Preview
Filing # 105959714 E-Filed 04/07/2020 01:14:44 PM
IN THE CIRCUIT COURT OF THE 17"
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
Case No. CACE 19-020722 (04)
OVAIS HAIDER ALI, TRAVIS COLE,
OVAIS MAHMOOD, ADEEL ARIF,
ELIZABETH ILAWAN and DENIS
BELIUKOV,
Plaintiffs,
vs.
VINCE ECOM EMPIRE, LLC and
YVENSON ISRAEL,
Defendants.
/
DEFENDANTS’ FIRST REQUEST FOR PRODUCTION
OF DOCUMENTS TO PLAINTIFF, ADEEL ARIF
Pursuant to Fla. R. Civ. P. 1.350, Defendants, Vince Ecom Empire, LLC and Yvenson
Israel (collectively the “Defendants”) request Plaintiff, Adeel Arif (“Plaintiff”) to produce the
following documents at the office of Marshall Grant, PLLC, 197 South Federal Highway, Suite
200, Boca Raton, FL 33432, for inspection and copying, within the time permitted by the Florida
Rules of Civil Procedure, unless otherwise shortened by the Court.
DEFINITIONS AND INSTRUCTIONS
When relevant or when used in this Request for Production, refer to the following
definitions and instructions:
A. “Document” means any written or graphic matter or other means of preserving
thought or expression, and all tangible things from which information can be processed or
transcribed, including the originals and all non-identical copies, whether different from the
original by reason of any notation made on such copy or otherwise, including, but not limited to,
correspondence, memoranda, notes, messages, letters, telegrams, emails, facsimiles, teletype,
telefax bulletins, meetings, or other communications, interoffice and intra-office telephone calls,
diaries, chronological data, minutes, books, reports, charts, ledgers, invoices, work-sheets,
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/07/2020 01:14:43 PM.****Ovais Haider Ali, et al. v. Vince Ecom Empire, LLC, et al.
Case No. CACE 19-020722 (04)
Defendants’ First Request for Production to Plaintiff
receipts, returns, computer print-outs, prospectuses, financial statements, schedules, affidavits,
contracts, cancelled checks, transcripts, statistics, surveys, magazine or newspaper articles,
releases (and any and all drafts, alterations and modifications, changes and amendments of any
of the foregoing), graphs or aural records or representations of any kind, including, without
limitation, photographs, charts, graphs, microfiche, microfilm, video-tape, recordings, motion
pictures and electronic, mechanical or electric recordings or representations of any kind
(including, without limitation, tapes, cassettes, discs and recordings), and including the file and
file cover.
B. “All Documents” means every document or group of documents for
communication as above defined known to you and every such document or communication
which can be located or discovered by reasonably diligent efforts.
Cc. All documents must be produced in their native format, including all metadata
associated with each document. These documents should be stored on a “zip” or “thumb” drive,
which will be provided to you upon request.
D. If any documents responsive to any request have been lost, mutilated or
destroyed, so state and identify each such document, and state to which request(s) the document
would have been responsive.
E. In the event that any document called for by these requests has been destroyed,
other than in the ordinary course of business, you shall identify such document and specify (i)
the date of its destruction, (ii) the reason for its destruction, (iii) the person authorizing its
destruction, and (iv) the custodian of the document immediately preceding its destruction. This
includes e-mails, text messages, WhatsApp, and social media posts that have been deleted.
F, “You”, “Your” and “Plaintiff? means the party to whom these requests are
addressed; that is, Adeel Arif, his/her agents, attorneys, and all of his/her other representatives.
G. “Person” means any natural person, individual, proprietorship, partnership,
corporation, association, organization, joint venture, firm, other business enterprise,
governmental body, group or natural persons or other entity.
H. “Communication” means any oral or written statement, dialogue, colloquialism,
discussion, conversation and agreement.
