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Filing # 48148117 E-Filed 10/26/2016 07:26:22 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE-16-011606 (13)
YARIV ALIMA,
Plaintiff/Counter-Defendant,
VS.
ATMOS TECHNOLOGY LLC,
ATMOS INVESTMENTS LLC,
CESY GROUP LLC,
ELH PRODUCTS, LLC,
ATMOS NATION LLC,
SMJ MARKETING, INC.,
IMPORT NATION, LLC,
CHARLY BENASSAYAG, P.A.,
ELI EROCH,
SHLOMI BITON, and
CHARLY BENASSAYAG.
Defendants/Counter-Plaintiffs.
/
NOTICE OF INTENT TO
SUBPOENA RECORDS WITHOUT DEPOSITION
YOU ARE NOTIFIED that after ten (10) days from the date of service of this notice, if
service is by delivery, or fifteen (15) days from the date of service, if service is by mail or email,
and if no objection is received from any party, the undersigned will issue the attached Subpoena
directed to Records Custodian, Berkowitz Pollack Brant, who is not a party to the above-styled
action.
The Subpoena will direct Berkowitz Pollack Brant to produce the items listed at the time
and place specified in the subpoena.
DATED October 26, 2016.
SHUTTS.COM | FORT LAUDERDALE | MIAMI | ORLANDO | SARASOTA | TALLAHASSEE | TAMPA | WEST PALM BEACH
** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 10/26/2016 7:26:21 PM.****Respectfully submitted,
SHUTTS & BOWEN LLP
Attorneys for Plaintiff
200 South Biscayne Boulevard
Suite 4100
Miami, Florida 33131
Telephone: (305) 358-6300
Facsimile: (305) 381-9982
By: /s/ Harold E. Patricoff
Harold E. Patricoff, Esq.
Florida Bar No. 508357
Hpatricoffi@shutts.com
Aleksey Shtivelman, Esq.
Florida Bar No, 99159
ashtivelman@shutts.com
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on October 26, 2016, a true and correct copy of the foregoing
was served via fax to: Leonard K. Samuels, Esq., |samucls(@ bergersingerman.com, Jordan Isrow,
Esq., jisrow@bergersingerman.com, DRT@bergersingerman.com, Berger Singerman LLP, 350
E. Las Olas Blvd., Suite 1000, Ft. Lauderdale, Florida 33301, Ken Waterway, Esq.,
kww(@waterwayblack.com, Waterway Black, 1401 E. Broward Blvd., Victoria Park Centre,
Suite 204, Fort Lauderdale, FL 33301.
By: /s/ Harold E. Patricoff
SHUTTS.COM | FORT LAUDERDALE | MIAMI | ORLANDO | SARASOTA | TALLAHASSEE | TAMPA | WEST PALM BEACHIN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE-16-011606 (13)
YARIV ALIMA,
Plaintiff/Counter-Defendant,
VS.
ATMOS TECHNOLOGY LLC,
ATMOS INVESTMENTS LLC,
CESY GROUP LLC,
ELH PRODUCTS, LLC,
ATMOS NATION LLC,
SMJ MARKETING, INC.,
IMPORT NATION, LLC,
CHARLY BENASSAYAG, P.A.,
ELI EROCH,
SHLOMI BITON, and
CHARLY BENASSAYAG.
Defendants/Counter-Plaintiffs.
/
SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS AND THINGS
WITHOUT DEPOSITION PURSUANT TO FLA. R. CIV. P. 1.351
(Documents may be mailed in lieu of appearance)
THE STATE OF FLORIDA
TO: Records Custodian
Berkowitz Pollack Brant
515 East Las Olas Boulevard
Fort Lauderdale, FL 33301
YOU ARE COMMANDED to appear at SHUTTS & BOWEN, 200 East Broward
Blvd. #2100, Fort Lauderdale, FL 33301, on November 30, 2016, at 10:00 a.m., and to have
with you at that time and place the following:
SEE SCHEDULE “A” ATTACHED HERETO.
