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Filing # 179354595 E-Filed 08/10/2023 11:32:19 AM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL ACTION
KSD PARTNERS, LLC, an Ohio
limited liability company,
Plaintiff,
VS. CASE NO. 2023-002230-CA
PUNTA GORDA HEALTH
INVESTORS, LLC, a Florida limited
liability company and FILEMAN LAW
FIRM, P.A., a Florida corporation, as
escrow agent,
Defendants.
/
DEFENDANT’S FIRST REQUEST TO PRODUCE
Defendant, PUNTA GORDA HEALTH INVESTORS, LLC, requests, pursuant to
Fla. R. Civ. P. 1.350 that Plaintiff, KSD PARTNERS, LLC, produce the things enumerated
herein for inspection and copying at Goldman, Tiseo & Sturges, P.A.,701 JC Center
Court, Suite 3, Port Charlotte, FL 33954 within 30 days of the date of the Certificate of
Service.
I.__Definitions
1 “Document”? means any documents in your custody, possession or control,
including, but not limited to, any printed, written, recorded, taped, electronic, graphic, or other
tangible matter from whatever source, however produced or reproduced, whether in draft or
otherwise, whether sent or received or neither, including the original, all amendments and
addenda and any non-identical copy (whether different from the original because of notes made
on or attached to such copy or otherwise) of any and all writing, correspondence, letters,
telegrams, telex communications, cables, notes, notations, papers, newsletters, memoranda,
inter-office communications, releases, agreements, contracts, books, pamphlets, studies,
minutes of meetings, recordings or other memorials of any type of personal or telephone
conversations, meetings or conferences (including, but not limited to, telephone bills and long
distance charge slips), reports, analyses, evaluations, estimates, projections, forecasts, receipts,
nt books,
statements, accounts, books of account, diaries, calendars, desk pads, appointme
stenographer's notebooks, transcripts, ledgers, registers, worksheets, journals, statistical
summaries , lists, tabulation s, digests, canceled or uncancell ed checks or
records, cost sheets,
drafts, vouchers, charge slips, invoices, purchase order, hotel charges, accountant's reports,
financial statements, newspapers, periodical or magazine materials, and any material
underlying, supporting or used in the preparation of any documents.
2 "Plaintiff' means the Plaintiff, KSD PARTNERS, LLC, and any employee, agent or
attorney for Plaintiff and any other person acting for, or on behalf of Plaintiff, or under Plaintiff's
authority or control.
3 "Defendants" means the Defendants, PUNTA GORDA HEALTH INVESTORS, LLC,
and any employee, agent or attorney for Defendants, and any other person acting for or on behalf
of Defendants’ authority and control.
4 “Property” means that property identified in the documents attached to Plaintiff's
Complaint.
If, INSTRUCTIONS
1 Any document as to which a claim of privilege is or will be asserted should be
identified by author, signatory, description (e.g. letter, memorandum, telex, recording, etc.), title
(if any), date, addresses (if any), general subject matter, present depository and present custodian
and a complete statement of the ground for the claim of privilege should be set forth.
2 If it is maintained that any document which is requested has been destroyed, set
forth the contents of the documents, the date of such destruction and the name of the person
who authorized or directed such destruction.
3 If any of the documents cannot be produced in full, produce to the extent possible,
specifying the reasons for the inability to produce the remainder.
4 This request is a continuing one. Ifafter producing documents, you become aware
of any further documents responsive to this request, you are required to produce such additional
documents.
IN, ITEMS TO BE PRODUCED
1 Any and all communications with any third-party regarding the allegations
raised in Plaintiffs Complaint.
2 Any and all communications or documents exchanged between the
Plaintiff and Defendants.
3 Any and all documents that you intend or anticipate you will use and/or
offer into evidence at the trial of this matter.
4 All documents reviewed, received, or considered by an expert that you
intend to call as a witness at trial.
5. Your entire file pertaining to the contract entered into between the parties,
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and accurate copy of the foregoing has been
furnished via the e-portal to Kevin F. Jursinski, Esq., Law Office of Jursinski & Murphy,
PLLC, 15701 S. Tamiami Trail, Fort Myers, FL 33908 fed mlawfl.com and
melissa(@jjmlawfl.com), this [ O day of August, 2023.
/ DN
/ALBURI ISEO, JR., ESQUIRE
/ Florj /Bar Number 0323240
GOLDMAN, TISEO & STURGES, P.A.
