IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR LEE COUNTY, FLORIDA CLARK L, DURPO, JR. and CLARK L, DURPO, Plaintiffs, CONSOLIDATED CASE NO. 13-CA-001057 BELLA LACTO CONDOMINIUM AT BAY BEACH CONDOMINIUM ASSOCIATION, INC., et al., Defendants. ESTERO BAY IMPROVEMENT ASSOCIATION, INC., et al., Plaintiffs, CASE NO. 14-CA-000083 CLARK L. DURPO and CLARK L, DURPO, JR. Defendants. PLAINTIFF CLARK L. DURPO'S FIRST SET OF INTERROGATORIES TO ASSOCIATIONS, WATERSIDE MANATEE BAY HOLDINGS, LLC; BELLA LAGO CONDOMINIUM AT BAY BEACH CONDOMINIUM ASSOCIATION, INC.; CASA MARINA ASSOCIATION, INC.; CASA MARINA II CONDOMINIUM ASSOCIATION, INC.; VALENCIA VILLAS AT BAY BEACH ASSOCIATION, INC.; WATERSIDE I AT BAY BEACH CONDOMINIUM ASSOCIATION, INC.; WATERSIDE II AT BAY BEACH CONDOMINIUM ASSOCIATION, INC.; WATERSIDE III AT BAY BEACH CONDOMINIUM ASSOCIATION, INC.; WATERSIDE IV AT BAY BEACH CONDOMINIUM ASSOCIATION, INC.; WATERSIDE V AT BAY BEACH CONDOMINIUM ASSOCIATION, INC.; ESTERO BAY IMPROVEMENT ASSOCIATION, INC.; BAYSIDE MASTER ASSOCIATION, INC.; WATERSIDE DOCK ASSOCIATION, INC.; CASA MARINA III CONDOMINIUM ASSOCIATION, INC.; MANATEE BAY AT BAY BEACH CONDOMINIUM ASSOCIATION, INC.; ROYAL PELICAN ASSOCIATION, INC.; SUNSET GULF CONDOMINIUM ASSOCIATION, INC.; HARBOR POINTK CONDOMINIUM ASSOCIATION, INC.; HIBISCUS POINTE CONDOMINIUM ASSOCIATION, INC.; AND THE PALMS OF BAY BEACH CONDOMINIUM ASSOCIATION, INC.
Plaintiff, CLARK L. DURPO ("Durpo"), by and through his undersigned counsel, pursuant to Fla. R, Civ. P, 1.340, hereby submits to the following individual Associations: WATERSIDE MANATEE BAY HOLDINGS, LLC; BELLA LAGO CONDOMINIUM AT BAY BEACH CONDOMINIUM ASSOCIATION, INC.; CASA MARINA ASSOCIATION, INC.; CASA MARINA II CONDOMINIUM ASSOCIATION, INC.; VALENCIA VILLAS AT BAY BEACH ASSOCIATION, INC.; WATERSIDE I AT BAY BEACH CONDOMINIUM ASSOCIATION, INC.; WATERSIDE II AT BAY BEACH CONDOMINIUM ASSOCIATION, INC.; WATERSIDE III AT BAY BEACH CONDOMINIUM ASSOCIATION, INC.; WATERSIDE IV AT BAY BEACH CONDOMINIUM ASSOCIATION, INC.; WATERSIDE V AT BAY BEACH CONDOMINIUM ASSOCIATION, INC.; ESTERO BAY IMPROVEMENT ASSOCIATION, INC.; BAYSIDE MASTER ASSOCIATION, INC.; WATERSIDE DOCK ASSOCIATION, INC.; CASA MARINA III CONDOMINIUM ASSOCIATION, INC.; MANATEE BAY AT BAY BEACH CONDOMINIUM ASSOCIATION, INC,; ROYAL PELICAN ASSOCIATION, INC.; SUNSET GULF CONDOMINIUM AS SOCIATION, INC.; HARBOR POINTE CONDOMINIUM ASSOCIATION, INC.; HIBISCUS POINTE CONDOMINIUM ASSOCIATION, INC.; AND THE PALMS OF BAY BEACH CONDOMINIUM ASSOCIATION, INC., (individually, "Association" ) the following interrogatories to be answered under oath: GENERAL INSTRUCTIONS A. Each interrogatory is to be answered separately and as completely as possible. The fact that investigation is continuing or that discovery is not complete shall not be used as an excuse for failure to answer each interrogatory as fully as possible. B. The answers should be based upon information known to you and includes information known to you through your agents or attorneys, other than information which is
subject to attorney/client or work product privilege. To the extent that the answer to any interrogatory in not based upon information known to you, specify the person possessing the information. C. If the answer to all or part of any interrogatory is not presently known or available, include a statement to that effect, specify the portion of the interrogatory which cannot be completely answered, and furnish all information that is known or available. D. Reference to documents generally is not sufficient. Where an interrogatory requests identification of specific documents, please identify the document, date of the document, title and author. DEFINITIONS Unless specifically indicated otherwise, the following definitions are applicable throughout these interrogatories and are incorporated by reference