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Filing # 74358879 E-Filed 07/02/2018 10:18:16 AM
IN THE CIRCUIT COURT OF THE
1774 JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE 18-002062 (09)
HIGH LINE PLANNING, LLC, a
Florida Company, CHAD SCHUK, and
JOHN LAZZARO,
Plaintiffs,
vs.
PATRICK MADDEN,
Defendant.
/
DEFENDANT’S AMENDED NOTICE OF INTENT
TO SERVE SUBPOENA DUCES TECUM UPON NON-PARTY
YOU ARE HEREBY NOTIFIED that after ten (10) days from the date of service of
this notice, and if no objection is received from any party, the undersigned will serve the
attached subpoena directed to:
REGIONS BANK
who is not a party, to produce the items listed at the time and place specified in the
subpoena.
CERTIFICATE OF SERVICE
WE CERTIFY that a copy hereof has been electronically filed and served using the
Florida Courts E-Filing Portal on all counsel of record identified on the attached Service
List on July 2, 2018.
COLE, SCOTT & KISSANE, P.A.
Attorneys for Plaintiffs
Esperante Building
222 Lakeview Avenue
Suite 120
West Palm Beach, FL 33401
E-Mail: jonathan.vine@csklegal.com
E-Mail: alan.stlouis@csklegal.com
COLE, SCOTT & KISSANE, P.A.
ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-9200 - (661) 683-8977 FAX
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 7/2/2018 10:18:17 AM.****CASE NO.: CACE 18-002062
E-Mail: sienna.osta@csklegal.com
Telephone: (561) 383-9200
Facsimile: (561) 683-8977
By: /s/ Alan St. Louis
JONATHAN VINE
FL Bar No.: 10966
ALAN ST. LOUIS
FL Bar No.: 70751
SIENNA L. OSTA
FL Bar No.: 124207
SERVICE LIST
Leon N. Patricios, Esq.
Zumpano Patricios & Winker P.A.
312 Minorca Avenue
Coral Gables, FL 33134
|patricios@zpw.law.com
5
COLE, SCOTT & KISSANE, P.A.
ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-9200 - (661) 683-8977 FAXCASE NO.: CACE 18-002062
IN THE CIRCUIT COURT OF THE
1774 JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE 18-002062 (09)
HIGH LINE PLANNING, LLC, a
Florida Company, CHAD SCHUK, and
JOHN LAZZARO,
Plaintiffs,
vs.
PATRICK MADDEN,
Defendant.
fi
SUBPOENA DUCES TECUM
**(Records may be delivered in lieu of appearance in-person)
THE STATE OF FLORIDA:
TO: REGIONS BANK
clo Corporation Service Company
1201 Hays Street
Tallahassee, FL 32301
YOU ARE COMMANDED to appear at COLE, SCOTT & KISSANE, P.A., 222
Lakeview Avenue, Suite 120, West Palm Beach, Florida 33401, on August 2, 2018 at
10:00 a.m., and to have with you at that time and place all documents and information
identified within Exhibit 1 attached hereto for inspection and copying.
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
appears on this subpoena and thereby eliminate your appearance at the time and
place specified above. 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. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY
WILL BE TAKEN.
-3-
COLE, SCOTT & KISSANE, P.A.
ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-9200 - (661) 683-8977 FAXCASE NO.: CACE 18-002062
If you fail to:
(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) 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 this attorney or the court, you shall respond to this subpoena as
directed.
Dated: July 2, 2018
COLE, SCOTT & KISSANE, P.A.
Attorneys for Plaintiffs
Esperante Building
222 Lakeview Avenue
Suite 120
West Palm Beach, Florida 33401
E-Mail: jonathan.vine@csklegal.com
E-Mail: alan.stlouis@csklegal.com
E-Mail: sienna.osta@csklegal.com
Telephone: (561) 383-9200
Facsimile: (561) 683-8977
By: /s/ Alan St. Louis
JONATHAN VINE
FL Bar No.: 10966
ALAN ST. LOUIS
FL Bar No.: 70751
SIENNA L. OSTA
FL Bar No.: 124207
If you are a person with a disability who needs any accommodation in order to
participate in this proceeding, you are entitled, at no cost to you, to the provision of certain
assistance. Please contact the ADA Coordinator, Diana Sobel, Room 20140, 201 S.E.
