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Filing # 173381595 E-Filed 05/17/2023 03:22:11 PM
IN THE CIRCUIT COURT OF THE EIGHTEENTH
JUDICIAL CIRCUIT IN AND FOR BREVARD COUNTY, FLORIDA
STEVEN WADE,
Plaintiff,
Vv. Case No. 05-2023-CA-017232
KRISTIN DANAE BLACK a/k/a KRISTIN
BRIMMER; CHARLES DAVID BLACK, a/k/a
CHAD BLACK, CHAD W. COOPER;
JENNIFER C. COOPER; KEITH PECOT; &
PURSUIT INVESTMENTS, LLC,
Defendants.
/
DEFENDANT, CHAD COOPER’S RESPONSE TO
PLAINTIFF’S FIRST REQUEST FOR PRODUCTION
Defendant, Chad Cooper, by and through undersigned counsel, and pursuant to Florida
Rule of Civil Procedure 1.350, hereby provides amended and supplemental written responses to
Plaintiff's First Request To Produce, dated April 17, 2023, and states:
1 Copies of any and all SMS messages exchanged between You and co-defendant
Charles David Black a/k/a Chad Black during the Relevant Time Period.
RESPONSE:
Objection. This request seeks documents not reasonably calculated to lead to the
discovery of admissible evidence and is unduly burdensome. Plaintiff’s request seeks all
communications for many years without limitation as to text messages related to the claims
or defenses in the litigation. Counsel for the Coopers is agreeable to further conferral with
Plaintiff's counsel to discuss narrowly tailoring the request.
2. Copies of any and all SMS messages exchanged between You and co-defendant
Kristin Danae Black during the Relevant Time Period.
RESPONSE:
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Filing 173381595 STEVEN WADE VS CHARLES D BLACK 05-2023-CA-017232-XXXX-XX
Objection. This request seeks documents not reasonably calculated to lead to the
discovery of admissible evidence and is unduly burdensome. Plaintiff’s request seeks all
communications for many years without limitation as to text messages related to the claims
or defenses in the litigation. Counsel for the Coopers is agreeable to further conferral with
Plaintiff's counsel to discuss narrowly tailoring the request.
3 A true and correct copy of the Florida Department of Motor Vehicle Title and bill
of sale for the Sport Utility Vehicle given to You by co-defendants Charles David Black and
Kristin Black in or around early 2020.
RESPONSE:
None.
4 Copies of any and all SMS messages exchanged between You and Ronald
Gazboda during the Relevant Time Period.
RESPONSE:
Objection. This request seeks documents not reasonably calculated to lead to the
discovery of admissible evidence and is unduly burdensome. Plaintiff’s request seeks all
communications for many years without limitation as to text messages related to the claims
or defenses in the litigation. Counsel for the Coopers is agreeable to further conferral with
Plaintiff's counsel to discuss narrowly tailoring the request.
5 Copies of any and all SMS messages exchanged between You and Stephen
Brimmer, Defendant Kristin Black’s father, during the time period from January 1, 2015 to the
present time.
RESPONSE:
Objection. This request seeks documents not reasonably calculated to lead to the
discovery of admissible evidence and is unduly burdensome. Plaintiff’s request seeks all
communications for many years without limitation as to text messages related to the claims
or defenses in the litigation. Counsel for the Coopers is agreeable to further conferral with
Plaintiff's counsel to discuss narrowly tailoring the request.
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Filing 173381595 STEVEN WADE VS CHARLES D BLACK 05-2023-CA-017232-XXXX-XX
6. All documents reflecting or otherwise documenting any and all gifts received by
You from any person involved in the subject litigation, including, but not limited to: vehicles,
cash, travel, airfare, meals and luxury clothing items during the Relevant Time Period.
RESPONSE:
None.
7 Copies of any and all photographs taken during the Relevant Time Period of your
trips with your wife, co-defendant, Jenn Cooper, co-defendant, Charles David Black, and co-
defendant Kristin Danae Black, including, but not limited to, those vacations taken to Hawaii,
Greece and Maldives, and any and all other vacations You took with them.
RESPONSE:
Objection. This request seeks documents not reasonably calculated to lead to the
discovery of admissible evidence. Photos and videos of the Coopers’ vacations with the
Blacks and anyone else fail to relate to any of the claims or defenses asserted in this
litigation and constitute an unreasonable invasion into the Coopers’ private life. Subject to
and without waiver of the foregoing objections, counsel for the Coopers is agreeable for
further conferral with Plaintiff’s counsel to discuss narrowly tailoring this request.
