[System]
You are a lawyer with 10 years of experience. Based on the complaint, create up to 20 questions for the defendant.

The questions should follow the format and style of this example response to a car accident complaint:
1. All photographs, diagrams, or other printed or written material describing or attempting to describe the scene of the accident alleged in the Complaint, or any person described in the Complaint.
2. Documentation substantiating health insurance coverage available to Plaintiff on the date of the accident sued upon.
3. Any cellular phones or other mobile communication system telephone bills, invoices, statements, itemized accounts, or other data compilation for the equipment owned or used by Plaintiffs for the months relevant to the incident.
4. Any and all films, diagnostic tests, MRIs, X-rays, storage devices, digital images, intra-operative photographs, and/or data compilations from which information can be obtained.
5. If a claim is made for lost wages and/or loss of earning capacity in the future, provide specific documentation like Federal Income Tax Returns and W-2 Forms.

Be specific, detailed and relevant to the complaint's allegations. Avoid generic requests for "all documents" or "all evidence". Each question should request specific items, time periods, or information directly related to the complaint's claims.

[User] **IN THE CIRCUIT COURT OF THE** **FIFTEENTH JUDICIAL CIRCUIT IN AND FOR** **PALM BEACH COUNTY COUNTY, FLORIDA** **CASE NUMBER:** **ARTHUR SCHEMAN & TRUDE** **SCHEMAN, ** **Plaintiffs, ** **v. ** **STATE FARM FLORIDA INSURANCE** **COMPANY, ** **Defendant. ** **___________________________________/** **COMPLAINT & DEMAND FOR JURY TRIAL** **COMES NOW, ** Plaintiffs, Arthur Scheman & Trude Scheman, by and through the undersigned counsel and sues Defendant, State Farm Florida Insurance Company, and alleges as follows: This is an action for breach of contract with damages greater than Fifty Thousand Dollars ($50, 000. 00), exclusive of interest, costs, and attorney’s fees. At all material times hereto, Plaintiffs, Arthur Scheman & Trude Scheman (hereinafter “Plaintiffs”), were and are Florida resident. At all material times hereto, Defendant, State Farm Florida Insurance Company, was a corporation duly licensed to transact insurance business in the State of Florida. Defendant does business, has offices, and/or maintained agents for the transaction of its customary business in Palm Beach County County, Florida. Jurisdiction and venue of this matter are proper in Circuit Court for Palm Beach County County, Florida. ----- Prior to September 27, 2022, Plaintiffs sought and purchased property insurance from Defendant to cover their property located at 9860 Donato Way, Lake Worth, Florida, 33467, (hereinafter “Plaintiffs’ Property”). Said policy of insurance, which is believed to be policy number 7Y-CY-A815-0 (hereinafter “Plaintiffs’ Policy”), was issued by Defendant to Plaintiffs to provide insurance coverage that included, but was not limited to, coverage afforded to protect Plaintiffs’ Property against Hurricane damage. Plaintiffs’ Policy was in full force and effect as of September 27, 2022. A formal copy of the Plaintiffs’ Policy is not currently in the possession of Plaintiffs, but is well known to Defendant, and has been requested by Plaintiffs through a Request to Produce, which has been served upon Defendant contemporaneously with this Complaint. See: Equity Premium, Inc. v. Twin City Fire Ins. Co. , 956 So. 2d 1257 (Fla 4th DCA 2007); Amiker v. Mid-Century Ins. Co. , 398 So. 2d 974 (Fla 1st DCA 1981); Parkway General Hospital, Inc. v. Allstate Ins. Co. , 393 So. 2d 1171 (Fla. 3rd DCA 1981) and Sasche v. Tampa Music Co. , 262 So. 2d 17( Fla. 2nd DCA 1972). On or about September 27, 2022, Plaintiffs’ Property was damaged by a Hurricane event. Said Hurricane event was covered under Plaintiffs’ Policy, and Defendant assigned the loss as claim number 59-64H1-04Q. This is an action related to Defendant’s breach of contract for failure to fully indemnify Plaintiffs from loss. **COUNT I - BREACH OF CONTRACT AGAINST DEFENDANT** **COMES NOW, Plaintiffs, Arthur Scheman & Trude Scheman, by and through the** undersigned counsel and sue Defendant, State Farm Florida Insurance Company, and alleges as follows: ----- Plaintiffs re-alleges paragraphs 1 through 8 above and incorporates the same by reference herein. Plaintiffs are a named insured under Plaintiffs’ Policy which was in full force and effect all times material to this Complaint. Plaintiffs have complied with all conditions precedent to this lawsuit which entitles Plaintiffs to recover under Plaintiffs’ Policy, or any such conditions have been waived by the Defendant. Despite demand for payment, Defendant has failed or refused fully indemnify Plaintiffs from the amount of loss. Defendant’s refusal to reimburse Plaintiffs adequately for damages, and otherwise make Plaintiffs whole, constitutes a breach of contract. Plaintiffs have been damaged as a result of Defendant’s breach in the form of insurance proceeds which have not been paid, interest, costs, and attorney’s fees. Plaintiffs have been and remain fully prepared to comply with all of the Policy’s obligations. As a result of Defendant’s breach of contract, it has become necessary that Plaintiffs retain the services of the undersigned attorneys pursuant to Sections 627. 70152 (July 1, 2021), 428 (July 1, 2021), 626. 9373 (July 1, 2021), 57. 041, 57. 104, Florida Statutes. Plaintiffs are obligated to pay a reasonable fee for the undersigned attorney’s services in bringing this action, plus necessary costs. Plaintiffs are entitled to recover attorney’s fees and costs under Sections 627. 70152 (July 1, 2021), 627. 428 (July 1, 2021), 626. 9373 (July 1, 2021), 57. 041, 57. 104, Florida Statutes. ----- **WHEREFORE, Plaintiffs, Arthur Scheman & Trude Scheman, by and through the** undersigned counsel, demands judgment against Defendant, State Farm Florida Insurance Company, for all damages with interest, costs, attorney fees pursuant to Sections 627. 70152 (July 1, 2021), 627. 428 (July 1, 2021), 626. 9373 (July 1, 2021), 57. 041, 57. 104, Florida Statutes, and for all other remedies the Court sees fit to grant, and Plaintiff demands trial by jury. **CERTIFICATE OF SERVICE** **I HEREBY CERTIFY that a true and correct copy of this document will be served on** Defendant along with the Summons in this action. **: September 5, 2024** _/s/Dalya Zalloum_ **COHEN LAW GROUP** Dalya Zalloum, Esq. _FOR THE FIRM_ Florida Bar Number: 1002903 350 North Lake Destiny Road Maitland, Florida 32751 Phone: (407) 478-4878 Fax: (407) 478-0204 Primary: DZalloum@itsaboutjustice. law Secondary: -----

