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ORDER ACCEPTING AGREED CASE MANAGEMENT PLAN

Document LINDA ALGOZZINI, AS PERSONAL REPRESENTATIVE OF THE ESTATE OF DUSTIN LEE LAUN V BOYNTON MEMORIAL CHAPEL LTD, 50-2023-CA-015790-XXXA-MB, No. 06 (Florida State, P...
**** CASE NUMBER: 502023CA015790XXXAMB Div: AE **** Filing # 186231209 E-Filed 11/15/2023 05:23:53 PM
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MOTION PLAINTIFF'S MOTION FOR LEAVE TO AMEND COMPLAINT TO ADD CLAIM FOR PUNITIVE DAMAGES

Document PULTE, WILLIAM J V JONES, BRANDON, 50-2022-CA-012238-XXXX-MB, No. 1046 (Florida State, Palm Beach County, Fifteenth Circuit Court Mar. 19, 2025)
Nonetheless, Jones embarked on a malicious and 2 defamatory campaign against Pulte that not only harmed Pulte’ reputation (among other damages), but cost Jones his job at PulteGroup.
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NOTICE SUPPLEMENTAL OPPOSITION TO DFT'S MOTION TO COMPEL ANSWERS TO DFT'S FIRST SET OF INTERROGS F/B PLT

Document PULTE, WILLIAM J V JONES, BRANDON, 50-2022-CA-012238-XXXX-MB, No. 981 (Florida State, Palm Beach County, Fifteenth Circuit Court Mar. 7, 2025)
502022CA012238XXXXMB NOT A CERTIFIED COPY Filing # 218314619 E-Filed 03/07/2025 11:39:37 AM FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 03/07/2025 11:39:37 AM NOT A CERTIFIED COPY NOT A CERTIFIED COPY NOT A CERTIFIED COPY NOT A CERTIFIED COPY NOT A CERTIFIED COPY NOT A CERTIFIED COPY 5 NOT A CERTIFIED COPY
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Answer and Demand for Jury Trial

Document SERGIO SAN ANTONIO VS NATIONWIDE MOVE MANAGEMENT LLC ET AL, 2024-007887-CA-01, Doc-72-Answer-and-Demand-for-Jury-Trial (Fla. 11th Cir. Ct. Feb. 26, 2025)
Motion for Jury Trial
SERVICES (“AMS”), by and through the undersigned counsel and in accordance with the Florida Rules of Civil Procedure, hereby responds to Plaintiff, SERGIO SAN ANTONIO’s (“Plaintiff”) Amended Complaint (the “Amended Complaint”) [D.E.
For its Third Affirmative Defense, AMS states that Plaintiff cannot bring a claim per the Binding Estimate anywhere other than Palm Beach County, Florida.
For its Fourth Affirmative Defense, AMS states that Plaintiff has cannot meet the amount in controversy to plead a case in circuit court.
For its Eleventh Affirmative Defense, AMS states that it was never in the possession of any of the subject goods, such that it could be liable for the purported damages thereto.
AMS hereby demands the recovery of all attorney’s fees and costs incurred which relate to, or arise out of, this litigation, including all appellate proceedings.
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MOTION FOR PROTECTIVE ORDER

Document PULTE, WILLIAM J V JONES, BRANDON, 50-2022-CA-012238-XXXX-MB, No. 946 (Florida State, Palm Beach County, Fifteenth Circuit Court Feb. 26, 2025)
The Subpoena is also barred by Florida’s apex doctrine, which requires a court to prohibit a deposition where the individual to be deposed is a high-level corporate officer and produces an affidavit or declaration explaining his or her lack of unique personal knowledge of the issues being litigated.
“Virtually every court that has addressed deposition notices directed at an official at the highest level or apex of corporate management has observed that such discovery creates a tremendous potential for abuse or harassment.” Id. at 461 (quotations omitted).
A court should prevent an apex subpoena from going forward when the deponent (1) meets the high-level officer requirement, and (2) provides an affidavit or declaration explaining their lack of unique, personal knowledge of the issues being litigated.
In so doing, the 4th DCA stated that “requiring Mr. Musk to sit for a deposition would serve no purpose other than to harass and burden Tesla and disrupt Mr. Musk’s ability to meet his obligations to consumers, stockholders, Tesla’s employees, and other activities integral to his position as CEO.” Id. at 197-98.
And, while it is difficult to evaluate Plaintiff’s requests given their absence of boundaries or limitations, it is clear that Plaintiff has not even attempted to establish why he must pursue that information from Zeumer when, based on the Court’s docket, the parties are still working through getting discovery from each other.
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Motion to Strike