L “Relating to” means its common broad definition, and is intended to include any
document or fact that evidences, shows, reflects, refers to, mentions, concems or in any other
way relates to the allegation, facts, events or persons referred to in the Requests for Production.Ovais Haider Ali, et al. v. Vince Ecom Empire, LLC, et al.
Case No. CACE 19-020722 (04)
Defendants’ First Request for Production to Plaintiff
J. The “Complaint” means the latest amended Complaint filed in the above
captioned case.
K. “Identify”, when used with reference to a natural person, means state:
1. his full name and address (or if the present is not known, his last known
address);
2. the full name and address of each of his employers, each corporation of
which he is an officer or director and each business in which he is a principal;
3. his present (or, if the present is not known his last known) position and his
position or positions at the time of the act to which the request answer relates;
4. each position he has ever held with you and the date such positions were
held;
5. such other information sufficient to enable Plaintiff(s)/Defendant(s) to
identify the person.
L. “Identify”, when used with reference to any entity other than a natural person,
means:
1. state the full name of the entity, the type of entity (e.g. corporation,
partnership, etc.) the address of its principal place of business, its principal business activity and,
if it is a corporation, the jurisdiction under the laws of which it has been organized and the date
of such organization;
2. identify each of the entities - officers, directors, shareholders or other
principals;
3. state whatever other information you may have concerning the existence
or identity of the entity.
M. __If objection is taken to any of the following requests, or if Plaintiff fails to fully
respond to any request, state the specific grounds therefore and respond to such request to the
extent to which there is no objection. If privilege is asserted as to any of the documents
requested, fully identify for each such document: (i) its date; (ii) the type of documents (e.g.,
letter, memo, etc.); and (iii) the general subject matter.
N. As used herein, the singular and masculine form of noun and pronoun shall
embrace, and be read and applied as, the plural or feminine or neuter, as circumstances may
make appropriate.Ovais Haider Ali, et al. v. Vince Ecom Empire, LLC, et al.
Case No. CACE 19-020722 (04)
Defendants’ First Request for Production to Plaintiff
oO. Unless otherwise specified, the time frame for this request for production is
January 1, 2017 to the present.
FIRST REQUEST FOR PRODUCTION OF DOCUMENTS
Request No. 1:
any online sale of products.
Request No. 2:
All documents related to Plaintiffs’ financial information regarding
All of Plaintiffs credit card, bank, and financial statements related
to any of Plaintiff's Amazon account.
Request No. 3:
Request No. 4:
Request No. 5:
Request No. 6:
accounts.
Request No. 7:
of your Amazon accounts.
Request No. 8:
client of the Defendants.
Request No. 9:
Request No. 10:
Request No. 11:
Request No. 12:
Request No. 13:
Request No. 14:
Request No. 15:
Request No. 16:
Request No. 17:
All communications between you and Defendants.
All communications between the Defendants and Amazon.
All communications between you and Amazon.
All Amazon reviews you have received on any of your Amazon
All communications between you and any other customers of any
All communications between you and any other customers or
All communications between you and Ovais Haider Ali.
All communications between you and Travis Cole.
All communications between you and Ovais Mahmood.
All communications between you and Adeel Arif.
All communications between you and Elizabeth Ilawan.
All communications between you and Denis Beliukov.
All communications between you and Richard Dunlop.
All communications between you and Christopher Clark.
All communications between you and Dough Hecht.Ovais Haider Ali, et al. v. Vince Ecom Empire, LLC, et al.
Case No. CACE 19-020722 (04)
Defendants’ First Request for Production to Plaintiff
Request No. 18:
Request No. 19:
Request No. 20:
Request No. 21:
Request No. 22:
Request No. 23:
Request No. 24:
Request No. 25:
Request No. 26:
Request No. 27:
Request No. 28:
Request No. 29:
Request No. 30:
Request No. 31:
Request No. 32:
Request No. 33:
Request No. 34:
Request No. 35:
Request No. 36:
All communications between you and Jessica Lee.
