IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CIRCUIT CIVIL DIVISION JAMES McLYNAS, Plaintiff, Case No. 16-006722-CI PINELLAS COUNTY SHERIFF'S OFFICE, Defendant. NOTICE OF SERVICE OF DEFENDANT’S ANSWERS TO PLAINTIFF'S INTERROGATORIES Defendant, PINELLAS COUNTY SHERIFF'S OFFICE', by and through the undersigned attomey, hereby files its Notice of Service of Defendant’s Answers to Plaintiff's Interrogatories served on Defendant with Plaintiff's Complaint on October 25, 2016. CERTIFICATE OF SERVICE I CERTIFY that on December 9, 2016, I electronically filed the foregoing with the Clerk of the Court through the Florida Courts E-Filing Portal, which will send a notice of electronic filing pursuant to the Clerk’s electronic service list to Gerasimos “Jerry” Theophilopoulos, Esq., Crow ' “Bob Gus i, in his official capacity as Sheriff of Pinellas County, Florida’ is the only proper party defendant in this case. Pinellas County Sheriff's Office is not a legal entity capable of being sued. However, at this stage Plaintiff's error does not affect the substantial rights of the party but should be corrected pursuant to Florida Rules of Civil Procedure.Law Group, P.A., 1247 S. Pinellas Avenue, Tarpon Springs, FL 34589, marialitigation@gmail.com; attomeyjerry(@gmail.com, attomey for Plaintiff. PINELLAS COUNTY SHERIFF GEXBRAL COUNSEL'S OFFICE aul G. Rozelle Senior Associate Counsel FBN: 75948 10750 Ulmerton Road Largo, FL 33778 Telephone: (727) 582-6274 Facsimile: (727) 582-6459 Prozelle@pesonet.com Amarcott] @pesonet.com Attomey for DefendantDEFENDANT’S ANSWERS TO PLAINTIFF'S, JAMES McLYNAS, INTERROGATORIES What is the name and address of the person answering these interrogatories and, if applicable, the person's official position or relationship with the party to whom the interrogatories are directed? Response: The person verifying these interrogatories is Denise Thomas. Her address is Pinellas County Sheriff's Office, 10750 Ulmerton Road, Largo, FL 33778. She holds the title of Claims Adjuster. Identify (name and address) anyone who has or may have knowledge or information regarding the facts and circumstances surrounding the various public records issues that are the subject of this lawsuit, State the subject of each person’s knowledge or information, and whether this person’s knowledge is reduced to writing in any form, and if'so, its location. Respon: Objection. This interrogatory is vague, ambiguous, unduly burdensome, and not relevant or reasonably calculated to lead to the discovery of admissible evidence. The phrase “various public records issues that are the subject of this lawsuit” is indecipherable, making it impossible for the Sheriff to adequately respond. The term “issue,” defined as “a material point in dispute” by Black's Law Dictionary, is vague, ambiguous, and overly broad. Plaintiff's Complaint is comprised of 57 paragraphs, all of which could be said to raise at least one, if not multiple “issues,” both of fact and law. Each paragraph of the Complaint contains at least one “material point in dispute” where the Sheriff has denied the averments in that particular paragraph within the Complaint. In this interrogatory, however, Plaintiffhas failed to identify the point or points that he considers to be material or in dispute. For example, Plaintiff cites multiple provisions of the Florida Statutes, the interpretation of which may be in dispute. Deciphering Plaintiff's intent with respect to the numerous contentions in his prolix Complaint would be unduly burdensome, if not impossible, and it would also not be relevant or likely to lead to the discovery of admissible evidence. The term “various,” which Plaintiff uses to modify the term “issues,” only adds further to the ambiguity. The term “various” in vague and ambiguous, and provides no direction as to the particular “issues” about which Plaintiff is seeking information. Please identify (name and address) the individual or individuals that have the most knowledge concerning the various public records request issues that are the subject of this lawsuit against the PCSO.Respon: Objection. This interrogatory is vague, ambiguous, unduly burdensome, and not relevant or reasonably calculated to lead to the discovery of admissible evidence. The phrase “various public records request issues” is indecipherable, making it impossible for the Sheriff to adequately respond. An “issue” can be any material point in dispute. Plaintiff's Complaint is