Document SERGIO SAN ANTONIO VS NATIONWIDE MOVE MANAGEMENT LLC ET AL, 2024-007887-CA-01, Doc-71-Motion-to-Strike (Fla. 11th Cir. Ct. Feb. 24, 2025)
Motion to Strike
fail to admit the causeofaction, they are immaterial, and theyfail to allege sufficient ultimate facts
gave possession of his household goods to Defendant Ocean Moving for the limited purpose of
Defendant negligently failed to deliver the household goodsin as good condition as whenentrusted
Without morefacts, this affirmative mustbe stricken as factually deficient becauseit fails to allege
Defendant in the amount spent by Plaintiff in moving to strike the innumerable affirmative 06O6.565"IW-I"[6G6"02M3/L-I60"-.0"6.I6G"-.K"52LW"7IW6G"G63/6O"IW/5"472GI"066H5"b25I"-.0"MG7M6G8" defenses that were duplicated and enter any such otherrelief this Court deems just and proper.
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ANSWER & AFFIRMATIVE DEFENSES

Document IPN LLC V TUV INVESTMENTS LLC, 50-2024-CA-006829-XXXA-MB, No. 30 (Florida State, Palm Beach County, Fifteenth Circuit Court Feb. 24, 2025)
Filing # 217470259 E-Filed 02/24/2025 08:52:17 PM NOT A CERTIFIED COPY FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 02/24/2025 08:52:17 PM NOT A CERTIFIED COPY NOT A CERTIFIED COPY NOT A CERTIFIED COPY NOT A CERTIFIED COPY NOT A CERTIFIED COPY NOT A CERTIFIED COPY NOT A CERTIFIED COPY NOT A CERTIFIED COPY
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OBJECTION

Document IPN LLC V TUV INVESTMENTS LLC, 50-2024-CA-006829-XXXA-MB, No. 29 (Florida State, Palm Beach County, Fifteenth Circuit Court Feb. 24, 2025)
Second, none of efendants submitted an affirmation detailing the actions they had been ordered to take to¢try’to obtain the First Republic documents.
None of the Defendants, including the co-executors Max and Jacob Miller, bothered to file anything.
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MOTION NONPARTY PULTEGROUP, INC.'S MOTION FOR LEAVE TO ATTEND DEPOSITIONS OF CURRENT AND FORMER PULTEGROUP PERSONNEL

Document PULTE, WILLIAM J V JONES, BRANDON, 50-2022-CA-012238-XXXX-MB, No. 940 (Florida State, Palm Beach County, Fifteenth Circuit Court Feb. 20, 2025)
In this case, Plaintiff is seeking to depose no less than fifteen nonparty individuals who are current or former personnel of nonparty PulteGroup, including PulteGroup’s Chief Executive Officer, its General Counsel, nine of PulteGroup’s individual Directors, its Vice President of Investor Relations and Corporate Communications, PulteGroup’s Director of Market Intelligence, and its former Senior Vice President of Human Resources.
Despite soliciting the testimony of these personnel, Plaintiff William J. Pulte (“Plaintiff”) has objected to PulteGroup having an attorney or representative attend each of these depositions to preserve PulteGroup’s rights and privileges.
In the jurisdictional discovery phase of this case, Plaintiff took the deposition of Defendant Brandon Jones (“Defendant”), who is a former Senior Vice President of Field Operations at PulteGroup.
Since Defendant’s jurisdictional deposition, Plaintiff has issued at least fifteen deposition subpoenas to current and former PulteGroup personnel, including PulteGroup’s Chief Executive Officer (Ryan Marshall), its General Counsel (Todd Sheldon), nine of PulteGroup’s individual Directors (“Nonparty Board Members”), its Vice President of Investor Relations and Corporate Communications (Jim Zeumer), PulteGroup’s Director of Market Intelligence (Stephanie Byron), and its former Senior Vice President of Human Resources (Michelle Hairston).
Instead, “[t]he presence of witnesses at a deposition is controlled by Florida Rule of Civil Procedure 1.280[d],…which provides that upon a motion by a party and for good cause shown, the court in which an action is pending may enter a protective order that discovery may be conducted with no one present except persons designated by the court.” Smith, 564 So.
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Motion for Extension of Time

Document SERGIO SAN ANTONIO VS NATIONWIDE MOVE MANAGEMENT LLC ET AL, 2024-007887-CA-01, Doc-68-Motion-for-Extension-of-Time (Fla. 11th Cir. Ct. Feb. 17, 2025)
Motion to Extend Time
Defendant, NATIONWIDE MOVING SERVICES, INC. d/b/a AMERISAFE MOVING SERVICES (“AMS”), by and through its undersigned counsel and pursuant to Florida Rule of Civil Procedure 1.090, hereby files this Motion for Extension of Time to Respond to Discovery as to Plaintiff, SERGIO SAN ANTONIO’s (“Plaintiff”) Request for Production and Supplemental Interrogatories, and in support thereof, states as follows:
Florida Rule of Civil Procedure 1.090 allows the Court to extend the time for AMS to respond to Plaintiff’s discovery for good cause.
Good cause exists here as the undersigned counsel from has pressing obligations in unrelated matters and an extension would not prejudice Plaintiff.
Responding to the extensive discovery, and incurring the necessary associates fees and costs, will frustrate AMS’s ability to reach a resolution with Plaintiff.
Consequently, AMS respectfully requests that the deadline to respond to the extensive January 17, 2025, discovery be extended by 3-weeks, to March 10, 2025.
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Notice of Answer to Interrogatories