All communications between you and Tara Derenoncourt.
All communications between you and Gabe Hinds.
All communications between you and William Canavan.
All communications between you and Patrick Merryman.
All communications between you and Kristy Turner.
All communications between you and Marcus Apodaca.
All communications between you and George Kenneth McGill.
All communications between you and Joshua Burnett.
All communications between you and Francisco Tafoya.
All communications between you and Demetria Phillips.
All communications between you and Hakim Greenidge.
All communications between you and Joshua Johnson.
All communications between you and Nicholas John Skorobatsch.
All communications between you and Leonard Paul Skorobatsch.
All communications between you and Miguel Hills.
All communications between you and Stewart Escalon.
All communications between you and Jacob Newcomb.
All documents related to information of Plaintiffs’ profits and
losses from any of the Plaintiffs’ Amazon accounts.
Request No. 37:
Plaintiffs’ Amazon accounts.
Request No. 38:
the Defendants.
All documents related to credit card statements related to the
All documents related to training materials Plaintiffs received fromOvais Haider Ali, et al. v. Vince Ecom Empire, LLC, et al.
Case No. CACE 19-020722 (04)
Defendants’ First Request for Production to Plaintiff
Request No. 39: All documents Plaintiff received from Defendants.
Request No. 40: All documents you sent to Defendants.
Request No. 41: All documents related to statements made by Defendants to you.
Request No. 42: Copies of all social media posts or comments, internet posts, or
online communications that you made or were posted to any account owed or managed by you
that related to the Defendants.
Request No. 43: All documents received from Amazon related any of Plaintiffs’
Amazon accounts.
Request No. 44: All documents received from any Plaintiff to this action.
Request No. 45: All communications with any virtual assistants that were referred
or recommended by the Defendants to Plaintiff.
Request No. 46: All documents relating to any money paid to any virtual assistant
that were referred or recommended by the Defendants to Plaintiff related to any of Plaintiffs’
Amazon accounts.
Request No. 47: All documents relating to any mistakes, errors, or improper actions
taken by a virtual assistant that were referred or recommended by the Defendants to Plaintiff
against Plaintiffs.
Request No. 48: All communications with anyone wherein that communication you
recommend to use or look into using the Defendants’ services to another person(s) or entity.
Request No. 49: All communications with anyone that referred you to the
Defendants or recommend you work with the Defendants.
Request No. 50: All documents that support the allegations in your Amended
Complaint.
Request No. 51: All communications that contain any fraudulent statements by the
Defendants.
Request No. 52: All documents that contain any fraudulent statements by the
Defendants.
Request No. 53: All documents submitted to Amazon related to any of your
Amazon accounts.Ovais Haider Ali, et al. v. Vince Ecom Empire, LLC, et al.
Case No. CACE 19-020722 (04)
Defendants’ First Request for Production to Plaintiff
Request No. 54: All documents submitted to any government agency related to any
of your Amazon accounts.
Request No. 55: All communications with any government agency related to any of
your Amazon accounts.
Request No. 56: All documents received from any government agency related to
any of your Amazon accounts.
Request No. 57: Any tax returns and tax documents related to any of your Amazon
accounts.
Request No. 58: All financial documents related to any of your Amazon accounts.
Request No. 59: All documents related to any payments you have made to the
Defendants.
Request No. 60: Copies of all reviews you post online or shared with anyone else of
the Defendants.
Request No. 61: All documents submitted to any third party vendors, services or
any competitors of the Defendants.
Request No. 62: All documents showing the amount of damages you have suffered
as a result of the Defendants’ actions.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via e-
mail to: Alan Dagen, Esquire, The Law Offices of Alan P. Dagen, P.A., 746 Heritage Drive,
Weston, FL 33326; alan@litigationlawyerattorney.com, on this 7m day of April, 2020.
