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Filing # 87870203 E-Filed 04/11/2019 09:11:12 PM
IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT,
IN AND FOR MARION COUNTY, FLORIDA
TREASURE ISLAND CAFE, LLC, CASE NO.: 18-CC-0702
Plaintiff/Counter-Defendant,
VS.
SKYLARK-SCHIPPERS, LLC,
Defendant/Counter-Plaintiff.
and
SKYLARK-SCHIPPERS, LLC,
Third Party-Plaintiff,
VS.
TROY A. FORD,
Third Party-Defendant.
/
TREASURE ISLAND CAFE, LLC’S FIRST REQUEST FOR PRODUCTION OF
DOCUMENTS DIRECTED TO SKYLARK-SCHIPPERS, LLC
COMES NOW, the Plaintiff/Counter-Defendant, TREASURE ISLAND CAFE, LLC
(hereinafter “Treasure Island”), by and through its undersigned counsel, hereby requests pursuant
to Rule 1.350, Florida Rules of Civil Procedure, that the Defendant/Counter-Plaintiff, SKYLARK-
SCHIPPERS, LLC, produce and permit it to inspect and/or copy such of the following documents
and items as are in the possession, custody or control of the Defendant, at the offices of LEE LAW
GROUPK PLLC, 3804 W. North B Street, Tampa, FL 33609 on or before thirty (30) days of
service hereof.
Definitions
As used in this Request for Production, the following terms and definitions are intended
to apply:
Electronically Filed Marion Case # 18CC000702AX 04/11/2019 09:11:12 PM1. “You” or “Your” refers to the Defendant, SKYLARK-SCHIPPERS, LLC, and
includes all former employees, representatives, agents, and any other persons or entities acting on
their behalf. Your response to these Requests must reflect and contain the knowledge of all persons
embraced by the terms “you” or “your”.
2. Plaintiff refers to TREASURE ISLAND CAFE, LLC, and includes all former
employees, representatives, agents, as well as any other persons or entities acting on behalf of any
named Plaintiff.
3. Defendant refers to SXYLARK-SCHIPPERS, LLC, and includes any subsidiaries,
divisions, predecessors or affiliated companies.
4. Communication refers to the transmission, transfer, or receipt of information in any
form, by any means, in any manner at any time or place, under any circumstances whatsoever,
including but not limited to verbal communications such as in-person discussions or telephone
conversations and electronic communications or correspondence such as e-mails or texts.
5. Document _or Documents refers to writing, letters, memoranda, e-mails, texts,
recorded recollections of conferences or conversations, reports, studies, lists, any written
compilation of data, papers, books, records, contracts, drawings, photographs, electronic
recordings of any form, and all other identifiable objects upon which any inscription, handwriting,
typing, printing, drawing, representation by any means, is recorded, reproduced, perpetuated,
maintained or preserved. These terms embrace the original and any reproduction or copies of the
foregoing.
6. Thing(s) refers to any tangible object(s).
7. Regarding or Relating refers to concerning, respecting, referring to.
8. Subject Property or Premises refers to 1601 NE 25" Avenue, Suite #209, Ocala, FL
34470.
Documents Requested
1. Any and all communications and documents relevant to the allegations that the
requisite written notice was not provided by the Plaintiff.
2. Any and all communications and documents exchanged between the Defendant and
the previous Landlord of the Subject Property.CERTIFICATE OF SERVICE
I HEREBY CERTIFY that the foregoing document is being served on April 11, 2019 via
an automatic e-mail generated by the Florida Court’s E-filing Portal to:
All Parties of Record on the E-Service List.
/s/ Haksoo Stephen Lee
Haksoo Stephen Lee, ESQ.
FBN: 88698
LEE LAW GROUP, PLLC
3804 W. North B Street
Tampa, FL 33609
(P): 813-606-4533
(F): 813-606-4500
hlee@flrights.com
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Filing # 87870203 E-Filed 04/11/2019 09:11:12 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT, IN AND FOR MARION COUNTY, FLORIDA TREASURE ISLAND CAFE, LLC, CASE NO.: 18-CC-0702 Plaintiff/Counter-Defendant, VS. SKYLARK-SCHIPPERS, LLC, Defendant/Counter-Plaintiff. and SKYLARK-SCHIPPERS, LLC, Third Party-Plaintiff, VS. TROY A. FORD, Third Party-Defendant. / TREASURE ISLAND CAFE, LLC’S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS DIRECTED TO SKYLARK-SCHIPPERS, LLC COMES NOW, the Plaintiff/Counter-Defendant, TREASURE ISLAND CAFE, LLC (hereinafter “Treasure Island”), by and through its undersigned counsel, hereby requests pursuant to Rule 1.350, Florida Rules of Civil Procedure, that the Defendant/Counter-Plaintiff, SKYLARK- SCHIPPERS, LLC, produce and permit it to inspect and/or copy such of the following documents and items as are in the possession, custody or control of the Defendant, at the offices of LEE LAW GROUPK PLLC, 3804 W. North B Street, Tampa, FL 33609 on or before thirty (30) days of service hereof. Definitions As used in this Request for Production, the following terms and definitions are intended to apply: Electronically Filed Marion Case # 18CC000702AX 04/11/2019 09:11:12 PM1. “You” or “Your” refers to the Defendant, SKYLARK-SCHIPPERS, LLC, and includes all former employees, representatives, agents, and any other persons or entities acting on their behalf. Your response to these Requests must reflect and contain the knowledge of all persons embraced by the terms “you” or “your”. 2. Plaintiff refers to TREASURE ISLAND CAFE, LLC, and includes all former employees, representatives, agents, as well as any other persons or entities acting on behalf of any named Plaintiff. 3. Defendant refers to SXYLARK-SCHIPPERS, LLC, and includes any subsidiaries, divisions, predecessors or affiliated companies. 4. Communication refers to the transmission, transfer, or receipt of information in any form, by any means, in any manner at any time or place, under any circumstances whatsoever, including but not limited to verbal communications such as in-person discussions or telephone conversations and electronic communications or correspondence such as e-mails or texts. 5. Document _or Documents refers to writing, letters, memoranda, e-mails, texts, recorded recollections of conferences or conversations, reports, studies, lists, any written compilation of data, papers, books, records, contracts, drawings, photographs, electronic recordings of any form, and all other identifiable objects upon which any inscription, handwriting, typing, printing, drawing, representation by any means, is recorded, reproduced, perpetuated, maintained or preserved. These terms embrace the original and any reproduction or copies of the foregoing. 6. Thing(s) refers to any tangible object(s). 7. Regarding or Relating refers to concerning, respecting, referring to. 8. Subject Property or Premises refers to 1601 NE 25" Avenue, Suite #209, Ocala, FL 34470. Documents Requested 1. Any and all communications and documents relevant to the allegations that the requisite written notice was not provided by the Plaintiff. 2. Any and all communications and documents exchanged between the Defendant and the previous Landlord of the Subject Property.CERTIFICATE OF SERVICE I HEREBY CERTIFY that the foregoing document is being served on April 11, 2019 via an automatic e-mail generated by the Florida Court’s E-filing Portal to: All Parties of Record on the E-Service List. /s/ Haksoo Stephen Lee Haksoo Stephen Lee, ESQ. FBN: 88698 LEE LAW GROUP, PLLC 3804 W. North B Street Tampa, FL 33609 (P): 813-606-4533 (F): 813-606-4500 hlee@flrights.com