On May 10, 115 a
No Value
was filed
involving a dispute between
Llerena, Ashel Alexander,
and
Granny'S Garden Ii Inc,
Rodriguez Chavez, Adrian,
for CIRCUIT CIVIL
in the District Court of Osceola County.
Preview
Filing # 189181448 E-Filed 01/05/2024 01:05:14 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY FLORIDA
ASBEL ALEXANDER LLERENA, CASE NO: 2020 CA 002872 AN
Plaintiff,
vs.
ADRIAN RODRIGUEZ CHAVEZ,
and GRANNY’S GARDEN II, INC.,
Defendant.
/
REQUEST TO PRODUCE
Plaintiff, ASBEL ALEXANDER LLERENA, in accordance with Rule l.350 of the Florida
Rules of Civil Procedure, requests the Defendants, ADRIAN RODRIGUEZ CHAVEZ, and
GRANNY’S GARDEN II, INC., to produce to the Plaintiff at the offices of Morgan and Morgan,
200 Broadway Avenue, Kissimmee, Florida, within thirty (30) days of service, or such other time
as might be mutually agreed upon by the attorneys for the parties, for the purpose of inspection
and copying the matters described on the attached list.
The Plaintiff need to examine, copy and inspect the described items and are unable to obtain
said described items by other means, or alternatively, Plaintiff is otherwise entitled to said items
under the applicable Florida Rules of Civil Procedure and case law interpreting same.
Defendant shall produce the following:
1. A copy of any and all surveillance videotapes or digital video recordings taken of
Plaintiff, ASBEL ALEXANDER LLERENA, by any entity on your behalf including
investigation entities or individuals.
2. A copy of any and all reports created during the surveillance of Plaintiff, ASBEL
ALEXANDER LLERENA.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on January 5, 2023, I electronically filed the foregoing with
the Clerk of the Courts by using the Florida Courts eFiling Portal. I further certify that Pursuant to
Rule 2.516(b)(1) I forwarded the foregoing this same day via Email to: Scott Shelton, Esq. of
Cole, Scott & Kissane, P.A., Scott.Shelton@csklegal.com; gary.lewis@csklegal.com;
Sandra.mcintosh@csklegal.com.
/s/ Melissa Alzate
Melissa Alzate, Esquire
FBN 1013530
Morgan & Morgan Orlando P.A.
198 Broadway Avenue
Kissimmee, Florida 34741
Telephone: (407) 452-1597
Facsimile: (407) 452-1623
Primary Email: MAlzate@forthepeople.com
Secondary Email: MCorianoLopez@forthepeople.com
Tertiary Email: VPagan@forthepeople.com
Attorney for Plaintiff
Document Filed Date
March 02, 2024
Case Filing Date
May 10, 115
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Filing # 189181448 E-Filed 01/05/2024 01:05:14 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY FLORIDA ASBEL ALEXANDER LLERENA, CASE NO: 2020 CA 002872 AN Plaintiff, vs. ADRIAN RODRIGUEZ CHAVEZ, and GRANNY’S GARDEN II, INC., Defendant. / REQUEST TO PRODUCE Plaintiff, ASBEL ALEXANDER LLERENA, in accordance with Rule l.350 of the Florida Rules of Civil Procedure, requests the Defendants, ADRIAN RODRIGUEZ CHAVEZ, and GRANNY’S GARDEN II, INC., to produce to the Plaintiff at the offices of Morgan and Morgan, 200 Broadway Avenue, Kissimmee, Florida, within thirty (30) days of service, or such other time as might be mutually agreed upon by the attorneys for the parties, for the purpose of inspection and copying the matters described on the attached list. The Plaintiff need to examine, copy and inspect the described items and are unable to obtain said described items by other means, or alternatively, Plaintiff is otherwise entitled to said items under the applicable Florida Rules of Civil Procedure and case law interpreting same. Defendant shall produce the following: 1. A copy of any and all surveillance videotapes or digital video recordings taken of Plaintiff, ASBEL ALEXANDER LLERENA, by any entity on your behalf including investigation entities or individuals. 2. A copy of any and all reports created during the surveillance of Plaintiff, ASBEL ALEXANDER LLERENA. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on January 5, 2023, I electronically filed the foregoing with the Clerk of the Courts by using the Florida Courts eFiling Portal. I further certify that Pursuant to Rule 2.516(b)(1) I forwarded the foregoing this same day via Email to: Scott Shelton, Esq. of Cole, Scott & Kissane, P.A., Scott.Shelton@csklegal.com; gary.lewis@csklegal.com; Sandra.mcintosh@csklegal.com. /s/ Melissa Alzate Melissa Alzate, Esquire FBN 1013530 Morgan & Morgan Orlando P.A. 198 Broadway Avenue Kissimmee, Florida 34741 Telephone: (407) 452-1597 Facsimile: (407) 452-1623 Primary Email: MAlzate@forthepeople.com Secondary Email: MCorianoLopez@forthepeople.com Tertiary Email: VPagan@forthepeople.com Attorney for Plaintiff