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IN THE CIRCUIT COURT FOR THE TWELFTH JUDICIAL CIRCUIT
IN AND FOR SARASOTA COUNTY, FLORIDA
CIVIL DIVISION
TIBAR, LLC, TERESA BASNIGHT, and
MICHAEL A. BASNIGHT,
Plaintiff,
Case No. 2008 CA 18070
Vv
WILLIAMS, PARKER, HARRISON, DIETZ &
GETZEN, P.A., JOHN MOORE, and TERRI
COSTA,
Defendants.
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SUBPOENA DUCES TECUM FOR DEPOSITION
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THE STATE OF FLORIDA: —yi*
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TO: Corporate Representative of Optimal Outcomes, LLC c=
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By Serving its Registered Agent:
CT Corporation Systems
1200 South Pine Island Road
Plantation, FL 33324
Optimal Outcomes, LLC shal! designate the following person or persons to testify:
Patrick Marston or the person or persons with the most knowledge concerning: (1) the
potential purchase of the property located at 1287 US 41 Bypass South, Venice, FL
34285; (2) the documents requested on Exhibit A attached hereto; and (3) the person or
persons responsible for the records requested on Exhibit A attached hereto.
YOU ARE COMMANDED to appear before a erson authorized by law to take
depositions at Plaza Suites, 111 Second Avenue N.E., 9!
f Floor, St. Petersburg, FL 33701
(scheduled through Esquire Deposition Solutions at 813-221-2535), on August 23, 2010 at 1:00
p.m., for the taking of your deposition in this action and to have with you at that time and place
the following:
See Exhibit A attached hereto.
If you fail to appear, you may be in contempt of Court.
(iyi‘
PD.4085987.1
You are subpoenaed to appear by the following attorney and, unless excused from this
Subpoena by this attorney or the Court, you shall respond to this Subpoena as directed.
DATED: ¥[4lia
FOR THE COURT:
Jessica Kirkwood Alley 177059
PHELPS DUNBAR LLP
100 South Ashley Drive ¢ Suite 1900
Tampa, Florida 33602-5311
(813) 472-7550
(813) 472-7570 (FAX)
ingram|](@phelps.com
alleyj@phelps.com
Counsel for Williams, Parker, Harrison,
Dietz and Getzen, P.A.
-2-
PD.4085987.}
—_ —
Exhibit A
] All documents relating to Optimal Outcomes, LLC’s (“Optimal”) potential purchase
of the property located at 1287 US 41 Bypass South, Venice, FL 34285 (the “Property”) from
January 1, 2006 through December 31, 2006.
2 All documents relating to Optimal’s requirement, request, or desire to obtain personal
guarantees of the Heart and Vascular Center of Venice, P.A.’s (“HVCV”) lease associated with
the Property.
3 All documents relating to communications between Optimal, Patrick Marston, or any
other representative of Optimal and HVCV, Audrey Gow, Tom Dart, or any other representative
of HVCV or HVC Ventures, LLC regarding Optimal’s requirement, request, or desire to obtain
personal guarantees of the HVCV’s lease associated with the Property.
.3-
PD.4085987.1
RETURN OF SERVICE
State of Florida County of Sarasota Circuit Court
Case Number: 2008 CA 18070 Court Date: 8/23/2010 1:00 pm
Plaintiff:
TIBAR, LLC, TERESA BASNIGHT, and MICHAEL A. BASNIGHT
VS.
Defendant:
WILLIAMS , PARKER, HARRISON, DIETZ & GETZEN, P.A., JOHN MOORE,
and TERRI COSTA
For:
Lawrence P. Ingram, Esq.
Phelps Dunbar LLP
100 South Ashely Drive
Suite 1900
Tampa, FL 33602
Received by Florida Litigation Support Services, Inc on the 5th day of August, 2010 at 9:30 am to be served on Corporate
Representative of Optimal Outcomes, LLC, by serving its Registered Agent: CT Corporation Systems, 1200 South
Pine Island Road, Plantation, FL 33324.
|, Eric Deal, do hereby affirm that on the 5th day of August, 2010 at 10:40 am, I:
served the within corporation by delivering a true copy of the Subpoena Duces Tecum for Deposition on CT CORP
SYSTEMS as Registered Agent, of the within named corporation, at 1200 South Pine Island Road, Plantation, FL 33324,
pursuant to F.S. 48.081(3).
Additional Information pertaining to this Service:
Subpoena date is 8/23/2010 @ 1 pm
For contact, Donna Moch, Section Head Process for CT CORP.
Description of Person Served: Age: 40, Sex: F, Race/Skin Color: white, Height: 5'6", Weight: 140, Hair: brown, Glasses:
N
| certify that | am over the age of 18, have no interest in the above action, and am a Special Process Server, in good
standing, in the judicial circuit in which the process was served.
