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Electronically Filed 04/05/2013 12:44:04 PM ET
IN THE CIRCUIT COURT FOR THE 11TH JUDICIAL CIRCUIT,
IN AND FOR MIAMI-DADE COUNTY, FLORIDA
WELLS FARGO BANK, NA, GENERAL JURISDICTION DIVISION
Plaintiff, CASE NO.
2010 030707 CA 01
VS.
CARLOS G. ORCHARD; CHERI A.
PRINCE A/K/A CHERI PRINCE; ANY
DEFENDANTS, CARLOS G.
AND ALL UNKNOWN PARTIES
ORCHARD AND CHERI
CLAIMING BY, THROUGH, UNDER,
PRINCE’S, PRE-TRIAL
AND AGAINST THE HEREIN NAMED
REQUEST FOR PRODUCTION
INDIVIDUAL DEFENDANT(S) WHO
ARE NOT KNOWN TO BE DEAD OR
ALIVE, WHETHER SAID UNKNOWN
PARTIES MAY CLAIM AN INTEREST
AS SPOUSES, HEIRS, DEVISEES,
GRANTEES, OR OTHER CLAIMANTS;
TENANT #1, TENANT #2, TENANT #2,
and TENANT #4 the names being fictitious
to account for parties in possession,
Defendants.
/
Defendants, CARLOS G. ORCHARD and CHERI PRINCE, pursuant to Fla. R. Civ. P.
1,350, request the Plaintiff, WELLS FARGO BANK, NA, to produce and permit the Defendants
to inspect and copy, within 30 days, each of the following documents:
1 All exhibits, documents, records, computerized data files, or expert reports which
Plaintiff may rely upon at trial.
All documents Plaintiff intends to rely upon at trial to support the allegations that
Plaintiff performed all conditions precedent to foreclosure.
Any signature receipts evidencing the delivery of any letters purporting to satisfy
conditions precedent to foreclosure.
All documents, records, computerized data files, invoices, payment receipts, or
other evidence of fees, costs, and amounts due and owing which Plaintiff will
seek reimbursement of at trial.
Ice Legal, PA.
1015 N. STATE RD. 7, SUITE C, ROYAL PALM BEACH, FL 33411 * TELEPHONE (561) 729-0530
CASE NO. 2010 030707 CA 01
For any expert witnesses that may be called at trial please provide his or her
‘urriculum vitae and a list of cases in which he or she has been retained as an
expert, including cases in which he or she has testified.
For any expert witnesses that may be called at trial all documents he or she
reviewed or relied upon in forming their opinions for testifying.
For any documents produced which contain coded entries, the key or other
document which deciphers or otherwise details the meaning of the entries.
Dated: April 4, 2013.
ICE LEGAL, P.A.
Counsel for Defendants
1015 N. State Road 7, Suite C
Royal Palm Beach, FL 33411
Telephone: (561) 729-0530
Designated Email for Service:
service@icelegal.com
servicel @icelegal.com
service2@icelegal.com
By:
CHRISTOPHER T. IMMEL
Florida Bar No. 0066204
2
Ice Legal, PA.
1015 N. STATE RD. 7, SUITE C, ROYAL PALM BEACH, FL 33411 * TELEPHONE (561) 729-0530
CASE NO. 2010 030707 CA 01
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served this April
4, 2013 to all parties on the attached service list. Service was by email to all parties not exempt
from Rule 2.516 Fla. R. Jud. Admin. at the indicated email address on the service list, and by
U.S. Mail to any other parties.
ICE LEGAL, P.A.
Counsel for Defendants
1015 N. State Road 7, Suite C
Royal Palm Beach, FL 33411
Telephone: (561) 729-0530
Designated Email for Service:
service@icelegal.com
servicel @icelegal.com
service2@icelegal.com
+ A ‘)
By: CA ENS Ke L
CHRISTOPHER T. IMMEL
Florida Bar No. 0066204
SERVICE LIST
Eleane Sosa-Bruzon, Esq.
RONALD R. WOLFE & ASSOCIATES,
P.L.
P.O. Box 250108
Tampa, FL 33622
(813) 251-4766
eservice@wolfelawfl.com
Plaintiff's counsel
3
Ice Legal, P.A.