comprised of 57 paragraphs, all of which could be said to raise at least one, if not multiple “issues,” both of fact and law. Each paragraph of the Complaint contains at least one “material point in dispute” where the Sheriff has denied the averments in that particular paragraph within the Complaint. In this interrogatory, however, Plaintiff has failed to identify the point or points that he considers to be material or in dispute. The term “various” provides further ambiguity to this interrogatory, as itis an uncertain term, only indicating that there exist differing “issues” of a number greater than one. Merriam-Webster Dictionary. Furthermore, “individual or individuals that have the most knowledge” of these “various” “issues” is a subjective determination, and is thus also vague and ambiguous. Even were the Sheriff able to decipher the meaning of the phrase “various public records issues,” the burden of determining the person with the most knowledge as to each of those material points in dispute would be undue. Please identify any and all past or present PCSO employees who have worked on or have knowledge of, the matters identified in the Complaint. For each person, state their address, telephone number, job description, general responsibilities at PCSO, work performed in relation to the events described in the Complaint, dates of employment, and reason for termination if the employee is no longer with the PCSO. Respon Objection. This interrogatory is vague, ambiguous, unduly burdensome, and not relevant or reasonably calculated to lead to the discovery of admissible evidence. The term “matters,” just like the term “issues,” is vague and ambiguous and provides no guidance or direction to the Sheriff. Second, the concept of employees who have “worked on” the “matters” is even more problematic. ‘The term “worked on” is vague, ambiguous, and subject to too many interpretations to be at all meaningful in the context of this interrogatory. Plaintiff fails to specify the manner of “work,” the capacity in which that “work” was done, or any time frame. Depending on the particular “matter,” this, interrogatory could include an indefinite span of time, and the Sheriff employees nearly 3,000 members at any given time, An attempt to identify any employee who had any connection to or any knowledge of anything that could be considered a “matter,” over an indefinite amount of time, would be unduly burdensome, if not impossible.State the facts upon which you rely for each affirmative defense in your answer to the ‘Complaint and identify any records that relate to those facts and every person who has knowledge of those facts. [Note: affirmative defenses are mere legal conclusions which are not “self-explanatory.” This interrogatory seeks what current facts, i.e, who, what, where, when, why and how, exist to support those defenses.] Respons Objection. The interrogatory is vague, ambiguous, and unduly burdensome because, among other reasons, it seeks to have the Sheriff identify “any records that relate to those facts” and “every person who has knowledge of those facts.” With respect to the Sheriff's thirteen affirmative defenses, all of which are self-explanatory, the Sheriff states the following as additional bases for asserting those affirmative defenses in addition to the averments contained within those affirmative defenses themselves: (1) With respect to the Sheriff's First Affirmative Defense, among other things, there is no legal basis in Chapter 119 for maintaining a lawsuit in the nature of a complaint against the Sheriff and for seeking, or being awarded, declaratory and injunctive relief. Plaintiff's Complaint also contains blank lines and spaces and other errata — including the attachment of apparently random documents, incomplete documents, and documents that Plaintiff or someone acting on his behalf altered -- that make it appear that Plaintiff and his lawyer filed and served a rough draft of the Complaint rather than a document that was complete. The Complaint fails to state a claim on which relief can be granted because the Court cannot fill in Plaintiff's banks for him. Dismissal of this lawsuit is also warranted for the reasons set forth below, among other reasons. (2) With respect to the Sheriff's Second Affirmative Defense, among other things, the Plaintiff cannot assert claims on behalf of Jerry Theophilopolous concerning public records requests that Jerry Theophilopolous made of the Sheriff. Jerry