into each specific request for documents. A. As used herein, "you" or "your" means the party or parties to whom these Interrogatories are addressed, including any persons acting or purporting to act on behalf of you, including, but not limited to, officers, employees, agents, attorneys, or independent contractors. B. As used herein, "Plaintiffs" or "Durpos" means Clark L. Durpo and Clark L. Durpo, Jr. and their administrators, successors, agents, attorneys, representatives, executors, and assigns and all other persons acting or purporting to act or to have acted on behalf of Clark L. Durpo and Clark L. Durpo, Jr, C. As used herein, the term "Amended Complaint" means the Amended Complaint dated October 25, 2013 filed by the Durpos in Case No. 13-CA-001057, D. As used herein, the term "Counterclaim" means the Counterclaim dated November 27, 2013 asserted against the Durpos and filed in Case No. 13-CA-001057.
E. The term "EBIA Complaint" means the Complaint dated January 10, 2014 filed by Estero Bay Improvement Association, Inc., Bayside Master Association, Inc., and Waterside Dock Association, Inc. in Case No. 14-CA-000083. F. As used herein, the term "Associations" means BELLA LAGO CONDOMINIUM AT BAY BEACH CONDOMINIUM ASSOCIATION, INC., CASA MARINA ASSOCIATION, INC., CASA MARINA II CONDOMINIUM ASSOCIATION, INC., CASA MARINA III CONDOMINIUM ASSOCIATION, INC., HARBOUR POINTE CONDOMINIUM ASSOCIATION, INC., HIBISCUS POINTE CONDOMINIUM ASSOCIATION, INC,, MANATEE BAY AT BAY BEACH CONDOMINIUM ASSOCIATION, INC., ROYAL PELICAN ASSOCIATION, INC., SUNSET GULF CONDOMINIUM ASSOCIATION, INC,, THE PALMS OF BAY BEACH CONDOMINIUM ASSOCIATION, INC., VALENCIA VILLAS AT BAY BEACH ASSOCIATION, INC., WATERSIDE I AT BAY BEACH CONDOMINIUM ASSOCIATION, INC., WATERSIDE II AT BAY BEACH CONDOMINIUM ASSOCIATION, INC., WATERSIDE III AT BAY BEACH CONDOMINIUM ASSOCIATION, INC., WATERSIDE IV AT BAY BEACH CONDOMINIUM ASSOCIATION, INC., WATERSIDE V AT BAY BEACH CONDOMINIUM ASSOCIATION, INC., WATERSIDE MANATEE BAY HOLDINGS, LLC, ESTERO BAY IMPROVEMENT ASSOCIATION, INC., BAYSIDE MASTER ASSOCIATION, INC., and WATERSIDE DOCK ASSOCIATION, INC. G. As used herein, the term "EBIA" means the Estero Bay Improvement Association, Inc. H. As used herein, the term "BMA" means the Bayside Master Association, Inc. I. As used herein, the term "WDA" means the Waterside Dock Association, Inc.
J. As used herein, the term "Bay Beach Community" means the planned community on the south end of Fort Myers Beach, Florida, as referenced in paragraphs 7 and 8 of the Amended Complaint. K. As used herein, the term "Golf Course Property" shall mean and refer to the real property, commonly known as the Ft. Myers Beach Golf Club, owned by the Durpos as referred to in paragraph 7 of the Amended Complaint. L. As used herein, the term "System" shall mean the unified surface water management system within the Bay Beach Development Regional Impact as referred to in paragraph 30 of the Amended Complaint. M. As used herein, "Cost Share Agreement" means the agreement entered into by Bay Beach Golf Club, Inc. and Estero Bay Improvement Association, Inc. effective February 22, 2005. N, As used herein, "SFWMD" refers to the South Florida Water Management District. O. As used herein, "Permit" means Permit Number 36-00611-S issued by the South Florida Water Management District on November 18, 1985 and any subsequent modifications, including Permit Nos. 36-00611-S-02 and 36-00611-S-03. P. As used herein, the terms "person" or "persons" mean any natural persons, and all legal or business entities, including, but not limited to partnerships, corporations, joint ventures, trusts or estates and the agents, subsidiaries, affiliates, directors, officers, employees, attorneys, anyone acting for any of them at their direction, or under their control and any combination of the above.