8 Receipts from any purchases you made during the above-cited vacations
including, but not limited to, hotel rooms, rental vehicles, meals, entertainment and souvenirs.
RESPONSE:
Objection: This request seeks documents which is not reasonably calculated to lead
to the discovery of admissible evidence. Receipts from the Coopers’ purchases of various
goods and services during their vacation are not relevant to any of the claims or defenses
made in this proceeding. Subject to and without waiver of the foregoing objections,
Coopers will produce any receipts of flights and/or hotels they have from the “above-cited
vacation”; otherwise none.
9 Defendant Chad Cooper is requested to produce any property in his possession
that was given to him as a gift by co-defendants Charles and Kristin Black for inspection, or if
such property no longer is in Your possession, photographs of the items.
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Filing 173381595 STEVEN WADE VS CHARLES D BLACK 05-2023-CA-017232-XXXX-XX
RESPONSE:
None.
10. Complete financial records for the Elevation Church credit card in Your name,
VISA iS curing the Relevant Time Period.
RESPONSE:
None.
11. Complete financial records showing the gunite purchases Defendant Chad Black
admitted You made for him during the Relevant Time Period.
RESPONSE:
Objection: This request is vague and ambiguous as to what is being requested. Mr.
Cooper is unaware of what Mr. Black may or may not have admitted, where he admitted it,
when he admitted it and the purpose of such admission. Plaintiff has failed to identify with
any specificity the nature of the admission upon which its request for production is
predicated. Subject to and without waiver of the foregoing objection, Mr. Cooper is not in
possession of any of the financial records showing gunite purchases he made for Chad
Black.
12. Any and all video footage or photographs of the luxury vacations You took with
co-defendants Charles David Black and Kristin Danae Black during the Relevant Time Period.
RESPONSE:
Objection. This request seeks documents not reasonably calculated to lead to the
discovery of admissible evidence. Photos and videos of the Coopers’ vacations with the
Blacks and anyone else fail to relate to any of the claims or defenses asserted in this
litigation and constitute an unreasonable invasion into the Coopers’ private life. Subject to
and without waiver of the foregoing objections, counsel for the Coopers is agreeable for
further conferral with Plaintiffs counsel to discuss narrowly tailoring this request.
13. Any and all documents, including all communications and documents reflecting
those communications, of any nature, relating to Legacy Pools Service, LLC during the Relevant
Time Period.
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Filing 173381595 STEVEN WADE VS CHARLES D BLACK 05-2023-CA-017232-XXXX-XX
RESPONSE:
Mr. Cooper will produce any and all documents in his custody, possession or
control.
14. Any and all documents, including all communications and documents reflecting
those communications, of any nature, including, but not limited to SMS messages and emails
between You and co-defendant Charles David Black related to gunite, and/or or work or
services performed by Prestige Gunite during the Relevant Time Period.
RESPONSE:
Mr. Cooper will produce any and all documents in his custody, possession or
control.
/s/ Joseph C. Crawford
JOSEPH C. CRAWFORD
FL Bar No.: 124653
DEAN MEAD
7380 Murrell Road, Suite 200
Viera, FL 32940
Tel: (321) 259-8900; Fax: (321) 254-4479
E-Mail: jcrawford@deanmead.com
Imetress@deanmead.com
Attorney for Defendants, Chad W. Cooper
and Jennifer C. Cooper
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Filing 173381595 STEVEN WADE VS CHARLES D BLACK 05-2023-CA-017232-XXXX-XX
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 17th day of May, 2023, this document was
electronically transmitted to the Clerk of Court via the Florida Courts E-Filing Portal (“FCEP”),
which will send electronic notification to the following:
Blake Stewart, Esq. Karen M. Montas, Esq.
Stewart Law CS, LLC Johnson & Montas, P.A.
1033 Florida Avenue South 1290 U.S. Highway 1
Rockledge, Florida 32955 Rockledge, Florida 32955
blake@stewartlawes.com kmontas@jbclaw.con:
staff@stewardlawes.com nbeladino@jbclaw.com
Attorney for Plaintiff kmmteam@jbclaw.com
Attorneys for Defendant, Pecot
Bryan K. Mickler, Esq.
