No Value: BIBERSTEIN, HARRY vs. KIRCHBERGER, GABRIEL

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                                Filing # 101905287 E-Filed 01/20/2020 01:58:15 PM

                   IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
                            IN AND FOR CHARLOTTE COUNTY, FLORIDA


      HARRY BIEBERSTEIN

                      Plaintiff,

      VS.                                                           CASE NO.:         17-CA-917

      GABRIEL KIRCHBERGER, CAROL DEVILLE.
      SOUTHERN SHORES ENTERPRISES, LLC, a
      Florida limited liability company and
      MOONSTONE HOLDINGS, LLC,
      Nevada limited liability company,

                      Defendants.


                     NDANT MOONST! INE HOLDINGS LLC'S GENERAL OBJECTIONS AND
                               RESPONSE TO REQUEST FOR PRODUCTION

                      COMES NOW          MOONSTONE      HOLDINGS,        LLC,     Defendant,   by and through its

      undersigned counsel and replies to the Plaintiff's First Request for Production filed November 19, 2019
      and states as follows:

            STANDING         GENERAL       OBJECTION    TH                      EST FOR    PRODUCTION OF
                                               DOCUMENTS

              1      Defendant MOONSTONE            HOLDINGS,     LLC objects to any Production

      request which necessitates Defendant to gather information from any source not readily available.

      MOONSTONE HOLDINGS,                LLC responds to any and all document requests utilizing the

      information currently available.    MOONSTONE          HOLDINGS,     LLC has not consulted any

      outside sources over which it has no authority . During the pendency of discovery MOONSTONE

      HOLDINGS,      LLC reserves its rights to identify and discover all documents during the duration

      of this matter; at trial, MOONSTONE HOLDINGS, LLC will utilize all such documents, as well

      as any and all documents within the possession of any persons or entity not currently employed or

      involved with MOONSTONE HOLDINGS,               LLC.

             2.      MOONSTONE HOLDINGS,               LLC objects to any Production request requiring
that Defendant produce the entire, or any and all documents as an unduly burdensome request as

Defendant does not have the ability to know or identify each and every such document.

          3.      MOONSTONE HOLDINGS, LLC generally objects to any and all requests that

requires Defendant to produce any item or document that might qualify for any applicable privilege.

          4      In the event the Defendant supplies any documents pursuant to the Request for

Production that would later be determined to be privileged that said production does not create a waiver

of any right to privilege or any and all grounds permitting objection to the discovery of such document

and respect to the subject matter contained in said document or documents and shall not create a waiver

of the right of Defendant to object to the utilization of those documents at future proceedings,

          $       MOONSTONE HOLDINGS, LLC                objects to any and all Requests requiring

production of items that might contain confidential business or proprietary information.

          6       MOONSTONE HOLDINGS, LLC's production of any and all documents do not

constitute an admission by Defendant that the information in any and all documents might be authentic

or admissible, at future proceedings nor shall that constitute any waiver on the part of MOONSTONE

HOLDINGS, LLC          to object to the use of such document or information in future proceedings in this

matter.


                                           RESPONSE


          Moonstone has provided all that is in their possession with the exception of the requests in
paragraphs 7-13, 15, 16, and 20-23 for which it seeks a protective order.



                                     CERTIFICATE OF SERVICE


          1 HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by via
the E-Portal to Ryan W. Owen, Esquire, as Attorney for Plaintiff, Adams & Reese, LLP 1515 Ringling
Blvd. Suite 700, Sarasota, Fl,  an.owen@®:   aw.com.  David K. Oaks, Esquire, David K. Oaks, P.A.
-497 E, Marion Ave. Punta Gorda, FL 33950 doaksesq/@comeast.net:
Glenn Siegel 17825 Murdock Circle, Suite A Port Charlotte, Florida 33948, kim@glenn siegellaw.com
Christopher Klein cklein@worldwidelaw.com this 20th of January, 2020.
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                                                 ROBERT W. SEGUR, ESQUIRE
                                                 ROBERT W. SEGUR, P.A.
                                                 2828 S. McCall Road, PMB 56
                                                 Englewood, FL 34224
                                                 941-473-8878
                                                 Fla. Bar No.: 0700932
                                                 legal@segurlaw.net
                                                 Attomey for Moonstone Holdings