[Assistant] IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA ARTHUR SCHEMAN & TRUDE SCHEMAN, Plaintiffs, _Ê_ vs. STATE FARM FLORIDA INSURANCE COMPANY, Defendant. ____________________________________/ **DEFENDANT’S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO** **PLAINTIFFS** Defendant, STATE FARM FLORIDA INSURANCE COMPANY, (hereinafter “State Farm” or “Defendant”), pursuant to Rule 1. 350, Florida Rules of Civil Procedure, hereby requests that Plaintiffs, ARTHUR SCHEMAN & TRUDE SCHEMAN (“Plaintiffs”), produce the following for inspection and/or copying at the offices of the undersigned counsel within 30 days after service of this request. You are advised that you shall serve a written response to this Request for Production within the time period set forth above. For each of the designated items or categories of documents listed below, you shall state in your response the documents are attached unless the request is objected to, in which event you must state the reasons for your objections. You are further notified that upon production of the requested documents, you shall either produce them as they are kept in the usual course of business or shall identify them to correspond with the categories in this Request. The Plaintiffs shall produce all documents within their possession, custody, or control, including but not limited to all documents in the possession, ----- Ê custody, or control of their attorneys, directors, officers, employees, agents, accountants or representatives. If any document cannot be produced in full, produce it to the extent possible and identify each page or portion of the document withheld and the reasons it has been withheld. DEFINITIONS Ê The term "documents" means and includes, without limitation, all writings of any kind, including the originals and all non-identical copies or drafts, whether printed, recorded, stored, or reproduced by any mechanical or electronic process or written or produced by hand, including computer tapes (and backup tapes), whether different from the original by reason of any notation made on such copy or draft or otherwise including, without limitation, correspondence, memoranda, notes, diaries, statistics, letters, e-mail, electronic computer files, telegrams, minutes, contracts, reports, accident reports, incident reports, studies, calculations, computations, surveys, checks, statements, receipts, returns, summaries, pamphlets, books, prospectuses, circulars, trade letters, advertisements, interoffice communications, offers, notations of any sort of conversation(s), telephone calls, meetings or other communications, bulletins, printed matter, computer print-outs, teletypes, facsimiles, invoices, work sheets and all drafts, alterations, modifications, changes, and amendments of any of the foregoing, graphic or aural writs, records or representations of any kind including, without limitation, photographs, charts, graphs, microfiche, microfilm, videotape, recordings, motion pictures; and electronic, mechanical or electric records or representations of any kind including, without limitation, tapes, cassettes and disc recordings, and writings and printed material of every kind, whether or not the document is out of your possession, custody or control. Ê The term "correspondence" means any tangible object that conveys information or memorializes information that was conveyed in tangible or oral form including, but not limited to, writings, letters, memoranda, electronic mail (otherwise known as “e-mail”), facsimiles, reports, notes, telegrams and interoffice communication. Ê The term "relating to" as used herein is defined to mean evidencing, referring to, pertaining to, consisting of, reflecting, concerning, or in any way logically or factually connected with the matters discussed. Ê The term “property” or “subject property” refers to the property located at 9860 Donato Way, Lake Worth, FL 33467. Ê The term “you” or “your” refers to Plaintiffs, Arthur Scheman and Trude Scheman. Ê The term “Loss” or “this Claim” refers to the loss described in the Complaint or the loss reported to State Farm for aof loss occurring on or about September 27, 2022, claim number assigned 59-64H1-04Q. ----- Ê **DOCUMENTS REQUESTED** Ê Any and all documents, including, but not limited to, correspondence from you or any agent of yours to State Farm and/or its agents beginning from thethe Loss was reported to State Farm through the present. Ê Any and all documents, including, but not limited to, correspondence from State Farm and/or its agents to you and/or your agents beginning from thethe Loss was reported to State Farm through the present. Ê Any and all documents evidencing agreements for representation between yourself and any individual or business entity representing you in this Claim, including but not limited to contracts, letters of representation, correspondence, and fee schedules for representation by public adjusters or public adjuster firms. ÊThisÊrequestÊdoesÊnotÊseekÊagreementsÊforÊlegalÊrepresentation, Ê _butÊdoesÊseekÊunredactedÊdocumentsÊresponsiveÊtoÊthisÊrequest. ÊÊÊ_ _Ê_ Ê Any and all documents evidencing an assignment of benefits between yourself and any individual or business entity that relate to the Loss or any portion of the subject Property for which you are claiming damages concerning the Loss. Ê Ê Any and all documents evidencing the damages that you are claiming as a result of the Loss, including, but not limited to estimates, contracts, receipts, statements, invoices, and work orders. Ê Any and all documents evidencing the damages that you are claiming to any personal property as a result of the Loss, including, but not limited to estimates, contracts, receipts, statements, and invoices. Ê Any and all documents relating to repairs or other work performed to the roof of the subject property since thethe roof was last replaced through the present. Ê Any and all documents relating to the most recent replacement of the roof of the subject Property. Ê Any and all documents evidencing estimates, work orders, invoices, statements, and receipts relating to the repair or replacement of the roof of the subject Property. Ê Any and all documents relating to your purchase of a tarp for the roof of the subject Property relating to this Loss. Ê Any and all documents that evidence, depict, or reflect the age or condition of the roof of the subject Property at the time of the Loss. Ê Any and all documents evidencing the replacement of damaged property as a result of your loss, including but not limited to contracts, receipts, canceled checks, bills of sale, statements, ATM receipts, credit card statements, and invoices. ----- Ê Ê Any and all bills or invoices incurred by you as a result of the Loss. Ê Any and all documents evidencing any repairs performed prior to September 27, 2022, for any area of the subject Property relating to the Loss. Ê Any and all documents evidencing any repairs performed prior to September 27, 2022, to the roof of the Property. Ê Any and all documents evidencing any repairs performed prior to September 27, 2022, to the interior of the Property. Ê Any and all documents evidencing any repairs performed prior to September 27, 2022, to the exterior of the subject Property relating to the Loss. Ê Any and all documents evidencing all repairs performed at any time after September 27, 2022, to any area of the subject Property relating to the Loss. Ê Any and all documents evidencing all repairs performed at any time after September 27, 2022, to the interior of the subject Property relating to the Loss. Ê Any and all documents evidencing all repairs performed at any time after September 27, 2022, to the roof of the subject Property relating to the Loss. Ê Any and all documents evidencing all repairs performed at any time after September 27, 2022, to the exterior of the subject Property relating to the Loss. Ê Any and all maintenance records for any portion or area of the subject Property relating to the Loss. Ê Any and all documents evidencing repairs relating to the roof of the subject Property or service calls to a roofing company at any time from thethe roof was last replaced through theof loss, including but not limited to work orders, invoices, statements, inspections, estimates, and receipts. Ê Any and all documents you received from any roofing company, contractor, handyman, and any other person or company that you or any of your agents retained to inspect any portion or area of the Property relating to the Loss. Ê Any and all documents you received from any roofing company, contractor, handyman, and any other person or company that you or any of your agents retained to perform repairs or renovations to any portion or area of the Property relating to the Loss. Ê Any and all documents reflecting payment(s) made by you or your agents to any roofing company, contractor, handyman, and any other person or company that you or your agents retained for any reason relating to the Loss. ----- Ê Ê Any and all documents reflecting, depicting or otherwise evidencing any efforts to protect the Property from further damage after discovery of the Loss. Ê Any and all documents in your possession that were prepared by third-parties who inspected or evaluated the subject Property relating to the Loss. Ê Any and all photographs, videographs, recordings, film, diagrams, drawings, charts, sketches or any other documents illustrating the damages sustained in the Loss. Ê Any and all photographs, videographs, recordings, film, diagrams, drawings, charts, sketches or any other documents illustrating the pre-loss condition (prior to September 27, 2022) of any portion or area of the subject Property you are claiming as part of this Loss. Ê Any and all documents evidencing application for or issuance of building permits for any portion of the subject Property relating to the Loss from theyou purchased the subject Property through the present. Ê All maintenance and/or repair records for the Subject Property from theof purchase through the present. Ê All documents relating to any prior insurance claims at the Subject Property, including, but not limited to, any repair receipts, estimates, photographs, and/or invoices. Ê Any and all bills incurred as a result of any prior loss to the subject Property. Ê Copies of any pre-purchase inspection reports for the Subject Property. Ê Copies of any inspection reports for the Subject Property prepared on or after theof purchase of the Subject Property through the present. Ê Any and all documents in your possession relating to the Loss. **Ê** Ê Any and all documents upon which you relied upon in answering the Interrogatories or that are referenced in your Answers to Interrogatories. ----- #### CERTIFICATION The undersigned certifies that this request, response or objection is: (A) consistent with these rules and warranted by existing [law][ or][ a] good [faith] argument [for][ the] extension, modification, [or][ reversal][ of] existing law; (B) not interposed for any improper purpose, such as to harass or to cause unnecessary delay or needless increase in the cost of litigation; and (C) not unreasonable or unduly burdensome or expensive, given [the][ needs][ of][ the] case, [the] discovery already [had][ in] the case, the amount in controversy, and the importance of the issues at stake in the litigation #### KELLEY KRONENBERG /s/ Melanie S. Wes ## eman_ Melanie S. Weseman, Esq. Fla. Bar No. : 506451 mweseman@kelleykronenberg. com 1475 Centrepark Boulevard, Suite 275 West Palm Beach, FL 33401 Telephone: (561) [684-5956] #### (Certificate [of][ Service][ on] Following Page) ----- **CERTIFICATE OF SERVICE** I HEREBY CERTIFY that on the 16th day of January, 2025, this document was filed using the Florida Courts E-Filing Portal. This document is being served on all counsel and pro se parties of record by the Florida Courts E-Filing Portal, pursuant to and in compliance with Fla. R. Jud. Admin. 2. 516. The mailing and electronic addresses are: Dalya Zalloum, Esquire, Cohen Law Group, 350 North Lake Destiny Road, Maitland, FL 32751, DZalloum@itsaboutjustice. law, (407) 478-4878, Attorney for Plaintiffs. **KELLEY KRONENBERG** /s/ MelanieÊS. ÊWeseman **Melanie S. Weseman, Esq. ** Fla. Bar No. : 506451 mweseman@kelleykronenberg. com **John S. Riordan, Esq. ** Fla. Bar No. : 0568694 jriordan@kelleykronenberg. com 1475 Centrepark Boulevard, Suite 275 West Palm Beach, FL 33401 Telephone: (561) 684-5956 Facsimile: (561) 684-5753 Attorneys for State Farm Insurance Company Address for service of pleadings only: mweseman@kelleykronenberg. com hmoore@kelleykronenberg. com -----


[System]
You are a lawyer with 10 years of experience. Based on the complaint, create up to 20 questions for the defendant.

The questions should follow the format and style of this example response to a car accident complaint:
1. All photographs, diagrams, or other printed or written material describing or attempting to describe the scene of the accident alleged in the Complaint, or any person described in the Complaint.
2. Documentation substantiating health insurance coverage available to Plaintiff on the date of the accident sued upon.
3. Any cellular phones or other mobile communication system telephone bills, invoices, statements, itemized accounts, or other data compilation for the equipment owned or used by Plaintiffs for the months relevant to the incident.
4. Any and all films, diagnostic tests, MRIs, X-rays, storage devices, digital images, intra-operative photographs, and/or data compilations from which information can be obtained.
5. If a claim is made for lost wages and/or loss of earning capacity in the future, provide specific documentation like Federal Income Tax Returns and W-2 Forms.

Be specific, detailed and relevant to the complaint's allegations. Avoid generic requests for "all documents" or "all evidence". Each question should request specific items, time periods, or information directly related to the complaint's claims.

