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Filing # 69128897 E-Filed 03/12/2018 02:33:48 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO. 18-001322
KARMEL RUNCIE,
Plaintiff,
INTERNATIONAL VILLAGE
ASSOCIATION, INC. and
DOREEN SYRLIK
Defendants.
PLAINTIFF’S REQUEST FOR INSPECTION TO DEFENDANT INTERNATIONAL
VILLAGE AS: TATION, INC. PURSUANT TO FLA. R. CIV. P. 1.350
TO: Daniel Klein, Esq. (danicl.klcin@ al.com)
Samuel Fallk, Esq. (samuel. fallk@esklegal.com)
9150 South Dadeland Boulevard, Suite 1400
Miami, Florida 33156
PLEASE TAKE NOTICE that, pursuant to Fla. R. Civ. P. 1.350, the undersigned attorney
hereby requests temporary access to Defendant, International Village’s tangible file(s) containing
Plaintiff’s permanent resident application and to the official records of Defendant, International
Village, described herein, to inspect and/or copy the documents, at the time, date and location
indicated below.
Time/Date Location
9:30 a.m. Cole, Scott & Kissane P.A
April 20, 2018 Lakeside Office Center
600 North Pine Island Road, Ste. 500
Plantation, FL 33324
Dated: March 12, 2018
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 3/12/2018 2:33:48 PM.****DEFINITIONS
As used herein, the term “document” or “documents” shall mean every writing of record
of every type and description that is in the possession, custody, or control of Defendant,
including, without limitation, correspondence, statements, affidavits, memoranda, stenographic
and handwritten notes, diagrams, studies, publications, books, pamphlets, pictures, drawings and
schematics of every type, film, voice recordings, audio tape recordings, maps, reports, surveys,
minutes, telegrams, telexes, contracts, memoranda of agreement, diaries, graphs, checks, bank
statements, income tax forms, other forms, microfilms, statistical computations, data processing
cards, computer records and computer tapes and printouts or things similar to any of the
foregoing; and every copy of such document where the original is not in the possession, custody,
or control of Defendant, or Defendant’s counsel. Any such document bearing on any sheet or
side thereof, any marks such as (but not limited to) initials, stamped indicia, comments or
notations, or any character not a part of the original text or photographic reproduction thereof, is
to be considered and identified as a separate document.
As used herein, the term “communication” or “communications” means any transmission
of information from one person to another, including without limitation by personal meeting,
telephone, letter, telegraph, electronic mail ("e-mail"), electronic bulletin boards, electronic "chat
rooms," and other similar forms of electronic correspondences, teleconference, facsimile, or telexDOCUME!
'S TO BE INSPECTED AND/OR COPIED
1. The entire file for 3680 Inverrary Drive, Unit 3B Lauderhill, Florida 33319.
2. All applications and supporting documents! regarding Plaintiff's permanent
residency application.
3. All communications regarding Plaintiff’s permanent resident application, with the
exception of any confidential attorney-client communications.
4. All documents received from Tenant Evaluations LLC regarding Plaintiff’s
permanent resident application.
5. All rules, regulations, policies and/or procedures regarding the review and/or
approval of permanent resident applications.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on March 12, 2018, the foregoing was served via facsimile and
electronically filed with the Clerk of Court using the Florida E-Filing Portal and electronically
delivered to Daniel Klein, Esq. (danicl.klein@écsklegal.com; tania.cabrera@esklegal.com);
Samuel Fallk, Esq. (samucl.fallk@csklegal.com; linda. vitti@esklegal.com).
By: Chelsea Lewis, Esq.
Chelsea Lewis, Esq.
Fla. Bar No. 111607
Lewis Law LLC
151 N. Nob Hill Rd., Suite 348
Plantation, FL 33324
chelsealewispa@ gmail.com
Tel. 954-870-9734
Fax 1-888-388-7360
Preview
Filing # 69128897 E-Filed 03/12/2018 02:33:48 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. 18-001322 KARMEL RUNCIE, Plaintiff, INTERNATIONAL VILLAGE ASSOCIATION, INC. and DOREEN SYRLIK Defendants. PLAINTIFF’S REQUEST FOR INSPECTION TO DEFENDANT INTERNATIONAL VILLAGE AS: TATION, INC. PURSUANT TO FLA. R. CIV. P. 1.350 TO: Daniel Klein, Esq. (danicl.klcin@ al.com) Samuel Fallk, Esq. (samuel. fallk@esklegal.com) 9150 South Dadeland Boulevard, Suite 1400 Miami, Florida 33156 PLEASE TAKE NOTICE that, pursuant to Fla. R. Civ. P. 1.350, the undersigned attorney hereby requests temporary access to Defendant, International Village’s tangible file(s) containing Plaintiff’s permanent resident application and to the official records of Defendant, International Village, described herein, to inspect and/or copy the documents, at the time, date and location indicated below. Time/Date Location 9:30 a.m. Cole, Scott & Kissane P.A April 20, 2018 Lakeside Office Center 600 North Pine Island Road, Ste. 500 Plantation, FL 33324 Dated: March 12, 2018 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 3/12/2018 2:33:48 PM.****DEFINITIONS As used herein, the term “document” or “documents” shall mean every writing of record of every type and description that is in the possession, custody, or control of Defendant, including, without limitation, correspondence, statements, affidavits, memoranda, stenographic and handwritten notes, diagrams, studies, publications, books, pamphlets, pictures, drawings and schematics of every type, film, voice recordings, audio tape recordings, maps, reports, surveys, minutes, telegrams, telexes, contracts, memoranda of agreement, diaries, graphs, checks, bank statements, income tax forms, other forms, microfilms, statistical computations, data processing cards, computer records and computer tapes and printouts or things similar to any of the foregoing; and every copy of such document where the original is not in the possession, custody, or control of Defendant, or Defendant’s counsel. Any such document bearing on any sheet or side thereof, any marks such as (but not limited to) initials, stamped indicia, comments or notations, or any character not a part of the original text or photographic reproduction thereof, is to be considered and identified as a separate document. As used herein, the term “communication” or “communications” means any transmission of information from one person to another, including without limitation by personal meeting, telephone, letter, telegraph, electronic mail ("e-mail"), electronic bulletin boards, electronic "chat rooms," and other similar forms of electronic correspondences, teleconference, facsimile, or telexDOCUME! 'S TO BE INSPECTED AND/OR COPIED 1. The entire file for 3680 Inverrary Drive, Unit 3B Lauderhill, Florida 33319. 2. All applications and supporting documents! regarding Plaintiff's permanent residency application. 3. All communications regarding Plaintiff’s permanent resident application, with the exception of any confidential attorney-client communications. 4. All documents received from Tenant Evaluations LLC regarding Plaintiff’s permanent resident application. 5. All rules, regulations, policies and/or procedures regarding the review and/or approval of permanent resident applications. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on March 12, 2018, the foregoing was served via facsimile and electronically filed with the Clerk of Court using the Florida E-Filing Portal and electronically delivered to Daniel Klein, Esq. (danicl.klein@écsklegal.com; tania.cabrera@esklegal.com); Samuel Fallk, Esq. (samucl.fallk@csklegal.com; linda. vitti@esklegal.com). By: Chelsea Lewis, Esq. Chelsea Lewis, Esq. Fla. Bar No. 111607 Lewis Law LLC 151 N. Nob Hill Rd., Suite 348 Plantation, FL 33324 chelsealewispa@ gmail.com Tel. 954-870-9734 Fax 1-888-388-7360