Preview
Filing # 115584042 E-Filed 10/26/2020 11:33:29 AM
IN THE CIRCUIT COURT OF THE
ELEVENTH JUDICIAL CIRCUIT IN AND
FOR MIAMI-DADE COUNTY, FLORIDA
CIVIL DIVISION
JOHN HUGHES, III, as receiver of Flicker
Construction, Inc., an inactive Florida CASE NO. 2019-003916-CA-01
corporation,
Plaintiff,
vs.
ROMAN FLICKER and MID-CONTINENT
CASUALTY COMPANY,
Defendants.
/
RE-NOTICE OF TAKING DEPOSITION DUCES TECUM
Defendant, Mid-Continent Casualty Company, through undersigned counsel, will take the
deposition duces tecum of the individual listed below and on the date and time specified below
and you are to bring with you all documents listed on Schedule "A" attached to this Notice of
Taking Deposition and to the Subpoena Duces Tecum served on October 7, 2020.
Deponent Date & Time Place
Isaac Amsalem
3201 Northeast 183rd Street November 13, 2020 Via Zoom*
Aventura, FL 33160 @ 10:00 a.m.
*Zoom link:
https://veritext.zoom.us/j/92994542647?pwd=anB0YkxXZ3ZkcGIxdGRWVWNNcFlQdz09
Meeting ID: 92994542647
Password: y9cOw71inv
Dial by your location:
+1 8884754499 US
Meeting ID: 92994542647
Password: 8909513160
0979020\306868853.v1
CASE NO. 2019-003916-CA-01
upon oral examination before Veritext Court Reporters or Notary Public in and for the State of
Florida, or some other officer duly authorized by law to take depositions in the state. The
deposition will continue from day to day until completed. The deposition is being taken for the
purpose of discovery, for use at trial, or both of the foregoing, or for such other purposes as are
permitted under the applicable and governing rules. See attached Schedule A for details.
Respectfully submitted,
HINSHAW & CULBERTSON, LLP
/s/ Alina N. Yaniz
Edward T. Sylvester
Florida Bar No. 0051612
esylvester@hinshawlaw.com
Alina N. Yaniz
Florida Bar No. 1003560
ayaniz@hinshawlaw.com
2525 Ponce de Leon Boulevard, 4th Floor
Coral Gables, Florida 33134
Telephone: 305-358-7747
Facsimile: 305-577-1063
Attorneys for Mid Continent Casualty Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on October 26, 2020, a true and correct copy of the foregoing
has been filed via the E-Filing System and served on all counsel of record.
HINSHAW & CULBERTSON, LLP
/s/ Alina N. Yaniz
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CASE NO. 2019-003916-CA-01
Schedule A
Isaac Amsalem Bentley Holdings
References:
1. “Document(s)” means the original, duplicate or any copy of all written, printed, typed,
recorded, graphic or photographic matter or sound reproduction, including but not limited
to all correspondence, e-mail, files, books and records, ledgers, surveys, cancelled
checks, check stubs invoices, letters, telegrams, internal memoranda, reports, studies,
calendars, minutes, pamphlets, notes, charts, tabulations, legal documents, photographs,
videotapes, maps, accounting entries, records of meetings, records of telephone
conferences or other communications, tape recordings, microfilms, punch cards,
recordings used in date processing and computer tapes and discs together with the written
information necessary to understand and use such files and recordings, and all other data
compilations from which the information can be obtained.
2. The term “document(s)” is further defined to include all notes or notations on such
document(s) and all exhibits or attachments or other materials affixed thereto.
3. The term “all documents” means every document or group of documents as above
defined that are known to you or that can be located or discovered by reasonably diligent
efforts.
4. As used herein the singular shall include the plural, the plural shall include the singular,
and masculine, feminine and neuter shall include each of the other genders.
5. The term “and” includes “or” and vice versa. Moreover, the terms “and” and “or” shall
be construed conjunctively and disjunctively as necessary to make the request inclusive
rather than exclusive.