[User] **IN THE CIRCUIT COURT OF THE** **FIFTEENTH JUDICIAL CIRCUIT IN AND FOR** **PALM BEACH COUNTY COUNTY, FLORIDA** **CASE NUMBER:** **ARTHUR SCHEMAN & TRUDE** **SCHEMAN, ** **Plaintiffs, ** **v. ** **STATE FARM FLORIDA INSURANCE** **COMPANY, ** **Defendant. ** **___________________________________/** **COMPLAINT & DEMAND FOR JURY TRIAL** **COMES NOW, ** Plaintiffs, Arthur Scheman & Trude Scheman, by and through the undersigned counsel and sues Defendant, State Farm Florida Insurance Company, and alleges as follows: This is an action for breach of contract with damages greater than Fifty Thousand Dollars ($50, 000. 00), exclusive of interest, costs, and attorney’s fees. At all material times hereto, Plaintiffs, Arthur Scheman & Trude Scheman (hereinafter “Plaintiffs”), were and are Florida resident. At all material times hereto, Defendant, State Farm Florida Insurance Company, was a corporation duly licensed to transact insurance business in the State of Florida. Defendant does business, has offices, and/or maintained agents for the transaction of its customary business in Palm Beach County County, Florida. Jurisdiction and venue of this matter are proper in Circuit Court for Palm Beach County County, Florida. ----- Prior to September 27, 2022, Plaintiffs sought and purchased property insurance from Defendant to cover their property located at 9860 Donato Way, Lake Worth, Florida, 33467, (hereinafter “Plaintiffs’ Property”). Said policy of insurance, which is believed to be policy number 7Y-CY-A815-0 (hereinafter “Plaintiffs’ Policy”), was issued by Defendant to Plaintiffs to provide insurance coverage that included, but was not limited to, coverage afforded to protect Plaintiffs’ Property against Hurricane damage. Plaintiffs’ Policy was in full force and effect as of September 27, 2022. A formal copy of the Plaintiffs’ Policy is not currently in the possession of Plaintiffs, but is well known to Defendant, and has been requested by Plaintiffs through a Request to Produce, which has been served upon Defendant contemporaneously with this Complaint. See: Equity Premium, Inc. v. Twin City Fire Ins. Co. , 956 So. 2d 1257 (Fla 4th DCA 2007); Amiker v. Mid-Century Ins. Co. , 398 So. 2d 974 (Fla 1st DCA 1981); Parkway General Hospital, Inc. v. Allstate Ins. Co. , 393 So. 2d 1171 (Fla. 3rd DCA 1981) and Sasche v. Tampa Music Co. , 262 So. 2d 17( Fla. 2nd DCA 1972). On or about September 27, 2022, Plaintiffs’ Property was damaged by a Hurricane event. Said Hurricane event was covered under Plaintiffs’ Policy, and Defendant assigned the loss as claim number 59-64H1-04Q. This is an action related to Defendant’s breach of contract for failure to fully indemnify Plaintiffs from loss. **COUNT I - BREACH OF CONTRACT AGAINST DEFENDANT** **COMES NOW, Plaintiffs, Arthur Scheman & Trude Scheman, by and through the** undersigned counsel and sue Defendant, State Farm Florida Insurance Company, and alleges as follows: ----- Plaintiffs re-alleges paragraphs 1 through 8 above and incorporates the same by reference herein. Plaintiffs are a named insured under Plaintiffs’ Policy which was in full force and effect all times material to this Complaint. Plaintiffs have complied with all conditions precedent to this lawsuit which entitles Plaintiffs to recover under Plaintiffs’ Policy, or any such conditions have been waived by the Defendant. Despite demand for payment, Defendant has failed or refused fully indemnify Plaintiffs from the amount of loss. Defendant’s refusal to reimburse Plaintiffs adequately for damages, and otherwise make Plaintiffs whole, constitutes a breach of contract. Plaintiffs have been damaged as a result of Defendant’s breach in the form of insurance proceeds which have not been paid, interest, costs, and attorney’s fees. Plaintiffs have been and remain fully prepared to comply with all of the Policy’s obligations. As a result of Defendant’s breach of contract, it has become necessary that Plaintiffs retain the services of the undersigned attorneys pursuant to Sections 627. 70152 (July 1, 2021), 428 (July 1, 2021), 626. 9373 (July 1, 2021), 57. 041, 57. 104, Florida Statutes. Plaintiffs are obligated to pay a reasonable fee for the undersigned attorney’s services in bringing this action, plus necessary costs. Plaintiffs are entitled to recover attorney’s fees and costs under Sections 627. 70152 (July 1, 2021), 627. 428 (July 1, 2021), 626. 9373 (July 1, 2021), 57. 041, 57. 104, Florida Statutes. ----- **WHEREFORE, Plaintiffs, Arthur Scheman & Trude Scheman, by and through the** undersigned counsel, demands judgment against Defendant, State Farm Florida Insurance Company, for all damages with interest, costs, attorney fees pursuant to Sections 627. 70152 (July 1, 2021), 627. 428 (July 1, 2021), 626. 9373 (July 1, 2021), 57. 041, 57. 104, Florida Statutes, and for all other remedies the Court sees fit to grant, and Plaintiff demands trial by jury. **CERTIFICATE OF SERVICE** **I HEREBY CERTIFY that a true and correct copy of this document will be served on** Defendant along with the Summons in this action. **: September 5, 2024** _/s/Dalya Zalloum_ **COHEN LAW GROUP** Dalya Zalloum, Esq. _FOR THE FIRM_ Florida Bar Number: 1002903 350 North Lake Destiny Road Maitland, Florida 32751 Phone: (407) 478-4878 Fax: (407) 478-0204 Primary: DZalloum@itsaboutjustice. law Secondary: -----

[Assistant] **IN THE CIRCUIT COURT OF THE** **FIFTEENTH JUDICIAL CIRCUIT IN AND FOR** **PALM BEACH COUNTY COUNTY, FLORIDA** **CASE NUMBER:** **ARTHUR SCHEMAN & TRUDE** **SCHEMAN, ** **Plaintiffs, ** **v. ** **STATE FARM FLORIDA INSURANCE** **COMPANY, ** **Defendant. ** **___________________________________/** **PLAINTIFFS’ FIRST REQUEST TO PRODUCE TO DEFENDANT** Plaintiffs, Arthur Scheman & Trude Scheman, by and through the undersigned counsel, under Florida Rules of Civil Procedure 1. 350 and 1. 280(a), submits to Defendant, State Farm Florida Insurance Company, the following Request to Produce and requests that Defendant furnish copies to Plaintiffs at 350 North Lake Destiny Road, Maitland, Florida, 32751, or via E-Mail, within forty-five (45) days of service of the Complaint herein. **DEFINITIONS AND INSTRUCTIONS** For purposes of this Request to Produce, the following terms and definitions are provided: Plaintiffs: The term “Plaintiffs” as used herein shall mean Arthur Scheman & Trude Scheman and their representatives as defined below. Defendant: The term “Defendant” shall mean State Farm Florida Insurance Company, whether by that name or any other, and its representatives as defined below. Representatives: The term "representatives" shall mean any and all present or former partners, agents, employees, servants, officers, directors, attorneys, consultants, sureties, indemnificators, insurers, independent contractors and other persons acting or purporting to act on behalf of the entity referred to. ----- You and Your: The terms "you" and "your" shall refer to Defendant (defined above) and any other person or entity acting or purporting to act on its behalf. Document: The term "document" shall mean any written, printed, typed or other graphic or photographic matter (including without limitation, photographs, charts, graphs, microfiche, microfilm, videotapes, recordings and motion pictures and data stored on a computer disc or computer hard drive) and shall include the originals, identical copies and all non-identical copies, whether different from the original by reason of any notation made on each copy or otherwise and shall include, without limiting the generality of the foregoing, all letters, telegrams, teletypes, correspondence, contracts, agreements, notes, mechanical and electronic sound recordings and transcripts thereof (including, without limitation, tapes, cassettes and discs), computer records, computer printouts, other printed matter produced through computers, calendar and diary entries, memoranda, notes and records of all telephone or personal conversations, meetings and other communication, inter-office and intra-office communications, statements, manuals, summaries and compilations, minutes of meetings, charges, maps, reports, analysis, studies, graphs, prospectus, returns, statistics, pamphlets, books, offers, bulletins, order papers, articles, catalogs, records, tables, books of account, ledgers, vouchers, canceled checks, invoices, bills, receipts, tickets, worksheets and all drafts, alterations, modifications and changes to any of the foregoing, as well as all digitally stored and generated documents and notes. Communication: The term "communication" as used herein shall mean any contact between or among the parties indicated, including but not limited to, all documents (defined above), telephone or personal conversations, meetings, e-mails or electronic contacts, conferences and discussions. Once identified, a communication may be subsequently identified by use of a common description. ----- Identify: The term “identify” when used with reference to a person shall mean to: a. State the full name of the person; b. State the full name of the last known employer of the person; c. State the last known occupation