Theophilopolous is not a party to this lawsuit and, therefore, Jerry Theophilopolous’s claims and rights — and the Sheriff's defenses to those claims — cannot be litigated in it. Jerry Theophilopolous must litigate those claims for himself, in this or another forum. (3) With respect to the Sheriff's Third Affirmative Defense, the Plaintiff cannot assert claims on behalf of Jerry Theophilopolous concerning public records requests that Jerry Theophilopolous made of the Sheriff. Jerry Theophilopolous is not a party to this lawsuit and, therefore, his claims and rights — and the Sheriff's defenses to those claims — cannot be litigated in it. The Complaint makes a number of allegations and seeks relief that implicates Jerry Theophilopolous’s rights and, therefore, he must be joined as an indispensable party to this case. The failure to(4) 6) © a (8) join a necessary and indispensable party warrants dismissal under the Florida Rules of Civil Procedure. With respect to the Sheriff's Fourth Affirmative Defense, among other things, Plaintiff has not alleged that the individuals to whom he made his public records requests were custodians of the Sheriff's records. The edited and altered attachments to Plaintiff's Complaint contain emails between himself and numerous people who are not the Sheriff's records custodians, including Plaintiff's own attorney, the undersigned counsel, the Sheriff himself, certain members of the Tampa Bay news media, various deputies and other personnel at the Pinellas County Sheriff's Office, and, in Exhibit W, unnamed, unidentified Persons. Plaintiff's failure to make his public records requests to a records custodian is fatal to his claim for relief under established Florida law. With respect to the Sheriff's Fifth Affirmative Defense, among other things, this proposition asserted in this affirmative defense is well settled in Florida case law. With respect to the Sheriff's Sixth Affirmative Defense, among other things, that affirmative defense contains factual averments which are incorporated into this Answer. Plaintiff has made hundreds of public records requests of the Pinellas County Sheriff's Office over the last six years. The Complaint, on its face, makes no claim and contains no factual averments that Plaintiff has been prevented from making public records requests of the Pinellas County Sheriff's Office. Indeed, Plaintiff made a records request of the Sheriff as recently as this morning. The applicable case law is well-settled that injunctive relief is unavailable under the circumstances that Plaintiff has pleaded in his Complaint, even if Plaintiff had correctly pleaded a claim for relief that would have permitted the entry of injunctive relief. With respect to the Sheriff's Seventh Affirmative Defense, see Plaintiff's own Complaint, which contains no averments with respect to Fla. Stat. § 284.30. With respect to the Sheriff's Eighth Affirmative Defense, among other things, Plaintiff has sent more than a thousand emails to dozens of members of the Pinellas County Sheriff's Office over the last six years. Some of these emails ~ approximately two- to three hundred of them -- have contained what purport to be public records requests under Chapter 119. Some of those requests have been. buried in lengthy, confusing emails for the apparent purpose of hiding the requests, in an attempt to catch the Sheriff in a violation of Chapter 119. Some of Plaintiff's requests have been labeled with confusing and occasionally duplicative 1-digit numbers. Some of Plaintiff's requests have been duplicative or slightly changed from other requests. Plaintiff frequently makes his requests at a rate of a dozen or more a day, sometimes sending the requests seconds apart at all hours of9) (10) the day to many combinations of different people within the Sheriff's Office. Plaintiff frequently makes his requests to numerous and different individuals within the Sheriff's office — including individual members of the public records processing unit, members of general counsel’s office, individual deputies, supervisors, and others, including the Sheriff himself — with the apparent purpose of creating confusion and further generating the bases for frivolous litigation such as this. The net effect of the volume and nature of the requests, the months and in some cases years that have passed since Plaintiff communicated with anyone about them, and with the manner in which they were transmitted, evidences a