Preview
Filing# 143319364 E-Filed 02/04/2022 01:15:31 PM
IN THE CIRCUITCOURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE-21-008854
DIVISION: 21
THERMOSET ROOFING CORP.,
Plaintiff,
V
TURN TWO ELECTRIC INC.,
a Florida corporation,and
LASHAWN LATTIBEAUDIERE,
an individual,
Defendants.
i
PRODUCTION FROM
PLAINTIFF'S NOTICE OF
NON-PARTY: METAL EDGE TECHNOLOGY, INC.
YOU ARE NOTIFIED that,pursuant to Florida Rule of Civil Procedure 1.351, after 15
days from the date of service of this Notice, the undersigned will apply to the Clerk of this Court
for issuance of the attached subpoena directed to Metal Edge Technology, Inc., who is not a
party, to produce the items listed at the time and place specifiedin the subpoena. Objections to
the issuance of this subpoena must be filed with the Clerk of the Circuit Court within 10 days of
the date of this Notice.
1
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/04/2022 01:15:31 PM.****
Dated: February 4,2022. Respectfullysubmitted,
s/ Michael L. Buckner
Michael L. Buckner, Esquire
Florida Bar No. 106331
BUCKNER LEGAL SELF-HELP PROGRAM, INC.
Email: michaelbuckneilaw@gmail-com
5224 NW 96th Drive
Coral Springs,Florida 33076-2487
Office: +1-954-347-0112
Facsimile: +1-954-513-4796
Attorneyfor the Defendants,
Turn Two Electric Inc., and
Lathawn Lattibeaudiere
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing document was filed
and was sent by e-mail from the Florida Courts' E-Filing Portal system, unless
electronically
otherwise noted below, on all counsel or partiesof record listed below, on February 4,2022:
Gary L. Brown, Esquire
Email. gbrown@kelleykronenberg.com
John M. Dejager,Esquire
Email. jdejager@kelleykronenberg.com
Kelley Kronenberg, PA
10360 West State Road 84
Fort Lauderdale, Florida 33324
Attorneysfor the Plaintiff/Counter-Defendant,
Thermoset Roofing Corp.
s/ Michael L. Buckner
Michael L. Buckner, Esquire
2
IN THE CIRCUITCOURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE-21-008854
DIVISION: 21
THERMOSET ROOFING CORP.,
Plaintiff,
V
TURN TWO ELECTRIC INC.,
a Florida corporation,and
LASHAWN LATTIBEAUDIERE,
an individual,
Defendants.
i
DEFENDANTS' SUBPOENA FOR PRODUCTION OF
DOCUMENTS FROM NONPARTY:
METAL EDGE TECHNOLOGY, INC.
THE STATE OF FLORIDA
TO: Metal Edge Technology, Inc., c/o Adam Honig, Registered Agent, 2148 NW 17th Street,
Pompano Beach, Florida 33069
YOU MUST go to Buckner Legal Self-HelpProgram, Inc.,5224NW 96th Drive Coral Springs,
Florida 33076-2487, on Tuesday, March 15,2022, at 10:00 a.m. and bring with you at that time
and place the following:
1. Documents and communications relatingto the occupationallicense,business license,
government authorization for Metal Edge Technology, Inc. ("Metal Edge")
certificate or
to engage in business operations at 500 NW12th Avenue, Pompano Beach, Florida
33069 (the"Property")during the 2021 calendar year.
2. Documents and communications identifying
the date that Metal Edge began conducting
business operationsat the Property.
3 Documents and communications listingMetal Edge's business income during the 2018,
2019. 2020 and 2021 calendar years.
4. Documents and communications identifying Metal Edge employees, agents and
that worked at the Property during the 2021 calendar year.
representatives
1
These items will be inspectedand may be copied at that time. You will not have to leave the
items.
original
You may obey this subpoena by providing readable copies of the items to be produced to the
party or his/her attorney whose name appears on this subpoena on or before the scheduled date of
production.You may condition the preparationof the copies upon payment in advance of the
If you mail, e-mail or deliver the copies to the attorney whose
reasonable cost of preparation.
name appears on this subpoena before the date indicated above, you do not have to appear in
person.
You may be in contempt of court if you fail to: (1) appear as specified;(2) furnish the records
instead of appearing as provided above; or (3)objectto this subpoena.
You can only be excused by the person whose name appears on this subpoena and, unless
excused by that person of the Court, you shall respond as directed.
who needs any accommodation in order to participate
If you are a person with a disability in this
proceeding,you are entitled,at no cost to you, to the provisionof certain assistance. Please
contact Diana Sobel, Room 20140, 201 S.E. Sixth Street,Fort Lauderdale, Florida 33301, 954-
831-7721 at least 7 days before your scheduled court appearance, or immediately upon receiving
this notification if the time before the scheduled appearance is less than 7 days; if you are
hearing or voice impaired,call 711.
Dated:
CLERK OF THE CIRCUIT COURT (SEAL)
By-
Deputy Clerk
2
ICERTIFY that I gave notice to every other party to this action of my intent to serve a subpoena
upon a person who is not a party to this action directingthat person to produce documents or
thingswithout deposition.I also certifythat no objectionunder Florida Rule of Civil Procedure
1.351 has been received by the undersigned within 10 days of service of this notice, if service
was by hand-deliveryor appropriatefacsimile transmission, and within 15 days if service was by
mail or e-mail.
Dated: Respectfullysubmitted,
s/ Michael L. Buckner
Michael L. Buckner, Esquire
Florida Bar No. 106331
BUCKNER LEGAL SELF-HELP PROGRAM, INC.