Respectfully submitted,
MARSHALL GRANT, PLLC
Counsel for Defendants
197 South Federal Highway, Suite 200
Boca Raton, FL 33432
Telephone: 561.361.1000
Facsimile: 561.672.7581
Email: jgrant@marshallgrant.com
By:___/s/ Joe M. Grant
JOE M. GRANT
Florida Bar No. 137758
Preview
Filing # 105959714 E-Filed 04/07/2020 01:14:44 PM IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA Case No. CACE 19-020722 (04) OVAIS HAIDER ALI, TRAVIS COLE, OVAIS MAHMOOD, ADEEL ARIF, ELIZABETH ILAWAN and DENIS BELIUKOV, Plaintiffs, vs. VINCE ECOM EMPIRE, LLC and YVENSON ISRAEL, Defendants. / DEFENDANTS’ FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO PLAINTIFF, ADEEL ARIF Pursuant to Fla. R. Civ. P. 1.350, Defendants, Vince Ecom Empire, LLC and Yvenson Israel (collectively the “Defendants”) request Plaintiff, Adeel Arif (“Plaintiff”) to produce the following documents at the office of Marshall Grant, PLLC, 197 South Federal Highway, Suite 200, Boca Raton, FL 33432, for inspection and copying, within the time permitted by the Florida Rules of Civil Procedure, unless otherwise shortened by the Court. DEFINITIONS AND INSTRUCTIONS When relevant or when used in this Request for Production, refer to the following definitions and instructions: A. “Document” means any written or graphic matter or other means of preserving thought or expression, and all tangible things from which information can be processed or transcribed, including the originals and all non-identical copies, whether different from the original by reason of any notation made on such copy or otherwise, including, but not limited to, correspondence, memoranda, notes, messages, letters, telegrams, emails, facsimiles, teletype, telefax bulletins, meetings, or other communications, interoffice and intra-office telephone calls, diaries, chronological data, minutes, books, reports, charts, ledgers, invoices, work-sheets, *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/07/2020 01:14:43 PM.****Ovais Haider Ali, et al. v. Vince Ecom Empire, LLC, et al. Case No. CACE 19-020722 (04) Defendants’ First Request for Production to Plaintiff receipts, returns, computer print-outs, prospectuses, financial statements, schedules, affidavits, contracts, cancelled checks, transcripts, statistics, surveys, magazine or newspaper articles, releases (and any and all drafts, alterations and modifications, changes and amendments of any of the foregoing), graphs or aural records or representations of any kind, including, without limitation, photographs, charts, graphs, microfiche, microfilm, video-tape, recordings, motion pictures and electronic, mechanical or electric recordings or representations of any kind (including, without limitation, tapes, cassettes, discs and recordings), and including the file and file cover. B. “All Documents” means every document or group of documents for communication as above defined known to you and every such document or communication which can be located or discovered by reasonably diligent efforts. Cc. All documents must be produced in their native format, including all metadata associated with each document. These documents should be stored on a “zip” or “thumb” drive, which will be provided to you upon request. D. If any documents responsive to any request have been lost, mutilated or destroyed, so state and identify each such document, and state to which request(s) the document would have been responsive. E. In the event that any document called for by these requests has been destroyed, other than in the ordinary course of business, you shall identify such document and specify (i) the date of its destruction, (ii) the reason for its destruction, (iii) the person authorizing its destruction, and (iv) the custodian of the document immediately preceding its destruction. This includes e-mails, text messages, WhatsApp, and social media posts that have been deleted. F, “You”, “Your” and “Plaintiff? means the party to whom these requests are addressed; that is, Adeel Arif, his/her agents, attorneys, and all of his/her other representatives. G. “Person” means any natural person, individual, proprietorship, partnership, corporation, association, organization, joint venture, firm, other business enterprise, governmental body, group or natural persons or other entity. H. “Communication” means any oral or written statement, dialogue, colloquialism, discussion, conversation and agreement. L “Relating to” means its common broad definition, and is intended to include any document or