or title of the person with such employer; d. State the last known business telephone number of the person; e. State the last known home address of the person; and f. State the last known home telephone number of the person. Once identified, a person may be subsequently identified by uniform use of a standard name. Identify: The term “identify” when used with reference to a document shall mean to: a. State a complete description of the document; b. Identify the person who prepared the document; c. State theon which the document was prepared; d. State the location at which the document was prepared; and e. Identify the person who presently has care, custody and control of the document. Once identified, a document may be subsequently identified by uniform use of a standard description. Person: The term “person” as used herein shall mean a natural person other than an entity and shall be construed to include groups of natural persons. **INSTRUCTIONS** Should Defendant object to a Request to Produce or not respond pursuant to a claim of privilege, Defendant is required to: a. State the basis of the claim of privilege; b. Identify the subject matter of the information to which a claim of privilege is made; c. Identify all persons or entities who have had access to or claimed to be privileged or were present when the privileged information was discussed, and d. Identify all persons or entities to which the privileged information has been disclosed. ----- **PLAINTIFFS’ FIRST REQUEST TO PRODUCE TO DEFENDANT** A true and correct copy of all DEC pages and the full and complete insurance policy(s) referenced in Plaintiffs’ Complaint and a sworn statement of a corporate officer of Defendant attesting to the coverage and authenticity of the policy. **RESPONSE:** A copy of any and all other DEC pages and insurance policy(s) that may provide coverage to either Plaintiffs for the damages claimed in Plaintiffs’ Complaint. **RESPONSE:** A copy of each and every document (defined above) that you reasonably anticipate may be introduced into evidence at the trial of this matter. **RESPONSE:** A copy of any and all documents that you allege may support any affirmative defense which you have raised in this matter. **RESPONSE:** A copy of any and all documents that you allege may support any Motion to Dismiss which you have filed in this matter. **RESPONSE:** Copies of any and all statements, and any transcripts from any person who has knowledge of the facts in this matter including any expert witness or Defendant (defined above) herein. **RESPONSE:** ----- Copies of any and all recorded statement(s) and telephone conversations, as well as any transcripts for the same that have been reduced to writing and/or transcribed, including but not limited to Examinations Under Oath, which were taken of or provided by any insured or their representatives (defined above) that are in your possession or control. **RESPONSE:** Copies of any and all recorded statement(s) and telephone conversations, as well as any transcripts for the same that have been reduced to writing and/or transcribed, which were taken of or provided by any witness that are in your possession or control. **RESPONSE:** Each and every document, report, chart, graph, object, summary, compilation of data or other thing relied upon by any of your experts, in whole or in part, in the formulation of any opinions and conclusion in this case. **RESPONSE:** Copies of any photographs of Plaintiffs’ Property located at 9860 Donato Way, Lake Worth, Florida, 33467 which are in your possession or control. **RESPONSE:** Copies of any photographs that reflect any damage at Plaintiffs’ Property located at 9860 Donato Way, Lake Worth, Florida, 33467that are in your possession or control. **RESPONSE:** Copies of any photographs of any work performed at Plaintiffs’ Property located at 9860 Donato Way, Lake Worth, Florida, 33467 that are in your possession or control. **RESPONSE:** ----- Copies of any and all estimates and damage appraisals and other documents (defined above) referencing damage appraisals regarding Plaintiffs’ Property located at 9860 Donato Way, Lake Worth, Florida, 33467that are in your possession or control. **RESPONSE:** Copies of any and all documents (defined above) upon which you based any denials of coverage for the loss described in Plaintiffs’ Complaint. **RESPONSE:** Copies of any and all documents (defined above) upon which you based any denials of all or part of the amount of loss claimed by Plaintiffs. **RESPONSE:** If there are any denials of insurance coverage by Defendant, then copies are requested of any and all applications for insurance, insurance forms, data sheets, correspondence, notices, facsimile, e-mails and other documents (defined above) that reference in any way any the insurance policy at issue in this matter. **RESPONSE:** Copies of any and all correspondence, facsimile, notices, e-mails and other documents (defined above) that reference in any way any notices that you provided to Plaintiffs regarding cancellation of the insurance policy at issue in this matter. **RESPONSE:** Copies of all PORS, Proof of Mailing and other documents (defined above) that reflect in any way mailings made by you to Plaintiffs regarding cancellation of the policy of insurance at issue in this matter. **RESPONSE:** ----- All reports and current curriculum vitae from any expert(s) retained by you for any reason regarding Plaintiffs’ claim. **RESPONSE:** Any and all e-mails, letters, facsimile, and other correspondence regarding any claims made by Plaintiffs for property insurance benefits as a result of the Hurricane event of September 27, 2022, including but not limited to, correspondence with experts, correspondence with experts, independent adjusters, appraisers, inspectors, and any other third party. **RESPONSE:** All documents reflecting any payment made to any person (defined above) or entity for any reason as a result of the Hurricane event described in Plaintiffs’ Complaint. **RESPONSE:** All books, treaties or authority used by Defendant’s adjuster in determining what amount to pay or deny regarding the claim at issue. **RESPONSE:** All writings, memoranda, notes or other materials reflecting examination of Plaintiffs’ Property by Defendant or its agents. **RESPONSE:** All proofs of loss received by Defendant from Plaintiffs. **RESPONSE:** All estimates received by Defendant from any source for repairs to Plaintiffs’ Property. **RESPONSE:** ----- Defendant’s latest claims manual or statement of policies and procedures on the processing or handling of property damage claims. **RESPONSE:** Any training manuals, guides and documents that Defendant has provided to its adjusters regarding adjusting Hurricane damage claims from the past three years to the present. **RESPONSE:** Copies of any peer reviews, estimates, or comparative estimates generated by anyone on Defendant’s behalf regarding the amount of loss at issue. **RESPONSE:** All documents showing the total amount paid during the past three years to any third parties providing services, analyses, or opinions regarding Plaintiffs’ claim. **RESPONSE:** A copy of the contract/agreement/document (if any) that Defendant has with anyone, including but not limited to contractors, engineers, adjusters, or experts, who may provide testimony at the trial of this matter. **RESPONSE:** A copy of each resume, curriculum vitae, and other document listing the qualifications of each and every expert and/or consultant hired by you or your representatives (defined above) who may testify at trial. **RESPONSE:** ----- All documents that relate to the drafting, meaning, and interpretation of any language, terms, or provisions, used in the policy at issue. **RESPONSE:** Pursuant to Fla. R. Civ. P. 1. 310(b)(6), please produce three (3) alternatives for deposition to occur no earlier than thirty (30) days but no later than one hundred-twenty (120) days from service for the deposition of the corporate representative(s) with the most knowledge of the claim asserted by the Plaintiffs’ Complaint as well as the individual(s) primarily responsible for the decision to deny indemnifying Plaintiffs’ amount of loss. A designation of the information upon which such examination will proceed will be provided under separate cover. **RESPONSE:** Copies of any and all notices sent by you or your representatives (defined above) to any insured to participate in a mediation program under Fla. Stat. § 627. 7015 and copies of any and all PORS, Proof of Mailing and other documents (defined above) which reflect in any way mailings made by you to any insured regarding the same. **RESPONSE:** **CERTIFICATE OF SERVICE** **I HEREBY CERTIFY that a true and correct copy of this document will be served on** Defendant along with the Summons and the Complaint in this action. **: September 5, 2024** _/s/Dalya Zalloum_ **COHEN LAW GROUP** Dalya Zalloum, Esq. _FOR THE FIRM_ Florida Bar Number: 1002903 350 North Lake Destiny Road Maitland, Florida 32751 Phone: (407) 478-4878 Fax: (407) 478-0204 Primary: DZalloum@itsaboutjustice. law Secondary: -----


