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Filing # 93172374 E-Filed 07/25/2019 03:20:25 PM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL ACTION
HARRY BIEBERSTEIN,
Plaintiff,
vs. CASE NO. 17-CA-917
GABRIEL KIRCHBERGER, et al.,
Defendants.
/
NOTICE OF PRODUCTION FROM NON-PARTIES
PLEASE TAKE NOTICE that, pursuant to Rule 1.351, Florida Rules of Civil Procedure,
after ten (10) days from the date of service of this notice, and if no objection is received from any
party, Plaintiff HARRY BIEBERSTEIN will issue or apply to the Clerk of this Court for
issuance of subpoenas in the attached forms to:
Charlotte State Bank & Trust
Attention: Subpoena Compliance
1100 Tamiami Trail
Port Charlotte, Florida 33953
Englewood Bank & Trust
Attention: Subpoena Compliance
1111 South McCall Road
Englewood, Florida 34223
GNK Sky Realty, Inc.
Attention: Subpoena Compliance
c/o Lee Yearick, Registered Agent
1810 El Jobean Road, Suite 5
Port Charlotte, Florida 33948
Robert W. Segur, P.A.
Attention: Subpoena Compliance
c/o Robert W. Segur, Registered Agent
2828 South McCall Road, PMB 56
Englewood, Florida 34224
567428891
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I electronically filed the foregoing document on July 25, 2019
with the Clerk of Court using the Florida Courts E-Filing Portal, which will send a notice of
electronic filing to: Glenn N. Siegel, Esquire, Glenn N. Siegel, P.A., 17825 Murdock Circle,
Suite A, Port Charlotte, Florida 33948, at kim@glennsiegellaw.com, Counsel for Gabriel
Kirchberger; David K. Oaks, Esquire, David K. Oaks, P.A., 407 East Marion Avenue, Suite
101, Punta Gorda, Florida 33950, at doaksesq@comeast.net, Counsel for Carol DeVille and
Southern Shore Enterprises, LLC, Robert W. Segur, Esquire, Robert W. Segur P.A., 2828 S.
McCall Road PMB 56, Englewood, Florida 34224, at legal@segurlaw.net, Counsel for
Moonstone Holdings, LLC, Niclas Kirchberger, and Christine Frazer; Brian McNamara,
Esquire, McNamara Legal Services, P.A., 3447 Pine Ridge Road, Suite 101, Naples, Florida
34109, at brian@menamaralegalservices.com, Co-Counsel for Defendants Andreas Kirchberger
and Golden Key Properties, LLC; and Sebastian Nye-Schmitz, Esquire, The Nye-Schmitz Law
Firm, P.A., 3447 Pine Ridge Road, Suite 101, Naples, Florida 34109, at sns@swfltaxlaw.com,
Co-Counsel for Defendants Andreas Kirchberger and Golden Key Properties, LLC; and a true
copy has been furnished on the same date via U.S. Mail to: Andreas Kirchberger, 395
Commercial Court, Suite A, Venice, Florida 34292; and Golden Key Properties, LLC c/o The
Nye-Schmitz Law Firm, P.A., Registered Agent, 3447 Pine Ridge Road, Suite 101, Naples,
Florida 34109.
ADAMS AND REESE LLP
1515 Ringling Boulevard, Suite 700
Sarasota, Florida 34236
Primary: ryan.owen@arlaw,.com
Primary: drew.chesanek@arlaw.com
Secondary: deborah.woodson@arlaw.com
Telephone: (941) 316-7600
Counsel for Plaintiff
By: /s/Rvan W. Owen
Ryan W. Owen
Florida Bar No. 0029355
Drew F. Chesanek
Florida Bar No. 0115933
567428891
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL ACTION
HARRY BIEBERSTEIN,
Plaintiff,
Vv. CASE NO. 17-CA-917
GABRIEL KIRCHBERGER, et al.,
Defendants.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
Option to Produce by Mail
TO: Charlotte State Bank & Trust
Attention: Subpoena Compliance
1100 Tamiami Trail
Port Charlotte, Florida 33953
YOU ARE HEREBY COMMANDED to appear at the law offices of Adams and Reese
LLP, 1515 Ringling Boulevard, Suite 700, Sarasota, Florida 34236, during normal business
hours, within 30 days of service of this subpoena, and to have with you at that time and place the
following:
REGARDING: Gabriel Kirchberger
1 All loan applications for any loans made to Gabriel Kirchberger or guaranteed by
Gabriel Kirchberger at any time from January 1, 2012 to the date of your response.