fact that evidences, shows, reflects, refers to, mentions, concems or in any other way relates to the allegation, facts, events or persons referred to in the Requests for Production.Ovais Haider Ali, et al. v. Vince Ecom Empire, LLC, et al. Case No. CACE 19-020722 (04) Defendants’ First Request for Production to Plaintiff J. The “Complaint” means the latest amended Complaint filed in the above captioned case. K. “Identify”, when used with reference to a natural person, means state: 1. his full name and address (or if the present is not known, his last known address); 2. the full name and address of each of his employers, each corporation of which he is an officer or director and each business in which he is a principal; 3. his present (or, if the present is not known his last known) position and his position or positions at the time of the act to which the request answer relates; 4. each position he has ever held with you and the date such positions were held; 5. such other information sufficient to enable Plaintiff(s)/Defendant(s) to identify the person. L. “Identify”, when used with reference to any entity other than a natural person, means: 1. state the full name of the entity, the type of entity (e.g. corporation, partnership, etc.) the address of its principal place of business, its principal business activity and, if it is a corporation, the jurisdiction under the laws of which it has been organized and the date of such organization; 2. identify each of the entities - officers, directors, shareholders or other principals; 3. state whatever other information you may have concerning the existence or identity of the entity. M. __If objection is taken to any of the following requests, or if Plaintiff fails to fully respond to any request, state the specific grounds therefore and respond to such request to the extent to which there is no objection. If privilege is asserted as to any of the documents requested, fully identify for each such document: (i) its date; (ii) the type of documents (e.g., letter, memo, etc.); and (iii) the general subject matter. N. As used herein, the singular and masculine form of noun and pronoun shall embrace, and be read and applied as, the plural or feminine or neuter, as circumstances may make appropriate.Ovais Haider Ali, et al. v. Vince Ecom Empire, LLC, et al. Case No. CACE 19-020722 (04) Defendants’ First Request for Production to Plaintiff oO. Unless otherwise specified, the time frame for this request for production is January 1, 2017 to the present. FIRST REQUEST FOR PRODUCTION OF DOCUMENTS Request No. 1: any online sale of products. Request No. 2: All documents related to Plaintiffs’ financial information regarding All of Plaintiffs credit card, bank, and financial statements related to any of Plaintiff's Amazon account. Request No. 3: Request No. 4: Request No. 5: Request No. 6: accounts. Request No. 7: of your Amazon accounts. Request No. 8: client of the Defendants. Request No. 9: Request No. 10: Request No. 11: Request No. 12: Request No. 13: Request No. 14: Request No. 15: Request No. 16: Request No. 17: All communications between you and Defendants. All communications between the Defendants and Amazon. All communications between you and Amazon. All Amazon reviews you have received on any of your Amazon All communications between you and any other customers of any All communications between you and any other customers or All communications between you and Ovais Haider Ali. All communications between you and Travis Cole. All communications between you and Ovais Mahmood. All communications between you and Adeel Arif. All communications between you and Elizabeth Ilawan. All communications between you and Denis Beliukov. All communications between you and Richard Dunlop. All communications between you and Christopher Clark. All communications between you and Dough Hecht.Ovais Haider Ali, et al. v. Vince Ecom Empire, LLC, et al. Case No. CACE 19-020722 (04) Defendants’ First Request for Production to Plaintiff Request No. 18: Request No. 19: Request No. 20: Request No. 21: Request No. 22: Request No. 23: Request No. 24: Request No. 25: Request No. 26: Request No. 27: Request No. 28: Request No. 29: Request No. 30: Request No. 31: Request No. 32: Request No. 33: Request No. 34: Request No. 35: Request No. 36: All communications between you and Jessica Lee. All communications between you and Tara Derenoncourt. All communications between you and Gabe Hinds. All communications between you and