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Filing # 176629703 E-Filed 07/03/2023 12:28:30 PM
IN THE CIRCUIT COURT, THIRD
JUDICIAL CIRCUIT, IN AND FOR
MADISON COUNTY, FLORIDA.
CASE NO. 2023-071-CA
CENTRA NCFL PROPERTIES LLC,
Plaintiff,
VS.
S & S SENIOR HOUSING OF MADISON, LLC;
KENNETH MARK SIMONS; JAMES R. BAILEY;
VICTOR W. MASON; UNITED STATES OF
AMERICA DEPARTMENT OF TREASURY;
STATE OF FLORIDA DEPARTMENT OF
REVENUE; STEVE HALL CARPET & TILE,
LLC; UNKNOWN TENANT 1; UNKNOWN
TENANT 2; S & S SENIOR HOUSING OF
BURNSVILLE, LLC; S & S SENIOR HOUSING
OF LOUISBURG, LLC; and TROY & JENNY
ENTERPRISES, INC., a Florida corporation,
Defendants.
DEFENDANT’S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF
The Defendant, Troy & Jenny Enterprises, Inc., a Florida corporation, through the
undersigned counsel, and pursuant to Rule 1.350, Florida Rules of Civil Procedure, propounds the
following Requests for Production to the Plaintiff, Centra NCFL Properties LLC (“Centra”), which
shall be responded to within thirty (30) days from the date of service hereof.
DEFINITIONS
1 The words "Centra" or "you" or "your" means the Plaintiff, Centra NCFL Properties
LLC (“Centra” and all agents, employees, representatives or other persons or entities related to
said party or acting on behalf of said party during any of the time periods identified in the
Complaint.
1
Electronically Filed Madison Case # 2023000071CAAXMX 07/03/2023 12:28:30 PM
2 This Request for Production requests and shall be construed to include
electronically stored information pursuant to Rule | .350(b), Florida Rules of Civil Procedure. All
data should be produced in its native format or as close to native as practicable (e.g., email
in a PST file). Pictures of hard copy documents (TIFF, PDF, etc.) should only be created and
produced after consultation with the undersigned attorney.
3 The word "Document" shall be defined to the broadest extent permitted under the
Florida Rules of Civil Procedure and includes the original and any non-identical copy (whether
different from the original because of notes made on or attachments to such copy or because of
metadata or otherwise) of all media by which data or information may be communicated or
maintained including, without limitation, writings, drawings, graphs, charts, transcripts,
photographs, film, videotapes, tapes, computer printouts, computer disks or tapes, data processing
records, and other data compilations from which information can be obtained; all correspondence,
telegrams, and other written communications, including without limitation electronic mail; all
contracts, agreements, confirmations, invoices, receipts, adding machine tapes, calculations,
ledgers, journals and books of account; all notes, memoranda, analyses, reports, studies, forecasts,
work papers and minutes of meetings, all books, pamphlets, newspaper and periodical articles and
clippings, lists, manuals, guides and tables; and all other written, printed, typed, recorded or
graphic material of any nature whatsoever. The term document specifically includes drafts of any
of the requested materials.
4 The word "Metadata" shall be defined to the broadest extent permitted under the
Florida Rules of Civil Procedure, and consists of information that is usually not visible to the user
and reflects characteristics of the ESI (such as origin, usage, structure, and alteration). Systems
and applications automatically generate most metadata. For example, metadata can describe how,
when, and by whom ESI was created, accessed, and modified. Some metadata, such as file dates
and sizes, can easily be seen by users. Other metadata is hidden or embedded and generally
unavailable to computer users. There can be hundreds or even thousands of fields of metadata
associated with an individual file. In fact, some ESI may be comprised more of metadata than data.
5 The words "Native format" shall be defined to the broadest extent permitted under
the Florida Rules of Civil Procedure, and consists of electronically stored information in a
reasonably usable form so that is searchable. A native format production consists of responsive
ESI in the form that it is ordinarily maintained on the producing party's systems, and it usually
includes the metadata associated with the documents. The benefits of native production include
likely savings in costs and time compared to other formats, which require conversion of the ESI
into images and associated load files, and avoiding later disputes over whether the format selected
was reasonably usable. Many review tools allow for common native file types to be viewed on the
review platform, making it unnecessary to manually open each file in the associated application.