Q. As used herein, to "identify" a person shall mean to state the full name, the present or last known business and residence addresses and telephone numbers, the job title and a description of the job responsibilities of such person. R. As used herein, the singular shall include the plural, the plural shall include the singular, and the masculine shall include the feminine and/or neuter. S. As used herein, "documents" shall refer to and shall include, without limitation and in the singular as well as in the plural, any stored or retained data or information in any form, including but not limited to all memoranda (including written memoranda of telephone conversations, other oral communications, discussions, agreements, acts, and activities), letters, e-mails, postcards, telegrams, intraoffice and interoffice communications, electronic communications, correspondence, handwritten or typewritten notes, pamphlets, diaries, sound recordings, transcripts of sound recordings, contracts, agreements, books, reports, catalogs, price lists, financial statements, book of accounts, journals, ledgers, purchase orders, invoices, indices, summaries and histories of customer transactions, data processing cards, other data processing materials, data sheets, tapes, e-mail messages, electronic mail system messages or other electronic communications, photographs, photostats, microfilm, maps, directives, bulletins, circulars, notices, messages, tabulations, notes, economic or statistical studies, surveys, polls, minutes, instructions, requests, canceled checks, calendars, desk pads, appointment books, scrapbooks, notebooks, specifications, drawings, diagrams, sketches, and writings and records of every kind and character, including preliminary drafts and other copies of the foregoing, however produced or reproduced. T. As used herein, "all documents" shall refer to and shall include every document, as above-defined, within your possession, custody, or control. U. As used herein, the terms "action" and "case" refer to the above-styled lawsuit.
V, As used herein, "Describe"/"Description" or "Explain"/"Explanation" or "State" as used hereafter is intended to and shall be interpreted to request a full and fair statement of the fact or matter being explained or described, including a statement of all facts and circumstances necessary to understand and evaluate the fact or matter being explained or described and the dates of the events described, the identity of all persons named or otherwise referred to in such description, and the identity of all the non-privileged documentation in your care, custody, possession, or control that directly relates or involves each of those facts and circumstances, W. As used herein, the term "relating to" shall mean constituting, describing, discussing, mentioning, commenting about, referring to, reflecting, or in any way logically or factually connecting with the matter described in that Paragraph of this Interrogatory. X. As used herein, "Date" means the exact day, month and year of an event if ascertainable or, if not, your best approximation thereof (including relationship to other events). Y. As used herein, the terms "and/or," "and," and "or" shall each be construed disjunctively and conjunctively as necessary to elicit the greatest amount of information and to encompass the greatest amount of information that would otherwise be construed to fall within the scope of the interrogatories set forth below. Z. Any terms not otherwise defined herein, shall have the meaning ascribed to them in the Amended Complaint in this matter. INSTRUCTIONS 1. If any Interrogatory is objected to on the grounds of privilege or otherwise: a) Set forth fully each objection, stating the facts upon which you rely as the basis for the objection;
b) If you claim that the requested information is subject to privilege, please respond to the request to the extent not privileged and comply with subsection (a) of this paragraph as to the remainder of the Interrogatory; and c) Identify all persons known to have seen the document or to whom the substance of the information has been disclosed. 2. All information is to be divulged which is in your possession or in the possession of your attorneys, investigators, agents, employees, or other representatives of you and/or your attorneys. 3. Where an individual interrogatory calls for an answer which involves more than one part, each part of the answer should be clearly set out so that it is understandable. If any of the interrogatories cannot be answered in full, please answer to the extent possible and submit any supplemental information at a later date. In the event that an answer cannot be completed in the space provided, please continue on an additional sheet. 4. If you lack the information necessary to answer any of the interrogatories, please describe the specific efforts made by you or anyone on your behalf to ascertain the information and state as definitely as possible when you anticipate obtaining the information and supplementing your response. (REMAINDER OF PAGE INTENTIONALLY LEFT BLANK&
INTERROGATORIES l. Identify the name, address, and telephone number of the person answering or assisting with answering these interrogatories, and, if applicable, the person's official position or relationship with the party to whom the interrogatories are directed. 2. List the names, addresses, and phone numbers of all persons who are believed or known by you, your agent or attorneys to have any knowledge concerning any of the issues in this lawsuit and specify the subject matter about which the witness has knowledge, 3. Identify all experts who you intend to call as a witness at any hearing or in the trial of this cause, 4. Please state and describe with specificity all language in any documents supporting your alleged irrevocable license, express easement, implied easement, and easement by necessity giving rise to your legal right to use the System. 5. Please state and describe with specificity the payments that you have made for any maintenance, liability, or operational expenses associated with the Golf Course Property or the System. 6. Please state and describe with specificity all language in any agreement signed by the Durpos and you that gives you permission and/or a legal right to use the System or the Golf Course Property for stormwater and surface water management.