The payment history for any loans given to or guaranteed by Gabriel Kirchberger.
All documents (i.e. wire transfer receipts, cancelled checks, or ACH payment
records) reflecting your receipt of payment upon any loans given to or guaranteed by
Gabriel Kirchberger.
Copies of the signature cards for each account upon which Gabriel Kirchberger is or
was an authorized signatory at any time from January 1, 2012 to the present.
All account statements from any and all accounts upon which Gabriel Kirchberger is
or was an account holder or an authorized signatory at any time from January 1, 2012
to the date of your response.
562406121 Page 1 of 2
6. All documents provided by the account holder(s) in connection with the
stablishment of any account(s) upon which Gabriel Kirchberger is or was an
authorized signatory at any time from January 1, 2012 to the present.
The access records for any safety deposit box which is owned by Gabriel Kirchberger
or which Gabriel Kirchberger has the right to access from January 1, 2012 to the
present.
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. You may comply with this subpoena by providing legible copies
of the items to be produced to the attorney whose name appears on this subpoena on or
before the scheduled date of production. You may condition the preparation of the copies
upon the payment in advance of the reasonable cost of preparation. You may mail or deliver
the copies to the attorney whose name and address appears below on this subpoena and
thereby eliminates your appearance at the time and place specified above. Any copying
costs to be charged must be approved in advance by the undersigned attorneys.
IF YOU HAVE ANY QUESTIONS WITH REGARD TO THIS SUBPOENA,
PLEASE CONTACT ME AT THE NUMBER LISTED BELOW.
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 whose name appears on this subpoena.
Tf you fail to: (a) appear as specified, or (b) furnish the records instead of appearing as
provided above; or (c) object to this subpoena you may be in contempt of Court. You are
subpoenaed to appear by the following attorney, and unless excused from this subpoena by the
attorney or the Court, you shall respond to this subpoena as directed.
DATED on this day of August 2019.
RYAN W. OWEN, ESQUIRE
FOR THE COURT
Ryan W. Owen, Esquire
Fla Bar No. 0029355
Primary Email: ryan, owen@arlaw.com
Secondary Email: deborah.woodson@arlaw.com
ADAMS AND REESE LLP
1515 Ringling Boulevard, Suite 700
Sarasota, Florida 34236
Telephone: 941-316-7600
Counsel for Plaintiff
62406121 Page 2 of 2
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL ACTION
HARRY BIEBERSTEIN,
Plaintiff,
Vv. CASE NO. 17-CA-917
GABRIEL KIRCHBERGER, et al.,
Defendants.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
Option to Produce by Mail
TO: Englewood Bank & Trust
Attention: Subpoena Compliance
1111 South McCall Road
Englewood, Florida 34223
YOU ARE HEREBY COMMANDED to appear at the law offices of Adams and Reese
LLP, 1515 Ringling Boulevard, Suite 700, Sarasota, Florida 34236, during normal business
hours, within 30 days of service of this subpoena, and to have with you at that time and place the
following:
REGARDING: Gabriel Kirchberger
1 All loan applications for any loans made to Gabriel Kirchberger or guaranteed by
Gabriel Kirchberger at any time from January 1, 2012 to the date of your response.
The payment history for any loans given to or guaranteed by Gabriel Kirchberger.
All documents (i.e. wire transfer receipts, cancelled checks, or ACH payment
records) reflecting your receipt of payment upon any loans given to or guaranteed by
Gabriel Kirchberger.
Copies of the signature cards for each account upon which Gabriel Kirchberger is or
was an authorized signatory at any time from January 1, 2012 to the present.