Law Offices of Mickler & Mickler, LLP
5452 Arlington Expy.
Jacksonville, Florida 32211
court@planlaw.com
bmickler@planlaw.com
Attorney for Defendant, Black
/s/ Joseph C. Crawford
JOSEPH C. CRAWFORD
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Filing 173381595 STEVEN WADE VS CHARLES D BLACK 05-2023-CA-017232-XXXX-XX
Preview
Filing # 173381595 E-Filed 05/17/2023 03:22:11 PM IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT IN AND FOR BREVARD COUNTY, FLORIDA STEVEN WADE, Plaintiff, Vv. Case No. 05-2023-CA-017232 KRISTIN DANAE BLACK a/k/a KRISTIN BRIMMER; CHARLES DAVID BLACK, a/k/a CHAD BLACK, CHAD W. COOPER; JENNIFER C. COOPER; KEITH PECOT; & PURSUIT INVESTMENTS, LLC, Defendants. / DEFENDANT, CHAD COOPER’S RESPONSE TO PLAINTIFF’S FIRST REQUEST FOR PRODUCTION Defendant, Chad Cooper, by and through undersigned counsel, and pursuant to Florida Rule of Civil Procedure 1.350, hereby provides amended and supplemental written responses to Plaintiff's First Request To Produce, dated April 17, 2023, and states: 1 Copies of any and all SMS messages exchanged between You and co-defendant Charles David Black a/k/a Chad Black during the Relevant Time Period. RESPONSE: Objection. This request seeks documents not reasonably calculated to lead to the discovery of admissible evidence and is unduly burdensome. Plaintiff’s request seeks all communications for many years without limitation as to text messages related to the claims or defenses in the litigation. Counsel for the Coopers is agreeable to further conferral with Plaintiff's counsel to discuss narrowly tailoring the request. 2. Copies of any and all SMS messages exchanged between You and co-defendant Kristin Danae Black during the Relevant Time Period. RESPONSE: 04205276.v1 Filing 173381595 STEVEN WADE VS CHARLES D BLACK 05-2023-CA-017232-XXXX-XX Objection. This request seeks documents not reasonably calculated to lead to the discovery of admissible evidence and is unduly burdensome. Plaintiff’s request seeks all communications for many years without limitation as to text messages related to the claims or defenses in the litigation. Counsel for the Coopers is agreeable to further conferral with Plaintiff's counsel to discuss narrowly tailoring the request. 3 A true and correct copy of the Florida Department of Motor Vehicle Title and bill of sale for the Sport Utility Vehicle given to You by co-defendants Charles David Black and Kristin Black in or around early 2020. RESPONSE: None. 4 Copies of any and all SMS messages exchanged between You and Ronald Gazboda during the Relevant Time Period. RESPONSE: Objection. This request seeks documents not reasonably calculated to lead to the discovery of admissible evidence and is unduly burdensome. Plaintiff’s request seeks all communications for many years without limitation as to text messages related to the claims or defenses in the litigation. Counsel for the Coopers is agreeable to further conferral with Plaintiff's counsel to discuss narrowly tailoring the request. 5 Copies of any and all SMS messages exchanged between You and Stephen Brimmer, Defendant Kristin Black’s father, during the time period from January 1, 2015 to the present time. RESPONSE: Objection. This request seeks documents not reasonably calculated to lead to the discovery of admissible evidence and is unduly burdensome. Plaintiff’s request seeks all communications for many years without limitation as to text messages related to the claims or defenses in the litigation. Counsel for the Coopers is agreeable to further conferral with Plaintiff's counsel to discuss narrowly tailoring the request. 04205276.v1 Filing 173381595 STEVEN WADE VS CHARLES D BLACK 05-2023-CA-017232-XXXX-XX 6. All documents reflecting or otherwise documenting any and all gifts received by You from any person involved in the subject litigation, including, but not limited to: vehicles, cash, travel, airfare, meals and luxury clothing items during the Relevant Time Period. RESPONSE: None. 7 Copies of any and all photographs taken during the Relevant Time Period of your trips with your wife, co-defendant, Jenn Cooper, co-defendant, Charles David Black, and co- defendant Kristin Danae Black, including, but not limited to, those vacations taken to Hawaii, Greece and Maldives, and any and all other vacations You took with them. RESPONSE: Objection. This request seeks documents not reasonably calculated to lead to the discovery of admissible evidence. Photos and videos of the Coopers’ vacations with the Blacks and anyone else fail to relate to any of the claims or defenses asserted in this litigation and constitute an unreasonable invasion into the Coopers’ private life. Subject to and without waiver of the foregoing objections, counsel for the Coopers is agreeable for further conferral with Plaintiff’s counsel to discuss narrowly tailoring this request. 