[Example: Native format is the file structure of an electronic document as defined by the original
creating application. If a spreadsheet was created using Microsoft Excel, then the native format of
the spreadsheet would be its original Microsoft Excel format. If the producing party takes native
documents and converts them to another electronic format such as searchable PDFs, RTF files,
MHT files etc., the resultant production is not in native format.]
6. The words "Person" or "Persons" mean all natural persons ("individual" or
"individuals") and entities, including without limitation: corporations, companies, partnerships,
limited partnerships, joint ventures, trusts, estates, associations, public agencies, departments,
bureaus and boards.
7
The word "Communication" means every manner or means of disclosure, transfer
or exchange, and every disclosure, transfer or exchange, of information whether orally or face-to-
face, or by telephone, mail, E-Mail, personal delivery, document, computer transmission,
interactive medium transmission, or otherwise.
8 The word "Electronic data" means all information stored in a digital format.
Electronic data includes, but is not limited to, electronic mail messages and attachments, contacts,
journal entries, calendar entries, word processing documents, spreadsheets, databases including all
records and fields and structural information, charts, graphs, and any and all miscellaneous files
responsive to the following requests. The responding party is expected to search for any and all
information stored on smart phones, tablets, hard disks, floppy disks, CDs, DVDs, USB devices,
Personal Digital Assistants (such as Palm Pilots, Blackberrys and Treos), and in any other vehicle
for digital data storage and/or transmittal. The term electronic data also includes the file, folder
tabs and/or containers and labels appended to, or associated with, any physical storage device
associated with the information described above.
9. As used in this First Request for Production, the phrases:
“Loan” shall refer to the $4,200,000.00 loan made by Centra to various entities
names in the Complaint.
“Burnsville Property” shall refer to the property identified by the Yancey County
Property Appraiser's Office as Parcel Number 081016748727000. The site is
further described in the Official Record Book 781, Page 34. The site is a rectangular
shaped parcel and is located at the northeastern corner of Love Fox Road (also
known as West Church Road) and Franklin Drive. According to the Yancey County
Property Appraiser'’s website, the site contains 198,633+ square feet (4.56 acres) of
total area.
“Louisburg Property” shall refer to property identified by the Franklin County
Property Appraiser's Office as Parcel ID 2847-77-8254. According to the plat, the
subject contains 176,8540 square feet (4.060 acres) of the area and is irregularly
shaped.
“Madison Property” shall refer to the property generally described via a lengthy
metes and bounds description of property lying in Section 30, Township 2 North,
Range 10 East; Madison County, Florida, and further identified as being at 765 and
855 NE Delphinium Street and NE Dill Street Madison, Florida 32340.
“Appraisal Report” shall mean any communication, written or oral, of an appraisal,
appraisal review, appraisal consulting service, analysis, opinion, or conclusion
relating to the nature, quality, value, or utility of a specified interest in, or aspect
of, identified real property, and includes any report communicating an appraisal
analysis, opinion, or conclusion of value, regardless of title.
10. The singular and plural forms shall be construed interchangeably so as to bring
within the scope of this document request any information which might otherwise be construed
as outside their scope.
11. "And" and "or" shall be construed interchangeably so as to bring within the scope
of this document request any information which might otherwise be construed as outside their
scope.
12. "Any" and "all" shall be construed to bring within the scope of this request any
information which might be construed to relate to the subject matter of the request.
13. The use of the singular form of any word includes the plural and vice versa. The
masculine includes the feminine and neuter genders. The past tense includes the present tense
where the clear meaning is not distorted by the change in tense.
14. All other names or terms herein not specifically defined or identified shall have the
same meaning as is commonly understood and referred to by and among the parties.
1S. Unless otherwise stated herein, the "relevant time period" encompassed by this
subpoena shall be from January 1, 2021, through the date of Centra’s Response to this Request for
Production.
16. "Possession, custody, or control" as used herein shall have the same meaning as
in Rule 34(a) of the Federal Rules of Civil Procedure.
INSTRUCTIONS
1 This document request is continuing in nature and when new documents,
knowledge or information comes to the attention of the Plaintiff the documents, knowledge or
information supplied in response to this First Request for Production document request shall be
supplemented forthwith.
2 If you at any time you had possession, custody, or control of any document
requested herein, and such document has been lost, destroyed, discarded, or is not presently in
your possession, these documents shall be identified as completely as possible, by providing the
following information:
a. The names of the authors of the document;
b. The names of the persons to whom the documents or copies were sent;
Cc The date of the document;
The date on which the document was received by each addressee, copyee, or its
recipients;
A description of the nature and subject matter of the document that is as complete
as possible;
The date on which the document was lost, discarded, or destroyed; and
The manner in which the document was lost, discarded, or destroyed.