lack of good faith, equitable conduct by Plaintiff that prevents the entry of the relief sought in the Complaint. Plaintiff's purported public records request appear to be for no purpose other than to flood the Sheriff's Office with correspondence and generate the kind of vexatious, recreational litigation that the courts have consistently rejected in other lawsuits similar to this one. Plaintiff has waived any relief that he might have been entitled to by the significant delays in time between when he propounded the requests and when he brought his lawsuit, and including the manner in which he has conducted this lawsuit, which evidences a lack of any genuine desire to obtain the records that he claims he wants. Plaintiff is estopped from making claims related to records requests that he long ago abandoned, And Plaintiff's unclean hands, as described above and evidenced throughout his years- long conduct in thousands of pages of correspondence prevents the award of equitable or any other relief in this lawsuit. Furthermore, see the Answer concerning the Twelfth Affirmative Defense, below. With respect to the Sheriff's Ninth Affirmative Defense, among other things, Plaintiff has on occasion failed to pick up materials that were available to him and has had mail returned as undeliverable. As detailed below, Plaintiff has been sent estimates in connection with performing the extraordinary work necessary to respond to a number of his public records requests. Other than on a few occasions in 2010, and on an occasion when his girlfriend paid for him many years ago, Plaintiff has failed to respond to any of these estimates other than with a barrage of further emails and requests. Plaintiff has refused every opportunity offer to him, in writing or on the telephone, to limit, narrow, or prioritize his scores of public records requests. The volume and nature of Plaintiff's records requests, combined with his failure to consummate them constitutes and demonstrates the lack of a genuine, good faith desire to inspect or receive any of the records that he has requested and, therefore, bars this lawsuit under established Florida law. With respect to the Sheriff's Tenth Affirmative Defense, among other things, the Sheriff is under no legal obligation to produce another agency's records.(11) With respect to the Sheriff's Eleventh Affirmative Defense, among other things, nowhere in his Complaint does Plaintiff claim that he paid a deposit on receipt of any of the cost estimates that were sent to him in connection with his public records requests. Furthermore, please see the response concerning the Twelfth Affirmative Defense, below. (12) With respect to the Sheriff's Twelfth Affirmative Defense, among other things, the Sheriff has sent Plaintiff numerous emails and letters over the years pursuant to Chapter 119 providing estimates for the extraordinary labor associated with responding to some of his public records requests. In the last approximately four years, it does not appear that Plaintiff has made a single deposit associated with any public records request. Kim Harwell appears to have paid for a handful of records on Plaintiff's behalf in 2012 or 2013 (on which occasions, of course, Plaintiff and Ms. Harwell received the responsive records). Plaintiff's failure to make a deposit for the estimated costs associated with responding to his requests — both those requests that are in issue in this lawsuit and others ~ has resulted in those requests being closed (in the same manner as, for example, Plaintiff's failure to pick up records or accept delivery of his mail). Similarly, Plaintiff's failure to resolve or conclude his outstanding requests has on occasion, depending on the sheer volume of Plaintiff's requests, the proximity of the new requests to other requests for which Plaintiff's has not paid the estimate or that he has otherwise ignored, and other factors, has led to the Sheriff not accepting further requests from Plaintiff until he satisfied or resolved the numerous, recent, prior requests, (13) With respect to the Sheriff's Thirteenth Affirmative Defense, among other things, it is apparent from the face of the documents that Plaintiff fraudulently and mendaciously attached to his Complaint that those documents have been edited and altered from any possible originals. 