William Canavan. All communications between you and Patrick Merryman. All communications between you and Kristy Turner. All communications between you and Marcus Apodaca. All communications between you and George Kenneth McGill. All communications between you and Joshua Burnett. All communications between you and Francisco Tafoya. All communications between you and Demetria Phillips. All communications between you and Hakim Greenidge. All communications between you and Joshua Johnson. All communications between you and Nicholas John Skorobatsch. All communications between you and Leonard Paul Skorobatsch. All communications between you and Miguel Hills. All communications between you and Stewart Escalon. All communications between you and Jacob Newcomb. All documents related to information of Plaintiffs’ profits and losses from any of the Plaintiffs’ Amazon accounts. Request No. 37: Plaintiffs’ Amazon accounts. Request No. 38: the Defendants. All documents related to credit card statements related to the All documents related to training materials Plaintiffs received fromOvais Haider Ali, et al. v. Vince Ecom Empire, LLC, et al. Case No. CACE 19-020722 (04) Defendants’ First Request for Production to Plaintiff Request No. 39: All documents Plaintiff received from Defendants. Request No. 40: All documents you sent to Defendants. Request No. 41: All documents related to statements made by Defendants to you. Request No. 42: Copies of all social media posts or comments, internet posts, or online communications that you made or were posted to any account owed or managed by you that related to the Defendants. Request No. 43: All documents received from Amazon related any of Plaintiffs’ Amazon accounts. Request No. 44: All documents received from any Plaintiff to this action. Request No. 45: All communications with any virtual assistants that were referred or recommended by the Defendants to Plaintiff. Request No. 46: All documents relating to any money paid to any virtual assistant that were referred or recommended by the Defendants to Plaintiff related to any of Plaintiffs’ Amazon accounts. Request No. 47: All documents relating to any mistakes, errors, or improper actions taken by a virtual assistant that were referred or recommended by the Defendants to Plaintiff against Plaintiffs. Request No. 48: All communications with anyone wherein that communication you recommend to use or look into using the Defendants’ services to another person(s) or entity. Request No. 49: All communications with anyone that referred you to the Defendants or recommend you work with the Defendants. Request No. 50: All documents that support the allegations in your Amended Complaint. Request No. 51: All communications that contain any fraudulent statements by the Defendants. Request No. 52: All documents that contain any fraudulent statements by the Defendants. Request No. 53: All documents submitted to Amazon related to any of your Amazon accounts.Ovais Haider Ali, et al. v. Vince Ecom Empire, LLC, et al. Case No. CACE 19-020722 (04) Defendants’ First Request for Production to Plaintiff Request No. 54: All documents submitted to any government agency related to any of your Amazon accounts. Request No. 55: All communications with any government agency related to any of your Amazon accounts. Request No. 56: All documents received from any government agency related to any of your Amazon accounts. Request No. 57: Any tax returns and tax documents related to any of your Amazon accounts. Request No. 58: All financial documents related to any of your Amazon accounts. Request No. 59: All documents related to any payments you have made to the Defendants. Request No. 60: Copies of all reviews you post online or shared with anyone else of the Defendants. Request No. 61: All documents submitted to any third party vendors, services or any competitors of the Defendants. Request No. 62: All documents showing the amount of damages you have suffered as a result of the Defendants’ actions. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via e- mail to: Alan Dagen, Esquire, The Law Offices of Alan P. Dagen, P.A., 746 Heritage Drive, Weston, FL 33326; alan@litigationlawyerattorney.com, on this 7m day of April, 2020. Respectfully submitted, MARSHALL GRANT, PLLC Counsel for Defendants 197 South Federal Highway, Suite 200 Boca Raton, FL 33432 Telephone: 561.361.1000 Facsimile: 561.672.7581 Email: jgrant@marshallgrant.com By:___/s/ Joe M. Grant JOE M. GRANT Florida Bar No. 137758