6. The term “communication” shall mean and refer to both written and oral exchanges
between or among any person or persons and/or entities, regardless of whether designated
confidential, privileged, or otherwise, including but not limited to conversations,
telephone calls, letters, notes, memoranda, reports, telegrams, confirmations, exhibits,
drawing, sketches and any other “document” or “thing” as earlier defined which
constitutes, confirms, embodies or otherwise relates to the communications.
7. As used herein, the term “person” or “persons” shall mean and refer to any individual,
corporation, partnership, proprietorship, joint venture, or any legal entity, as well as to
any and all officers, directors, agents, servants, employees, legal representatives, experts
and consultants of the entity, however denominated. In addition, the term “person” or
“persons” shall be deemed to include artificial persons, governments (or divisions,
departments, and agencies thereof), quasi-public entities, and all other forms of
organization or association.
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CASE NO. 2019-003916-CA-01
8. The terms “any,” “all,” “any and all,” “each,” “every,” and “each and every” are to be
construed as bringing within the scope of these Requests for Production all responses that
might otherwise be construed to be outside their scope.
9. The terms “relates to,” “related to,” and “relating to” mean having any connection,
association, or concern with, or any relevance, relation, pertinence, or applicability to, or
any implication for or bearing upon the subject of the inquiry.
10. The terms “MCC” or “Mid-Continent” mean Mid-Continent Casualty Company,
including agents, employees, independent contractors, attorneys, and all other persons
acting or purporting to act on its behalf.
11. The term "you" or "your" refers to Bentley Holdings, LLC ("Bentley") including agents,
attorneys, employees, and all other persons acting or purporting to act on the
Association's behalf.
12. The term "Project" refers to the 2010 construction project (including tile installation) at
the Kosta Seafood & More… restaurant located in the Vue at Brickell Condominium,
1250 South Miami Avenue, Miami, Florida.
13. The term "site" refers to the Kosta Seafood & More… restaurant located in the Vue at
Brickell Condominium, 1250 South Miami Avenue, Miami, Florida.
14. The term “Complaint” means the Complaint and Demand for Jury Trial filed by Receiver
against MCC in the Circuit Court for the Eleventh Judicial Circuit, Case No. 15-020355
CA 01.
15. The term "Perea Lawsuit" refers to the lawsuit styled, Manuel Perea vs. Flicker
Construction, Inc., Case No. 10-58780 CA 02, brought in the Circuit Court of the
Eleventh Judicial Circuit in and for Miami-Dade County, Florida.
16. The term "incident" refers to the event described in the Perea Lawsuit that allegedly
occurred on September 6, 2010, while Manuel Perea was walking through the site and a
spiral staircase used to access a loft fell on top of him causing injuries.
Designated Topics
1. Any facts or information known or reasonably available concerning the action styled:
John Hughes, III, as Receiver of Flicker Construction, Inc. v. Roman Flicker and Mid-
Continent Casualty Company, Miami Dade Case No. 2019-003916-CA-01.
2. The identity of persons and/or entities who leased property from Bentley Holdings, LLC
for the purpose of constructing a restaurant known as Kosta Seafood & More….at the
site, including the requirements of any lease agreement entered into between Bentley and
any tenant occupying the site.
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CASE NO. 2019-003916-CA-01
3. Knowledge of the work that Mr. Isaac Amsalem certified on the City of Miami Building
Department Permit Application for Permit Number 105002997, that Roman Flicker
and/or Flicker Construction, Inc. ("Flicker") had the authority to perform at 1250 South
Miami Avenue, Miami, Florida .
4. Knowledge of any agreements between any person or entity and Roman Flicker and/or
Flicker that in anyway relate to the work that Mr. Isaac Amsalem certified on the permit
application for City of Miami Building Permit Number 105002997, that Roman Flicker
and/or Flicker had the authority to perform.
5. Knowledge of the relationship between Bentley's lessee at the site and Roman Flicker
and/or Flicker, including any agreements for services in connection with the Project and
work to be performed at the Project.