6. As to cach of the concurrently served requests for admissions, if any, of your response is anything but an unqualified admission, state all facts upon which you base your qualified admission or denial. Respons. (1) Asto Request for Admissions (RFA) No. 1: Among other reasons, the Sheriff cannot authenticate the truthfulness of the document labelled “Exhibit A.” The Sheriff believes that the document contains statements that are, in fact, not truthful. (2) Asto RFA No. 2: Among other reasons, the document labelled “Exhibit B,” or any version thereof, was not posted in the lobby of the PCSO in 2012,QB) (4) () ©) aM (8) (9) (10) As to RFA No. 3: Among other reasons, the document labelled “Exhibit B,” or any version thereof, was not posted in the lobby of the PCSO in 2013. As to RFA No. 4: Among other reasons, the documents labelled “Exhibit C” are not true and accurate copies of the emails between Plaintiff and PCSO. The emails have been tampered with. The dates and Plaintiff's email address have been altered and it is possible that other alterations have been made, too. As to RFA No. 5: Among other reasons, the document labelled “Exhibit D” is not a true and accurate copy of the emails between Plaintiff and PCSO. The emails have been tampered with, The dates and Plaintiff's email address have been altered, and it appears that two separate emails have been cut-and-pasted to look as though they were one email thread. In addition, this one document is taken out of context and does not include the 15 public records requests made by Plaintiff to PCSO between May 24 and May 28, 2016, nor does it include the responses from PCSO acknowledging each request. ‘As to RFA No. 6: Among other reasons, the document labelled “Exhibit E” is not a true and accurate copy of the emails between Plaintiff and PCSO. The emails have been tampered with. The dates and times have been altered, and page two of Exhibit E has been altered to omit content from PCSO’s response. In addition, this one document is taken out of context and does not include the 9 public records requests made by Plaintiff to PCSO between April 24 and April 27, 2016, nor does it include the responses from PCSO acknowledging each request. As to RFA No. 7: Among other reasons, the document labelled “Exhibit F” is not a true and accurate copy of the email between Plaintiff and PCSO. This email has been tampered with. The response from PCSO appears to have been cut-and- pasted onto the bottom of a separate email. In addition, this one document is taken out of context and does not include the 4 public records requests made by Plaintiff to PCSO between May 8 and May 17, 2016, nor does it include the response from PCSO acknowledging each request. It also does not include the May 17, 2016 response from PCSO providing records responsive to Plaintiff's May 12, 2016 request. As to RFA No. 8: Among other reasons, the document labelled “Exhibit G” does not include the response from PCSO acknowledging the request, nor does it include the responsive records that were provided to Plaintiff by PCSO. As to RFA No. 9: Among other reasons, the document labelled “Exhibit H” does not include the response from PCSO acknowledging the request, nor does it include the responsive records that were provided to Plaintiff by PCSO. As to RFA No. 10: Among other reasons, the document labelled “Exhibit I” appears to actually be an email from Plaintiff to Plaintiff's counsel that alters theay (2) a3) (4) as) (16) multiple emails that purport to be between Plaintiff and PCSO to make them appear as one document. As to RFA No. 11: See response to Interrogatory No. 10, above. Among other reasons, the document labelled “Exhibit I” appears to be an email from Plaintiff to his lawyer; it is not a public records request of the PCSO. Exhibit I alters ‘multiple emails that purport to be between Plaintiff and PCSO to make them appear as one document. There is no document in the Sheriff's possession, custody, or control that is or that appears to be concordant with Exhibit I ‘As to RFA No. 12: On March 11, 2014, PCSO responded to Plaintiffs request labeled “Exhibit K” by email, attaching a letter that requested remittance of outstanding fees owed to PCSO for prior public records requests. PCSO further responded with past-due invoices on March 12, 2014. After Plaintiff claimed that he could not open the attachments to the March 12, 2014 email, PCSO sent another email on November 10, 2014, informing Plaintiff that the invoices would be sent to his address on file with the Clerk of the Court via U.S. mail. PCSO responded with yet another