If you assert a privilege, work product immunity, or decline to provide a response
on the basis of some other objection, then:
identify and describe the document or communication in question, including its
title, its general subject matter, its date and its author;
describe the basis for the asserted privilege or objection;
identify every person to whom the document was sent, or every person present
when the communication was made; and
identify the present custodian of the document, if any, and include sufficient facts
for the Court to make a full determination of whether the claim or objection is valid.
4 If any one or more of these requests is or are objected to on the grounds of privilege,
overbreadth, vagueness or any similar ground, you are to respond to each such request as narrowed
to conform with the objection.
5 Where a request calls for documents, some of which are known to you and some of
which are not, provide those documents which are known and identify those documents which are
not known.
6. Please produce all documents and things within your possession, custody or
control.
7
Where a request calls for documents known to you on the basis of hearsay, indicate
that the documents are being supplied on that basis and the source and manner in which they came
to your attention.
8 In no event is any response to be left blank or any request to go unresponded to. If
a response to a request is "none" "unknown," such statement should also be written in the
response.
9 Unless you produce the documents as they are kept in the usual course of business,
identify in your written response, as well as affixing a label on each document identifying as such,
the particular request(s) to which each document responds, even if a document responds to more
than one request (in that case, identify each request). Unless you produce the requested documents
as they are kept in the usual course of business, please do not produce an undifferentiated group
of documents without identifying each document by the particular request(s) to which each
document responds.
10. Unless you produce the documents as they are kept in the usual course of business,
please produce all documents at the offices of Defendant's counsel, 320 White Avenue S.E., Live
Oak, Florida 32064.
11. You may furnish the requested documents in a computer readable electronic storage
format.
12. Copies of documents which are identical duplicates of other documents which have
already been produced for inspection and copying in this action need not be produced again, except
that the duplicates must be produced if handwritten or any other type of notes or similar
intelligence appear thereon or are attached thereto, including markings on slips indicating the
routing of the document to individuals or organizations.
THE ITEMS TO BE PRODUCED ARE DESCRIBED AS FOLLOWS:
The entire Loan file.
Complete payment history for the Loan.
All Appraisal Reports of the Burnsville Property.
All Appraisal Reports of the Louisburg Property.
All Appraisal Reports of the Madison Property.
6. Copy of all foreclosure complaints, deed of trust enforcement actions and
documents of any nature in which Centra has commenced, sought to commence, attempted or
threatened legal action, enforcement and/or collection of any kind of its Loan with respect to the
Burnsville Property.
7
Copy of all foreclosure complaints, deed of trust enforcement actions and
documents of any nature in which Centra has commenced, sought to commence, attempted or
threatened legal action, enforcement and/or collection of any kind of its Loan with respect to the
Louisburg Property.
Date: July 3, 2023.
ANDREW J. DECKER, III, PLLC
By. /s/ AndrewJ. Decker, IIT
Andrew J. Decker, III
Florida Bar No. 267211
320 White Avenue
Live Oak, Florida 32064
Telephone: (386) 364-4440
Email: andy@decker.law
Counsel for Defendant,
Troy & Jenny Enterprises, Inc.
CERTIFICATE OF SERVICE
I CERTIFY, in accordance with Rule 2.516, Florida Rules of Judicial Administration, that
as a registered participant who uses the Florida Courts e-Filing Portal I have filed and served a
true and correct copy of the foregoing via the e-Filing Portal on this 3rd day of July, 2023, to the
following:
Amy M. Kiser, Esquire Cary A. “Bo” Hardee, III, Esquire
Gilbert Garcia Group, P.A. Hardee Law Firm, P.A.
Sapphire Title & Escrow Company Post Office Drawer 450
2313 West Violet Street Madison, Florida 32341
Tampa, Florida 33603 bohardee@aol.com
akiser@gilbertgrouplaw.com
Byron Wright, III, Esquire
Katherine C. Kerwin, Esquire Bruner Wright, P.A.