8 Receipts from any purchases you made during the above-cited vacations including, but not limited to, hotel rooms, rental vehicles, meals, entertainment and souvenirs. RESPONSE: Objection: This request seeks documents which is not reasonably calculated to lead to the discovery of admissible evidence. Receipts from the Coopers’ purchases of various goods and services during their vacation are not relevant to any of the claims or defenses made in this proceeding. Subject to and without waiver of the foregoing objections, Coopers will produce any receipts of flights and/or hotels they have from the “above-cited vacation”; otherwise none. 9 Defendant Chad Cooper is requested to produce any property in his possession that was given to him as a gift by co-defendants Charles and Kristin Black for inspection, or if such property no longer is in Your possession, photographs of the items. 04205276.v1 Filing 173381595 STEVEN WADE VS CHARLES D BLACK 05-2023-CA-017232-XXXX-XX RESPONSE: None. 10. Complete financial records for the Elevation Church credit card in Your name, VISA iS curing the Relevant Time Period. RESPONSE: None. 11. Complete financial records showing the gunite purchases Defendant Chad Black admitted You made for him during the Relevant Time Period. RESPONSE: Objection: This request is vague and ambiguous as to what is being requested. Mr. Cooper is unaware of what Mr. Black may or may not have admitted, where he admitted it, when he admitted it and the purpose of such admission. Plaintiff has failed to identify with any specificity the nature of the admission upon which its request for production is predicated. Subject to and without waiver of the foregoing objection, Mr. Cooper is not in possession of any of the financial records showing gunite purchases he made for Chad Black. 12. Any and all video footage or photographs of the luxury vacations You took with co-defendants Charles David Black and Kristin Danae Black during the Relevant Time Period. RESPONSE: Objection. This request seeks documents not reasonably calculated to lead to the discovery of admissible evidence. Photos and videos of the Coopers’ vacations with the Blacks and anyone else fail to relate to any of the claims or defenses asserted in this litigation and constitute an unreasonable invasion into the Coopers’ private life. Subject to and without waiver of the foregoing objections, counsel for the Coopers is agreeable for further conferral with Plaintiffs counsel to discuss narrowly tailoring this request. 13. Any and all documents, including all communications and documents reflecting those communications, of any nature, relating to Legacy Pools Service, LLC during the Relevant Time Period. 04205276.v1 Filing 173381595 STEVEN WADE VS CHARLES D BLACK 05-2023-CA-017232-XXXX-XX RESPONSE: Mr. Cooper will produce any and all documents in his custody, possession or control. 14. Any and all documents, including all communications and documents reflecting those communications, of any nature, including, but not limited to SMS messages and emails between You and co-defendant Charles David Black related to gunite, and/or or work or services performed by Prestige Gunite during the Relevant Time Period. RESPONSE: Mr. Cooper will produce any and all documents in his custody, possession or control. /s/ Joseph C. Crawford JOSEPH C. CRAWFORD FL Bar No.: 124653 DEAN MEAD 7380 Murrell Road, Suite 200 Viera, FL 32940 Tel: (321) 259-8900; Fax: (321) 254-4479 E-Mail: jcrawford@deanmead.com Imetress@deanmead.com Attorney for Defendants, Chad W. Cooper and Jennifer C. Cooper 04205276.v1 Filing 173381595 STEVEN WADE VS CHARLES D BLACK 05-2023-CA-017232-XXXX-XX CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 17th day of May, 2023, this document was electronically transmitted to the Clerk of Court via the Florida Courts E-Filing Portal (“FCEP”), which will send electronic notification to the following: Blake Stewart, Esq. Karen M. Montas, Esq. Stewart Law CS, LLC Johnson & Montas, P.A. 1033 Florida Avenue South 1290 U.S. Highway 1 Rockledge, Florida 32955 Rockledge, Florida 32955 blake@stewartlawes.com kmontas@jbclaw.con: staff@stewardlawes.com nbeladino@jbclaw.com Attorney for Plaintiff kmmteam@jbclaw.com Attorneys for Defendant, Pecot Bryan K. Mickler, Esq. Law Offices of Mickler & Mickler, LLP 5452 Arlington Expy. Jacksonville, Florida 32211 court@planlaw.com bmickler@planlaw.com Attorney for Defendant, Black /s/ Joseph C. Crawford JOSEPH C. CRAWFORD 04205276.v1 Filing 173381595 STEVEN WADE VS CHARLES D BLACK 05-2023-CA-017232-XXXX-XX