7. Please state and describe with specificity all language in the Cost Share Agreement stating that you have a right to use the System. 8. Please state and describe with specificity all steps taken to record the Cost Share Agreement in the public records of Lee County, Florida. 9. Please state and describe with specificity the names and addresses of the subscribing witnesses to the Cost Share Agreement. 10. Please state and describe with specificity any attempts to notify the Durpos of the existence of the Cost Share Agreement and/or your use of the System, including the dates of each attempt. 11. Please state and describe with specificity all language in the conveyances, attached to the Counterclaim as Composite Exhibits A-Q as described in paragraph 121 of the Counterclaim, which you believe creates an implied easement or any other interest that gives you a legal right to use the System. 12. Please state and describe with specificity any steps taken to convert the Permit from a construction permit to an operational permit. 13. Please state and describe with specificity the language in any document supporting that the Permit was converted from a constructional permit to an operational permit.
14. Please state and describe with specificity the date that the Permit expired, or explain why the Permit is still effective. 15, Please state and describe with specificity how the Permit gives you the right to use the System when the Permit has not been converted to an operational permit and is no longer effective. 16. Please list all facts in your possession that the Durpos had knowledge of the Associations'se of the Golf Course Property and/or System for its stormwater and surface water discharge. 17. Please list all sums incurred by you in the construction of the System. 18. Please list all facts in your possession that the Durpos had knowledge of the Cost Sharing Agreement prior to purchase the Golf Course Property.
, on behalf of Defendant, WATERSIDE MANATEE BAY HOLDINGS, LLC being first duly sworn in accordance with law, do hereby depose and state that I have read the responses to Plaintiff's First Set of Interrogatories and that the responses are true and correct. WATERSIDE HOLDINGS, LLC MANATEE BAY of WATERSIDE MANATEE BAY HOLDINGS, LLC and that he/she, being authorized to do so, executed this Verification on behalf of WATERSID MANATEE BAY HOLDINGS, LLC.
, on behalf of Defendant, BELLA LAGO CONDOMINIUM AT BAY BEACH CONDOMINIUM ASSOCIATION, INC. being first duly sworn in accordance with law, do hereby depose and state that I have read the responses to Plaintiff's First Set of Interrogatories and that the responses are true and correct, BELLA LAGO CONDOMINIUM AT BAY BEACH CONDOMINIUM ASSOCIATION, INC. personally came before me this day and of BELLA LAGO CONDOMINIUM AT BAY BEACH CONDOMINIUM ASSOCIATION, INC. and that he/she, being authorized to do so, executed this Verification on behalf of BELLA LAGO CONDOMINIUM AT BAY BEACH CONDOMINIUM ASSOCIATION, INC.
, on behalf of Defendant, CASA MARINA ASSOCIATION, INC. being first duly sworn in accordance with law, do hereby depose and state that I have read the responses to Plaintiff's First Set of Interrogatories and that the responses are true and correct. CASA MARINA ASSOCIATION, INC. of CASA MARINA ASSOCIATION, INC. and that he/she, being authorized to do so, executed this Verification on behalf of CASA MARINA ASSOCIATION, INC,
, on behalf of Defendant, CASA MARINA II CONDOMINIUM ASSOCIATION, INC. being first duly sworn in accordance with law, do hereby depose and state that I have read the responses to Plaintiff's First Set of Interrogatories and that the responses are true and correct. CASA MARINA II CONDOMINIUM ASSOCIATION, INC. of CASA MARINA II CONDOMINIUM ASSOCIATION, INC. and that he/she, being authorized to do so, executed this Verification on behalf of CASA MARINA II CONDOMINIUM ASSOCIATION, INC.