All account statements from any and all accounts upon which Gabriel Kirchberger is
or was an account holder or an authorized signatory at any time from January 1, 2012
to the date of your response.
62403131 Page 1 of 2
6. All documents provided by the account holder(s) in connection with the
stablishment of any account(s) upon which Gabriel Kirchberger is or was an
authorized signatory at any time from January 1, 2012 to the present.
The access records for any safety deposit box which is owned by Gabriel Kirchberger
or which Gabriel Kirchberger has the right to access from January 1, 2012 to the
present.
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. You may comply with this subpoena by providing legible copies
of the items to be produced to the attorney whose name appears on this subpoena on or
before the scheduled date of production. You may condition the preparation of the copies
upon the payment in advance of the reasonable cost of preparation. You may mail or deliver
the copies to the attorney whose name and address appears below on this subpoena and
thereby eliminates your appearance at the time and place specified above. Any copying
costs to be charged must be approved in advance by the undersigned attorneys.
IF YOU HAVE ANY QUESTIONS WITH REGARD TO THIS SUBPOENA,
PLEASE CONTACT ME AT THE NUMBER LISTED BELOW.
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 whose name appears on this subpoena.
Tf you fail to: (a) appear as specified, or (b) furnish the records instead of appearing as
provided above; or (c) object to this subpoena you may be in contempt of Court. You are
subpoenaed to appear by the following attorney, and unless excused from this subpoena by the
attorney or the Court, you shall respond to this subpoena as directed.
DATED on this day of August 2019.
RYAN W. OWEN, ESQUIRE
FOR THE COURT
Ryan W. Owen, Esquire
Fla Bar No. 0029355
Primary Email: ryan, owen@arlaw.com
Secondary Email: deborah.woodson@arlaw.com
ADAMS AND REESE LLP
1515 Ringling Boulevard, Suite 700
Sarasota, Florida 34236
Telephone: 941-316-7600
Counsel for Plaintiff
562403131 Page 2 of 2
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL ACTION
HARRY BIEBERSTEIN,
Plaintiff,
Vv. CASE NO. 17-CA-917
GABRIEL KIRCHBERGER, et al.,
Defendants.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
Option to Produce by Mail
TO: GNK Sky Realty, Inc.
Attention: Subpoena Compliance
c/o Lee Yearick, Registered Agent
1810 El Jobean Road, Suite 5
Port Charlotte, Florida 33948
YOU ARE HEREBY COMMANDED to appear at the law offices of Adams and Reese LLP,
1515 Ringling Boulevard, Suite 700, Sarasota, Florida 34236, during normal business hours,
within 30 days of service of this subpoena, and to have with you at that time and place the
following:
REGARDING: Any and all communications with Gabriel Kirchberger from May
31, 2014 to the date of your response including:
1 All e-mails, text messages, letters, or any other form of correspondence by, between,
and among GNK Sky Realty, Inc., its officers, directors, employees, and agents and
Gabriel Kirchberger; and
All contracts entered into, on behalf of, or authorized by Gabriel Kirchberger,
regardless of whether Gabriel Kirchberger was acting on his own behalf or on behalf
of some other individual or entity.
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. You may comply with this subpoena by providing legible copies
of the items to be produced to the attorney whose name appears on this subpoena on or
before the scheduled date of production. You may condition the preparation of the copies
56303552_1 Page 1 of 2
upon the payment in advance of the reasonable cost of preparation. You may mail or deliver
the copies to the attorney whose name and address appears below on this subpoena and
thereby eliminates your appearance at the time and place specified above. Any copying
costs to be charged must be approved in advance by the undersigned attorneys.
IF YOU HAVE ANY QUESTIONS WITH REGARD TO THIS SUBPOENA,
PLEASE CONTACT ME AT THE NUMBER LISTED BELOW.
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 whose name appears on this subpoena.
Tf you fail to: (a) appear as specified, or (b) furnish the records instead of appearing as
provided above; or (c) object to this subpoena you may be in contempt of Court. You are
subpoenaed to appear by the following attorney, and unless excused from this subpoena by the
attorney or the Court, you shall respond to this subpoena as directed.