email on December 18, 2014, after the invoices sent to Plaintiff via U.S. mail, to the address that Plaintiff had on file with the Clerk of the Court, were retumed to sender unable to forward. As to RFA No. 13: On March 11, 2014, PCSO responded to Plaintiffs request labeled “Exhibit L” by email, attaching a letter that requested remittance of outstanding fees owed to PCSO for prior public records requests. PCSO further responded with past-due invoices on March 12, 2014. After Plaintiff claimed that he could not open the attachments to the March 12, 2014 email, PCSO sent another email on November 10, 2014, informing Plaintiff that the invoices would be sent to his address on file with the Clerk of the Court via U.S. mail. PCSO responded with yet another email on December 18, 2014, after the invoices sent to Plaintiff via U.S. mail, to the address that Plaintiff had on file with the Clerk of the Court, were returned to sender unable to forward. As to RFA No. 14 Objection. Plaintiff has propounded Interrogatories in excess of the thirty, including subparts, permitted by Fla. R. Civ. P. 1.340(a) without leave of court. As to RFA No. 15: Objection. Plaintiff has propounded Interrogatories in excess of the thirty, including subparts, permitted by Fla. R. Civ. P, 1.340(a) without leave of court. As to RFA No. 16: Objection. Plaintiff has propounded Interrogatories in excess of the thirty, including subparts, permitted by Fla. R. Civ. P. 1.340(a) without leave of court.(17) Asto RFA No. 17: Objection. Plaintiff has propounded Interrogatories in excess of the thirty, including subparts, permitted by Fla. R. Civ. P. 1.340(a) without leave of court. (18) Asto RFA No. 18: Objection. Plaintiff has propounded Interrogatories in excess of the thirty, including subparts, permitted by Fla. R. Civ. P. 1.340(a) without leave of court. (19) As to RFA No. 19: Objection. Plaintiff has propounded Interrogatories in excess of the thirty, including subparts, permitted by Fla. R. Civ. P. 1.340(a) without leave of court. (20) As to RFA No. 20: Objection. Plaintiff has propounded Interrogatories in excess of the thirty, including subparts, permitted by Fla. R. Civ. P. 1.340(a) without leave of court. (21) Asto RFA No. 21: Objection. Plaintiff has propounded Interrogatories in excess of the thirty, including subparts, permitted by Fla. R. Civ. P. 1.340(a) without leave of court. (22) Asto RFA No. 22: Objection. Plaintiff has propounded Interrogatories in excess of the thirty, including subparts, permitted by Fla. R. Civ. P. 1.340(a) without leave of court. (23) Asto RFA No. 23: Objection. Plaintiff has propounded Interrogatories in excess of the thirty, including subparts, permitted by Fla. R. Civ. P. 1.340(a) without leave of court. Please explain the factual and legal basis for Sheriff Bob Gualtieri’s statement to the ‘Tampa Bay Times concerning the Complaint/Lawsuit in this case in which he is quoted as saying the following, “It’s frivolous, without any merit and really a bunch of nonsense.” Response: Objection. Plaintiff has propounded Interrogatories in excess of the thirty, including subparts, permitted by Fla. R. Civ. P. 1.340(a) without leave of court. Describe what involvement Sheriff Bob Gualtieri had in regards to the Plaintiff, James ‘McLynas’ public records requests that are the subject of this ComplainLawsuit and identify the issues discussed and identify the individuals by name and address that Sheriff Bob Gualtieri discussed these various issues with. Responsi Objection. Plaintiff has propounded Interrogatories in excess of the thirty, including subparts, permitted by Fla. R. Civ. P. 1.340(a) without leave of court.10, Mh. 12. 13. 14. As to Exhibit B filed with the Complaint in this case, please describe the author of Exhibit B, where it was placed, and the reason(s) for its use at PCSO. Respon: Objection. Plaintiff has propounded Interrogatories in excess of the thirty, including subparts, permitted by Fla. R. Civ. P. 1.340(a) without leave of court. As to Exhibits C, D, E & F filed with the Complaint in this case, explain why separate invoices were not used for each specific public records request by the Plaintiff and why the invoices were lumped together without any itemization for specific dates of requests by the Plaintiff. Response: Objection. Plaintiff has propounded Interrogatories in excess of the thirty, subparts, permitted by Fla. R. Civ. P. 1.340(a) without leave of court. cluding Explain in detail