6. The incident that occurred on September 6, 2010 at the site involving Manuel Perea.
Documents Requested
1. All documents relating to the Project, from the inception of your records through
the date the records are produced, including all manner and type of record however maintained in
your normal course of business, which may include, but should not be limited to, the following:
contracts, subcontracts, agreements, job logs, payroll logs, identity of employees, identity of
subcontractors, permits pulled, correspondence, memoranda, notes, inspection reports,
photographs, estimates, electronic communications, and any other type of document that is
related to the Project.
2. All documents, including contracts or agreements, for the work that Mr. Isaac
Amsalem certified on the City of Miami Building Department Permit Application for Permit
Number 105002997 that Flicker and/or Roman Flicker had the authority to perform at 1250
South Miami Avenue, Miami, Florida.
3. All certificates of insurance for Flicker, Roman Flicker, and any other contractor
or subcontractor that was involved in the work that Mr. Isaac Amsalem certified on the City of
Miami Building Department Permit Application for Permit Number 105002997 that Flicker
and/or Roman Flicker had the authority to perform.
4. All documents that identify the persons and/or entities that were commissioned by
or on behalf of Bentley and/or its lessee of the site as contractors, subcontractors, employees
and/or material-men for any goods or services related to the work that Mr. Isaac Amsalem
certified on the City of Miami Building Department Permit Application for Permit Number
105002997 that Flicker and/or Roman Flicker had the authority to perform.
5. All documents that discuss, mention, or any way describe the relationship
between Bentley and its lessee at the site and Bentley's lessee and Flicker and/or Roman Flicker,
or any other contractor or subcontractor on the project, in connection with the work that Mr.
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CASE NO. 2019-003916-CA-01
Isaac Amsalem certified on the City of Miami Building Department Permit Application for
Permit Number 105002997 that Flicker and/or Roman Flicker had the authority to perform.
6. All documents that discuss, mention, or in any way describe the work that Mr.
Isaac Amsalem certified on the City of Miami Building Department Permit Application for
Permit Number 105002997 that Flicker and/or Roman Flicker had the authority to perform, from
the date of inception through present, including the extent of participation of all of the
subcontractors at the project, including Manuel Perea.
7. Transcripts of any Statements made by you to any individual or entity related to
the incident involving Manuel Perea from the time of its occurrence through the present,
including any statements made to MCC and any testimony provided in the underlying action,
styled: Manuel Perea v. Flicker Construction, Inc., Circuit Court of the 11th Judicial Circuit in
and for Miami-Dade County, Case No. 10-58782-CA-01.
8. All documents exchanged between Century Wide Remodeling, Inc. ("Century"),
Kosta Seafood, Bentley, Roman Flicker, Flicker and Manuel Perea, or any combination thereof,
relating to the worth that Mr. Isaac Amsalem certified on the City of Miami Building Department
Permit Application for Permit Number 105002997 that Flicker and/or Roman Flicker had the
authority to perform, from the date of inception of the Project through the present, including
communications concerning insurance coverage and employment of Manuel Perea.
9. Any and all policies of insurance including, but not limited to, commercial
general liability, workers' compensation and excess and/or umbrella policies, issued to you or
any other person or entity for the purpose of insuring any risk at the Project and in effect on
September 6, 2010.
10. All documents evidencing and/or relating to any payments you made to Flicker,
Roman Flicker, and Manuel Perea during the period September 6, 2008 through September 6,
2011 including, but not limited to, cancelled checks, withholding statements, pay stubs, deposit
slips, W-2 statements, 1099 statements, W-9 statements, receipts and/or reimbursements, related
to the work that Mr. Isaac Amsalem certified on the City of Miami Building Department Permit
Application for Permit Number 105002997 that Flicker and/or Roman Flicker had the authority
to perform.
11. All documents evidencing and/or relating to any benefits you provided to, or
made available to Roman Flicker, Flicker and Manuel Perea during the September 6, 2008
through September 6, 2011 time period including, but not limited to, health, dental, vision,
disability, life and/or occupational insurance benefits, vacation time, comp time, sick time and/or
holiday time benefits, workers’ compensation and/or unemployment compensation benefits in
connection with the work that Mr. Isaac Amsalem certified on the City of Miami Building
Department Permit Application for Permit Number 105002997 that Flicker and/or Roman
Flicker had the authority to perform.
