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Filing # 175181511 E-Filed 06/13/2023 10:20:46 AM
IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT
IN AND FOR BREVARD COUNTY, FLORIDA
STEVEN WADE, Case No.: 05-2023-CA-17232
Plaintiff,
Vv.
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.
/
NOTICE OF PRODUCTION FROM NON-PARTIES
You are hereby notified that, after ten days from the date of service of this notice via the
Portal, if no objection is received, the undersigned will issue the attached subpoena duces tecum
directed to:
American Airlines, Inc.
Attn: Corporation Service Company
1201 Hays Street
Tallahassee, FL 32301
Who is not a party to this action, to produce the items listed at the date, time, and place specified
in the subpoena duces tecum. In accordance with Florida Rule of Civil Procedure 1.351(b), any
objection to production pursuant to said Rule must be served within ten days of the date of service
of this Notice.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 13th day of June 2023 the foregoing document was
filed with the Florida Courts E-Filing Portal, pursuant to Florida Rule of Judicial Administration
2.516, and thereby served upon all counsel of record.
/s/ Blake Stewart
Blake Stewart, Esq.
FBN: 84716
Stewart Law CS, LLC
1033 Florida Avenue South
Rockledge, FL 32955
Telephone: (321) 541-6845
staff@stewartlawes.com
Blake@stewartlawes.com
Filing 175181511 STEVEN WADE VS CHARLES D BLACK 05-2023-CA-017232-XXXX-XX
IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT
IN AND FOR BREVARD COUNTY, FLORIDA
STEVEN WADE, Case No.: 05-2023-CA-17232
Plaintiff,
Vv.
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.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA
TO: American Airlines, Inc.
Attn: Corporation Service Company
1201 Hays Street
Tallahassee, FL 32301
YOU ARE HEREBY COMMANDED to produce within twenty (20) days of receipt of
this subpoena by 11:00 A.M. the following:
1 Any and all records relating to any and all transactions involving Chad W. Cooper for
the past five (5) years.
Any and all records relating to any and all transactions involving Jennifer C. Cooper for
the past five (5) years.
Any and all records relating to any and all transactions involving a payment address of
2810 Brandywine Lane, Melbourne, FL 32904 (owned by Chad and Jenn Cooper) for
the past five (5) years.
Any and all airline tickets bought by Elevation Church (Melbourne Branch) [run by
Defendants Chad William Cooper and Jennifer C. Cooper] for the past five (5) years.
Any and all reports, records, and inventory related in any way to Jennifer C. Cooper
[Elevation Church pastor].
Any and all reports, records, and inventory bought by Chad W. Cooper [Elevation
Church pastor].
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items.
Filing 175181511 STEVEN WADE VS CHARLES D BLACK 05-2023-CA-017232-XXXX-XX
You will be in compliance with this subpoena if you elect to mail, e-mail, or,
facsimile legible copies of the documents requested above on or before July 15,
2023, 2023, to: Cheyenne Orman, Paralegal, STEWART LAW CS, 1033 Florida
Avenue South, Rockledge, FL 32955; e-mail: paralegal@stewartlawes.com; or,
facsimile: (321) 966-1255. You will be reimbursed for excessive costs incurred by you
associated with copying the above referenced documents. If you wish to be reimbursed, please
include an invoice for the copying costs along with the records that you produce, indicating the
name and address of the payee and an itemization of the total costs. Please contact the
undersigned attorney in advance if the cost of reproducing these records will exceed $30.00.
Should you have any questions regarding this subpoena, please call Cheyenne Orman, Paralegal,
at (321) 541-6845. 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
named on this subpoena.
Tf you fail to:
1. appear as specified; or
2. furnish the 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 following attorney, and unless
excused from this subpoena by this attorney, or the Court, you shall respond to this subpoena as
directed.
THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN AT
THIS TIME, BUT THE RIGHT TO DEPOSE YOUR CORPORATE REPRESENTATIVE
IN THE FUTURE IS EXPRESSLY RESERVED.
/s/ Blake Stewart
Blake Stewart, Esq.