Assistant United States Attorney 2810 Remington Green Circle
111 North Adams Street, 4th Floor Tallahassee, Florida 32308
Tallahassee, Florida 32301 twright@brunerwright.con
safin.state.court@usdoj.gov
ANDREW J. DECKER, III, PLLC
By: /s/ AndrewJ. Decker, IIT
Andrew J. Decker, III
Florida Bar No. 267211
320 White Avenue
Live Oak, Florida 32064
Telephone: (386) 364-4440
Email: andy@decker.law
Counsel for Defendant,
Troy & Jenny Enterprises, Inc
10
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Filing # 176629703 E-Filed 07/03/2023 12:28:30 PM IN THE CIRCUIT COURT, THIRD JUDICIAL CIRCUIT, IN AND FOR MADISON COUNTY, FLORIDA. CASE NO. 2023-071-CA CENTRA NCFL PROPERTIES LLC, Plaintiff, VS. S & S SENIOR HOUSING OF MADISON, LLC; KENNETH MARK SIMONS; JAMES R. BAILEY; VICTOR W. MASON; UNITED STATES OF AMERICA DEPARTMENT OF TREASURY; STATE OF FLORIDA DEPARTMENT OF REVENUE; STEVE HALL CARPET & TILE, LLC; UNKNOWN TENANT 1; UNKNOWN TENANT 2; S & S SENIOR HOUSING OF BURNSVILLE, LLC; S & S SENIOR HOUSING OF LOUISBURG, LLC; and TROY & JENNY ENTERPRISES, INC., a Florida corporation, Defendants. DEFENDANT’S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF The Defendant, Troy & Jenny Enterprises, Inc., a Florida corporation, through the undersigned counsel, and pursuant to Rule 1.350, Florida Rules of Civil Procedure, propounds the following Requests for Production to the Plaintiff, Centra NCFL Properties LLC (“Centra”), which shall be responded to within thirty (30) days from the date of service hereof. DEFINITIONS 1 The words "Centra" or "you" or "your" means the Plaintiff, Centra NCFL Properties LLC (“Centra” and all agents, employees, representatives or other persons or entities related to said party or acting on behalf of said party during any of the time periods identified in the Complaint. 1 Electronically Filed Madison Case # 2023000071CAAXMX 07/03/2023 12:28:30 PM 2 This Request for Production requests and shall be construed to include electronically stored information pursuant to Rule | .350(b), Florida Rules of Civil Procedure. All data should be produced in its native format or as close to native as practicable (e.g., email in a PST file). Pictures of hard copy documents (TIFF, PDF, etc.) should only be created and produced after consultation with the undersigned attorney. 3 The word "Document" shall be defined to the broadest extent permitted under the Florida Rules of Civil Procedure and includes the original and any non-identical copy (whether different from the original because of notes made on or attachments to such copy or because of metadata or otherwise) of all media by which data or information may be communicated or maintained including, without limitation, writings, drawings, graphs, charts, transcripts, photographs, film, videotapes, tapes, computer printouts, computer disks or tapes, data processing records, and other data compilations from which information can be obtained; all correspondence, telegrams, and other written communications, including without limitation electronic mail; all contracts, agreements, confirmations, invoices, receipts, adding machine tapes, calculations, ledgers, journals and books of account; all notes, memoranda, analyses, reports, studies, forecasts, work papers and minutes of meetings, all books, pamphlets, newspaper and periodical articles and clippings, lists, manuals, guides and tables; and all other written, printed, typed, recorded or graphic material of any nature whatsoever. The term document specifically includes drafts of any of the requested materials. 4 The word "Metadata" shall be defined to the broadest extent permitted under the Florida Rules of Civil Procedure, and consists of information that is usually not visible to the user and reflects characteristics of the ESI (such as origin, usage, structure, and alteration). Systems and applications automatically generate most metadata. For example, metadata can describe how, when, and by whom ESI was created, accessed, and modified. Some metadata, such as file dates and sizes, can easily be seen by users. Other metadata is hidden or embedded and generally unavailable to computer users. There can be hundreds or even thousands of fields of metadata associated with an individual file. In fact, some ESI may be comprised more of metadata than data. 5 The words "Native format" shall be defined to the broadest extent permitted under the Florida Rules of Civil Procedure, and consists of electronically stored information in a reasonably usable form so that is searchable. A native format production consists of responsive ESI in the form that it is ordinarily maintained on the producing party's systems, and it usually includes the metadata associated with the documents. The benefits of native production include likely savings in costs and time compared to other formats, which require conversion of the ESI into images and associated load files, and avoiding later disputes over whether the format selected was reasonably usable. Many review tools allow for common native file types to be viewed on the review platform, making it unnecessary to manually open each file in the associated application. [Example: Native format is the file structure of an electronic document as defined by the original creating application. If a spreadsheet was created using Microsoft Excel, then the native format of the spreadsheet would be its original Microsoft Excel format. If the producing party takes native documents and converts them to another electronic format such as searchable PDFs, RTF files, MHT files etc., the resultant production is not in native format.] 