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CASE NO. 2019-003916-CA-01
12. All documents related to any work performed for you by Roman Flicker, Flicker,
and Manuel Perea at any time, including, but not limited to, daily logs, performance logs, and/or
any and all other job-related record keeping and/or reporting, specifically with regard to the work
that Mr. Isaac Amsalem certified on the City of Miami Building Department Permit Application
for Permit Number 105002997 that Flicker and/or Roman Flicker had the authority to perform.
13. Any form of employment records related to Manuel Perea for the period
September 6, 2008 through September 6, 2011 and Mr. Perea’s involvement with the work that
Mr. Isaac Amsalem certified on the City of Miami Building Department Permit Application for
Permit Number 105002997 that Flicker and/or Roman Flicker had the authority to perform.
14. Any and all written agreements between you and your tenant at the site, and any
and all written agreements between you and Roman Flicker and/or Flicker and/or Manuel Perea
for the work that Mr. Isaac Amsalem certified on the City of Miami Building Department Permit
Application for Permit Number 105002997 that Flicker and/or Roman Flicker had the authority
to perform.
15. All documents that relate to the scope of any work to be performed by Roman
Flicker, Flicker, and/or Manuel Perea for you or any other entity at the site during the period
September 6, 2008 through September 6, 2011.
16. All documents in your possession, custody or control pertaining to the Perea
Lawsuit, including, but limited to, any and all deposition transcripts, expert reports, medical
records, interrogatories, requests for admissions, pleadings, documents produced pursuant to any
subpoena or document production request, and/or any other documents of any kind pertaining to
the Perea Lawsuit.
27. All non-privileged correspondence sent by you and received by you related to the
Perea Lawsuit, including, but not limited to, electronic mail, documents transmitted via
facsimile, and documents sent or received via the U.S. postal service or any other means of
transmittal.
18. Your entire file pertaining to the lease of any property to CV-Ches, Corp. and/or
Kosta Seafood and/or any of their authorized representatives.
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Preview
Filing # 115584042 E-Filed 10/26/2020 11:33:29 AM IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CIVIL DIVISION JOHN HUGHES, III, as receiver of Flicker Construction, Inc., an inactive Florida CASE NO. 2019-003916-CA-01 corporation, Plaintiff, vs. ROMAN FLICKER and MID-CONTINENT CASUALTY COMPANY, Defendants. / RE-NOTICE OF TAKING DEPOSITION DUCES TECUM Defendant, Mid-Continent Casualty Company, through undersigned counsel, will take the deposition duces tecum of the individual listed below and on the date and time specified below and you are to bring with you all documents listed on Schedule "A" attached to this Notice of Taking Deposition and to the Subpoena Duces Tecum served on October 7, 2020. Deponent Date & Time Place Isaac Amsalem 3201 Northeast 183rd Street November 13, 2020 Via Zoom* Aventura, FL 33160 @ 10:00 a.m. *Zoom link: https://veritext.zoom.us/j/92994542647?pwd=anB0YkxXZ3ZkcGIxdGRWVWNNcFlQdz09 Meeting ID: 92994542647 Password: y9cOw71inv Dial by your location: +1 8884754499 US Meeting ID: 92994542647 Password: 8909513160 0979020\306868853.v1 CASE NO. 2019-003916-CA-01 upon oral examination before Veritext Court Reporters or Notary Public in and for the State of Florida, or some other officer duly authorized by law to take depositions in the state. The deposition will continue from day to day until completed. The deposition is being taken for the purpose of discovery, for use at trial, or both of the foregoing, or for such other purposes as are permitted under the applicable and governing rules. See attached Schedule A for details. Respectfully submitted, HINSHAW & CULBERTSON, LLP /s/ Alina N. Yaniz Edward T. Sylvester Florida Bar No. 0051612 esylvester@hinshawlaw.com Alina N. Yaniz Florida Bar No. 1003560 ayaniz@hinshawlaw.com 2525 Ponce de Leon Boulevard, 4th Floor Coral Gables, Florida 33134 Telephone: 305-358-7747 Facsimile: 305-577-1063 Attorneys for Mid Continent Casualty Company CERTIFICATE OF SERVICE I HEREBY CERTIFY that on October 26, 2020, a true and correct copy of the foregoing has been filed via the E-Filing System and served on all counsel of record. HINSHAW & CULBERTSON, LLP /s/ Alina N. Yaniz Page 2 of 7 0979020\306868853.v1 CASE NO. 2019-003916-CA-01 Schedule A Isaac Amsalem Bentley Holdings References: 1. “Document(s)” means the original, duplicate or any copy of all written, printed, typed, recorded, graphic or photographic matter or sound reproduction, including but not limited to all correspondence, e-mail, files, books and records, ledgers, surveys, cancelled checks, check stubs invoices, letters, telegrams, internal memoranda, reports, studies, calendars, minutes, pamphlets, notes, charts, tabulations, legal documents, photographs, videotapes, maps, accounting entries, records of meetings, records of telephone conferences or other communications, tape recordings, microfilms, punch cards, recordings used in date processing and computer tapes and discs together with the written information necessary to understand and use such files and recordings, and all other data compilations from which the information can be obtained. 2. The term “document(s)” is further defined to include all notes or notations on such document(s) and all exhibits or attachments or other materials affixed thereto. 3. The term “all documents” means every document or group of documents as above defined that are known to you or that can be located or discovered by reasonably diligent efforts. 4. As used herein the singular shall include the plural, the plural shall include the singular, and masculine, feminine and neuter shall include each of the other genders. 5. The term “and” includes “or” and vice versa. Moreover, the terms “and” and “or” shall be construed conjunctively and disjunctively as necessary to make the request inclusive rather than exclusive. 6. The term “communication” shall mean and refer to both written and oral exchanges between or among any person or persons and/or entities, regardless of whether designated confidential, privileged, or otherwise, including but not limited to conversations, telephone calls, letters, notes, memoranda, reports, telegrams, confirmations, exhibits, drawing, sketches and any other “document” or “thing” as earlier defined which constitutes, confirms, embodies or otherwise relates to the communications. 7. As used herein, the term “person” or “persons” shall mean and refer to any individual, corporation, partnership, proprietorship, joint venture, or any legal entity, as well as to any and all officers, directors, agents, servants, employees, legal representatives, experts and consultants of the entity, however denominated. In addition, the term “person” or “persons” shall be deemed to include artificial persons, governments (or divisions, departments, and agencies thereof), quasi-public entities, and all other forms of organization or association. Page 3 of 7 0979020\306868853.v1 CASE NO. 2019-003916-CA-01 8. The terms “any,” “all,” “any and all,” “each,” “every,” and “each and every” are to be construed as bringing within the scope of these Requests for Production all responses that might otherwise be construed to be outside their scope. 9. The terms “relates to,” “related to,” and “relating to” mean having any connection, association, or concern with, or any relevance, relation, pertinence, or applicability to, or any implication for or bearing upon the subject of the inquiry. 10. The terms “MCC” or “Mid-Continent” mean Mid-Continent Casualty Company, including agents, employees, independent contractors, attorneys, and all other persons acting or purporting to act on its behalf. 11. The term "you" or "your" refers to Bentley Holdings, LLC ("Bentley") including agents, attorneys, employees, and all other persons acting or purporting to act on the Association's behalf. 12. The term "Project" refers to the 2010 construction project (including tile installation) at the Kosta Seafood & More… restaurant located in the Vue at Brickell Condominium, 1250 South Miami Avenue, Miami, Florida. 13. The term "site" refers to the Kosta Seafood & More… restaurant located in the Vue at Brickell Condominium, 1250 South Miami Avenue, Miami, Florida. 14. The term “Complaint” means the Complaint and Demand for Jury Trial filed by Receiver against MCC in the Circuit Court for the Eleventh Judicial Circuit, Case No. 15-020355 CA 01. 15. The term "Perea Lawsuit" refers to the lawsuit styled, Manuel Perea vs. Flicker Construction, Inc., Case No. 10-58780 CA 02, brought in the Circuit Court of the Eleventh Judicial Circuit in and for Miami-Dade County, Florida. 