UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

In re: EXCLUSIVE DOORS AND

WINDOWS, LLC.,

 Debtor. /

Case no.: 19-11829-AJC

Chapter 13

MARCIA T. DUNN, Chapter 7 Trustee of 

the Bankruptcy Estate of EXCLUSIVE 

DOORS AND WINDOWS, LLC,

Plaintiff,

vs.

LUIS CARLOS PIMENTEL, an 

individual; EXCLUSIVE ACCORDIONS 

LLC, a dissolved Florida limited liability 

company; MIAMI DADE ACCORDIONS 

LLC, a dissolved Florida limited liability 

company; and ALL STAR SHUTTER 

LLC, a Florida limited liability company, 

Defendants.

_____________________________/

Adversary Proceeding No.: 20-01360-AJC

DEFENDANT’S RESPONSE TO REQUEST FOR PRODUCTION

Defendant, LUIS CARLOS PIMENTEL, by and through undersigned counsel, 

responds to Plaintiff’s Request for Production and states:

1. None in Defendant’s possession.

2. Objection as to the form of the request. Without waiving said objection, none in 

Defendant’s possession.

3. Objection overly broad and unduly burdensome. The petition in the underlying 

case was filed on February 11, 2019, and Plaintiff’s request for documents from 

February 2015 to the present is excessive. The documents requested were 

Case 20-01360-AJC Doc 72 Filed 06/21/21 Page 1 of 4
previously provided to the trustee. See attached letter related to computers

turned over to the trustee.

4. Objection to the form of the request and overly broad and unduly burdensome. 

The petition in the underlying case was filed on February 11, 2019, and Plaintiff’s 

request for documents from February 2015 to the present is excessive. The 

documents requested were previously provided to the trustee.

5. Objection, overly broad and unduly burdensome and not reasonably calculated to 

lead to admissible evidence. Without waiving said objection, none in Defendant’s 

possession.

6. Objection as to the form of the request. However without waiving said objection, 

none in Defendant’s possession.

7. Objection, overly broad and unduly burdensome. The documents requested 

were provided to the trustee previously. None in Defendant’s possession. 

8. Objection as to the form of the question and overly broad and unduly 

burdensome. The documents requested were provided to the trustee previously. 

None in Defendant’s possession. 

9. Objection as to the form of the request. Without waiving said object, none in 

Defendant’s possession.

10.Objection as to the form of the request. Without waiving said object, other than 

the bank statements previously provided to the trustee, none in Defendant’s 

possession.

Case 20-01360-AJC Doc 72 Filed 06/21/21 Page 2 of 4
11.Objection irrelevant and not reasonably calculated to lead to admissible

evidence. Without waiving said object, see attached documents in Defendant’s 

possession.

12.Objection irrelevant and not reasonably calculated to lead to admissible

evidence. Without waiving said object, see attached documents in Defendant’s 

possession.

13.See attached payments history in Defendant’s possession.

14.Objection irrelevant. Without waiving said objection, see attached purchase 

documents in Defendant’s possession.

15.Objection irrelevant, and not reasonably calculated to lead to admissible 

evidence. Without waiving said objection, Defendant no longer has the vehicle in 

question which was involved in accident resulting in a total loss.

16.Objection irrelevant and not reasonably calculated to lead to admissible 

evidence. Without waiving said objection, Defendant no longer has the vehicle in 

question which was involved in accident resulting in a total loss.

17.See attached tax returns.

18.Objection overly broad and unduly burdensome. The petition in the underlying 

case was filed on February 11, 2019, and Plaintiff’s request for documents from 

February 2015 to the present is excessive. Defendant does not have access to 

any company bank accounts, and Defendant’s bank statement in his possession 

include dates after the petition date which we object to providing.

19. Objection overly broad and unduly burdensome and not reasonably calculated to 

lead to admissible evidence. The petition in the underlying case was filed on 

Case 20-01360-AJC Doc 72 Filed 06/21/21 Page 3 of 4
February 11, 2019, and Plaintiff’s request for documents from February 2015 to 

the present is excessive. The documents requested were previously provided to 

the trustee.

20.Objection irrelevant and overly broad. Without waiving said objection, none in 

Defendant’s possession.

###

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true copy of this Request for Production was served

electronically on all parties listed on the Electronic Mail Notice List generated with the 

filing of said Notice on this 21st day of June 2021.

/s/ Ricardo A. Rodriguez______

Ricardo A Rodriguez, Esq.

Rodriguez Law, P.L. 

900 West 49th Street, Suite 505

Hialeah, FL 33012

Tel: 305-262-8226 / Fax: 305-262-8229

Email: ricardo@rdgzlaw.com

Service Email: mail@rdgzlaw.com

FBN: 0496901

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