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
SHUTTS.COM | FORT LAUDERDALE | MIAMI | ORLANDO ) SARASOTA | TALLAHASSEE | TAMPA | WEST PALM BEACHSCHEDULED 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.
Tf 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 November __, 2016
HAROLD E. PATRICOFF, ESQ.
For the 17th Judicial Circuit Court
By: /s/ Harold E. Patricoff
Harold E. Patricoff, Esq.
Florida Bar No. 508357
hpatricoff@shutts.com
SHUTTS & BOWEN
200 South Biscayne Blvd., 41“ Floor
Miami, Florida 33131
Tel. No.: (305) 358-6300
Attorneys for the Plaintiff
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SHUTTS.COM | FORT LAUDERDALE | MIAMI | ORLANDO | SARASOTA | TALLAHASSEE TAMPA | WEST PALM BEACHSCHEDULE “A”
DEFINITIONS
As used in this request, the following words shall be defined as follows:
A. The term “document(s)” means all writings of any kind, including the originals
and all non-identical copies, whether different from the original by reason of any notation made
on such copies or otherwise, including (without limitation) correspondence, insurance policies
and/or certificates, memoranda, notes, diaries, statistics, letters, e-mails, text messages, instant
messages, telegrams, minutes, contracts, reports, studies, checks, bank statements, statements,
receipts, returns, summaries, pamphlets, books, prospectuses, inter-office and intra-office
communications, offers, notations of any sort of conversation, telephone calls, meetings, or other
communications, bulletins, printed matter, computer print-outs, teletypes, telefax, invoices,
worksheets and all drafts, alterations, modifications, changes, and amendments of any of the
foregoing, graphic or aural writs, records or representations of any kind, including (without
limitation) photographs, charts, graphs, microfiche, microfilm, videotape, recordings, motion
pictures; electronic, mechanical or electric records or representations of any kind, including
(without limitation) tapes, cassettes and discs; and computer generated or stored records or
representations of any kind. The term “document(s)" includes, without limitation, all
“Electronically Stored Information” or “ESI”, as such terms are defined herein below.
B. “Electronically Stored Information” or “ESI” means writings, drawings, graphs,
charts, photographs, sound recordings, images, emails, and other data or data compilations stored
in any medium from which information can be obtained and which is translated, if necessary, by
the parties to whom this Request is directed, into reasonably usable form.
Cc. “You” or “Your” refers to Berkowitz Pollack Brant, its officers, directors, agents,
attomeys, affiliates, subsidiaries, divisions, partners, parents, predecessors, successors, joint
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SHUTTS.COM | FORT LAUDERDALE | MIAMI | ORLANDO ) SARASOTA | TALLAHASSEE | TAMPA | WEST PALM BEACHventurers, employees, representatives and any and all other persons acting for, purporting to act
for, or subject to the control of Berkowitz Pollack Brant or its subsidiaries, parents, predecessors
or successors.
D. The “Companies” refers to: Atmos Technology, LLC, Atmos Investments, LLC
Local Map Ranking LLC d/b/a CESY Group, LLC, ELH Products, LLC, Atmos Nation, LLC,
and Import Nation, LLC, or any agent, partner, representative, employee, servant, officer,
director, independent contractor, predecessor, successor and assign or other person acting on
behalf of Atmos Technology, LLC, Atmos Investments, LLC, Local Map Ranking LLC d/b/a
CESY Group, LLC, ELH Products, LLC, Atmos Nation, LLC, and Import Nation, LLC
E. “Or” shall mean and/or.
F. “And” shall mean and/or.
G. As used herein the singular shall include the plural, the plural shall include the
singular, and the masculine, feminine, and neuter shall include each of the other genders.
H. The terms “relate to,” “relating to,” or “regarding” mean to embody, record, refer
to, concern, reflect, or in any manner involve or otherwise implicate the subject matter(s) of the
Request.