as to how the PCSO estimated the cost of $1,554.83 for 90 hours of labor for the Plaintiff's public records requests from April 24-40, 2016 as described in more detail in Exhibit C attached to the Complaint in this case. Response: Objection. Plaintiff has propounded Interrogatories in excess of the thirty, including subparts, permitted by Fla. R. Civ. P. 1.340(a) without leave of court. Explain in detail as to how the PCSO estimated the cost of $104.82 for 7 hours of labor for the Plaintiff's public records requests from May 8-14, 2016 as described in more detail in Exhibit C attached to the Complaint in this case. Respons Objection. Plaintiff has propounded Interrogatories in excess of the thirty, including subparts, permitted by Fla. R. Civ. P. 1.340(a) without leave of court. Explain in detail as to how the PCSO estimated the cost of $908.44 for 53 hours of labor for the Plaintiffs public records requests from May 22-28, 2016 as described in more detail in Exhibit C attached to the Complaint in this case. Response: Objection. Plaintiff has propounded Interrogatories in excess of the thirty, including subparts, permitted by Fla. R. Civ. P. 1.340(a) without leave of court. Explain in detail as to how the PCSO estimated the cost of $2,735.35 for 120.5 hours of labor for the Plaintiff's public records request seeking any and all memorandums” 10directives, or emails concerning the process and procedure for the specific handling of James McLynas’ public records request, including requests made from his email address as further described in more detail in Exhibit G attached to the Complaint in this case. Respon: Objection. Plaintiff has propounded Interrogatories in excess of the thirty, including, subparts, permitted by Fla. R. Civ. P. 1.340(a) without leave of court. 15. Explain why the Defendant failed to respond to the Plaintiff's 7 emails dated February 18, 2016, as described in better detail in Exhibit I of the Plaintiff's Complaint, and if Defendant claims to have responded provide the date(s) of response and who the author was of the respons(es). Response: Objection. Plaintiff has propounded Interrogatories in excess of the thirty, including subparts, permitted by Fla. R. Civ. P. 1.340(a) without leave of court. 16. Explain the legal basis and cite to any Florida caselaw that supports Shannon Lockheart’s email dated February 23, 2016, to the Plaintiff, wherein she states that the PCSO"s response to Plaintiff's public records request was accurate as the PCSO “did not have the document in our possession as it was in the possession of the State Attorney's Office and sealed under court order.” Response: Objection. Plaintiff has propounded Interrogatories in excess of the thirty, including subparts, permitted by Fla. R. Civ. P. 1.340(a) without leave of court. 17. Explain why the Defendant failed to produce any records or invoices with regards to Plaintiff's public records requests to the Defendant PCSO as described in detail in Exhibits K, L, M, N, O, P,Q, R, S that are attached to Plaintiff's Complaint. Response: Objection. Plaintiff has propounded Interrogatories in excess of the thirty, including subparts, permitted by Fla. R. Civ. P. 1.340(a) without leave of court. STATE OF FLORIDA — ) COUNTY OF PINELLAS ) Denise Thomas, being first duly sworn on oath, deposes and says she is the claims adjuster for Bob Gualtieri, Pinellas County Sheriff's Office, and she has read the Responses and iObjections of Defendant to Plaintiff's Interrogatories; she has the authority to prepare the responses; the responses were prepared with the assistance and advice of counsel and employees of the Pinellas County Sheriff's Office upon whose advice she has relied; the responses, subject to inadvertent or undiscovered errors, are based on, and therefore limited by, the records and information still in existence, or presently recollected and thus far discovered in the course of the 00d faith preparation of these responses; consequently, Defendant(s) reserve(s) the right to make any changes in the responses if it appears at any time that omissions or errors have been made therein; and subject to the limitations set forth herein, the responses are true to the best of her knowledge, information and belief. deena Denise Thomas Swom to and subscribed before me on December. oi » 2016, by Denise Thomas, who is personally known to me, Gp Notary Public —‘State of Florida LICE M. MARCOTT Commission # FF 219962 Expires Jy 27,2019 12