[System]
You are a lawyer with 10 years of experience. Based on the complaint, create up to 20 questions for the defendant.

The questions should follow the format and style of this example response to a car accident complaint:
1. All photographs, diagrams, or other printed or written material describing or attempting to describe the scene of the accident alleged in the Complaint, or any person described in the Complaint.
2. Documentation substantiating health insurance coverage available to Plaintiff on the date of the accident sued upon.
3. Any cellular phones or other mobile communication system telephone bills, invoices, statements, itemized accounts, or other data compilation for the equipment owned or used by Plaintiffs for the months relevant to the incident.
4. Any and all films, diagnostic tests, MRIs, X-rays, storage devices, digital images, intra-operative photographs, and/or data compilations from which information can be obtained.
5. If a claim is made for lost wages and/or loss of earning capacity in the future, provide specific documentation like Federal Income Tax Returns and W-2 Forms.

Be specific, detailed and relevant to the complaint's allegations. Avoid generic requests for "all documents" or "all evidence". Each question should request specific items, time periods, or information directly related to the complaint's claims.

[User] IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIRCUIT CIVIL DIVISION ______________________________________/ SEH 27 LLC, a Delaware limited liability company, Plaintiff, v. COVENTRY 871 LLC, a Delaware limited liability company; LENDINGONE LLC, a Delaware limited liability company; ICON EQUITY GROUP LLC, a Florida limited liability company; and 879 COVENTRY STREET HOLDINGS LLC, a Florida limited liability company. Defendants. ________________________________________/ **VERIFIED COMPLAINT** Plaintiff, SEH 27 LLC, a Delaware limited liability company, sues Defendants Coventry 871 LLC, a Delaware Limited Liability Company, LendingOne LLC, a Delaware Limited Liability Company, Icon Equity Group LLC, a Florida Limited Liability Company, and 879 Coventry Street Holdings LLC, a Florida Limited Liability Company, (collectively, “Defendants”) and alleges: **INTRODUCTION** Plaintiff filed an action on a debt and for foreclosure, which is currently pending in the Circuit Court in and for the Fifteenth Judicial Circuit, against a number of defendants, including Anthony Shafer, a guarantor, to collect an outstanding debt and foreclose certain security interests (the “Foreclosure Action”). ----- After the Foreclosure Action was filed, and during the same period of time in which the debtor and the guarantors sought and obtained repayment extensions and a forbearance agreement, guarantor Anthony Shafer directed and caused the fraudulent transfer of assets in hopes of frustrating Plaintiff’s rights as creditor and Plaintiff’s expected collection efforts. Among the fraudulent transfers is the transfer of 100% membership interest in 879 Coventry Street Holdings LLC which is now the subject of this action. 879 Coventry Street Holdings LLC owns a property located at 879 Coventry Street Boca Raton Florida 33487 (the “879 Coventry Property”) and 871 Coventry Street Boca Raton Florida 33487 (the “871 Coventry Property”) (collectively, the “Coventry Properties”). In this Verified Complaint, Plaintiff sues Coventry 871 LLC, who was the transferee in the fraudulent transfer of the membership interest in 879 Coventry Street Holdings LLC. Plaintiff names Defendant Icon Equity Group LLC, a Florida Limited Liability Company controlled by Anthony Shafer, and 879 Coventry Street Holdings LLC, the Florida Limited Liability Company whose membership interest was fraudulently transferred, as nominal defendants. In addition, Plaintiff names Defendant LendingOne LLC as a nominal defendant, based on an apparent mortgage held by LendingOne LLC and secured by the 879 Coventry Property. Plaintiff seeks avoidance, damages, and any further relief as is just and proper. **PARTIES AND JURISDICTION** This is an action for statutory relief and damages in an amount greater than Fifty Thousand Dollars ($50, 000. 00), exclusive of interest, costs, and attorney’s fees, and thus, is within the jurisdictional limits of this Court. 2 ----- Plaintiff is a company existing and operating under and by virtue of the laws of the State of Delaware. Defendant Coventry 871 LLC is a company existing and operating under and by virtue of the laws of the State of Delaware. Defendant LendingOne LLC is a Delaware limited liability company that holds a lien on the 879 Coventry Property by virtue of a mortgage and is named in this action as a nominal defendant. No wrongdoing by Defendant LendingOne LLC is known or alleged as of this time. Defendant Icon Equity Group LLC is or was a Florida limited liability company having its principal place at 23 S. Swinton Ave, Delray Beach, in Palm Beach County, Florida. According to public state records, Defendant Icon Equity Group LLC was recently dissolved on September 27, 2024 and is named as a nominal defendant. Defendant 879 Coventry Street Holdings LLC is a Florida limited liability company having its principal place at the 871 Coventry Property in Palm Beach County, Florida and is named as a nominal defendant. This Court has jurisdiction over all defendants because each of them: (1) operates, conducts, engages in, or carries on a business or business venture in this state or has an office or agency in this state that gave rise to this action as set forth in Fla. Stat. § 48. 193(1)(a); (2) engages in substantial and not isolated activity within this state as set forth in Fla. Stat. § 48. 193(2); or (3) owns, uses, possesses, and/or holds a lien secured by real property in Palm Beach County, Florida. Venue is proper in Palm Beach County, Florida, under Fla. Stat. §§ 47. 011 and 041. 3 ----- **BACKGROUND AND FACTUAL ALLEGATIONS** **A. ** **The Foreclosure Action. ** On or about November 5, 2021, Anthony Shafer, as manager of Icon Development Holdings II, LLC, signed and executed a promissory note in the original principal sum of $10, 800, 000. 00 that became due on April 30, 2023. The promissory note had a corresponding mortgage that was recorded on November 12, 2021, in Official Records Book 33046, Page 121 in the public records of Palm Beach County, Florida. Anthony Shafer also signed an unlimited guaranty, unconditionally and continually guaranteeing the referenced promissory note. At Icon Development Holdings II LLC’s request, the original maturityof April 30, 2023 was extended through multiple amendments, the last of which extended the maturity to March 31, 2024. Icon Development Holdings II LLC then defaulted pursuant to the terms and conditions of the loan by, among other things, failing to pay the whole of the then outstanding principal, plus all accrued and unpaid interest (including default interest) upon the extended maturity of the promissory note on March 31, 2024. On April 12, 2024, Anthony Shafer, Icon Development Holdings II, LLC, and other corporate guarantors, entered into a forbearance agreement with Plaintiff. The very next month, Icon Development Holdings II, LLC defaulted on the payments required by the forbearance agreement. Under the forbearance agreement, Anthony Shafer acknowledged the full amount of the debt, waived all defenses, and consented to a judgment for the total debt, which continues to accrue default interest. 4 ----- On June 25, 2024, Plaintiff filed a Verified Complaint for Foreclosure and Damages in the Palm Beach County Action which named Anthony Shafer as a defendant, among others. On September 27, 2024, the trial court in the Foreclosure Action entered an agreed order on order to show cause, where it found that Plaintiff is likely to prevail in the action under Fla. Stat §702. 10(2)(d). In addition, in the same Foreclosure Action, a Motion for Summary Judgment was filed by Plaintiff on October 18, 2024 which is yet to be heard. **B. ** **Anthony Shafer’s Precipitous Drop in Net Worth and the 879 Coventry Street** **Holding LLC Transfer. ** Anthony Shafer provided Plaintiff with a personal financial statementd December 1, 2023 that stated that at the time: (1) Anthony Shafer’s net worth was $174 million dollars; (2) listed Icon Equity Group LLC as his employer; (3) listed Anthony Shafer as the sole owner of 879 Coventry Street Holdings LLC; (4) listed Anthony Shafer as owning the Coventry Properties through his ownership interest in 879 Coventry Street Holdings, LLC. Additionally, the operating agreement for Icon Equity Group LLC, d April 27, 2021, lists Anthony Shafer as its sole member and manager. The legal description of the 871 Coventry Property is Lot 16, Block 2 of BEL MARRA SUBDIVISION, according to the Plat thereof as recorded in Plat Book 25, Page 30, of Public Records of Palm Beach County, Florida. The legal description of the 879 Coventry Property is Lot 17, Block 2 of BEL MARRA SUBDIVISION, according to the Plat thereof as recorded in Plat Book 25, Page 30, of Public Records of Palm Beach County, Florida. On October 5, 2024, Anthony Shafer produced a personal financial statement in compliance with a court order from the Court in the Foreclosure Action. In those intervening ten months since the December 1, 2023 personal financial statement, Anthony Shafer’s self-reported 5 ----- net worth dwindled to just shy of two million dollars-reflecting a purported drop of more than $172 million dollars. Numerous assets, including membership interests in corporate entities and real property, were removed from Anthony Shafer’s October 2024 personal financial statement without explanation as to whether they were transferred and, if so, for what consideration, if any. Upon information and belief, Anthony Shafer has engaged in and continues to engage in actions to dissipate his assets in an effort to frustrate and defraud his creditors, including Plaintiff. On August 31, 2024, Icon Equity Group LLC an entity that Anthony Shafer manages, controls, and claimed to own, assigned 100% membership interest in 879 Coventry Street Holdings LLC (the “Transfer”). The Transfer was for no or only nominal and insufficient consideration. On September 27, 2024, Icon Equity Group LLC was administratively dissolved according to state public records. **COUNT I-FRAUDULENT TRANSFER UNDER FLA. STAT. § 726. 105(1)(a)** Plaintiff repeats and realleges paragraphs 1-30 above, as if fully set forth herein. Section 105(1)(a) of the Florida Uniform Fraudulent Transfer Act, Fla. Stat. 101 et. seq. provides that a transfer made by a debtor is fraudulent as to a creditor (whether the creditor’s claim arose before or after the transfer was made) if the debtor made the transfer with actual intent to hinder, delay or defraud any creditor of the debtor. Plaintiff was a creditor of Anthony Shafer within the meaning of section 105(1)(a) before and at the time of the Transfer. Anthony Shafer, as manager of Icon Equity Group LLC, made the Transfer with the actual intent to hinder, delay or defraud his creditors, including Plaintiff, in violation of Fla. 6 ----- Stat. § 726. 105(1)(a). Icon Equity Group LLC was a mere instrumentality used to fraudulently transfer the membership interest in 879 Coventry Street Holdings LLC (and the Coventry Properties) to Coventry 871 LLC. Anthony Shafer’s actual intent can be evidenced by the following badges of fraud: (a) At the time the Transfer was made, Anthony Shafer had been sued by Plaintiff in the Foreclosure Action seeking payment of millions of dollars in damages. (b) The Transfer was made after it became clear that Anthony Shafer would incur a substantial debt as guarantor for Icon Development Holdings II LLC. The Transfer constitutes a fraudulent transfer pursuant to Fla. Stat. § 726. 105(1)(a). As a direct and proximate result of the Transfer, Plaintiff has been harmed and continues to be harmed. Upon information and belief, Plaintiff is under secured and will not be made whole if it forecloses on the collateral in the Foreclosure Action. In addition, as a direct and proximate result of the Transfer, Plaintiff incurred or will incur damages in an amount to be determined at trial. The Transfer is subject to avoidance and recovery pursuant to Fla. Stat. § 105(1)(a). **WHEREFORE, Plaintiff respectfully requests a judgment in its favor against Defendants, ** and for the Court to: (i) find that the transfer of the membership interest in 879 Coventry Street Holdings LLC to 871 Coventry LLC was a fraudulent transfer pursuant to Fla. Stat. § 105(1)(a); (ii) award damages against Defendants, jointly and severally, in the amount of the value of the membership interest in 879 Coventry Street Holdings LLC; (iii) avoid the Transfer; (iv) enter provisional remedies against further transfers by Defendants of the membership interest 7 ----- in 879 Coventry Street Holdings LLC and the Coventry Properties, including but not limited to injunctive relief; and (v) award such and further relief as is just and proper. **COUNT II-FRAUDULENT TRANSFER UNDER FLA. STAT. § 726. 105(1)(b)** Plaintiff repeats and reallege paragraphs 1-30 above, as if fully set forth herein. Section 105(1)(b) of the Florida Uniform Fraudulent Transfer Act, Fla. Stat. 101 et. seq. provides that a transfer made by a debtor is fraudulent as to a creditor if the debtor made the transfer without receiving a reasonably equivalent value in exchange for the transfer or obligation, and the debtor either was engaged or was about to engage in a business or a transaction for which the remaining assets of the debtor were unreasonably small in relation to the business or transaction or intended to incur, or believed or reasonably should have believed that he or she would incur, debts beyond his or her ability to pay as they became due. Plaintiff was a creditor of Anthony Shafer within the meaning of section 105(1)(b) before and at the time of the Transfer. Anthony Shafer, through his control and management of Icon Equity Group LLC transferred the membership interest in 879 Coventry Street Holdings LLC to Coventry 871 LLC for less than reasonably equivalent value at a time when: (1) Anthony Shafer was engaged or was about to engage in a business or a transaction for which his remaining assets were unreasonably small in relation to the business or transaction, and/or (2) Anthony Shafer intended to incur, or believed or reasonably should have believed that he would incur, debts beyond his ability to pay as they became due. Specifically, Anthony Shafer transferred the membership interest in 879 Coventry Street Holdings LLC to Coventry 871 LLC when Anthony Shafer was a defendant under the Foreclosure Action, which will likely impose over $9 million in joint and several liability against him, plus additional liabilities in the form of costs and interest. 8 ----- The Transfer constitutes a fraudulent transfer pursuant to Fla. Stat. § 726. 105(1)(b). As a direct and proximate result of the Transfer, Plaintiff has been harmed. Upon information and belief, Plaintiff is under secured and will not be made whole if it forecloses on the collateral in the Foreclosure Action. In addition, as a direct and proximate result of the Transfer, Plaintiff has incurred or will incur damages in an amount to be determined at trial. The Transfer is subject to avoidance and recovery pursuant to Fla. Stat. § 105(1)(b). **WHEREFORE, Plaintiff respectfully requests a judgment in its favor against Defendants, ** and for the Court to: (i) find that the transfer of the membership interest in 879 Coventry Street Holdings LLC to 871 Coventry LLC was a fraudulent transfer pursuant to Fla. Stat. § 105(1)(b); (ii) award damages against Defendants, jointly and severally, in the amount of the value of the membership interest in 879 Coventry Street Holdings LLC; (iii) avoid the Transfer; (iv) enter provisional remedies against further transfers by Defendants of the membership interest in 879 Coventry Street Holdings LLC and the Coventry Properties, including but not limited to injunctive relief; and (v) award such and further relief as is just and proper. [SIGNAUTRES ON FOLLOWING PAGE] 9 -----d: October 28, 2024 Respectfully submitted, SEQUOR LAW, P. A. 1111 Brickell Avenue, Ste. 1250 Miami, FL 33131 Tel: (305) 372-8282 Fax: (305) 372-8202 By: /s/ Arnoldo B. Lacayo Arnoldo B. Lacayo Florida Bar No. 675482 Email: alacayo@sequorlaw. com Jennifer Mosquera Florida Bar No. : 1018656 Email: jmosquera@sequorlaw. com **CERTIFICATE OF SERVICE** I HEREBY CERTIFY that a true and correct copy of the foregoing was filed and sent via electronic service using the portal system with the Florida Courts eFiling Portal which sent e-mail notification of such filing in accordance with Rule 2. 516 Fla. R. Jud. Admin. to all parties on the attached Service List on October 28, 2024. _/s/ Arnoldo B. Lacayo_ Arnoldo B. Lacayo 10 -----