I. “Members” means: Mr. Yariv Alima, SMJ Marketing, Inc., Charly Benassayag,
P.A., Mr. Eli Eroch, Mr. Shlomi Biton, and Mr. Charly Benassayag or any agent, partner,
representative, employee, servant, officer, director, independent contractor, predecessor,
successor and assign or other person acting on behalf of Mr. Yariv Alima, SMJ Marketing, Inc.,
Charly Benassayag, P.A., Mr. Eli Eroch, Mr. Shlomi Biton, and Mr. Charly Benassayag.
4
SHUTTS.COM | FORT LAUDERDALE | MIAMI | ORLANDO | SARASOTA | TALLAHASSEE TAMPA | WEST PALM BEACHINSTRUCTIONS
A. Produce all Documents and things as they are kept in the ordinary course of
business, including with all staples and clips attached and with all associated file folders, dividers
and labels.
B. Each Person or entity referred to herein includes (without limitation) each of his,
her or its predecessors, successors, or assigns, and their past or present employees, agents,
representatives, and anyone acting or purporting to act on behalf of any of them.
Cc. If any Documents are withheld from production on grounds of privilege or
immunity, identify cach such Document by specifying: (1) the date of the Document; (2) the
identity of all Persons who prepared or signed the Document; (3) the identity of all Persons
designated as addresses; (4) the identity of all Persons who received any copy of the Document;
(5) the type of Document (e.g., memorandum, report, letter, etc.); (6) the subject matter of the
Document; and (7) the basis for withholding the Document.
D. If any Document requested herein has been destroyed, discarded or otherwise
disposed of, identify the Document by providing the following information: (1) the type of
Document; (2) the date of the Document; (3) the name of each Person who prepared it; (4) each
Person who signed it; and (5) each Person to whom it was directed, circulated or distributed.
Also, identify: (1) each Person who authorized the destruction or other disposition of the
Document, (2) each Person who destroyed or otherwise disposed of the Document, and (3)
provide the date of and reason for the destruction or other disposition of the Document.
E. No Document request or subpart hereof shall be construed as a limitation on any
other Document request hereof.
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SHUTTS.COM | FORT LAUDERDALE | MIAMI | ORLANDO | SARASOTA | TALLAHASSEE TAMPA | WEST PALM BEACHF. The request(s) to which each Document produced is responsive should be
indicated at the time the Document is produced.
G. Each Document furnished in response to these requests shall be identified by the
name of the Person from whose files that Document was taken and the file from which the
Document was taken.
H. This Subpoena Duces Tecum seeks Documents for the period from January 1,
2010 to the present.
SCHEDULE OF DOCUMENTS TO BE PRODUCED
Any and all documents in your possession, custody or control that relate or reflect or refer
to:
1. All financial statements, financial reports, compilations, balance sheets, journal
entries, cash flow statements, audit reports, and reports concerning the Companies and/or
Members.
2. All audits, analyses, and all reports prepared by you for the Companies.
3. All federal, state and local tax returns, 1099 forms, K1 statements, W2 forms,
income tax schedules regarding the Companies and/or Members.
4. All accounting software program reports (including but not limited to
QuickBooks), and any and all files and spreadsheets used for accounting purposes, concerning
the Companies.
5. All financial statements and reports which relate or reflect or refer to the financial
affairs of the Companies.
6. All documents regarding the banks used and maintained by the Companies.
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SHUTTS.COM | FORT LAUDERDALE | MIAMI | ORLANDO | SARASOTA | TALLAHASSEE TAMPA | WEST PALM BEACH7. All documents and reports regarding cash maintained and held by the Companies,
including records regarding the cash books, copies of the excel spreadsheets that have been
created showing the cash that has been received by the Companies, daily cash logs; and any
other records stating the amount of cash maintained by the Companies in their safe(s).
8. All reports regarding inventory and sales of the Companies (such as those from
software, including but not limited to “Joomla”).
9. All documents reflecting information that the Companies disclosed to You
regarding their finances.