Document SERGIO SAN ANTONIO VS NATIONWIDE MOVE MANAGEMENT LLC ET AL, 2024-007887-CA-01, Doc-65-Notice-of-Answer-to-Interrogatories (Fla. 11th Cir. Ct. Feb. 11, 2025)
COMES NOW, Defendant, OCEAN MOVING AND STORAGE CORP., by and through undersigned counsel, and hereby files this, its Notice of Service of Its Responses to Plaintiff’s First Set of Interrogatories to It.
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Answer and Affirmative Defense

Document SERGIO SAN ANTONIO VS NATIONWIDE MOVE MANAGEMENT LLC ET AL, 2024-007887-CA-01, Doc-64-Answer-and-Affirmative-Defense (Fla. 11th Cir. Ct. Feb. 5, 2025)
Answer
Admitted that a copy of a purported Revised Estimate by AMS is attached as “Exhibit ‘B’” and that the document speaks for itself; denied as to its validity, accuracy, authenticity, enforceability, applicability, relevance, and Plaintiff’s characterization.
Plaintiff additionally agreed in writing in his Bill of Lading as follows: By signing this form, you are waiving certain valuable coverage which protects your property above the minimum amounts set by law.
Accordingly, Plaintiff waived Defendant’s liability for damage to pressed wood (particle board) furniture and fragile or brittle items such as glass, china, ornaments, etc., as to any value in excess of $0.60 per article per pound.
Accordingly, Plaintiff waived Defendant’s liability for damage to pressed wood (particle board) furniture and fragile or brittle items such as glass, china, ornaments, etc., as to any value in excess of $0.60 per article per pound.
Accordingly, Plaintiff waived Defendant’s liability for damage to pressed wood (particle board) furniture and fragile or brittle items such as glass, china, ornaments, etc., as to any value in excess of $0.60 per article per pound.
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ORDER SETTING CASE MANAGEMENT PLAN FOR NON-COMPLEX CASES

Document KIMBERLY BLOCK v. TRADITIONS REALTY, LLC, et al., 2023-CA-010136, 10 (Fla. 4th Cir. Ct. Aug. 28, 2023)
with the Court’s Judicial Assistant a hearing on the Each civil division’s Trial Set Memorandum and the Fourth Judicial Circuit’s website: jud4.org.
requirements of the Fourth Judicial Circuit’s Second Amended Administrative Order 1.440(a) to schedule the case for trial pursuant to the division’s procedures.
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BRIEF

Document PULTE, WILLIAM J V JONES, BRANDON, 50-2022-CA-012238-XXXX-MB, No. 905 (Florida State, Palm Beach County, Fifteenth Circuit Court Jan. 31, 2025)
... produce leaves both this Court as well as Jones guessing as to what Plaintiff intends on producing, and what he deems related to “this litigation.”6 No discovery has implicated PulteGroup as being behind the alleged acts of Jones—as none ...
Rather than stating none exist, Plaintiff merely states that Defendant is in the possession of such communications.
Nonetheless, consistent with Plaintiff dawdling, nonspecific objections, Plaintiff states to both requests that “Plaintiff has produced thousands of documents in this case.
None of the alleged defamatory tweets at issue in this case made by Defendant concerned Defendant or were responsive to any statements or communications made by Plaintiff about Defendant.
... affiliates and/or representatives.” Additionally, the interrogatory is so broad that it would require Plaintiff to identify every traffic or parking violation and every speeding ticket or traffic fine he has paid within the relevant time period, none ...
Nonetheless, Plaintiff has used the term throughout his filings, including his own discovery requests, and has also previously defined the similar term “Pulte Relatives” in discovery he has served to Jones.
Pulte and his family have done none of these NOT A CERTIFIED COPY crimes that Jones falsely and publicly accuses." Plaintiff further alleges in paragraph 161 of the Fourth Amended Complaint, "In a tweet from March 10, 2022, Pulte ...
None of the alleged defamatory tweets at issue in this case made by Defendant concerned Defendant or were responsive to any statements or communications made by Plaintiff about Defendant.
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Motion to Amend

Document SERGIO SAN ANTONIO VS NATIONWIDE MOVE MANAGEMENT LLC ET AL, 2024-007887-CA-01, Doc-61-Motion-to-Amend (Fla. 11th Cir. Ct. Jan. 28, 2025)
Plaintiff, SERGIO SAN ANTONIO (“Plaintiff”) hereby moves to modify the current case management plan and in support thereof state as follows:
For this reason, Plaintiff filed an Amended Complaint on August 30, 2024, to properly name Defendant Amerisafe in the case caption.
After hearing argument from all counsel, this Court denied both Defendants’ Motion to Dismiss on January 16, 2025.
However, by the time that the Motions to Dismiss were addressed on January 16, 2025, many of the deadlines as outlined above were already expired.
Given the facts alleged herein, there is good cause here for the proposed amendment to the current case management plan sought, to allow the parties to engage in discovery and prepare for trial.
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