[Assistant] IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIRCUIT CIVIL DIVISION SEH 27 LLC, a Delaware limited liability company, Plaintiff, v. COVENTRY 871 LLC, a Delaware limited liability company; LENDINGONE LLC, a Delaware limited liability company; ICON EQUITY GROUP LLC, a Florida limited liability company; and 879 COVENTRY STREET HOLDINGS LLC, a Florida limited liability company, Defendant. / **PLAINTIFFS’ FIRST REQUEST** **FOR PRODUCTION TO DEFENDANT LENDINGONE LLC** Plaintiff, SEH 27 LLC, pursuant to Rules 1. 280 and 1. 350of the Florida Rules of Civil Procedure, hereby serves this First Request for Production son Defendant, LendingOne LLC. LendingOne LLC shall produce the documents requested below to Plaintiff through its counsel at a mutually convenient place within the time set by Rule 1. 350 or as otherwise agreed by the parties or ordered by the Court. SEQUOR LAW P A ----- **DEFINITIONS** For the purposes of the Requests and the instructions thereto, the following definitions apply: The rules of construction set forth in Rules 1. 280, and 1. 350 of the Florida Rules of Civil Procedure are incorporated herein. The terms “and” and “or” shall be individually interpreted in every instance as meaning “and/or” and shall not be interpreted disjunctively to exclude any information otherwise within the scope of any request. The terms “any” and “all” shall be considered to include “each” and “each and every. ” “Coventry Properties” refer to the properties located at 879 Coventry Street Boca Raton, Florida 33487 and 871 Coventry Street Boca Raton, Florida 33487. “Account” means any account, regardless of the type of account, whether open or closed, that is held in the name of any Relevant Party in connection with the Coventry Properties. “Loan” means a loan, letter of credit, line(s) of credit, debenture, mortgage and/or credit of any kind in connection with the Coventry Properties. “Communication” means any transmission of information, and shall include both oral and written communications, including without limitations communications by telephone, meetings, conferences, visits, discussions, negotiations, memoranda, mail, facsimile, electronic mail, other electronic- or internet-facilitated communication, or telegram. It further includes, but is not limited to, any summaries, reviews, reports, notes, logs, records, journals, minutes, or outlines concerning or memorializing the transmittal of information, and any contracts. 2 SEQUOR LAW P A ----- “Destination of Funds” shall mean the location where monies were sent, including the name of the account holder, account number, address, bank name and bank address or routing number. “Document(s)” means all originals, all drafts, all revised versions, and any and each copy bearing notations or marks not found on the original or draft, of any written, recorded, or graphic matter, however produced or reproduced, including, but not limited to, records relating to litigation, records relating to threats of claims, any typed or printed matter, correspondence, letters, faxes, interoffice communications, licenses, permits, diaries, calendars, memoranda, insurance policies, contracts or agreements, checks, statements of account, receipts, summaries, indices, data sheets, notes, papers, files, assignments, books, records, messages, reports, tables, graphs, computer printouts, tape recordings, transcripts, charts, logs, accounts, ledgers, studies, manuals, appraisals, consultant’s or expert’s reports, exhibits, notices, instructions, minutes, purchase orders, financial records, statements, bills, accounting records, tax records, accounting or tax work sheets, magnetic tapes, and any other data compilations from which information can be obtained or translated. The term “Document(s)” also includes all Communications. The term “Document(s)” also includes all ESI. The term “Document(s)” further includes all copies of Documents where the copy is not identical to the original. “ESI” means electronically stored information, and includes, but is not limited to, electronic data, computer programs (whether private, commercial, or work-in-progress), programming notes and instructions, activity listings of email transmittals and receipts, output resulting from the use of any software program, word-processing Documents, spreadsheets, database files, charts, graphs, PowerPoints, outlines, graphic files, miscellaneous files and file fragment, data compilations, voicemails, magnetic media, tapes electronic mail, text messages, 3 SEQUOR LAW P A ----- instant messages (IMs), WhatsApp messages, and/or Signal messages, on computer databases, indices, computers, backup storage media, cloud-based storage, CD-ROMs, DVDs, optical disks, hard drives, removable storage devices, floppy disks, regardless of the media on which they reside and regardless of whether said electronic data exist in an active file, deleted file, or file fragment, computer memories, cloudbased storage, hard disks, diskettes and cartridges, network drives, network memory storage, archived tapes and cartridges, removable media, magnetic tapes of all types, microfiche, and/or any other media used for digital data storage or transmittal. ESI also includes the file, folder tabs, and containers and labels appended to or associated with each original and non-identical copy. The term “Identify, ” when used with respect to persons, means to give, to the extent known: (i) the person’s full name; (ii) the person’s present or last known residential and business addresses; (iii) when referring to a natural person, additionally, the person’s present or last known place of employment and the person’s responsibilities with that employer. The term “Identify, ” when used with respect to Documents, means to give, to the extent known, the (i) type of Document; (ii) general subject matter; (iii)of the Document; and (iv) author(s), addressee(s), and recipient(s). “Including” means “including, but not limited to. ” “Person(s)” means any natural person, or any business, legal, or governmental entity, or association. “Relating to” means directly or indirectly, in whole or in part, relating to, referring to, pertaining to, mentioning, containing, discussing, embodying, identifying, stating, concerning, constituting, evidencing, recording, reflecting, substantiating, describing, summarizing, identifying, referring to in any way, or in any way relevant to. 4 SEQUOR LAW P A ----- “Relevant Period” shall mean the period beginning from January 1, 2023 to the present. “Relevant Parties” and/or “Relevant Party” refer to each of the following entities or individuals and extends to individuals bearing a name of similar variation as well as to any instance in which the Relevant Parties are reflected as having an relation to the matters set forth in the “Document Requests”: a. Anthony Shafer b. Coventry 871 LLC c. 879 Coventry Holding LLC d. Icon Equity Group LLC “State, ” “explain, ” and “describe” mean to set forth a complete and detailed statement of all information, circumstances, and facts that concern, refer to, relate to, reflect, comprise, or bear upon the matter concerning which information is requested. “You” and “Your” means the recipient of these Requests. **INSTRUCTIONS** Each Request shall be construed as being inclusive rather than exclusive. Thus, words importing the singular shall include the plural; words importing the plural shall include the singular; words importing one gender shall include both genders; the use of a verb in any tense, mood, or voice shall be construed as the use of the verb in all tenses, moods, or voices, as necessary to bring within the scope of the Requests all responses that might otherwise be construed to be outside of their scope; the words “and” and “or” shall be construed conjunctively or disjunctively as necessary to make the interrogatory or Document request inclusive; the word “all” means “any and all” and the word “any” means “any and all. ” 5 SEQUOR LAW P A ----- In producing Documents, you should furnish all Documents in your possession, custody, or control, regardless of whether such Documents are possessed directly by you or your agents, assigns, employees, or representatives, or by your attorneys or their agents, employees, representatives, or investigators. A Document is deemed in your actual or constructive possession, custody, or control if it is in your physical custody or if it is in the physical custody of any other person and you (i) own such Document in whole or in part; (ii) have a right, by control, contract, statute, order, or otherwise to use, inspect, examine, or copy such Document on any terms; (iii) have an understanding, express or implied, that you may use, inspect, examine, or copy such Documents upon any terms; or (iv) have, as a practical matter, been able to use, inspect, examine, or copy such Document when you sought to do so. For the avoidance of doubt, and without limiting the foregoing, a Document is deemed to be in your actual or constructive possession, custody, or control if it is accessible on a network or server maintained by you. Each of these Discovery Requests requires production in full, without abbreviation, redaction, or expurgation of any responsive Documents. If any responsive Document is not or cannot be produced in full, produce it to the extent possible, indicating which Document or portion of that Document is being withheld and the reason(s) it is being withheld. Produce any and all drafts of each Document that is responsive to any Document request and any and all copies of each such Document that are not identical in any respect, including but not limited to differences in handwritten notes, markings, stamps, interlineations, and