6. The words "Person" or "Persons" mean all natural persons ("individual" or "individuals") and entities, including without limitation: corporations, companies, partnerships, limited partnerships, joint ventures, trusts, estates, associations, public agencies, departments, bureaus and boards. 7 The word "Communication" means every manner or means of disclosure, transfer or exchange, and every disclosure, transfer or exchange, of information whether orally or face-to- face, or by telephone, mail, E-Mail, personal delivery, document, computer transmission, interactive medium transmission, or otherwise. 8 The word "Electronic data" means all information stored in a digital format. Electronic data includes, but is not limited to, electronic mail messages and attachments, contacts, journal entries, calendar entries, word processing documents, spreadsheets, databases including all records and fields and structural information, charts, graphs, and any and all miscellaneous files responsive to the following requests. The responding party is expected to search for any and all information stored on smart phones, tablets, hard disks, floppy disks, CDs, DVDs, USB devices, Personal Digital Assistants (such as Palm Pilots, Blackberrys and Treos), and in any other vehicle for digital data storage and/or transmittal. The term electronic data also includes the file, folder tabs and/or containers and labels appended to, or associated with, any physical storage device associated with the information described above. 9. As used in this First Request for Production, the phrases: “Loan” shall refer to the $4,200,000.00 loan made by Centra to various entities names in the Complaint. “Burnsville Property” shall refer to the property identified by the Yancey County Property Appraiser's Office as Parcel Number 081016748727000. The site is further described in the Official Record Book 781, Page 34. The site is a rectangular shaped parcel and is located at the northeastern corner of Love Fox Road (also known as West Church Road) and Franklin Drive. According to the Yancey County Property Appraiser'’s website, the site contains 198,633+ square feet (4.56 acres) of total area. “Louisburg Property” shall refer to property identified by the Franklin County Property Appraiser's Office as Parcel ID 2847-77-8254. According to the plat, the subject contains 176,8540 square feet (4.060 acres) of the area and is irregularly shaped. “Madison Property” shall refer to the property generally described via a lengthy metes and bounds description of property lying in Section 30, Township 2 North, Range 10 East; Madison County, Florida, and further identified as being at 765 and 855 NE Delphinium Street and NE Dill Street Madison, Florida 32340. “Appraisal Report” shall mean any communication, written or oral, of an appraisal, appraisal review, appraisal consulting service, analysis, opinion, or conclusion relating to the nature, quality, value, or utility of a specified interest in, or aspect of, identified real property, and includes any report communicating an appraisal analysis, opinion, or conclusion of value, regardless of title. 10. The singular and plural forms shall be construed interchangeably so as to bring within the scope of this document request any information which might otherwise be construed as outside their scope. 11. "And" and "or" shall be construed interchangeably so as to bring within the scope of this document request any information which might otherwise be construed as outside their scope. 12. "Any" and "all" shall be construed to bring within the scope of this request any information which might be construed to relate to the subject matter of the request. 13. The use of the singular form of any word includes the plural and vice versa. The masculine includes the feminine and neuter genders. The past tense includes the present tense where the clear meaning is not distorted by the change in tense. 14. All other names or terms herein not specifically defined or identified shall have the same meaning as is commonly understood and referred to by and among the parties. 1S. Unless otherwise stated herein, the "relevant time period" encompassed by this subpoena shall be from January 1, 2021, through the date of Centra’s Response to this Request for Production. 16. "Possession, custody, or control" as used herein shall have the same meaning as in Rule 34(a) of the Federal Rules of Civil Procedure. INSTRUCTIONS 1 This document request is continuing in nature and when new documents, knowledge or information comes to the attention of the Plaintiff the documents, knowledge or information supplied in response to this First Request for Production document request shall be supplemented forthwith. 