DATED on this day of August 2019.
RYAN W. OWEN, ESQUIRE
FOR THE COURT
Ryan W. Owen, Esquire
Fla Bar No. 0029355
Primary Email: ryan.owen@arlaw.com
Secondary Email: deborah,woodson@arlaw.com
ADAMS AND REESE LLP
1515 Ringling Boulevard, Suite 700
Sarasota, Florida 34236
Telephone: 941-316-7600
Counsel for Plaintiff
56303552_1 Page 2 of 2
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL ACTION
HARRY BIEBERSTEIN,
Plaintiff,
Vv. CASE NO. 17-CA-917
GABRIEL KIRCHBERGER, et al.,
Defendants.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
Option to Produce by Mail
TO: Robert W. Segur, P.A.
Attention: Subpoena Compliance
c/o Robert W. Segur, Registered Agent
2828 South McCall Road, PMB 56
Englewood, Florida 34224
YOU ARE HEREBY COMMANDED to appear at the law offices of Adams and Reese
LLP, 1515 Ringling Boulevard, Suite 700, Sarasota, Florida 34236, during normal business
hours, within 30 days of service of this subpoena, and to have with you at that time and place the
following:
REGARDING: Any and all documents evidencing any payments received from
Gabriel Kirchberger, individually or on behalf of any other individual or entity:
1 All checks deposited (front and back), incoming wire transfer receipts, ACH receipts,
credit card receipts, and/or cash received receipts;
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. You may comply with this subpoena by providing legible copies
of the items to be produced to the attorney whose name appears on this subpoena on or
before the scheduled date of production. You may condition the preparation of the copies
upon the payment in advance of the reasonable cost of preparation. You may mail or deliver
the copies to the attorney whose name and address appears below on this subpoena and
thereby eliminates your appearance at the time and place specified above. Any copying
costs to be charged must be approved in advance by the undersigned attorneys.
56365955-2 Page 1 of 2
IF YOU HAVE ANY QUESTIONS WITH REGARD TO THIS SUBPOENA,
PLEASE CONTACT ME AT THE NUMBER LISTED BELOW.
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 whose name appears on this subpoena.
If you fail to: (a) appear as specified, or (b) furnish the records instead of appearing as
provided above; or (c) object to this subpoena you may be in contempt of Court. You are
subpoenaed to appear by the following attorney, and unless excused from this subpoena by the
attorney or the Court, you shall respond to this subpoena as directed.
DATED on this day of August 2019.
RYAN W. OWEN, ESQUIRE
FOR THE COURT
Ryan W. Owen, Esquire
Fla Bar No. 0029355
Primary Email: ryan. owen@arlaw.com
Secondary Email: deborah.woods Darlaw.com
ADAMS AND REESE LLP
1515 Ringling Boulevard, Suite 700
Sarasota, Florida 34236
Telephone: 941-316-7600
Counsel for Plaintiff
56365955-2 Page 2 of 2
Preview
Filing # 93172374 E-Filed 07/25/2019 03:20:25 PM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL ACTION HARRY BIEBERSTEIN, Plaintiff, vs. CASE NO. 17-CA-917 GABRIEL KIRCHBERGER, et al., Defendants. / NOTICE OF PRODUCTION FROM NON-PARTIES PLEASE TAKE NOTICE that, pursuant to Rule 1.351, Florida Rules of Civil Procedure, after ten (10) days from the date of service of this notice, and if no objection is received from any party, Plaintiff HARRY BIEBERSTEIN will issue or apply to the Clerk of this Court for issuance of subpoenas in the attached forms to: Charlotte State Bank & Trust Attention: Subpoena Compliance 1100 Tamiami Trail Port Charlotte, Florida 33953 Englewood Bank & Trust Attention: Subpoena Compliance 1111 South McCall Road Englewood, Florida 34223 GNK Sky Realty, Inc. Attention: Subpoena Compliance c/o Lee Yearick, Registered Agent 1810 El Jobean Road, Suite 5 Port Charlotte, Florida 33948 Robert W. Segur, P.A. Attention: Subpoena Compliance c/o Robert W. Segur, Registered Agent 2828 South McCall Road, PMB 56 Englewood, Florida 34224 567428891 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I electronically filed the foregoing document on July 25, 2019 with