Extract to table

General Objections — Response to Blanket Objections Before addressing the twenty-three (23) specific categories of deficiencies, we must address Coastal Palms' blanket objections, which pervade the written responses accompanying the August 22, 2022 production

OTA agreements are typically renewed or renegotiated on an annual or biennial basis, and current agreements must exist for all properties

The absence of PMS data from the production is a critical gap that must be remedied

However, Coastal Palms' own copies of these submissions—together with loan agreements, covenant compliance certificates, and related correspondence—are independently discoverable and must be produced by Coastal Palms in response to the First RFP, irrespective of the status of the third-party subpoena

If Coastal Palms engaged any external accounting firm for annual compilations, reviews, or audits of its financial statements—or for the preparation of tax returns—those records are responsive and must be produced