2 If you at any time you had possession, custody, or control of any document requested herein, and such document has been lost, destroyed, discarded, or is not presently in your possession, these documents shall be identified as completely as possible, by providing the following information: a. The names of the authors of the document; b. The names of the persons to whom the documents or copies were sent; Cc The date of the document; The date on which the document was received by each addressee, copyee, or its recipients; A description of the nature and subject matter of the document that is as complete as possible; The date on which the document was lost, discarded, or destroyed; and The manner in which the document was lost, discarded, or destroyed. If you assert a privilege, work product immunity, or decline to provide a response on the basis of some other objection, then: identify and describe the document or communication in question, including its title, its general subject matter, its date and its author; describe the basis for the asserted privilege or objection; identify every person to whom the document was sent, or every person present when the communication was made; and identify the present custodian of the document, if any, and include sufficient facts for the Court to make a full determination of whether the claim or objection is valid. 4 If any one or more of these requests is or are objected to on the grounds of privilege, overbreadth, vagueness or any similar ground, you are to respond to each such request as narrowed to conform with the objection. 5 Where a request calls for documents, some of which are known to you and some of which are not, provide those documents which are known and identify those documents which are not known. 6. Please produce all documents and things within your possession, custody or control. 7 Where a request calls for documents known to you on the basis of hearsay, indicate that the documents are being supplied on that basis and the source and manner in which they came to your attention. 8 In no event is any response to be left blank or any request to go unresponded to. If a response to a request is "none" "unknown," such statement should also be written in the response. 9 Unless you produce the documents as they are kept in the usual course of business, identify in your written response, as well as affixing a label on each document identifying as such, the particular request(s) to which each document responds, even if a document responds to more than one request (in that case, identify each request). Unless you produce the requested documents as they are kept in the usual course of business, please do not produce an undifferentiated group of documents without identifying each document by the particular request(s) to which each document responds. 10. Unless you produce the documents as they are kept in the usual course of business, please produce all documents at the offices of Defendant's counsel, 320 White Avenue S.E., Live Oak, Florida 32064. 11. You may furnish the requested documents in a computer readable electronic storage format. 12. Copies of documents which are identical duplicates of other documents which have already been produced for inspection and copying in this action need not be produced again, except that the duplicates must be produced if handwritten or any other type of notes or similar intelligence appear thereon or are attached thereto, including markings on slips indicating the routing of the document to individuals or organizations. THE ITEMS TO BE PRODUCED ARE DESCRIBED AS FOLLOWS: The entire Loan file. Complete payment history for the Loan. All Appraisal Reports of the Burnsville Property. All Appraisal Reports of the Louisburg Property. All Appraisal Reports of the Madison Property. 6. Copy of all foreclosure complaints, deed of trust enforcement actions and documents of any nature in which Centra has commenced, sought to commence, attempted or threatened legal action, enforcement and/or collection of any kind of its Loan with respect to the Burnsville Property. 7 Copy of all foreclosure complaints, deed of trust enforcement actions and documents of any nature in which Centra has commenced, sought to commence, attempted or threatened legal action, enforcement and/or collection of any kind of its Loan with respect to the Louisburg Property. Date: July 3, 2023. ANDREW J. DECKER, III, PLLC By. /s/ AndrewJ. Decker, IIT Andrew J. Decker, III Florida Bar No. 267211 320 White Avenue Live Oak, Florida 32064 Telephone: (386) 364-4440 Email: andy@decker.law Counsel for Defendant, Troy & Jenny Enterprises, Inc. CERTIFICATE OF SERVICE I CERTIFY, in accordance with Rule 2.516, Florida Rules of Judicial Administration, that as a registered participant who uses the Florida Courts e-Filing Portal I have filed and served a true and correct copy of the foregoing via the e-Filing Portal on this 3rd day of July, 2023, to the following: Amy M. Kiser, Esquire Cary A. “Bo” Hardee, III, Esquire Gilbert Garcia Group, P.A. Hardee Law Firm, P.A. Sapphire Title & Escrow Company Post Office Drawer 450 2313 West Violet Street Madison, Florida 32341 Tampa, Florida 33603 bohardee@aol.com akiser@gilbertgrouplaw.com Byron Wright, III, Esquire Katherine C. Kerwin, Esquire Bruner Wright, P.A. Assistant United States Attorney 2810 Remington Green Circle 111 North Adams Street, 4th Floor Tallahassee, Florida 32308 Tallahassee, Florida 32301 twright@brunerwright.con safin.state.court@usdoj.gov ANDREW J. DECKER, III, PLLC By: /s/ AndrewJ. Decker, IIT Andrew J. Decker, III Florida Bar No. 267211 320 White Avenue Live Oak, Florida 32064 Telephone: (386) 364-4440 Email: andy@decker.law Counsel for Defendant, Troy & Jenny Enterprises, Inc 10