the Clerk of Court using the Florida Courts E-Filing Portal, which will send a notice of electronic filing to: Glenn N. Siegel, Esquire, Glenn N. Siegel, P.A., 17825 Murdock Circle, Suite A, Port Charlotte, Florida 33948, at kim@glennsiegellaw.com, Counsel for Gabriel Kirchberger; David K. Oaks, Esquire, David K. Oaks, P.A., 407 East Marion Avenue, Suite 101, Punta Gorda, Florida 33950, at doaksesq@comeast.net, Counsel for Carol DeVille and Southern Shore Enterprises, LLC, Robert W. Segur, Esquire, Robert W. Segur P.A., 2828 S. McCall Road PMB 56, Englewood, Florida 34224, at legal@segurlaw.net, Counsel for Moonstone Holdings, LLC, Niclas Kirchberger, and Christine Frazer; Brian McNamara, Esquire, McNamara Legal Services, P.A., 3447 Pine Ridge Road, Suite 101, Naples, Florida 34109, at brian@menamaralegalservices.com, Co-Counsel for Defendants Andreas Kirchberger and Golden Key Properties, LLC; and Sebastian Nye-Schmitz, Esquire, The Nye-Schmitz Law Firm, P.A., 3447 Pine Ridge Road, Suite 101, Naples, Florida 34109, at sns@swfltaxlaw.com, Co-Counsel for Defendants Andreas Kirchberger and Golden Key Properties, LLC; and a true copy has been furnished on the same date via U.S. Mail to: Andreas Kirchberger, 395 Commercial Court, Suite A, Venice, Florida 34292; and Golden Key Properties, LLC c/o The Nye-Schmitz Law Firm, P.A., Registered Agent, 3447 Pine Ridge Road, Suite 101, Naples, Florida 34109. ADAMS AND REESE LLP 1515 Ringling Boulevard, Suite 700 Sarasota, Florida 34236 Primary: ryan.owen@arlaw,.com Primary: drew.chesanek@arlaw.com Secondary: deborah.woodson@arlaw.com Telephone: (941) 316-7600 Counsel for Plaintiff By: /s/Rvan W. Owen Ryan W. Owen Florida Bar No. 0029355 Drew F. Chesanek Florida Bar No. 0115933 567428891 IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL ACTION HARRY BIEBERSTEIN, Plaintiff, Vv. CASE NO. 17-CA-917 GABRIEL KIRCHBERGER, et al., Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: Option to Produce by Mail TO: Charlotte State Bank & Trust Attention: Subpoena Compliance 1100 Tamiami Trail Port Charlotte, Florida 33953 YOU ARE HEREBY COMMANDED to appear at the law offices of Adams and Reese LLP, 1515 Ringling Boulevard, Suite 700, Sarasota, Florida 34236, during normal business hours, within 30 days of service of this subpoena, and to have with you at that time and place the following: REGARDING: Gabriel Kirchberger 1 All loan applications for any loans made to Gabriel Kirchberger or guaranteed by Gabriel Kirchberger at any time from January 1, 2012 to the date of your response. The payment history for any loans given to or guaranteed by Gabriel Kirchberger. All documents (i.e. wire transfer receipts, cancelled checks, or ACH payment records) reflecting your receipt of payment upon any loans given to or guaranteed by Gabriel Kirchberger. Copies of the signature cards for each account upon which Gabriel Kirchberger is or was an authorized signatory at any time from January 1, 2012 to the present. All account statements from any and all accounts upon which Gabriel Kirchberger is or was an account holder or an authorized signatory at any time from January 1, 2012 to the date of your response. 562406121 Page 1 of 2 6. All documents provided by the account holder(s) in connection with the stablishment of any account(s) upon which Gabriel Kirchberger is or was an authorized signatory at any time from January 1, 2012 to the present. The access records for any safety deposit box which is owned by Gabriel Kirchberger or which Gabriel Kirchberger has the right to access from January 1, 2012 to the present. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name and address appears below on this subpoena and thereby eliminates your appearance at the time and place specified above. Any copying costs to be charged must be approved in advance by the undersigned attorneys. IF YOU HAVE ANY QUESTIONS WITH REGARD TO THIS SUBPOENA, PLEASE CONTACT ME AT THE NUMBER LISTED BELOW. 