U oh AIC Center Court, Suite 3
‘Charlotte, Florida 33954
94 1) 625-6666
(9 f} 625-0660 Facsimile
atsiSeo@)\gtslawfirm.com
Us
lbairda@etslawfirm.com
Attorney for Defendants
J
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Filing # 179354595 E-Filed 08/10/2023 11:32:19 AM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL ACTION KSD PARTNERS, LLC, an Ohio limited liability company, Plaintiff, VS. CASE NO. 2023-002230-CA PUNTA GORDA HEALTH INVESTORS, LLC, a Florida limited liability company and FILEMAN LAW FIRM, P.A., a Florida corporation, as escrow agent, Defendants. / DEFENDANT’S FIRST REQUEST TO PRODUCE Defendant, PUNTA GORDA HEALTH INVESTORS, LLC, requests, pursuant to Fla. R. Civ. P. 1.350 that Plaintiff, KSD PARTNERS, LLC, produce the things enumerated herein for inspection and copying at Goldman, Tiseo & Sturges, P.A.,701 JC Center Court, Suite 3, Port Charlotte, FL 33954 within 30 days of the date of the Certificate of Service. I.__Definitions 1 “Document”? means any documents in your custody, possession or control, including, but not limited to, any printed, written, recorded, taped, electronic, graphic, or other tangible matter from whatever source, however produced or reproduced, whether in draft or otherwise, whether sent or received or neither, including the original, all amendments and addenda and any non-identical copy (whether different from the original because of notes made on or attached to such copy or otherwise) of any and all writing, correspondence, letters, telegrams, telex communications, cables, notes, notations, papers, newsletters, memoranda, inter-office communications, releases, agreements, contracts, books, pamphlets, studies, minutes of meetings, recordings or other memorials of any type of personal or telephone conversations, meetings or conferences (including, but not limited to, telephone bills and long distance charge slips), reports, analyses, evaluations, estimates, projections, forecasts, receipts, nt books, statements, accounts, books of account, diaries, calendars, desk pads, appointme stenographer's notebooks, transcripts, ledgers, registers, worksheets, journals, statistical summaries , lists, tabulation s, digests, canceled or uncancell ed checks or records, cost sheets, drafts, vouchers, charge slips, invoices, purchase order, hotel charges, accountant's reports, financial statements, newspapers, periodical or magazine materials, and any material underlying, supporting or used in the preparation of any documents. 2 "Plaintiff' means the Plaintiff, KSD PARTNERS, LLC, and any employee, agent or attorney for Plaintiff and any other person acting for, or on behalf of Plaintiff, or under Plaintiff's authority or control. 3 "Defendants" means the Defendants, PUNTA GORDA HEALTH INVESTORS, LLC, and any employee, agent or attorney for Defendants, and any other person acting for or on behalf of Defendants’ authority and control. 4 “Property” means that property identified in the documents attached to Plaintiff's Complaint. If, INSTRUCTIONS 1 Any document as to which a claim of privilege is or will be asserted should be identified by author, signatory, description (e.g. letter, memorandum, telex, recording, etc.), title (if any), date, addresses (if any), general subject matter, present depository and present custodian and a complete statement of the ground for the claim of privilege should be set forth. 2 If it is maintained that any document which is requested has been destroyed, set forth the contents of the documents, the date of such destruction and the name of the person who authorized or directed such destruction. 3 If any of the documents cannot be produced in full, produce to the extent possible, specifying the reasons for the inability to produce the remainder. 4 This request is a continuing one. Ifafter producing documents, you become aware of any further documents responsive to this request, you are required to produce such additional documents. IN, ITEMS TO BE PRODUCED 1 Any and all communications with any third-party regarding the allegations raised in Plaintiffs Complaint. 2 Any and all communications or documents exchanged between the Plaintiff and Defendants. 3 Any and all documents that you intend or anticipate you will use and/or offer into evidence at the trial of this matter. 4 All documents reviewed, received, or considered by an expert that you intend to call as a witness at trial. 5. Your entire file pertaining to the contract entered into between the parties, CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and accurate copy of the foregoing has been furnished via the e-portal to Kevin F. Jursinski, Esq., Law Office of Jursinski & Murphy, PLLC, 15701 S. Tamiami Trail, Fort Myers, FL 33908 fed mlawfl.com and melissa(@jjmlawfl.com), this [ O day of August, 2023. / DN /ALBURI ISEO, JR., ESQUIRE / Florj /Bar Number 0323240 GOLDMAN, TISEO & STURGES, P.A. U oh AIC Center Court, Suite 3 ‘Charlotte, Florida 33954 94 1) 625-6666 (9 f} 625-0660 Facsimile atsiSeo@)\gtslawfirm.com Us lbairda@etslawfirm.com Attorney for Defendants J