7
SHUTTS.COM | FORT LAUDERDALE | MIAMI | ORLANDO | SARASOTA | TALLAHASSEE TAMPA | WEST PALM BEACH
Preview
Filing # 48148117 E-Filed 10/26/2016 07:26:22 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-16-011606 (13) YARIV ALIMA, Plaintiff/Counter-Defendant, VS. ATMOS TECHNOLOGY LLC, ATMOS INVESTMENTS LLC, CESY GROUP LLC, ELH PRODUCTS, LLC, ATMOS NATION LLC, SMJ MARKETING, INC., IMPORT NATION, LLC, CHARLY BENASSAYAG, P.A., ELI EROCH, SHLOMI BITON, and CHARLY BENASSAYAG. Defendants/Counter-Plaintiffs. / NOTICE OF INTENT TO SUBPOENA RECORDS WITHOUT DEPOSITION YOU ARE NOTIFIED that after ten (10) days from the date of service of this notice, if service is by delivery, or fifteen (15) days from the date of service, if service is by mail or email, and if no objection is received from any party, the undersigned will issue the attached Subpoena directed to Records Custodian, Berkowitz Pollack Brant, who is not a party to the above-styled action. The Subpoena will direct Berkowitz Pollack Brant to produce the items listed at the time and place specified in the subpoena. DATED October 26, 2016. SHUTTS.COM | FORT LAUDERDALE | MIAMI | ORLANDO | SARASOTA | TALLAHASSEE | TAMPA | WEST PALM BEACH ** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 10/26/2016 7:26:21 PM.****Respectfully submitted, SHUTTS & BOWEN LLP Attorneys for Plaintiff 200 South Biscayne Boulevard Suite 4100 Miami, Florida 33131 Telephone: (305) 358-6300 Facsimile: (305) 381-9982 By: /s/ Harold E. Patricoff Harold E. Patricoff, Esq. Florida Bar No. 508357 Hpatricoffi@shutts.com Aleksey Shtivelman, Esq. Florida Bar No, 99159 ashtivelman@shutts.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that on October 26, 2016, a true and correct copy of the foregoing was served via fax to: Leonard K. Samuels, Esq., |samucls(@ bergersingerman.com, Jordan Isrow, Esq., jisrow@bergersingerman.com, DRT@bergersingerman.com, Berger Singerman LLP, 350 E. Las Olas Blvd., Suite 1000, Ft. Lauderdale, Florida 33301, Ken Waterway, Esq., kww(@waterwayblack.com, Waterway Black, 1401 E. Broward Blvd., Victoria Park Centre, Suite 204, Fort Lauderdale, FL 33301. By: /s/ Harold E. Patricoff SHUTTS.COM | FORT LAUDERDALE | MIAMI | ORLANDO | SARASOTA | TALLAHASSEE | TAMPA | WEST PALM BEACHIN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-16-011606 (13) YARIV ALIMA, Plaintiff/Counter-Defendant, VS. ATMOS TECHNOLOGY LLC, ATMOS INVESTMENTS LLC, CESY GROUP LLC, ELH PRODUCTS, LLC, ATMOS NATION LLC, SMJ MARKETING, INC., IMPORT NATION, LLC, CHARLY BENASSAYAG, P.A., ELI EROCH, SHLOMI BITON, and CHARLY BENASSAYAG. Defendants/Counter-Plaintiffs. / SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS AND THINGS WITHOUT DEPOSITION PURSUANT TO FLA. R. CIV. P. 1.351 (Documents may be mailed in lieu of appearance) THE STATE OF FLORIDA TO: Records Custodian Berkowitz Pollack Brant 515 East Las Olas Boulevard Fort Lauderdale, FL 33301 YOU ARE COMMANDED to appear at SHUTTS & BOWEN, 200 East Broward Blvd. #2100, Fort Lauderdale, FL 33301, on November 30, 2016, at 10:00 a.m., and to have with you at that time and place the following: SEE SCHEDULE “A” ATTACHED HERETO. 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 SHUTTS.COM | FORT LAUDERDALE | MIAMI | ORLANDO ) SARASOTA | TALLAHASSEE | TAMPA | WEST PALM BEACHSCHEDULED 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. Tf 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 November __, 2016 HAROLD E. PATRICOFF, ESQ. For the 17th Judicial Circuit Court By: /s/ Harold E. Patricoff Harold E. Patricoff, Esq. Florida Bar No. 508357 hpatricoff@shutts.com SHUTTS & BOWEN 200 South Biscayne Blvd., 41“ Floor Miami, Florida 33131 Tel. No.: (305) 358-6300 Attorneys for the Plaintiff 2 SHUTTS.COM | FORT LAUDERDALE | MIAMI | ORLANDO | SARASOTA | TALLAHASSEE TAMPA | WEST PALM BEACHSCHEDULE “A” DEFINITIONS As