FBN: 84716
Stewart Law CS, LLC
1033 Florida Avenue South
Rockledge, FL 32955
Telephone: (321) 541-6845
staff@stewartlawes.com
Blake@stewartlawes.com
paralegal@stewartlawes.com
Filing 175181511 STEVEN WADE VS CHARLES D BLACK 05-2023-CA-017232-XXXX-XX
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Filing # 175181511 E-Filed 06/13/2023 10:20:46 AM IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT IN AND FOR BREVARD COUNTY, FLORIDA STEVEN WADE, Case No.: 05-2023-CA-17232 Plaintiff, Vv. 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. / NOTICE OF PRODUCTION FROM NON-PARTIES You are hereby notified that, after ten days from the date of service of this notice via the Portal, if no objection is received, the undersigned will issue the attached subpoena duces tecum directed to: American Airlines, Inc. Attn: Corporation Service Company 1201 Hays Street Tallahassee, FL 32301 Who is not a party to this action, to produce the items listed at the date, time, and place specified in the subpoena duces tecum. In accordance with Florida Rule of Civil Procedure 1.351(b), any objection to production pursuant to said Rule must be served within ten days of the date of service of this Notice. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 13th day of June 2023 the foregoing document was filed with the Florida Courts E-Filing Portal, pursuant to Florida Rule of Judicial Administration 2.516, and thereby served upon all counsel of record. /s/ Blake Stewart Blake Stewart, Esq. FBN: 84716 Stewart Law CS, LLC 1033 Florida Avenue South Rockledge, FL 32955 Telephone: (321) 541-6845 staff@stewartlawes.com Blake@stewartlawes.com Filing 175181511 STEVEN WADE VS CHARLES D BLACK 05-2023-CA-017232-XXXX-XX IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT IN AND FOR BREVARD COUNTY, FLORIDA STEVEN WADE, Case No.: 05-2023-CA-17232 Plaintiff, Vv. 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. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA TO: American Airlines, Inc. Attn: Corporation Service Company 1201 Hays Street Tallahassee, FL 32301 YOU ARE HEREBY COMMANDED to produce within twenty (20) days of receipt of this subpoena by 11:00 A.M. the following: 1 Any and all records relating to any and all transactions involving Chad W. Cooper for the past five (5) years. Any and all records relating to any and all transactions involving Jennifer C. Cooper for the past five (5) years. Any and all records relating to any and all transactions involving a payment address of 2810 Brandywine Lane, Melbourne, FL 32904 (owned by Chad and Jenn Cooper) for the past five (5) years. Any and all airline tickets bought by Elevation Church (Melbourne Branch) [run by Defendants Chad William Cooper and Jennifer C. Cooper] for the past five (5) years. Any and all reports, records, and inventory related in any way to Jennifer C. Cooper [Elevation Church pastor]. Any and all reports, records, and inventory bought by Chad W. Cooper [Elevation Church pastor]. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. Filing 175181511 STEVEN WADE VS CHARLES D BLACK 05-2023-CA-017232-XXXX-XX You will be in compliance with this subpoena if you elect to mail, e-mail, or, facsimile legible copies of the documents requested above on or before July 15, 2023, 2023, to: Cheyenne Orman, Paralegal, STEWART LAW CS, 1033 Florida Avenue South, Rockledge, FL 32955; e-mail: paralegal@stewartlawes.com; or, facsimile: (321) 966-1255. You will be reimbursed for excessive costs incurred by you associated with copying the above referenced documents. If you wish to be reimbursed, please include an invoice for the copying costs along with the records that you produce, indicating the name and address of the payee and an itemization of the total costs. Please contact the undersigned attorney in advance if the cost of reproducing these records will exceed $30.00. Should you have any questions regarding this subpoena, please call Cheyenne Orman, Paralegal, at (321) 541-6845. 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 named on this subpoena. Tf you fail to: 1. appear as specified; or 2. furnish the 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 following attorney, and unless excused from this subpoena by this attorney, or the Court, you shall respond to this subpoena as directed. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN AT THIS TIME, BUT THE RIGHT TO DEPOSE YOUR CORPORATE REPRESENTATIVE IN THE FUTURE IS EXPRESSLY RESERVED. /s/ Blake Stewart Blake Stewart, Esq. FBN: 84716 Stewart Law CS, LLC 1033 Florida Avenue South Rockledge, FL 32955 Telephone: (321) 541-6845 staff@stewartlawes.com Blake@stewartlawes.com paralegal@stewartlawes.com Filing 175181511 STEVEN WADE VS CHARLES D BLACK 05-2023-CA-017232-XXXX-XX