electronic information. Documents referred to herein shall include all portions or pages of each Document referred to and all attachments, enclosures, appendices, and supporting Documentation, including, without limitation, originals, copies, drafts, working papers, routing slips, handwritten notes, and 6 SEQUOR LAW P A ----- similar materials (with or without notes or changes therein). All Documents that are physically attached to each other when located for production shall be left so attached when produced. Documents that are segregated or separated from other Documents, whether by inclusion in binders, files, subfiles, or by use of dividers, tabs, or any other method, shall be left so segregated or separated when produced. Documents shall be produced in the order in which they were maintained and in the files in which they were found. With respect to ESI: a. ESI shall be produced on readily accessible electronic media, including, without limitation, CD-ROM, DVD, USB flash drive, external hard drive (with standard PC compatible interface), or such other media as may be agreed upon (“Production Media”). A unique identifying label shall be affixed to each piece of Production Media, which identifies theof the production and the sequence of the material in that production. All Production Media shall be properly packaged to ensure safe shipping and handling. b. ESI shall be produced in Native Format, inclusive of all metadata along with the software necessary to interpret such files if such software is not readily available. A single Bates numbered TIFF placeholder shall be provided for any data provided in native format. The TIFF placeholder shall state: “This Document produced in native format, per Plaintiff’s request. ” c. Under no circumstances should ESI be converted from the form in which it is ordinarily maintained to a different form that makes it more difficult or burdensome to use. ESI should not be produced in a form that removes or significantly degrades the ability to search the ESI by electronic means where the ESI is ordinarily maintained in a way that makes it searchable by electronic means or which results in the loss of metadata. ESI shall be processed, to the extent practicable, in a manner that preserves all metadata, hidden columns or rows, hidden text or 7 SEQUOR LAW P A ----- worksheets, speaker notes, tracked changes, and comments. Databases or underlying data should not be produced without first discussing production format issues with Plaintiff’s counsel. Documents shall be produced as they are kept in the usual course of business or organized and labeled to correspond to the categories in this request. All hard-copy Documents shall be produced while maintaining the file folder, envelope, or other container in which the Documents are kept or maintained by you. If, for any reason, the container cannot be produced, produce copies of all labels or other identifying marks. OCR shall also be provided for all hardcopy Documents. The text for each hard-copy Document shall be generated by applying optical character recognition (OCR) technology to the scanned image of the Document, and providing that text file in searchable format. If any requested Document is not or cannot be produced in full, you are requested to produce such Document to the extent possible, indicating which Document or portion of that Document is being withheld and the reason that portion of the Document is being withheld. In producing Documents, you are requested to produce each Document requested together with all non-identical copies and drafts of that Document. If the original of any Document cannot be located, a copy shall be provided in lieu thereof, and shall be legible and bound or stapled in the same manner as the original. Whenever a request calls for production with respect to “each” one of a particular type or class of matters, events, persons, or entities, of which there is more than one, You are required to separately list, set forth, or identify for each thereof all of the information called for. If any Document or any part of a Document called for by these Discovery Requests has been destroyed, discarded, lost, or otherwise disposed of or placed beyond your custody or control, you shall furnish a list identifying each such Document by: (i); (ii) author; 8 SEQUOR LAW P A ----- (iii) recipient(s); (iv) type of Document (e. g. , letter, memorandum, chart, or e-mail); (v) general subject matter; (vi) the Document’s present or last-known location or custodian; (vii) theof the Document’s destruction or other disposition; (viii) the reason for such destruction or other disposition; and (ix) the person authorizing such destruction or other disposition. If a privilege is claimed as the basis for not producing any Document (such as the Attorney-Client Privilege or other exception from disclosure that you contend may apply), you are to furnish a privilege log setting forth, for each such Document: (i) the nature of the privilege claimed; (ii) theof the Document; (iii) the person(s) who prepared the Document; (iv) each person to whom a copy of the Document was furnished, or to whom its contents were communicated, including titles and job descriptions of any such person; (v) the person who has custody of such Document or a copy of such Document; (vi) any and all facts and reasons that you claim support each objection; (vii) the reason(s) for the preparation of the Document; (viii) each person who has knowledge of any of the facts or reasons that you claim support such objection; and (ix) all information relating hereto which is not within the scope of the privilege claimed. Documents not otherwise responsive to these Discovery Requests are to be produced if such Documents discuss or explain the Documents which are responsive to these Discovery Requests, or if such Documents are attached to Documents responsive to these Discovery Requests and constitute routing slips, transmittal memoranda, or letters, comments, evaluations, or similar materials. In responding to these Discovery Requests, if you encounter any ambiguity in construing an individual request or any definitions and instructions relevant thereto, set forth the matter or term deemed ambiguous and the construction used in responding to such request. 9 SEQUOR LAW P A ----- The past tense shall be construed to include the present tense, and vice versa, to make the Requests inclusive rather than exclusive. The singular shall be construed to include the plural, and vice versa, to make the Requests inclusive rather than exclusive. In the event You claim that any Document which was requested to be identified is unavailable, lost, misplaced, or destroyed, You must state the following: (a) theYou believe such Document became unavailable, lost, misplaced, or destroyed; (b) the reason why such Document became misplaced, lost, or destroyed; and (c) identify all persons who You know or believe have knowledge of such facts. **DOCUMENTS REQUESTED** Please produce the following: All Documents related to each loan application for approval of credit or financing related to any Account(s) or Loan(s). All monthly statements related to any Account(s) or Loan(s) during the Relevant Period. All Document reflecting the current amount due and owing related to any Account(s) or Loan(s). Account(s) or Loan(s) opening Documents. All other Documents relating to any Account(s) or Loan(s). 10 SEQUOR LAW P A ----- All financial statements, balance sheets, accounts receivable and payable ledgers, net worth statements, income statements, working capital statements, cash flow statements or any other financial matters relating to any Account(s) or Loan(s). All documents reflecting the Source of Funds for any Transfer during the Relevant Period to you or on your behalf by any Relevant Party in connection with any Account(s) or Loan(s). All documents reflecting the Source of Funds for any Transfer during the Relevant Period to you or on your behalf by any third party on behalf of any Relevant Party in connection with any Account(s) or Loan(s). All documents reflecting the Destination of Funds for any Transfer during the Relevant Period from you to any Relevant Party in connection with any Account(s) or Loan(s). All documents reflecting the Destination of Funds for any Transfer during the Relevant Period from you to any third party on behalf of any Relevant Party in connection with any Account(s) or Loan(s). All documents reflecting or concerning sales, leases, real estate brokerage services, transfer of title, mortgages, appraisals, homeowner’s association applications, or other agreements concerning the Coventry Properties. All communications between you, on the one hand, and any of the Relevant Parties, on the other hand, in connection with any Account(s) or Loan(s). All agreements executed by you during the Relevant Period with any of the Relevant Parties in connection with any Account(s) or Loan(s). d: November 25, 2024 Respectfully submitted, SEQUOR LAW, P. A. 1111 Brickell Avenue, Ste. 1250 11 SEQUOR LAW P A ----- Miami, FL 33131 Tel: (305) 372-8282 Fax: (305) 372-8202 By: /s/ Arnoldo B. Lacayo Arnoldo B. Lacayo Florida Bar No. 675482 Email: alacayo@sequorlaw. com Jennifer Mosquera Florida Bar No. : 1018656 Email: jmosquera@sequorlaw. com **CERTIFICATE OF SERVICE** I HEREBY CERTIFY that a true and correct copy of the foregoing was filed and sent via electronic service using the portal system with the Florida Courts eFiling Portal which sent e-mail notification of such filing in accordance with Rule 2. 516 Fla. R. Jud. Admin. to all parties on November 25, 2024. /s/ Arnoldo B. Lacayo Arnoldo B. Lacayo 12 SEQUOR LAW P A -----


