Motion,Ex Parte: First Citizens Bank & Trust Company Plaintiff vs. Miami S&E Group Inc, et al Defendant

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                                Filing# 165356759 E-Filed 01/24/2023 02:43:52                        PM
                     IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                               IN AND FOR BROWARD COUNTY, FLORIDA

 FIRST-CITIZENS            BANK & TRUST
 COMPANY,

                      Plaintiff,                           Case No.: CACE-21-011922
 VS.
                                                           Division:
 MIAMI S&E GROUP,                INC.,
 and   OHAD GUZI, and
 GUZI'S          INVESTMENTS, LLC.,
                      Defendant.
                                                      i


                                                  MOTION FOR CONTEMPT
             COMES NOW the Plaintiff,
                                   by and through its undersigned attorney,and petitions
                                                                                       the Court to issue an

Order AdjudicatingContempt of Court directed to            OHAD GUZI, for failure to appear for the takingof a deposition
in aid       of execution as requiredby the Rules of Civil Procedure and the subpoena served.              A   Certificate   of

Non-Appearance executed by the notary publicwho attended the scheduled depositionis attached                   hereto.


             WHEREFORE, Plaintiffrespectfully
                                          requests that the Defendant be found in contempt withthe opportunity

                    a depositionand complying with the Subpoena Duces Tecum, and paying reasonable attorney's
to purge by attending

fees of $150.00, pluscourt reporter costs and the fees associated with service ofthe       subpoena,plus any other relief

the Court deems proper. Plaintiff further requests that this file shall remain     open until the Defendant fullycomplies

with Plaintiffs post-judgment discoveryrequest.

                                                 CERTIFICATE OF SERVICE
             I   HEREBY CERTIFY that a true         and correct copy of the foregoing has been furnished to Miami        S&E
Group Inc,,Defendant, at 3740            N 54th Ave, Hollywood FL 33021, Ohad Guzi,,Defendant, at     Guzi's Investments,
               at 3740 N 54 AVE,
LLC,; Defendant,                                                                                   ,2023.
                                                  this-IL/--NJD
                                                          Januam?
         ,




                                                          Respectfullysubmitted,

                                                          MARCADIS SINGER, P.A.

                                                     By:.il
                                                     (    '*a!ph
                                                              0.Marfad*,
                                                                      Efqu*31'-Bf
                                                                               #1?-115-?
                                                     ( )RoberfJ. Lindeman, Esquire,FL Bar #112608
                                                     ( )StuartH. Marcadis, Esquire,FL Bar #121587
                                                        5104 South Westshore Blvd.,Tampa, FL 33611
                                                        813/288-1881, toll free 888/547-1881
                                                        Fax: 813/288-9678
                                                        E-service: pleadings@marcadislaw.com
                                                          ATTORNEY FOR PLAINTIFF
230120/106200/RSM


                   *** FILED:   BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/01/2023          11:26:18   AM.****
         IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                    IN AND FOR BROWARD COUNTY, FLORIDA



        FIRST CITIZENS BANK       &    TRUST              C..ALRIGINAL
        COMPANY,

              Plaintiff,              CASE NO:   CACE-21-011922


        VS.


        MIAMI S&E GROUP, INC.,
        AND OHAD GUZI AND
        GUZI'S INVESTMENTS, LLC.,


              Defendant.


                           ****************************

r                          CERTIFICATE OF NONAPPEARANCE

                I, COLLEEN SUMNER, Court Reporter, Notary
        Public for the State of Florida at Large, do hereby
        Certify, under penalty of perjury, that I appeared
        on the 1 lth day of January, 2023 at 4:05 p.m. VIA
        ZOOM WITH KIMBERLY SANTIESTEBAN, ESQ, for the purpose
    ?
        of taking the DUCES TECUM DEPOSITION IN AID OF
        EXECUTION OF OHAD GUZI, INDIVIDUALLY AND ON BEHALF OF
        MIAMI   S&E  GROUP, INC., AND GUZI'S INVESTMENTS, LLC.,
        to testify in the above-styled cause, that the hour of
        5:15 p.m. EST having arrived, said witness did not
        appear.

               Dated this 17th day of January, 2023,            at Tampa,
        Hillsborough County, Florida.




                       .?.?ZP??IUWN?e
                       Notiry Public, State of Florida
                       My Commission Expires 10/8/2025
                       No. HH 177082


                             INTEGRA REPORTING GROUP, LLC
                                        TAMPA, FLORIDA
                    INFO@?NTEGRAREPORTING.COM ' WWW.INTEGRAREPORTING.COM