16. The term "incident" refers to the event described in the Perea Lawsuit that allegedly occurred on September 6, 2010, while Manuel Perea was walking through the site and a spiral staircase used to access a loft fell on top of him causing injuries. Designated Topics 1. Any facts or information known or reasonably available concerning the action styled: John Hughes, III, as Receiver of Flicker Construction, Inc. v. Roman Flicker and Mid- Continent Casualty Company, Miami Dade Case No. 2019-003916-CA-01. 2. The identity of persons and/or entities who leased property from Bentley Holdings, LLC for the purpose of constructing a restaurant known as Kosta Seafood & More….at the site, including the requirements of any lease agreement entered into between Bentley and any tenant occupying the site. Page 4 of 7 0979020\306868853.v1 CASE NO. 2019-003916-CA-01 3. Knowledge of the work that Mr. Isaac Amsalem certified on the City of Miami Building Department Permit Application for Permit Number 105002997, that Roman Flicker and/or Flicker Construction, Inc. ("Flicker") had the authority to perform at 1250 South Miami Avenue, Miami, Florida . 4. Knowledge of any agreements between any person or entity and Roman Flicker and/or Flicker that in anyway relate to the work that Mr. Isaac Amsalem certified on the permit application for City of Miami Building Permit Number 105002997, that Roman Flicker and/or Flicker had the authority to perform. 5. Knowledge of the relationship between Bentley's lessee at the site and Roman Flicker and/or Flicker, including any agreements for services in connection with the Project and work to be performed at the Project. 6. The incident that occurred on September 6, 2010 at the site involving Manuel Perea. Documents Requested 1. All documents relating to the Project, from the inception of your records through the date the records are produced, including all manner and type of record however maintained in your normal course of business, which may include, but should not be limited to, the following: contracts, subcontracts, agreements, job logs, payroll logs, identity of employees, identity of subcontractors, permits pulled, correspondence, memoranda, notes, inspection reports, photographs, estimates, electronic communications, and any other type of document that is related to the Project. 2. All documents, including contracts or agreements, for the work that Mr. Isaac Amsalem certified on the City of Miami Building Department Permit Application for Permit Number 105002997 that Flicker and/or Roman Flicker had the authority to perform at 1250 South Miami Avenue, Miami, Florida. 3. All certificates of insurance for Flicker, Roman Flicker, and any other contractor or subcontractor that was involved in the work that Mr. Isaac Amsalem certified on the City of Miami Building Department Permit Application for Permit Number 105002997 that Flicker and/or Roman Flicker had the authority to perform. 4. All documents that identify the persons and/or entities that were commissioned by or on behalf of Bentley and/or its lessee of the site as contractors, subcontractors, employees and/or material-men for any goods or services related to the work that Mr. Isaac Amsalem certified on the City of Miami Building Department Permit Application for Permit Number 105002997 that Flicker and/or Roman Flicker had the authority to perform. 5. All documents that discuss, mention, or any way describe the relationship between Bentley and its lessee at the site and Bentley's lessee and Flicker and/or Roman Flicker, or any other contractor or subcontractor on the project, in connection with the work that Mr. Page 5 of 7 0979020\306868853.v1 CASE NO. 2019-003916-CA-01 Isaac Amsalem certified on the City of Miami Building Department Permit Application for Permit Number 105002997 that Flicker and/or Roman Flicker had the authority to perform. 6. All documents that discuss, mention, or in any way describe the work that Mr. Isaac Amsalem certified on the City of Miami Building Department Permit Application for Permit Number 105002997 that Flicker and/or Roman Flicker had the authority to perform, from the date of inception through present, including the extent of participation of all of the subcontractors at the project, including Manuel Perea. 7. Transcripts of any Statements made by you to any individual or entity related to the incident involving Manuel Perea from the time of its occurrence through the present, including any statements made to MCC and any testimony provided in the underlying action, styled: Manuel Perea v. Flicker Construction, Inc., Circuit Court of the 11th Judicial Circuit in and for Miami-Dade County, Case No. 10-58782-CA-01. 