1015 N. STATE RD. 7, SUITE C, ROYAL PALM BEACH, FL 33411 * TELEPHONE (561) 729-0530
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Electronically Filed 04/05/2013 12:44:04 PM ET IN THE CIRCUIT COURT FOR THE 11TH JUDICIAL CIRCUIT, IN AND FOR MIAMI-DADE COUNTY, FLORIDA WELLS FARGO BANK, NA, GENERAL JURISDICTION DIVISION Plaintiff, CASE NO. 2010 030707 CA 01 VS. CARLOS G. ORCHARD; CHERI A. PRINCE A/K/A CHERI PRINCE; ANY DEFENDANTS, CARLOS G. AND ALL UNKNOWN PARTIES ORCHARD AND CHERI CLAIMING BY, THROUGH, UNDER, PRINCE’S, PRE-TRIAL AND AGAINST THE HEREIN NAMED REQUEST FOR PRODUCTION INDIVIDUAL DEFENDANT(S) WHO ARE NOT KNOWN TO BE DEAD OR ALIVE, WHETHER SAID UNKNOWN PARTIES MAY CLAIM AN INTEREST AS SPOUSES, HEIRS, DEVISEES, GRANTEES, OR OTHER CLAIMANTS; TENANT #1, TENANT #2, TENANT #2, and TENANT #4 the names being fictitious to account for parties in possession, Defendants. / Defendants, CARLOS G. ORCHARD and CHERI PRINCE, pursuant to Fla. R. Civ. P. 1,350, request the Plaintiff, WELLS FARGO BANK, NA, to produce and permit the Defendants to inspect and copy, within 30 days, each of the following documents: 1 All exhibits, documents, records, computerized data files, or expert reports which Plaintiff may rely upon at trial. All documents Plaintiff intends to rely upon at trial to support the allegations that Plaintiff performed all conditions precedent to foreclosure. Any signature receipts evidencing the delivery of any letters purporting to satisfy conditions precedent to foreclosure. All documents, records, computerized data files, invoices, payment receipts, or other evidence of fees, costs, and amounts due and owing which Plaintiff will seek reimbursement of at trial. Ice Legal, PA. 1015 N. STATE RD. 7, SUITE C, ROYAL PALM BEACH, FL 33411 * TELEPHONE (561) 729-0530 CASE NO. 2010 030707 CA 01 For any expert witnesses that may be called at trial please provide his or her ‘urriculum vitae and a list of cases in which he or she has been retained as an expert, including cases in which he or she has testified. For any expert witnesses that may be called at trial all documents he or she reviewed or relied upon in forming their opinions for testifying. For any documents produced which contain coded entries, the key or other document which deciphers or otherwise details the meaning of the entries. Dated: April 4, 2013. ICE LEGAL, P.A. Counsel for Defendants 1015 N. State Road 7, Suite C Royal Palm Beach, FL 33411 Telephone: (561) 729-0530 Designated Email for Service: service@icelegal.com servicel @icelegal.com service2@icelegal.com By: CHRISTOPHER T. IMMEL Florida Bar No. 0066204 2 Ice Legal, PA. 1015 N. STATE RD. 7, SUITE C, ROYAL PALM BEACH, FL 33411 * TELEPHONE (561) 729-0530 CASE NO. 2010 030707 CA 01 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served this April 4, 2013 to all parties on the attached service list. Service was by email to all parties not exempt from Rule 2.516 Fla. R. Jud. Admin. at the indicated email address on the service list, and by U.S. Mail to any other parties. ICE LEGAL, P.A. Counsel for Defendants 1015 N. State Road 7, Suite C Royal Palm Beach, FL 33411 Telephone: (561) 729-0530 Designated Email for Service: service@icelegal.com servicel @icelegal.com service2@icelegal.com + A ‘) By: CA ENS Ke L CHRISTOPHER T. IMMEL Florida Bar No. 0066204 SERVICE LIST Eleane Sosa-Bruzon, Esq. RONALD R. WOLFE & ASSOCIATES, P.L. P.O. Box 250108 Tampa, FL 33622 (813) 251-4766 eservice@wolfelawfl.com Plaintiff's counsel 3 Ice Legal, P.A. 1015 N. STATE RD. 7, SUITE C, ROYAL PALM BEACH, FL 33411 * TELEPHONE (561) 729-0530