used in this request, the following words shall be defined as follows: A. The term “document(s)” means all writings of any kind, including the originals and all non-identical copies, whether different from the original by reason of any notation made on such copies or otherwise, including (without limitation) correspondence, insurance policies and/or certificates, memoranda, notes, diaries, statistics, letters, e-mails, text messages, instant messages, telegrams, minutes, contracts, reports, studies, checks, bank statements, statements, receipts, returns, summaries, pamphlets, books, prospectuses, inter-office and intra-office communications, offers, notations of any sort of conversation, telephone calls, meetings, or other communications, bulletins, printed matter, computer print-outs, teletypes, telefax, invoices, worksheets and all drafts, alterations, modifications, changes, and amendments of any of the foregoing, graphic or aural writs, records or representations of any kind, including (without limitation) photographs, charts, graphs, microfiche, microfilm, videotape, recordings, motion pictures; electronic, mechanical or electric records or representations of any kind, including (without limitation) tapes, cassettes and discs; and computer generated or stored records or representations of any kind. The term “document(s)" includes, without limitation, all “Electronically Stored Information” or “ESI”, as such terms are defined herein below. B. “Electronically Stored Information” or “ESI” means writings, drawings, graphs, charts, photographs, sound recordings, images, emails, and other data or data compilations stored in any medium from which information can be obtained and which is translated, if necessary, by the parties to whom this Request is directed, into reasonably usable form. Cc. “You” or “Your” refers to Berkowitz Pollack Brant, its officers, directors, agents, attomeys, affiliates, subsidiaries, divisions, partners, parents, predecessors, successors, joint 3 SHUTTS.COM | FORT LAUDERDALE | MIAMI | ORLANDO ) SARASOTA | TALLAHASSEE | TAMPA | WEST PALM BEACHventurers, employees, representatives and any and all other persons acting for, purporting to act for, or subject to the control of Berkowitz Pollack Brant or its subsidiaries, parents, predecessors or successors. D. The “Companies” refers to: Atmos Technology, LLC, Atmos Investments, LLC Local Map Ranking LLC d/b/a CESY Group, LLC, ELH Products, LLC, Atmos Nation, LLC, and Import Nation, LLC, or any agent, partner, representative, employee, servant, officer, director, independent contractor, predecessor, successor and assign or other person acting on behalf of Atmos Technology, LLC, Atmos Investments, LLC, Local Map Ranking LLC d/b/a CESY Group, LLC, ELH Products, LLC, Atmos Nation, LLC, and Import Nation, LLC E. “Or” shall mean and/or. F. “And” shall mean and/or. G. As used herein the singular shall include the plural, the plural shall include the singular, and the masculine, feminine, and neuter shall include each of the other genders. H. The terms “relate to,” “relating to,” or “regarding” mean to embody, record, refer to, concern, reflect, or in any manner involve or otherwise implicate the subject matter(s) of the Request. I. “Members” means: Mr. Yariv Alima, SMJ Marketing, Inc., Charly Benassayag, P.A., Mr. Eli Eroch, Mr. Shlomi Biton, and Mr. Charly Benassayag or any agent, partner, representative, employee, servant, officer, director, independent contractor, predecessor, successor and assign or other person acting on behalf of Mr. Yariv Alima, SMJ Marketing, Inc., Charly Benassayag, P.A., Mr. Eli Eroch, Mr. Shlomi Biton, and Mr. Charly Benassayag. 