Sixth Street, Fort Lauderdale, Florida 33301, 954-831-7721 at least 7 days before your
scheduled court appearance, or immediately upon receiving this notification if the time
before the scheduled appearance is less than 7 days; if you are hearing or voice impaired,
call 711.
-4-
COLE, SCOTT & KISSANE, P.A.
ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-9200 - (661) 683-8977 FAXCASE NO.: CACE 18-002062
EXHIBIT 1
Definitions
(a) The singular shall include the plural and vice versa; the terms “and” or “or” shall be
both conjunctive and disjunctive; and the term “including” mean “including without
limitation.”
(b) | The word “document” shall mean any writing, recording, or electronically stored
information in your actual or constructive possession, custody, care or control, which
pertain directly or indirectly, in whole or in part, either to any of the subjects listed below
or to any other matter relevant to the issues in this action, or which are themselves listed
below as specific documents, including, but not limited to: memoranda, notes, messages,
diaries, reports, charts, ledgers, invoices, or computer printouts.
(c) The words “pertain to” or “pertaining to” mean: relates to, refers to, contains,
concerns, describes, embodies, mentions, constitutes, constituting, supports,
corroborates, demonstrates, proves, evidences, shows, refutes, disputes, rebuts,
controverts or contradicts.
(d) | The term “communication” shall mean both oral and written communication, or the
transmittal of information (in the form of facts, ideas, inquiries, or otherwise).
Instructions
(a) For any documents that are stored or maintained in files in the normal course of
business, such documents shall be produced in such files, or in such a manner so as to
preserve and identify the file from which such documents were taken.
DOCUMENTS AND INFORMATION REQUESTED
1. All bank statements pertaining to checking account # MS or savings
account # =.
~5-
COLE, SCOTT & KISSANE, P.A.
ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-9200 - (661) 683-8977 FAX
Preview
Filing # 74358879 E-Filed 07/02/2018 10:18:16 AM IN THE CIRCUIT COURT OF THE 1774 JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 18-002062 (09) HIGH LINE PLANNING, LLC, a Florida Company, CHAD SCHUK, and JOHN LAZZARO, Plaintiffs, vs. PATRICK MADDEN, Defendant. / DEFENDANT’S AMENDED NOTICE OF INTENT TO SERVE SUBPOENA DUCES TECUM UPON NON-PARTY YOU ARE HEREBY NOTIFIED that after ten (10) days from the date of service of this notice, and if no objection is received from any party, the undersigned will serve the attached subpoena directed to: REGIONS BANK who is not a party, to produce the items listed at the time and place specified in the subpoena. CERTIFICATE OF SERVICE WE CERTIFY that a copy hereof has been electronically filed and served using the Florida Courts E-Filing Portal on all counsel of record identified on the attached Service List on July 2, 2018. COLE, SCOTT & KISSANE, P.A. Attorneys for Plaintiffs Esperante Building 222 Lakeview Avenue Suite 120 West Palm Beach, FL 33401 E-Mail: jonathan.vine@csklegal.com E-Mail: alan.stlouis@csklegal.com COLE, SCOTT & KISSANE, P.A. ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-9200 - (661) 683-8977 FAX *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 7/2/2018 10:18:17 AM.****CASE NO.: CACE 18-002062 E-Mail: sienna.osta@csklegal.com Telephone: (561) 383-9200 Facsimile: (561) 683-8977 By: /s/ Alan St. Louis JONATHAN VINE FL Bar No.: 10966 ALAN ST. LOUIS FL Bar No.: 70751 SIENNA L. OSTA FL Bar No.: 124207 SERVICE LIST Leon N. Patricios, Esq. Zumpano Patricios & Winker P.A. 312 Minorca Avenue Coral Gables, FL 33134 |patricios@zpw.law.com 5 COLE, SCOTT & KISSANE, P.A. ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-9200 - (661) 683-8977 FAXCASE NO.: CACE 18-002062 IN THE CIRCUIT COURT OF THE 1774 JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 18-002062 (09) HIGH LINE PLANNING, LLC, a Florida Company, CHAD SCHUK, and JOHN LAZZARO, Plaintiffs, vs. PATRICK MADDEN, Defendant. fi SUBPOENA DUCES TECUM **(Records may be delivered in lieu of appearance in-person) THE STATE OF FLORIDA: TO: REGIONS BANK clo Corporation Service Company 1201 Hays Street Tallahassee, FL 32301 YOU ARE COMMANDED to appear at COLE, SCOTT & KISSANE, P.A., 222 Lakeview Avenue, Suite 120, West Palm Beach, Florida 33401, on August 2, 2018 at 10:00 a.m., and to have with you at that time and place all documents and information identified within Exhibit 1 attached hereto for inspection and copying. 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 appears on this subpoena and thereby eliminate your appearance at the time and place specified above. 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. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. -3- COLE, SCOTT & KISSANE, P.A. ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-9200 - (661) 683-8977 FAXCASE NO.: CACE 18-002062 If you fail to: (1) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) 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 this attorney or the court, you shall respond to this subpoena as directed. Dated: July 2, 2018 COLE, SCOTT & KISSANE, P.A. Attorneys for Plaintiffs Esperante Building 222 Lakeview Avenue Suite 120 West Palm Beach, Florida 33401 E-Mail: jonathan.vine@csklegal.com E-Mail: alan.stlouis@csklegal.com E-Mail: sienna.osta@csklegal.com Telephone: (561) 383-9200 Facsimile: (561) 683-8977 By: /s/ Alan St. Louis JONATHAN VINE FL Bar No.: 10966 ALAN ST. LOUIS FL Bar No.: 70751 SIENNA L. OSTA FL Bar No.: 124207 If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact the ADA Coordinator, Diana Sobel, Room 20140, 201 S.E. Sixth Street, Fort Lauderdale, Florida 33301, 954-831-7721 at least 7 days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711. -4- COLE, SCOTT & KISSANE, P.A. ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-9200 - (661) 683-8977 FAXCASE NO.: CACE 18-002062 EXHIBIT 1 Definitions (a) The singular shall include the plural and vice versa; the terms “and” or “or” shall be both conjunctive and disjunctive; and the term “including” mean “including without limitation.” (b) | The word “document” shall mean any writing, recording, or electronically stored information in your actual or constructive possession, custody, care or control, which pertain directly or indirectly, in whole or in part, either to any of the subjects listed below or to any other matter relevant to the issues in this action, or which are themselves listed below as specific documents, including, but not limited to: memoranda, notes, messages, diaries, reports, charts, ledgers, invoices, or computer printouts. (c) The words “pertain to” or “pertaining to” mean: relates to, refers to, contains, concerns, describes, embodies, mentions, constitutes, constituting, supports, corroborates, demonstrates, proves, evidences, shows, refutes, disputes, rebuts, controverts or contradicts. (d) | The term “communication” shall mean both oral and written communication, or the transmittal of information (in the form of facts, ideas, inquiries, or otherwise). Instructions (a) For any documents that are stored or maintained in files in the normal course of business, such documents shall be produced in such files, or in such a manner so as to preserve and identify the file from which such documents were taken. DOCUMENTS AND INFORMATION REQUESTED 1. All bank statements pertaining to checking account # MS or savings account # =. ~5- COLE, SCOTT & KISSANE, P.A. ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-9200 - (661) 683-8977 FAX