8. All documents exchanged between Century Wide Remodeling, Inc. ("Century"), Kosta Seafood, Bentley, Roman Flicker, Flicker and Manuel Perea, or any combination thereof, relating to the worth that Mr. Isaac Amsalem certified on the City of Miami Building Department Permit Application for Permit Number 105002997 that Flicker and/or Roman Flicker had the authority to perform, from the date of inception of the Project through the present, including communications concerning insurance coverage and employment of Manuel Perea. 9. Any and all policies of insurance including, but not limited to, commercial general liability, workers' compensation and excess and/or umbrella policies, issued to you or any other person or entity for the purpose of insuring any risk at the Project and in effect on September 6, 2010. 10. All documents evidencing and/or relating to any payments you made to Flicker, Roman Flicker, and Manuel Perea during the period September 6, 2008 through September 6, 2011 including, but not limited to, cancelled checks, withholding statements, pay stubs, deposit slips, W-2 statements, 1099 statements, W-9 statements, receipts and/or reimbursements, related to the work that Mr. Isaac Amsalem certified on the City of Miami Building Department Permit Application for Permit Number 105002997 that Flicker and/or Roman Flicker had the authority to perform. 11. All documents evidencing and/or relating to any benefits you provided to, or made available to Roman Flicker, Flicker and Manuel Perea during the September 6, 2008 through September 6, 2011 time period including, but not limited to, health, dental, vision, disability, life and/or occupational insurance benefits, vacation time, comp time, sick time and/or holiday time benefits, workers’ compensation and/or unemployment compensation benefits in connection with the work that Mr. Isaac Amsalem certified on the City of Miami Building Department Permit Application for Permit Number 105002997 that Flicker and/or Roman Flicker had the authority to perform. Page 6 of 7 0979020\306868853.v1 CASE NO. 2019-003916-CA-01 12. All documents related to any work performed for you by Roman Flicker, Flicker, and Manuel Perea at any time, including, but not limited to, daily logs, performance logs, and/or any and all other job-related record keeping and/or reporting, specifically with regard to the work that Mr. Isaac Amsalem certified on the City of Miami Building Department Permit Application for Permit Number 105002997 that Flicker and/or Roman Flicker had the authority to perform. 13. Any form of employment records related to Manuel Perea for the period September 6, 2008 through September 6, 2011 and Mr. Perea’s involvement with the work that Mr. Isaac Amsalem certified on the City of Miami Building Department Permit Application for Permit Number 105002997 that Flicker and/or Roman Flicker had the authority to perform. 14. Any and all written agreements between you and your tenant at the site, and any and all written agreements between you and Roman Flicker and/or Flicker and/or Manuel Perea for the work that Mr. Isaac Amsalem certified on the City of Miami Building Department Permit Application for Permit Number 105002997 that Flicker and/or Roman Flicker had the authority to perform. 15. All documents that relate to the scope of any work to be performed by Roman Flicker, Flicker, and/or Manuel Perea for you or any other entity at the site during the period September 6, 2008 through September 6, 2011. 16. All documents in your possession, custody or control pertaining to the Perea Lawsuit, including, but limited to, any and all deposition transcripts, expert reports, medical records, interrogatories, requests for admissions, pleadings, documents produced pursuant to any subpoena or document production request, and/or any other documents of any kind pertaining to the Perea Lawsuit. 27. All non-privileged correspondence sent by you and received by you related to the Perea Lawsuit, including, but not limited to, electronic mail, documents transmitted via facsimile, and documents sent or received via the U.S. postal service or any other means of transmittal. 18. Your entire file pertaining to the lease of any property to CV-Ches, Corp. and/or Kosta Seafood and/or any of their authorized representatives. Page 7 of 7 0979020\306868853.v1