4 SHUTTS.COM | FORT LAUDERDALE | MIAMI | ORLANDO | SARASOTA | TALLAHASSEE TAMPA | WEST PALM BEACHINSTRUCTIONS A. Produce all Documents and things as they are kept in the ordinary course of business, including with all staples and clips attached and with all associated file folders, dividers and labels. B. Each Person or entity referred to herein includes (without limitation) each of his, her or its predecessors, successors, or assigns, and their past or present employees, agents, representatives, and anyone acting or purporting to act on behalf of any of them. Cc. If any Documents are withheld from production on grounds of privilege or immunity, identify cach such Document by specifying: (1) the date of the Document; (2) the identity of all Persons who prepared or signed the Document; (3) the identity of all Persons designated as addresses; (4) the identity of all Persons who received any copy of the Document; (5) the type of Document (e.g., memorandum, report, letter, etc.); (6) the subject matter of the Document; and (7) the basis for withholding the Document. D. If any Document requested herein has been destroyed, discarded or otherwise disposed of, identify the Document by providing the following information: (1) the type of Document; (2) the date of the Document; (3) the name of each Person who prepared it; (4) each Person who signed it; and (5) each Person to whom it was directed, circulated or distributed. Also, identify: (1) each Person who authorized the destruction or other disposition of the Document, (2) each Person who destroyed or otherwise disposed of the Document, and (3) provide the date of and reason for the destruction or other disposition of the Document. E. No Document request or subpart hereof shall be construed as a limitation on any other Document request hereof. 5 SHUTTS.COM | FORT LAUDERDALE | MIAMI | ORLANDO | SARASOTA | TALLAHASSEE TAMPA | WEST PALM BEACHF. The request(s) to which each Document produced is responsive should be indicated at the time the Document is produced. G. Each Document furnished in response to these requests shall be identified by the name of the Person from whose files that Document was taken and the file from which the Document was taken. H. This Subpoena Duces Tecum seeks Documents for the period from January 1, 2010 to the present. SCHEDULE OF DOCUMENTS TO BE PRODUCED Any and all documents in your possession, custody or control that relate or reflect or refer to: 1. All financial statements, financial reports, compilations, balance sheets, journal entries, cash flow statements, audit reports, and reports concerning the Companies and/or Members. 2. All audits, analyses, and all reports prepared by you for the Companies. 3. All federal, state and local tax returns, 1099 forms, K1 statements, W2 forms, income tax schedules regarding the Companies and/or Members. 4. All accounting software program reports (including but not limited to QuickBooks), and any and all files and spreadsheets used for accounting purposes, concerning the Companies. 5. All financial statements and reports which relate or reflect or refer to the financial affairs of the Companies. 6. All documents regarding the banks used and maintained by the Companies. 6 SHUTTS.COM | FORT LAUDERDALE | MIAMI | ORLANDO | SARASOTA | TALLAHASSEE TAMPA | WEST PALM BEACH7. All documents and reports regarding cash maintained and held by the Companies, including records regarding the cash books, copies of the excel spreadsheets that have been created showing the cash that has been received by the Companies, daily cash logs; and any other records stating the amount of cash maintained by the Companies in their safe(s). 8. All reports regarding inventory and sales of the Companies (such as those from software, including but not limited to “Joomla”). 9. All documents reflecting information that the Companies disclosed to You regarding their finances. 7 SHUTTS.COM | FORT LAUDERDALE | MIAMI | ORLANDO | SARASOTA | TALLAHASSEE TAMPA | WEST PALM BEACH