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Filing # 23756976 E-Filed 02/13/2015 02:53:06 PM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR COLLIER COUNTY, FLORIDA
JAMES ELSON,
Plaintiff,
vs. : CASE NO. 2013-CA-003346
RESTAURANT 460-5 SOUTH,
LLC, A Florida Corporation,
Defendant.
NOTICE OF INTENT TO SERVE 32 PARTY SUBPOENA FOR RECORDS
PURSUANT TO RULE 1.351, FLORIDA RULES OF CIVIL PROCEDURE
YOU ARE HEREBY NOTIFIED that fifteen (15) days after the date of this Notice,
if served by mail, or ten (10) days after this Notice, if delivered, Plaintiff JAMES ELSON
will serve a Subpoena Duces Tecum Without Deposition on the following entity for the
production of documents or things at the time, place and method designated in the
attached Subpoena Duces Tecum directed to:
Ambiance Audio Design & Security, Inc.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished on this_]#__ day of February, 2015, by e-service as follows:
napertpleadings@wickersmith.com, Craig Ferrante, Esquire, Wicker Smith O'Hara
McCoy & Ford, PA, 9128 Strada Place, Naples, FL 34108.
HANCOCK LAW,
. Hancock, FBN: 0017317
Primary: eservice@hancocklawpa. com
12687 SW CR 7698, Suite 2A
Lake Suzy, FL 34269
T: (941) 979-5226 F: (941) 979-5229
Attorney for Plaintiff James Elson
Filed with Collier County Clerk of CourtsIN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR COLLIER COUNTY, FLORIDA
JAMES ELSON,
Plaintiff,
vs. CASE NO. 2013-CA-003346
RESTAURANT 460-5T SOUTH,
LLC, A Florida Corporation,
Defendant.
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
(*Mail-Ins only*)
TO: Records Custodian
Ambiance Audio Design & Security, Inc.
1975 Frederick St.
Naples, FL 34112
YOU ARE HEREBY COMMANDED to appear in person with the requested
materials at 9:00 a.m. EST, or in the alternative, mail the requested materials to Hancock
Law, PA, 12687 SW CR 769, Suite 2A, Lake Suzy, FL 34269, on or before ten (10)
days of the receipt of this subpoena the following:
Your entire record, cover to cover, including but not limited to, all Requests for
Proposal, proposals, bids, invoices, orders, statements, logs, service contracts, and
installation contracts, regardless of date or format, and copies of all video or audio
recordings captured on March 13, 2009, pertaining to Restaurant 460-5" South, LLC,
d/b/a Osteria Tulia Restaurant.
You are not required to surrender the original items. If you appear in person with
the original materials, the same will be inspected and or photocopied in your presence.
You may also comply with this subpoena by producing legible copies of the items to be
produced to the attorney whose name appears on this subpoena on or before the
scheduled date of production. You may condition the preparation of copies upon the
payment in advance of the reasonable cost of preparation. You may mail or deliver the
copies to the attorney whose name appears on this subpoena and thereby
eliminate the requirement to appear in person with the requested records. If the
cost for copies exceeds $50.00, please contact the attorney for advance approval.
You have the right to object to the production pursuant to this subpoena at any time before
production by giving written notice to the attorney whose name appears on this subpoena.If you fail to:
1) appear as specified; or
2) furnish records instead of appearing as provided above, or
3) object to this subpoena,
You may be in contempt of court. You are subpoenaed by the attorneys whose names
appear on this subpoena and unless excused from this subpoena by the attorneys or the
Court, you shall respond to this subpoena as directed.
DATED ON
HANCOCK LAW, PA
Kenneth A. Hancock, Esq. FBN 0017317
eservice@hancocklawpa.com
12687 SW CR 769, Suite 2A
Lake Suzy, FL 34269
T: (941) 979-5226 F: (941) 979-5229
Attorney for Plaintiff James Elson
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Filing # 23756976 E-Filed 02/13/2015 02:53:06 PM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA JAMES ELSON, Plaintiff, vs. : CASE NO. 2013-CA-003346 RESTAURANT 460-5 SOUTH, LLC, A Florida Corporation, Defendant. NOTICE OF INTENT TO SERVE 32 PARTY SUBPOENA FOR RECORDS PURSUANT TO RULE 1.351, FLORIDA RULES OF CIVIL PROCEDURE YOU ARE HEREBY NOTIFIED that fifteen (15) days after the date of this Notice, if served by mail, or ten (10) days after this Notice, if delivered, Plaintiff JAMES ELSON will serve a Subpoena Duces Tecum Without Deposition on the following entity for the production of documents or things at the time, place and method designated in the attached Subpoena Duces Tecum directed to: Ambiance Audio Design & Security, Inc. CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished on this_]#__ day of February, 2015, by e-service as follows: napertpleadings@wickersmith.com, Craig Ferrante, Esquire, Wicker Smith O'Hara McCoy & Ford, PA, 9128 Strada Place, Naples, FL 34108. HANCOCK LAW, . Hancock, FBN: 0017317 Primary: eservice@hancocklawpa. com 12687 SW CR 7698, Suite 2A Lake Suzy, FL 34269 T: (941) 979-5226 F: (941) 979-5229 Attorney for Plaintiff James Elson Filed with Collier County Clerk of CourtsIN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA JAMES ELSON, Plaintiff, vs. CASE NO. 2013-CA-003346 RESTAURANT 460-5T SOUTH, LLC, A Florida Corporation, Defendant. SUBPOENA DUCES TECUM WITHOUT DEPOSITION (*Mail-Ins only*) TO: Records Custodian Ambiance Audio Design & Security, Inc. 1975 Frederick St. Naples, FL 34112 YOU ARE HEREBY COMMANDED to appear in person with the requested materials at 9:00 a.m. EST, or in the alternative, mail the requested materials to Hancock Law, PA, 12687 SW CR 769, Suite 2A, Lake Suzy, FL 34269, on or before ten (10) days of the receipt of this subpoena the following: Your entire record, cover to cover, including but not limited to, all Requests for Proposal, proposals, bids, invoices, orders, statements, logs, service contracts, and installation contracts, regardless of date or format, and copies of all video or audio recordings captured on March 13, 2009, pertaining to Restaurant 460-5" South, LLC, d/b/a Osteria Tulia Restaurant. You are not required to surrender the original items. If you appear in person with the original materials, the same will be inspected and or photocopied in your presence. You may also comply with this subpoena by producing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate the requirement to appear in person with the requested records. If the cost for copies exceeds $50.00, please contact the attorney for advance approval. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena.If you fail to: 1) appear as specified; or 2) furnish records instead of appearing as provided above, or 3) object to this subpoena, You may be in contempt of court. You are subpoenaed by the attorneys whose names appear on this subpoena and unless excused from this subpoena by the attorneys or the Court, you shall respond to this subpoena as directed. DATED ON HANCOCK LAW, PA Kenneth A. Hancock, Esq. FBN 0017317 eservice@hancocklawpa.com 12687 SW CR 769, Suite 2A Lake Suzy, FL 34269 T: (941) 979-5226 F: (941) 979-5229 Attorney for Plaintiff James Elson