Email: michaelbuckneilaw@gmail-com
5224 NW 96th Drive
Coral Springs,Florida 33076-2487
Office: +1-954-347-0112
Facsimile: +1-954-513-4796
Attorneyfor the Defendants,
Turn Two Electric Inc., and
Lathawn Lattibeaudiere
3
Preview
Filing# 143319364 E-Filed 02/04/2022 01:15:31 PM IN THE CIRCUITCOURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-21-008854 DIVISION: 21 THERMOSET ROOFING CORP., Plaintiff, V TURN TWO ELECTRIC INC., a Florida corporation,and LASHAWN LATTIBEAUDIERE, an individual, Defendants. i PRODUCTION FROM PLAINTIFF'S NOTICE OF NON-PARTY: METAL EDGE TECHNOLOGY, INC. YOU ARE NOTIFIED that,pursuant to Florida Rule of Civil Procedure 1.351, after 15 days from the date of service of this Notice, the undersigned will apply to the Clerk of this Court for issuance of the attached subpoena directed to Metal Edge Technology, Inc., who is not a party, to produce the items listed at the time and place specifiedin the subpoena. Objections to the issuance of this subpoena must be filed with the Clerk of the Circuit Court within 10 days of the date of this Notice. 1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/04/2022 01:15:31 PM.**** Dated: February 4,2022. Respectfullysubmitted, s/ Michael L. Buckner Michael L. Buckner, Esquire Florida Bar No. 106331 BUCKNER LEGAL SELF-HELP PROGRAM, INC. Email: michaelbuckneilaw@gmail-com 5224 NW 96th Drive Coral Springs,Florida 33076-2487 Office: +1-954-347-0112 Facsimile: +1-954-513-4796 Attorneyfor the Defendants, Turn Two Electric Inc., and Lathawn Lattibeaudiere CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing document was filed and was sent by e-mail from the Florida Courts' E-Filing Portal system, unless electronically otherwise noted below, on all counsel or partiesof record listed below, on February 4,2022: Gary L. Brown, Esquire Email. gbrown@kelleykronenberg.com John M. Dejager,Esquire Email. jdejager@kelleykronenberg.com Kelley Kronenberg, PA 10360 West State Road 84 Fort Lauderdale, Florida 33324 Attorneysfor the Plaintiff/Counter-Defendant, Thermoset Roofing Corp. s/ Michael L. Buckner Michael L. Buckner, Esquire 2 IN THE CIRCUITCOURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-21-008854 DIVISION: 21 THERMOSET ROOFING CORP., Plaintiff, V TURN TWO ELECTRIC INC., a Florida corporation,and LASHAWN LATTIBEAUDIERE, an individual, Defendants. i DEFENDANTS' SUBPOENA FOR PRODUCTION OF DOCUMENTS FROM NONPARTY: METAL EDGE TECHNOLOGY, INC. THE STATE OF FLORIDA TO: Metal Edge Technology, Inc., c/o Adam Honig, Registered Agent, 2148 NW 17th Street, Pompano Beach, Florida 33069 YOU MUST go to Buckner Legal Self-HelpProgram, Inc.,5224NW 96th Drive Coral Springs, Florida 33076-2487, on Tuesday, March 15,2022, at 10:00 a.m. and bring with you at that time and place the following: 1. Documents and communications relatingto the occupationallicense,business license, government authorization for Metal Edge Technology, Inc. ("Metal Edge") certificate or to engage in business operations at 500 NW12th Avenue, Pompano Beach, Florida 33069 (the"Property")during the 2021 calendar year. 2. Documents and communications identifying the date that Metal Edge began conducting business operationsat the Property. 3 Documents and communications listingMetal Edge's business income during the 2018, 2019. 2020 and 2021 calendar years. 4. Documents and communications identifying Metal Edge employees, agents and that worked at the Property during the 2021 calendar year. representatives 1 These items will be inspectedand may be copied at that time. You will not have to leave the items. original You may obey this subpoena by providing readable copies of the items to be produced to the party or his/her attorney whose name appears on this subpoena on or before the scheduled date of production.You may condition the preparationof the copies upon payment in advance of the If you mail, e-mail or deliver the copies to the attorney whose reasonable cost of preparation. name appears on this subpoena before the date indicated above, you do not have to appear in person. You may be in contempt of court if you fail to: (1) appear as specified;(2) furnish the records instead of appearing as provided above; or (3)objectto this subpoena. You can only be excused by the person whose name appears on this subpoena and, unless excused by that person of the Court, you shall respond as directed. who needs any accommodation in order to participate If you are a person with a disability in this proceeding,you are entitled,at no cost to you, to the provisionof certain assistance. Please contact Diana Sobel, Room 20140, 201 S.E. Sixth Street,Fort Lauderdale, Florida 33301, 954- 831-7721 at least 7 days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired,call 711. Dated: CLERK OF THE CIRCUIT COURT (SEAL) By- Deputy Clerk 2 ICERTIFY that I gave notice to every other party to this action of my intent to serve a subpoena upon a person who is not a party to this action directingthat person to produce documents or thingswithout deposition.I also certifythat no objectionunder Florida Rule of Civil Procedure 1.351 has been received by the undersigned within 10 days of service of this notice, if service was by hand-deliveryor appropriatefacsimile transmission, and within 15 days if service was by mail or e-mail. Dated: Respectfullysubmitted, s/ Michael L. Buckner Michael L. Buckner, Esquire Florida Bar No. 106331 BUCKNER LEGAL SELF-HELP PROGRAM, INC. Email: michaelbuckneilaw@gmail-com 5224 NW 96th Drive Coral Springs,Florida 33076-2487 Office: +1-954-347-0112 Facsimile: +1-954-513-4796 Attorneyfor the Defendants, Turn Two Electric Inc., and Lathawn Lattibeaudiere 3