On December 28, 2020 a
Motion,Ex Parte
was filed
involving a dispute between
Sun City Center West Master Association, Inc.,
and
Federation Of Kings Point Associations, Inc.,
Firstservice Residential Florida, Inc.,
for Civil
in the District Court of Hillsborough County.
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Filing # 131962268 E-Filed 08/03/2021 04:12:39 PM
IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR H1LLSBOROUGH COUNTY, FLORIDA
CIVIL DIVISION
SUN CITY CENTER WEST MASTER
ASSOCIATION, INC.,
Plaintiff/Counter-Defendant, Case No.: 20-CA-10043
vs. Division: A
FIRSTSERVICE RESIDENTIAL FLORIDA,
INC., and FEDERATION OF KINGS POINT
ASSOCIATIONS, INC.,
Defendants/Counter-Plaintiff.
/
MOTION FOR RULING Qn FEDERATIO_N'S OBJECTIONS TO N_OTICES_OF
PRODUCTION F_OR NON-PARTY
COMES NOW the Plaintiff, SUN CITY CENTER WEST MASTER ASSOCIATION,
INC. ("Master"), by and through its undersigned attorney, and files this, its Motion for Ruling on
the objections filed by the Defendant, FEDERATION OF KINGS POINT ASSOCIATIONS, INC.
("Federation"), to the Notices of Production for Non-Party that are proposed to be served upon the
non-parties Delphine Duerr, Lawrence Williams, and Darlene Glass as grounds therefore and
states as follows :
1. A Notice for Production of Non-Party was filed with the Court on or about July 21 ,
2021. The proposed subpoenas accompanied the Notices of Production.
2. Federation has objected to the subpoenas. The obj ections are not well founded.
WHEREFORE, the Plaintiff, Master, respectfully requests this Honorable Court for the
entry of an Order overruling the objections filed by the Defendant, Federation of Kings Point
Associations, Inc.
Page l of 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a the and correct copy of the foregoing has been furnished, by
electronic mail upon any registered participant who uses the Florida Courts E-Filing Portal in
conj unction with the instant cause of action in accordance with rule 2.516, Florida Rules of Judicial
Administration on this 3rd day of August, 2021 .
FRISCIA & ROSS, P.A.
Is/Francis E. Friscia
Francis E. Friscia, Esquire
5550 W. Executive Drive, Suite 250
Tampa, Florida 33609
T: 813.286.0888 /F: 813.286.0111
Primary: ffriscia@frpalega1.com
Secondary: os1ade@1811ea1.con3
Florida Bar #601380/SPN #0084509
John J. Cavaliere, III, Esquire
Florida Bar #112869
Primary: jcavaliere@flrpalegaLcom
Attorneys for Plaintiff,
SUN CITY CENTER WEST
MASTER ASSOCIATION, INC.
Page 2 of 2
Document Filed Date
August 03, 2021
Case Filing Date
December 28, 2020
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Filing # 131962268 E-Filed 08/03/2021 04:12:39 PM IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR H1LLSBOROUGH COUNTY, FLORIDA CIVIL DIVISION SUN CITY CENTER WEST MASTER ASSOCIATION, INC., Plaintiff/Counter-Defendant, Case No.: 20-CA-10043 vs. Division: A FIRSTSERVICE RESIDENTIAL FLORIDA, INC., and FEDERATION OF KINGS POINT ASSOCIATIONS, INC., Defendants/Counter-Plaintiff. / MOTION FOR RULING Qn FEDERATIO_N'S OBJECTIONS TO N_OTICES_OF PRODUCTION F_OR NON-PARTY COMES NOW the Plaintiff, SUN CITY CENTER WEST MASTER ASSOCIATION, INC. ("Master"), by and through its undersigned attorney, and files this, its Motion for Ruling on the objections filed by the Defendant, FEDERATION OF KINGS POINT ASSOCIATIONS, INC. ("Federation"), to the Notices of Production for Non-Party that are proposed to be served upon the non-parties Delphine Duerr, Lawrence Williams, and Darlene Glass as grounds therefore and states as follows : 1. A Notice for Production of Non-Party was filed with the Court on or about July 21 , 2021. The proposed subpoenas accompanied the Notices of Production. 2. Federation has objected to the subpoenas. The obj ections are not well founded. WHEREFORE, the Plaintiff, Master, respectfully requests this Honorable Court for the entry of an Order overruling the objections filed by the Defendant, Federation of Kings Point Associations, Inc. Page l of 2 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a the and correct copy of the foregoing has been furnished, by electronic mail upon any registered participant who uses the Florida Courts E-Filing Portal in conj unction with the instant cause of action in accordance with rule 2.516, Florida Rules of Judicial Administration on this 3rd day of August, 2021 . FRISCIA & ROSS, P.A. Is/Francis E. Friscia Francis E. Friscia, Esquire 5550 W. Executive Drive, Suite 250 Tampa, Florida 33609 T: 813.286.0888 /F: 813.286.0111 Primary: ffriscia@frpalega1.com Secondary: os1ade@1811ea1.con3 Florida Bar #601380/SPN #0084509 John J. Cavaliere, III, Esquire Florida Bar #112869 Primary: jcavaliere@flrpalegaLcom Attorneys for Plaintiff, SUN CITY CENTER WEST MASTER ASSOCIATION, INC. Page 2 of 2