on behalf of Defendant, VALENCIA VILLAS AT BAY BEACH ASSOCIATION, INC. being first duly sworn in accordance with law, do hereby depose and state that I have read the responses to Plaintiff's First Set of Interrogatories and that the responses are true and correct. VALENCIA VILLAS AT BAY BEACH ASSOCIATION, INC. of VALENCIA VILLAS AT BAY BEACH ASSOCIATION, INC. and that he/she, being authorized to do so, executed this Verification on behalf of VALENCIA VILLAS AT BAY BEACH ASSOCIATION, INC.
, on behalf of Defendant, WATERSIDE I AT BAY BEACH CONDOMINIUM ASSOCIATION, INC. being first duly sworn in accordance with law, do hereby depose and state that I have read the responses to Plaintiff s First Set of Interrogatories and that the responses are true and correct. WATERSIDE I AT BAY BEACH CONDOMINIUM ASSOCIATION, INC, Its; Date; of WATERSIDE I AT BAY BEACH CONDOMINIUM ASSOCIATION, INC. and that he/she, being authorized to do so, executed this Verification on behalf of WATERSIDE I AT BAY BEACH CONDOMINIUM ASSOCIATION, INC. WITNESS my hand and official Notarial Seal this clay of
, on behalf of Defendant, WATERSIDE II AT BAY BEACH CONDOMINIUM ASSOCIATION, INC. being first duly sworn in accordance with law, do hereby depose and state that I have read the responses to Plaintiff's First Set of Interrogatories and that the responses are true and correct. WATERSIDE II AT BAY BEACH CONDOMINIUM ASSOCIATION, INC. of WATERSIDE II AT BAY BEACH CONDOMINIUM ASSOCIATION, INC. and that he/she, being authorized to do so, executed this Verification on behalf of WATERSIDE II AT BAY BEACH CONDOMINIUM ASSOCIATION, INC.
, on behalf of Defendant, WATERSIDE III AT BAY BEACH CONDOMINIUM ASSOCIATION, INC. being first duly sworn in accordance with law, do hereby depose and state that I have read the responses to Plaintiff's First Set of Interrogatories and that the responses are true and correct. WATERSIDE III AT BAY BEACH CONDOMINIUM ASSOCIATION, INC. of WATERSIDE III AT BAY BEACH CONDOMINIUM ASSOCIATION, INC. and that he/she, being authorized to do so, executed this Verification on behalf of WATERSIDE III AT BAY BEACH CONDOMINIUM ASSOCIATION, INC.
, on behalf of Defendant, WATERSIDE IV AT BAY BEACH CONDOMINIUM ASSOCIATION, INC. being first duly sworn in accordance with law, do hereby depose and state that I have read the responses to Plaintiff's First Set of Interrogatories and that the responses are true and correct. WATERSIDE IV AT BAY BEACH CONDOMINIUM ASSOCIATION, INC. of WATERSIDE IV AT BAY BEACH CONDOMINIUM ASSOCIATION, INC. and that he/she, being authorized to do so, executed this Verification on behalf of WATERSIDE IV AT BAY BEACH CONDOMINIUM ASSOCIATION, INC. My Commission Expires;
, on behalf of Defendant, WATERSIDE V AT BAY BEACH CONDOMINIUM ASSOCIATION, INC. being first duly sworn in accordance with law, do hereby depose and state that I have read the responses to Plaintiff's First Set of Interrogatories and that the responses are true and correct. WATERSIDE V AT BAY BEACH CONDOMINIUM ASSOCIATION, INC. of WATERSIDE V AT BAY BEACH CONDOMINIUM ASSOCIATION, INC, and that he/she, being authorized to do so, executed this Verification on behalf of WATERSIDE V AT BAY BEACH CONDOMINIUM ASSOCIATION, INC.