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 whose name appears on this subpoena. Tf you fail to: (a) appear as specified, or (b) furnish the records instead of appearing as provided above; or (c) object to this subpoena you may be in contempt of Court. You are subpoenaed to appear by the following attorney, and unless excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as directed. DATED on this day of August 2019. RYAN W. OWEN, ESQUIRE FOR THE COURT Ryan W. Owen, Esquire Fla Bar No. 0029355 Primary Email: ryan, owen@arlaw.com Secondary Email: deborah.woodson@arlaw.com ADAMS AND REESE LLP 1515 Ringling Boulevard, Suite 700 Sarasota, Florida 34236 Telephone: 941-316-7600 Counsel for Plaintiff 62406121 Page 2 of 2 IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL ACTION HARRY BIEBERSTEIN, Plaintiff, Vv. CASE NO. 17-CA-917 GABRIEL KIRCHBERGER, et al., Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: Option to Produce by Mail TO: Englewood Bank & Trust Attention: Subpoena Compliance 1111 South McCall Road Englewood, Florida 34223 YOU ARE HEREBY COMMANDED to appear at the law offices of Adams and Reese LLP, 1515 Ringling Boulevard, Suite 700, Sarasota, Florida 34236, during normal business hours, within 30 days of service of this subpoena, and to have with you at that time and place the following: REGARDING: Gabriel Kirchberger 1 All loan applications for any loans made to Gabriel Kirchberger or guaranteed by Gabriel Kirchberger at any time from January 1, 2012 to the date of your response. The payment history for any loans given to or guaranteed by Gabriel Kirchberger. All documents (i.e. wire transfer receipts, cancelled checks, or ACH payment records) reflecting your receipt of payment upon any loans given to or guaranteed by Gabriel Kirchberger. Copies of the signature cards for each account upon which Gabriel Kirchberger is or was an authorized signatory at any time from January 1, 2012 to the present. All account statements from any and all accounts upon which Gabriel Kirchberger is or was an account holder or an authorized signatory at any time from January 1, 2012 to the date of your response. 62403131 Page 1 of 2 6. All documents provided by the account holder(s) in connection with the stablishment of any account(s) upon which Gabriel Kirchberger is or was an authorized signatory at any time from January 1, 2012 to the present. The access records for any safety deposit box which is owned by Gabriel Kirchberger or which Gabriel Kirchberger has the right to access from January 1, 2012 to the present. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name and address appears below on this subpoena and thereby eliminates your appearance at the time and place specified above. Any copying costs to be charged must be approved in advance by the undersigned attorneys. IF YOU HAVE ANY QUESTIONS WITH REGARD TO THIS SUBPOENA, PLEASE CONTACT ME AT THE NUMBER LISTED BELOW. 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 whose name appears on this subpoena. Tf you fail to: (a) appear as specified, or (b) furnish the records instead of appearing as provided above; or (c) object to this subpoena you may be in contempt of Court. You are subpoenaed to appear by the following attorney, and unless excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as directed. DATED on this day of August 2019. RYAN W. OWEN, ESQUIRE FOR THE COURT Ryan W. Owen, Esquire Fla Bar No. 0029355 Primary Email: ryan, owen@arlaw.com Secondary Email: deborah.woodson@arlaw.com ADAMS AND REESE LLP 1515 Ringling Boulevard, Suite 700 Sarasota, Florida 34236 Telephone: 941-316-7600 Counsel for Plaintiff 562403131 Page 2 of 2 IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL ACTION HARRY BIEBERSTEIN, Plaintiff, Vv. CASE NO. 17-CA-917 GABRIEL KIRCHBERGER, et al., Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: Option to Produce by Mail TO: GNK Sky Realty, Inc. Attention: Subpoena Compliance c/o Lee Yearick, Registered Agent 1810 El Jobean Road, Suite 5 Port Charlotte, Florida 33948 YOU ARE HEREBY COMMANDED to