimum, the burden on the 

Defendant to obtain the requested documents is no greater than the burden on Plaintiff.

3. Defendant gives these responses subject to the reservations of their rights to 

object to the introduction into evidence, in this or any other action, of any of the 

information, or material contained herein or produced hereunder on any ground, 

including, but not limited to, relevancy, materiality, hearsay, and authenticity. Defendant

makes these responses subject to the further reservation that such responses shall not 

waive their right to object to additional discovery in this case.

4. Defendant does not intend by the production of documents hereunder to 

waive any claim of privilege, including work product. If any document are produced for 

which any claim of privilege is applicable, such production shall be deemed inadvertent, 

or limited to that particular document, and not a waiver of any claim of privilege in its 

entirety. 

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5. Responses provided herein have been prepared pursuant to a reasonable and 

diligent investigation as required by the Florida Rules of Civil Procedure. To the extent 

these requests purport to require anymore, Defendant objects on the grounds that 

compliance with the requests would impose an undue burden and expense.

6. Defendant’s production herein shall not be interpreted as supplying the 

complete foundation for all facts upon which Defendant may rely in its case.

7. The mere agreement by Defendant to produce a document or categories of 

documents, as indicated below does not mean that such document or categories of 

documents are in Defendant’s possession, custody, or control.

RESPONSES TO REQUEST TO PRODUCE

1. To the extent applicable, the Defendant objects to the Plaintiff’s Request as 

any documentation responsive is protected by the attorney/client privilege. To the extent 

any documentation is not protected by the attorney/client privilege, at this time, the 

Defendant is no longer engaged in the business of aircraft maintenance. As such, any and 

all documents responsive to the Plaintiff’s Request, if any, which are in the possession, 

custody or control of the Defendant, are located in Pittsburgh, Pennsylvania. As the 

Defendant’s managing member primarily lives in Palm Beach County, Florida, he is 

unable to obtain any and all documents responsive to the Plaintiff’s Request until such 

time as he returns to Pittsburgh, Pennsylvania, in or around May 2020. As any 

documentation which might be responsive to the Plaintiff’s Request is located in 

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Pennsylvania, the Defendant shall produce any and all documents responsive to the 

Plaintiff’s upon returning to Pittsburgh, Pennsylvania, in or around May 2020.

2. At this time, the Defendant is no longer engaged in the business of aircraft 

maintenance. As such, any and all documents responsive to the Plaintiff’s Request, if 

any, which are in the possession, custody or control of the Defendant, are located in 

Pittsburgh, Pennsylvania. As the Defendant’s managing member primarily lives in Palm 

Beach County, Florida, he is unable to obtain any and all documents responsive to the 

Plaintiff’s Request until such time as he returns to Pittsburgh, Pennsylvania, in or around 

May 2020. As any documentation which might be responsive to the Plaintiff’s Request is 

located in Pennsylvania, the Defendant shall produce any and all documents responsive 

to the Plaintiff’s upon returning to Pittsburgh, Pennsylvania, in or around May 2020.

3. At this time, the Defendant is no longer engaged in the business of aircraft 

maintenance. As such, any and all documents responsive to the Plaintiff’s Request, if 

any, which are in the possession, custody or control of the Defendant, are located in 

Pittsburgh, Pennsylvania. As the Defendant’s managing member primarily lives in Palm 

Beach County, Florida, he is unable to obtain any and all documents responsive to the 

Plaintiff’s Request until such time as he returns to Pittsburgh, Pennsylvania, in or around 

May 2020. As any documentation which might be responsive to the Plaintiff’s Request is 

located in Pennsylvania, the Defendant shall produce any and all documents responsive 

to the Plaintiff’s upon returning to Pittsburgh, Pennsylvania, in or around May 2020. 

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Additionally, any documentation which supports the solvency of the Debtor is also in the 

possession, custody, or control of the Plaintiff.

4. At this time, the Defendant is no longer engaged in the business of aircraft 

maintenance. As such, any and all documents responsive to the Plaintiff’s Request, if 

any, which are in the possession, custody or control of the Defendant, are located in 

Pittsburgh, Pennsylvania. As the Defendant’s managing member primarily lives in Palm 

Beach County, Florida, he is unable to obtain any and all documents responsive to the 

Plaintiff’s Request until such time as he returns to Pittsburgh, Pennsylvania, in or around

May 2020. As any documentation which might be responsive to the Plaintiff’s Request is 

located in Pennsylvania, the Defendant shall produce any and all documents responsive 

to the Plaintiff’s upon returning to Pittsburgh, Pennsylvania, in or around May 2020.

5. The Defendant objects to this Request, as it is duplicative of the Plaintiff’s 

Request #4. 

6. At this time, the Defendant is no longer engaged in the business of aircraft 

maintenance. As such, any and all documents responsive to the Plaintiff’s Request, if 

any, which are in the possession, custody or control of the Defendant, are located in 

Pittsburgh, Pennsylvania. As the Defendant’s managing member primarily lives in Palm 

Beach County, Florida, he is unable to obtain any and all documents responsive to the 

Plaintiff’s Request until such time as he returns to Pittsburgh, Pennsylvania, in or around 

May 2020. As any documentation which might be responsive to the Plaintiff’s Request is 

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located in Pennsylvania, the Defendant shall produce any and all documents responsive 

to the Plaintiff’s upon returning to Pittsburgh, Pennsylvania, in or around May 2020.

7. At this time, the Defendant is no longer engaged in the business of aircraft 

maintenance. As such, any and all documents responsive to the Plaintiff’s Request, if 

any, which are in the possession, custody or control of the Defendant, are located in 

Pittsburgh, Pennsylvania. As the Defendant’s managing member primarily lives in Palm 

Beach County, Florida, he is unable to obtain any and all documents responsive to the 

Plaintiff’s Request until such time as he returns to Pittsburgh, Pennsylvania, in or around 

May 2020. As any documentation which might be responsive to the Plaintiff’s Request is 

located in Pennsylvania, the Defendant shall produce any and all documents responsive 

to the Plaintiff’s upon returning to Pittsburgh, Pennsylvania, in or around May 2020.

I HEREBY CERTIFY that I am admitted to the Bar of the United States District 

Court for the Southern District of Florida, and I am in compliance with the additional 

qualifications to practice in this Court set forth in Local Rule 2090-1(A).

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has 

been furnished by e-mail on the 17th day of February 2020 to:

Jesus M. Suarez, Esq.

jsuarez@gjb-law.com, gjbecf@gjb-law.com

PHILIP B. HARRIS, P.A. 

685 Royal Palm Beach Boulevard

Suite 205

Royal Palm Beach, FL 33411

Tel: 561-543-7963

Fax: 561-793-1020 

By: /s/ Philip B. Harris__________

Philip B. Harris, Esq.

FL Bar ID: 19781

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