Filing ft 14758427 Electronically Filed 06/12/2014 04:15:59 PM

Filing ft 14758427 Electronically Filed 06/12/2014 04:15:59 PM IN THE CIRCUIT COURT FOR THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA KENNETH MANFREDI, SR., KENNETH MANFREDI, JR., and ALEXANDER LIEBSTER as Trustee For the Estate of Ernesto Liebster Plaintiffs, CASE NO. 13-024268-CA 01 v. KOBALTEK, NC, an inactive Florida Corporation, MLLENIUM LOCK INC. d/b/a ULTIMATE LOCK SYSTEMS, a Texas Corporation; DARREN BAYSINGER, individually; RON DANIELS, individually; and Joseph Titone, individually, Defendants. DEFENDANTS' KOBALTEK, INC. & DARREN BAYSINGER'S RESPONSE TO PLAINTIFFS' REOUEST FOR PRODUCTION COMES NOW Defendants Kobaltek, Inc., and Darren Baysingcr, by and through undersigned counsel, and files this Response to Plaintiffs' Request for Production, and states as follows: I. Objection any and all documents between the attorney for Kobaltek, Inc. are privileged and confidential. 2. Objection — same 3. Objection — same 4. Objection — irrelevant and unlikely to lead to discovery of admissible evidence. Further, any pleadings in the case referred to are a matter of public record and said pleadings are equally available and accessible to all parties. 5. Objection — irrelevant and unlikely to lead to discovery of admissible evidence. Further, EFTA01198720 any and all documents, if any, were filed as pleadings and/or exhibits in the case referred to. 6. Objection — same as #5. 7. Objection - irrelevant and unlikely to lead to discovery of admissible evidence. Further, the Plaintiffs attached said settlement agreement as Exhibit Ito their Complaint, so Plaintiffs already have that document. 8. Objection — any and all documents between Joe Titone and Anthony Titone are confidential and privileged between the two attorneys. 9. Objection — same as #8. 10. Objection — same as #4 and further, undersigned counsel has not decided which documents will be presented at any hearing to be held in the future. I I. Objection — same as #10. 12. Objection — same as #10. /s/ Joe Titone Joe Titone Attorney FL BAR 203882 621 S.E. 5th Street Pompano Beach, Florida 33060 (954) 729-6490 (954) 941-2232 (FAX) Joetitone708@comcastnet /s/ Steve Mankodi Steve Mankodi Litigation Support Attorney FL BAR #: 10616 11972 West Sample Road Coral Springs, Florida 33065 954 295-1941 EFTA01198721 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing was served on June 12, 2014 upon George C. Paladis, Esq., & Michael J. Reppas, Esq., Law Office of Michael J. Reppas, IMI., 7850 NW 146Th Street, Suite 501, Miami Lakes, Florida 33016. EFTA01198722