appear at the law offices of Adams and Reese LLP, 1515 Ringling Boulevard, Suite 700, Sarasota, Florida 34236, during normal business hours, within 30 days of service of this subpoena, and to have with you at that time and place the following: REGARDING: Any and all communications with Gabriel Kirchberger from May 31, 2014 to the date of your response including: 1 All e-mails, text messages, letters, or any other form of correspondence by, between, and among GNK Sky Realty, Inc., its officers, directors, employees, and agents and Gabriel Kirchberger; and All contracts entered into, on behalf of, or authorized by Gabriel Kirchberger, regardless of whether Gabriel Kirchberger was acting on his own behalf or on behalf of some other individual or entity. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies 56303552_1 Page 1 of 2 upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name and address appears below on this subpoena and thereby eliminates your appearance at the time and place specified above. Any copying costs to be charged must be approved in advance by the undersigned attorneys. IF YOU HAVE ANY QUESTIONS WITH REGARD TO THIS SUBPOENA, PLEASE CONTACT ME AT THE NUMBER LISTED BELOW. 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 whose name appears on this subpoena. Tf you fail to: (a) appear as specified, or (b) furnish the records instead of appearing as provided above; or (c) object to this subpoena you may be in contempt of Court. You are subpoenaed to appear by the following attorney, and unless excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as directed. DATED on this day of August 2019. RYAN W. OWEN, ESQUIRE FOR THE COURT Ryan W. Owen, Esquire Fla Bar No. 0029355 Primary Email: ryan.owen@arlaw.com Secondary Email: deborah,woodson@arlaw.com ADAMS AND REESE LLP 1515 Ringling Boulevard, Suite 700 Sarasota, Florida 34236 Telephone: 941-316-7600 Counsel for Plaintiff 56303552_1 Page 2 of 2 IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL ACTION HARRY BIEBERSTEIN, Plaintiff, Vv. CASE NO. 17-CA-917 GABRIEL KIRCHBERGER, et al., Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: Option to Produce by Mail TO: Robert W. Segur, P.A. Attention: Subpoena Compliance c/o Robert W. Segur, Registered Agent 2828 South McCall Road, PMB 56 Englewood, Florida 34224 YOU ARE HEREBY COMMANDED to appear at the law offices of Adams and Reese LLP, 1515 Ringling Boulevard, Suite 700, Sarasota, Florida 34236, during normal business hours, within 30 days of service of this subpoena, and to have with you at that time and place the following: REGARDING: Any and all documents evidencing any payments received from Gabriel Kirchberger, individually or on behalf of any other individual or entity: 1 All checks deposited (front and back), incoming wire transfer receipts, ACH receipts, credit card receipts, and/or cash received receipts; These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name and address appears below on this subpoena and thereby eliminates your appearance at the time and place specified above. Any copying costs to be charged must be approved in advance by the undersigned attorneys. 56365955-2 Page 1 of 2 IF YOU HAVE ANY QUESTIONS WITH REGARD TO THIS SUBPOENA, PLEASE CONTACT ME AT THE NUMBER LISTED BELOW. 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 whose name appears on this subpoena. If you fail to: (a) appear as specified, or (b) furnish the records instead of appearing as provided above; or (c) object to this subpoena you may be in contempt of Court. You are subpoenaed to appear by the following attorney, and unless excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as directed. DATED on this day of August 2019. RYAN W. OWEN, ESQUIRE FOR THE COURT Ryan W. Owen, Esquire Fla Bar No. 0029355 Primary Email: ryan. owen@arlaw.com Secondary Email: deborah.woods Darlaw.com ADAMS AND REESE LLP 1515 Ringling Boulevard, Suite 700 Sarasota, Florida 34236 Telephone: 941-316-7600 Counsel for Plaintiff 56365955-2 Page 2 of 2