on behalf of ESTERO BAY IMPROVEMENT ASSOCIATION, INC. being first duly sworn in accordance with law, do hereby depose and state that I have read the responses to Plaintiff's First Set of Interrogatories and that the responses are true and correct. ESTERO BAY ASSOCIATION, INC. IMPROVEMENT of ESTERO BAY IMPROVEMENT ASSOCIATION, INC. and that he/she, being authorized to do so, executed this Verification on behalf of ESTERO BAY IMPROVEMENT ASSOCIATION, INC,
on behalf of BAYSIDE MASTER ASSOCIATION, INC, being first duly sworn in accordance with law, do hereby depose and state that I have read the responses to Plaintiff's First Set of Interrogatories and that the responses are true and correct. BAYSIDE MASTER ASSOCIATION, INC. of BAYSIDE MASTER ASSOCIATION, INC. and that he/she, being authorized to do so, executed this Verification on behalf of BAYSIDE MASTER ASSOCIATION, INC.
on behalf of WATERSIDE DOCK ASSOCIATION, INC. being first duly sworn in accordance with law, do hereby depose and state that I have read the responses to Plaintiff's First Set of Interrogatories and that the responses are true and correct. WATERSIDE DOCK ASSOCIATION, INC. of WATERSIDE DOCK ASSOCIATION, INC. and that he/she, being authorized to do so, executed this Verification on behalf of WATERSIDE DOCK ASSOCIATION, INC. WITNESS my hand and official Notarial Seal this clay of
, on behalf of Defendant, CASA MARINA III CONDOMINIUM ASSOCIATION, INC. being first duly sworn in accordance with law, do hereby depose and state that I have read the responses to Plaintiff's First Set of Interrogatories and that the responses are true and correct. CASA MARINA III CONDOMINIUM ASSOCIATION, INC. of CASA MARINA III CONDOMINIUM ASSOCIATION, INC. and that he/she, being authorized to do so, executed this Verification on behalf of CASA MARINA III CONDOMINIUM ASSOCIATION, INC.
on behalf of Defendant, ROYAL PELICAN ASSOCIATION, INC. being first duly sworn in accordance with law, do hereby depose and state that I have read the responses to Plaintiff's First Set of Interrogatories and that the responses are true and correct. ROYAL PELICAN ASSOCIATION, INC. of ROYAL PELICAN ASSOCIATION, INC, and that he/she, being authorized to do so, executed this Verification on behalf of ROYAL PELICAN ASSOCIATION, INC. 2014,
, on behalf of Defendant, SUNSET GULF CONDOMINIUM ASSOCIATION, INC. being first duly sworn in accordance with law, do hereby depose and state that I have read the responses to Plaintiff's First Set of Interrogatories and that the responses are true and correct. SUNSET GULF ASSOCIATION, INC. CONDOMINIUM of SUNSET GULF CONDOMINIUM ASSOCIATION, INC. and that he/she, being authorized to do so, executed this Verification on behalf of SUNSET GULF CONDOMINIUM ASSOCIATION, INC,
on behalf of Defendant, HARBOR POINTE CONDOMINIUM ASSOCIATION, INC. being first duly sworn in accordance with law, do hereby depose and state that I have read the responses to Plaintiff's First Set of Interrogatories and that the responses are true and correct. HARBOR POINTE CONDOMINIUM ASSOCIATION, INC. of HARBOR POINTE CONDOMINIUM ASSOCIATION, INC. and that he/she, being authorized to do so, executed this Verification on behalf of HARBOR POINTE CONDOMINIUM ASSOCIATION, INC.
on behalf of Defendant, HIBISCUS POINTE CONDOMINIUM ASSOCIATION, INC. being first duly sworn in accordance with law, do hereby depose and state that I have read the responses to Plaintiff's First Set of Interrogatories and that the responses are true and correct. HIBISCUS POINTE CONDOMINIUM ASSOCIATION, INC. of HIBISCUS POINTE CONDOMINIUM ASSOCIATION, INC. and that he/she, being authorized to do so, executed this Verification on behalf of HIBISCUS POINTE CONDOMINIUM ASSOCIATION, INC.
, on behalf of Defendant, THE PALMS OF BAY BEACH CONDOMINIUM ASSOCIATION, INC. being first duly sworn in accordance with law, do hereby depose and state that I have read the responses to Plaintiffs First Set of Interrogatories and that the responses are true and correct. THE PALMS OF BAY BEACH CONDOMINIUM ASSOCIATION, INC. of THE PALMS OF BAY BEACH CONDOMINIUM ASSOCIATION, INC. and that he/she, being authorized to do so, executed this Verification on behalf of THE PALMS OF BAY BEACH CONDOMINIUM AS SOCIATION, INC.