Under Penalties of Perjury, | declare | have read the foregoing document and the facts stated in it are true. NO NOTARY
REQUIRED PURSUANT TO F.S. 92.525(2)
_oa
E ric Deal
SPS 336
Florida Litigation Support Services, Inc
1901 West Cass Street
Tampa, FL 33606
(800) 747-9811
Our Job Serial Number: MJD-2010018852
Copyright © 1992-2010 Database Services, Inc. - Process Server's Toolbox V6.4e
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IN THE CIRCUIT COURT FOR THE TWELFTH JUDICIAL CIRCUIT IN AND FOR SARASOTA COUNTY, FLORIDA CIVIL DIVISION TIBAR, LLC, TERESA BASNIGHT, and MICHAEL A. BASNIGHT, Plaintiff, Case No. 2008 CA 18070 Vv WILLIAMS, PARKER, HARRISON, DIETZ & GETZEN, P.A., JOHN MOORE, and TERRI COSTA, Defendants. / a, = reo co? cr = Sat TS SUBPOENA DUCES TECUM FOR DEPOSITION wee —— Go cO C2 J “TI THE STATE OF FLORIDA: —yi* “——s Vy — Ne ae © 4 oD 5 Cc TO: Corporate Representative of Optimal Outcomes, LLC c= 3 By Serving its Registered Agent: CT Corporation Systems 1200 South Pine Island Road Plantation, FL 33324 Optimal Outcomes, LLC shal! designate the following person or persons to testify: Patrick Marston or the person or persons with the most knowledge concerning: (1) the potential purchase of the property located at 1287 US 41 Bypass South, Venice, FL 34285; (2) the documents requested on Exhibit A attached hereto; and (3) the person or persons responsible for the records requested on Exhibit A attached hereto. YOU ARE COMMANDED to appear before a erson authorized by law to take depositions at Plaza Suites, 111 Second Avenue N.E., 9! f Floor, St. Petersburg, FL 33701 (scheduled through Esquire Deposition Solutions at 813-221-2535), on August 23, 2010 at 1:00 p.m., for the taking of your deposition in this action and to have with you at that time and place the following: See Exhibit A attached hereto. If you fail to appear, you may be in contempt of Court. (iyi‘ PD.4085987.1 You are subpoenaed to appear by the following attorney and, unless excused from this Subpoena by this attorney or the Court, you shall respond to this Subpoena as directed. DATED: ¥[4lia FOR THE COURT: Jessica Kirkwood Alley 177059 PHELPS DUNBAR LLP 100 South Ashley Drive ¢ Suite 1900 Tampa, Florida 33602-5311 (813) 472-7550 (813) 472-7570 (FAX) ingram|](@phelps.com alleyj@phelps.com Counsel for Williams, Parker, Harrison, Dietz and Getzen, P.A. -2- PD.4085987.} —_ — Exhibit A ] All documents relating to Optimal Outcomes, LLC’s (“Optimal”) potential purchase of the property located at 1287 US 41 Bypass South, Venice, FL 34285 (the “Property”) from January 1, 2006 through December 31, 2006. 2 All documents relating to Optimal’s requirement, request, or desire to obtain personal guarantees of the Heart and Vascular Center of Venice, P.A.’s (“HVCV”) lease associated with the Property. 3 All documents relating to communications between Optimal, Patrick Marston, or any other representative of Optimal and HVCV, Audrey Gow, Tom Dart, or any other representative of HVCV or HVC Ventures, LLC regarding Optimal’s requirement, request, or desire to obtain personal guarantees of the HVCV’s lease associated with the Property. .3- PD.4085987.1 RETURN OF SERVICE State of Florida County of Sarasota Circuit Court Case Number: 2008 CA 18070 Court Date: 8/23/2010 1:00 pm Plaintiff: TIBAR, LLC, TERESA BASNIGHT, and MICHAEL A. BASNIGHT VS. Defendant: WILLIAMS , PARKER, HARRISON, DIETZ & GETZEN, P.A., JOHN MOORE, and TERRI COSTA For: Lawrence P. Ingram, Esq. Phelps Dunbar LLP 100 South Ashely Drive Suite 1900 Tampa, FL 33602 Received by Florida Litigation Support Services, Inc on the 5th day of August, 2010 at 9:30 am to be served on Corporate Representative of Optimal Outcomes, LLC, by serving its Registered Agent: CT Corporation Systems, 1200 South Pine Island Road, Plantation, FL 33324. |, Eric Deal, do hereby affirm that on the 5th day of August, 2010 at 10:40 am, I: served the within corporation by delivering a true copy of the Subpoena Duces Tecum for Deposition on CT CORP SYSTEMS as Registered Agent, of the within named corporation, at 1200 South Pine Island Road, Plantation, FL 33324, pursuant to F.S. 48.081(3). Additional Information pertaining to this Service: Subpoena date is 8/23/2010 @ 1 pm For contact, Donna Moch, Section Head Process for CT CORP. Description of Person Served: Age: 40, Sex: F, Race/Skin Color: white, Height: 5'6", Weight: 140, Hair: brown, Glasses: N | certify that | am over the age of 18, have no interest in the above action, and am a Special Process Server, in good standing, in the judicial circuit in which the process was served. Under Penalties of Perjury, | declare | have read the foregoing document and the facts stated in it are true. NO NOTARY REQUIRED PURSUANT TO F.S. 92.525(2) _oa E ric Deal SPS 336 Florida Litigation Support Services, Inc 1901 West Cass Street Tampa, FL 33606 (800) 747-9811 Our Job Serial Number: MJD-2010018852 Copyright © 1992-2010 Database Services, Inc. - Process Server's Toolbox V6.4e