No Value: BIBERSTEIN, HARRY vs. KIRCHBERGER, GABRIEL

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                                Filing # 100923820 E-Filed 12/30/2019 01:14:07 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, a
     Nevada limited liability company,

                    Defendants.
                                                            /

            DEFENDANT MOONSTONE HOLDINGS LLC'S GENERAL                              OBJECTIONS AND
                                    RESPONSE TO REQUEST FOR PRODUCTION

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

     undersigned counsel and replies to the Plaintiff's First Request for Production filed July 25, 2019 as

     modified on November 22. 2019 and states as follows:

           STANDING GENERAL OBJECTIONS TO THE REQUEST FOR PRODUCTION OF
                                             DOCUMENTS

             i      Defendant MOONSTONE          HOLDINGS, LLC objects to any Production

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

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

     information currently available.   MOONSTONE       HOLDINGS, LLC has npt 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 noticurrently 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 butdensome 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 productijon 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 ahd shall not create a waiver

of the right of Defendant to object to the utilization of those documents at fufure proceedings.

          5.   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 doquments 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

               Provided.

               Provided.

               Provided.

               Currently none available.

               Provided.

               None in Moonstone's possession.

               None in Moonstone's possession.
None in Moonstone’s possession.

               None in Moonstone's possession.

       10.     Provided redacted Bank Statements.

       i       Provided

       12.     Provided.

       13      None in Moonstone's possession

       14-18. See redacted bank statements.

       19.    None in Moonstone's possession.

       20.    None in Moonstone's possession.

       21     Provided.

       22     None in Moonstone's possession.

       23.    Provided.

       24.    None in Moonstone's possession.

       25- 32. Provided.

       31.    Partially provided, line items B, C. E. D, H, I, J. K. M, O, P. SV, W, and BB are not in
       Moonstone's possession.

       32.    Provided.

       33.    Provided.

       34.    None in Moonstone’s possession.

       35     Unknown at this time discovery is on-going.

       36.    Unknown at this time discovery is on-going.

       37     Unknown at this time discovery is on-going.

                                 CERTIFICATE OF SERVICE


        I 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, ryan.owen@arlaw.com; David K, Oaks, Esquire, David K. Oaks, P.A.
-497 E. Marion Ave. Punta Gorda, FL 33950 doaksesg@ecomeast.net:
Glenn Siegel 17825 Murdock Circle, Suite   A Port Charlotte, Florida 33948,   kim@gienn   siegellaw.com
Christopher Klein cklein@worldwidelaw.com this 30th of December, 2019.


                                                             fluy Ave. C
                                                   ROBERT W. SEGUR, HSQUIRE
                                                   ROBERT W, SEGUR, PBA.
                                                   2828 S. McCall    Road, PMB 56
                                                   Englewood, FL 34224
                                                   941-473-8878
                                                   Fla. Bar No.: 0700932
                                                   legal@segurlaw.net
                                                   Attorney for Moonstone|Holdings