[System]
You are a lawyer with 10 years of experience. Based on the complaint, create up to 20 questions for the defendant.

The questions should follow the format and style of this example response to a car accident complaint:
1. All photographs, diagrams, or other printed or written material describing or attempting to describe the scene of the accident alleged in the Complaint, or any person described in the Complaint.
2. Documentation substantiating health insurance coverage available to Plaintiff on the date of the accident sued upon.
3. Any cellular phones or other mobile communication system telephone bills, invoices, statements, itemized accounts, or other data compilation for the equipment owned or used by Plaintiffs for the months relevant to the incident.
4. Any and all films, diagnostic tests, MRIs, X-rays, storage devices, digital images, intra-operative photographs, and/or data compilations from which information can be obtained.
5. If a claim is made for lost wages and/or loss of earning capacity in the future, provide specific documentation like Federal Income Tax Returns and W-2 Forms.

Be specific, detailed and relevant to the complaint's allegations. Avoid generic requests for "all documents" or "all evidence". Each question should request specific items, time periods, or information directly related to the complaint's claims.

[User] IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA ANTHONY SIMEONE and FRANCES SIMEONE, Plaintiffs, vs. R. T. G. FURNITURE CORP. , Defendant. _________________________________/ **COMPLAINT** Plaintiffs, ANTHONY SIMEONE and FRANCES SIMEONE, sue Defendant, R. T. G. FURNITURE CORP. , and alleges: This is an action for damages that exceeds the minimum jurisdictional limits of $50, 000. 00. All acts complained of occurred in Palm Beach County, Florida and Palm Beach County is the proper venue for this action. All conditions precedent to bringing this action have occurred or been waived. Plaintiffs, ANTHONY SIMEONE and FRANCES SIMEONE, are residents of Palm Beach County, Florida. Defendant, R. T. G. FURNITURE CORP. , is a Florida profit corporation transacting its customary business in Palm Beach County, Florida. Prior to May 15, 2023, Plaintiffs, ANTHONY SIMEONE and FRANCES SIMEONE, purchased a chair from the "Rooms to Go" furniture store located at 9185 Glades Rd Ste A, Boca Raton, Palm Beach County, Florida. ----- Defendant, R. T. G. FURNITURE CORP. , owns and operates the "Rooms to Go" furniture store located at 9185 Glades Rd Ste A, Boca Raton, Palm Beach County, Florida. On or about May 15, 2023, Plaintiff, ANTHONY SIMEONE, was using the chair purchased from Defendant, R. T. G. FURNITURE CORP. , in his home in Palm Beach County, Florida. At that time and place, the chair collapsed beneath the Plaintiff, ANTHONY SIMEONE, causing him to suffer bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, lost wages and earning capacity, expense of hospitalization, medical and nursing care and treatment, and aggravation of a previously existing condition. The losses are either permanent or continuing and Plaintiff will suffer the losses in the future. Plaintiff, ANTHONY SIMEONE, used the chair in the manner intended and reasonably foreseeable to the Defendant, R. T. G. FURNITURE CORP. At all times material hereto, Defendant, R. T. G. FURNITURE CORP. , designed, manufactured, distributed, and/or sold the chair described herein. The chair described herein contained a defect that was present at the time of manufacture. While in use, the chair can break apart and collapse, creating a risk of injury to users. When the subject chair was placed into the stream of commerce by the Defendant it was not reasonably fit, suitable, or safe for its intended purpose or reasonably foreseeable use. **COUNT I - IMPLIED WARRANTY OF MERCHANTABILITY** Paragraphs 1-14 are re-alleged and incorporated herein. The chair designed, manufactured, distributed, and/or sold by the Defendant was not reasonably fit for either the uses intended or the uses reasonably foreseeable by the Defendant. While in use, the chair collapsed, injuring the Plaintiff. The chair's lack of fitness was the direct and proximate cause of the Plaintiff's injuries. ----- WHEREFORE, the Plaintiff, ANTHONY SIMEONE, demands judgment against Defendant, R. T. G. FURNITURE CORP. for damages, interest, costs and for such further relief as this court deems appropriate under the circumstances and further demand a trial by jury on all issues so triable as a matter of right. **COUNT II - IMPLIED WARRANTY OF FITNESS FOR PARTICULAR PURPOSE** Paragraphs 1-14 are re-alleged and incorporated herein. The chair designed, manufactured, distributed, and/or sold by the Defendant was not reasonably fit for the specific purpose for which the Defendant knowingly sold the product and for which Plaintiff bought the product in reliance on the judgment of the Defendant. While the chair was used as intended and for its specific purpose, the chair collapsed, injuring the Plaintiff. The chair's lack of fitness was the direct and proximate cause of the Plaintiff's injuries. WHEREFORE, the Plaintiff, ANTHONY SIMEONE, demands judgment against Defendant, R. T. G. FURNITURE CORP. for damages, interest, costs and for such further relief as this court deems appropriate under the circumstances and further demand a trial by jury on all issues so triable as a matter of right. **COUNT III - STRICT LIABILITY - MANUFACTURING DEFECT** Paragraphs 1-14 are re-alleged and incorporated herein. The chair that caused the Plaintiff's injuries was designed, manufactured, distributed, and/or sold by the Defendant, R. T. G. FURNITURE CORP. The chair was made differently than its intended design and therefore failed to perform as safely as intended. The chair was made in a manner that allowed it to break apart and collapse, creating a risk of injury to users. ----- The chair reached the Plaintiff without substantial change affecting its condition from the time it was manufactured. While the Plaintiff was using the chair, the manufacturing defect caused the chair to collapse and injure the Plaintiff. The chair’s manufacturing defect was the direct and proximate cause of the Plaintiff's injuries. WHEREFORE, the Plaintiff, ANTHONY SIMEONE, demands judgment against Defendant, R. T. G. FURNITURE CORP. for damages, interest, costs and for such further relief as this court deems appropriate under the circumstances and further demand a trial by jury on all issues so triable as a matter of right. **COUNT IV - STRICT LIABILITY - DESIGN DEFECT** Paragraphs 1-14 are re-alleged and incorporated herein. The chair that caused the Plaintiff's injuries was designed by the Defendant, R. T. G. FURNITURE CORP. The chair failed to perform as safely as an ordinary consumer would expect when used as intended or in a manner reasonably foreseeable by the Defendant. The chair reached the Plaintiff without substantial change affecting its condition from the time it was manufactured. While the Plaintiff was using the chair, the design defect caused the chair to collapse and injure the Plaintiff. The chair’s design defect was the direct and proximate cause of the Plaintiff's injuries. WHEREFORE, the Plaintiff, ANTHONY SIMEONE, demands judgment against Defendant, R. T. G. FURNITURE CORP. for damages, interest, costs and for such further relief as this court deems appropriate under the circumstances and further demand a trial by jury on all issues so triable as a matter of right. ----- **COUNT V - STRICT LIABILITY - FAILURE TO WARN** Paragraphs 1-14 are re-alleged and incorporated herein. The foreseeable risk of harm from the chair could have been reduced or avoided by providing reasonable instructions or warnings regarding the chair’s tendency to collapse. The failure to provide those warnings made the chair unreasonably dangerous by failing to alert the Plaintiff that the chair could break apart and collapse. Defendant, R. T. G. FURNITURE CORP. 'S, failure to warn was the direct and proximate cause of the Plaintiff's injuries. WHEREFORE, the Plaintiff, ANTHONY SIMEONE, demands judgment against Defendant, R. T. G. FURNITURE CORP. for damages, interest, costs and for such further relief as this court deems appropriate under the circumstances and further demand a trial by jury on all issues so triable as a matter of right. **COUNT VI - NEGLIGENCE** Paragraphs 1-14 are re-alleged and incorporated herein. As the designer, manufacturer, distributor, and/or seller of the chair, the Defendant owed a duty to use reasonable care in the design, manufacture, and/or sale of a product that was reasonably safe for its intended and foreseeable use. Defendant breached this duty by designing, manufacturing, and/or selling a chair that Defendant knew or should have known was defective and posed an unreasonable risk of injury to consumers. Defendant also failed to warn Plaintiffs of the unreasonable risk of injury in using a chair that Defendant knew or should have known was defective. As the direct and proximate cause of the Defendant’s negligence, the chair broke apart and collapsed when it was utilized in a normal and foreseeable manner by the Plaintiff. ----- As a direct and proximate result of the Defendant’s negligence, the Plaintiff, ANTHONY SIMEONE, suffered bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, lost wages and earning capacity, expense of hospitalization, medical and nursing care and treatment, and aggravation of a previously existing condition. The losses are either permanent or continuing and Plaintiff will suffer the losses in the future. WHEREFORE, the Plaintiff, ANTHONY SIMEONE, demands judgment against Defendant, R. T. G. FURNITURE CORP. for damages, interest, costs and for such further relief as this court deems appropriate under the circumstances and further demand a trial by jury on all issues so triable as a matter of right. **COUNT VII - LOSS OF CONSORTIUM** Paragraphs 1-14 are re-alleged and incorporated herein. At the time of the accident complained of in the Plaintiffs’ Complaint, the Plaintiffs were married. Plaintiffs continue to be married. That as a result of the negligent acts of the Defendant, the Plaintiffs were caused to suffer, and will continue to suffer in the future, loss of consortium, loss of society, affection, assistance, and conjugal fellowship, all to the detriment of their marital relationship. That all the injuries and damages were caused solely and proximately by the negligence of the Defendant. WHEREFORE, the Plaintiff, FRANCES SIMEONE, demands judgment against Defendant, R. T. G. FURNITURE CORP. for damages, interest, costs and for such further relief as this court deems appropriate under the circumstances and further demand a trial by jury on all issues so triable as a matter of right. ON NEXT PAGE] ----- Signed andd this 11[th] day of November 2024. **KOGAN AND DiSALVO, P. A. ** 3615 West Boynton Beach Blvd. Boynton Beach, FL 33436 Phone: (561) 375-9500 Fax: (561) 374-7898 By: _/s/ George M. Bakalar_ GEORGE M. BAKALAR, ESQ. Florida Bar No. : 802689 [Email: gmbakalar@koganinjurylaw. com](mailto:gmbakalar@koganinjurylaw. com) BRIGITTE M. JOLLIET, ESQ. Florida Bar No. : 1054771 [Email: bjolliet@koganinjurylaw. com](mailto:bjolliet@koganinjurylaw. com) Counsel for Plaintiffs Anthony Simeone and Frances Simeone. -----

[Assistant] IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA ANTHONY SIMEONE and FRANCES SIMEONE, Plaintiffs, vs. R. T. G. FURNITURE CORP. , Defendant. _________________________________/ **PLAINTIFFS’ FIRST REQUEST TO PRODUCE TO** **DEFENDANT, R. T. G. FURNITURE CORP. ** Plaintiffs, ANTHONY SIMEONE and FRANCES SIMEONE, by and through the undersigned counsel and pursuant to Rule 1. 350, Fla. R. Civ. P. , hereby request that Defendant, R. T. G. FURNITURE CORP. , produce at the offices of Plaintiffs’ counsel, located at 3615 W. Boynton Beach Boulevard, Boynton Beach, FL 33436, the following items within forty-five (45) days after service of this request: Any and all policies of insurance which you contend cover or may cover you for the allegations set forth in Plaintiff’s Complaint, including any and all declaration pages, policy forms and endorsements. Any and all documents related to the warnings and instructions provided with the subject chair (SKU No. 26320072) from January 2021 to the present. Any and all documents reflecting the sale and distribution of the subject chair (SKU No. 26320072) to the Plaintiff. Any and all documents reflecting the inspection of the subject chair (SKU No. 26320072) that was sold to the Plaintiff. ----- Copies of any and all marketing materials, advertisements, or promotional materials for the subject chair (SKU No. 26320072) from January 2021 to the present. Any and all documents concerning any known issues, complaints, or investigations related to defects or safety issues with the subject chair (SKU No. 26320072) from January 2021 to the present. Any and all documents, drawings, schematics, and specifications related to the design, manufacture, and assembly of the subject chair (SKU No. 26320072) from January 2021 to the present. Copies of any and all quality control and inspection reports for the subject chair (SKU No. 26320072), including any reports or assessments related to product safety, durability, or defect detection from January 2021 to the present. Copies of any and all warranty policies and records of any and all notices, consumer advisories, or safety bulletins issued regarding the subject chair (SKU No. 26320072) from January 2021 to present. Copies of any and all any recall notices or advisories that were provided to consumers or the retailer where Plaintiff purchased the chair from January 2021 to present. Copies of any and all consumer complaints, claims, incident reports, inspections, or investigations concerning the subject chair (SKU No. 26320072) from January 2021 to the present. Copies of the company’s product safety and quality assurance policies or procedures applicable to the subject chair (SKU No. 26320072) from January 2021 to the present. ----- Any and all risk management, safety assessments, or incident analysis reports prepared for the subject chair (SKU No. 26320072) from January 2021 to the present. Records showing the qualifications, training, and employment history of any employees responsible for the design, quality control, inspection, sale, or delivery of the subject chair (SKU No. 26320072) from January 2022 to the present. I HEREBY CERTIFY that a true and correct copy of the foregoing Request to Produce has been served on the Defendant along with the Summons and Complaint. **KOGAN AND DiSALVO, P. A. ** 3615 West Boynton Beach Blvd. Boynton Beach, FL 33436 Phone: (561) 375-9500 Fax: (561) 374-7898 By: _/s/ George M. Bakalar_ GEORGE M. BAKALAR, ESQ. Florida Bar No. : 802689 [Email: gmbakalar@koganinjurylaw. com](mailto:gmbakalar@koganinjurylaw. com) -----