On July 17, 2015 a
Party Discovery
was filed
involving a dispute between
Stephens Pipe & Steel, Llc,
and
Action Fence Enterprises, Inc.,
for Foreign Judgment (Civil)
in the District Court of Broward County.
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Filing # 39790524 E-Filed 04/04/2016 10:39:53 AM
In the Circuit Court of the Seventeenth Judicial Circuit
In and for Broward County, Florida
Case No.: CACE-15-012730
Division: Civil
Stephens Pipe & Steel, LLC f/k/a
Stephens Pipe & Steel, Inc.,
Plaintiff,
vs.
Richard J. Young, and
Action Fence Enterprises, Inc.,
Defendants.
/
PLAINTIFF’S REQUEST FOR PRODUCTION TO
RICHARD J. YOUNG
Pursuant to Fla. R. Civ. P. 1.350, Plaintiff requests Defendant, Richard J. Young, to
produce the items on the attached list to LAWCRAFT™ at their offices located at 100 NW
70" Avenue, Suite 200, Plantation, Florida, 33317 at 10:00 AM on the first business day 30
days from the mailing date below.
Instead of producing the documents at our office, you may mail copies of them to us
at the following address: LAWCRAFT™, Post Office Box 19359, Plantation, Florida 33318.
I certify that on APR 0 4 2016 a copy of this document was sent by
mail to: Action Fence Enterprises, Inc., c/o Richard J. Young, 3516 51st Street East,
Bradenton, FL. 34208 and Richard J. Young, 4632 Orlando Circle, Bradenton, FL. 34207.
ML
JERALYN SHELAN ni ® Florida Bar Number 932248
LAWCRAFT™ (Attorneys for Plaintiff # Matter Number 222011
PO BOX 19359, ion, FL 33318-0359
Phone: 954-587-1968 # Fax: (954) 587-2797
Primary Email: court@LAWCRAFTfirm.com
Secondary Email: jeralyn@lawcraftfirm.com
*** FILED: BROWARD COUNTY. FL HOWARD FORMAN, CLERK 4/4/2016 10:39:53 AM.****WHAT IS A REQUEST FOR PRODUCTION?
We are trying to collect the judgment that was entered against you. Court rules allow us to
ask you for documents about your financial situation and your assets. Send us copies of the
requested documents in the next 30 days. You cannot refuse to send us a document just because
you don’t want us to see it or think we don’t need it, like your tax returns. If you have a valid legal
objection, write in your objection and send us whatever you don’t object to. You have to send us a
document if you have it or can get it from someone else, such as your spouse or your bank. You
may send an original or a clean copy. For each item on the list, check off whether it is attached or
not. Mail this sheet and the documents to us at: LAWCRAFT™, Post Office Box 19359, Plantation,
FL 33318. For reference, our file number is
If you have any questions or want to make payments instead of sending us the
documents, call us at (954) 587-1968,
lL
The last 3 months paystubs for your job.
OC ATTACHED ONONE
The last 6 months statements for any
bank account your name is on.
OATTACHED ONONE
A blank (voided) check for any checking
account your name is on.
GATTACHED (NONE
The last 3 months statements for any
investment account your name is on.
OATTACHED ONONE
Documents for any medical or
benefits you receive.
O ATTACHED
disability
CS NONE
Documents for any Social Security or
other government benefits you receive.
ATTACHED NONE
The deed, mortgage, and lease for any
real estate you own or lease.
C ATTACHED “NONE
8. The title, finance agreement, and lease
for any vehicle you own or lease.
CATTACHED QONONE
9. Documents for any child support or
alimony you pay or receive.
OATTACHED ONONE
10. Your last 2 tax returns and W-2s.
CATTACHED CNONE
ll. The most recent tax return for any
business you are an owner or officer of.
Q ATTACHED ONONE
12. Your last 3 months household bills.
MATTACHED ONONE
13. Your
statements.
3 ATTACHED
last 3 months credit card
<= NONE
14, Any other judgments entered against
you.
ZT ATTACHED «NONE
PRINT NAME: __
Document Filed Date
April 04, 2016
Case Filing Date
July 17, 2015
Category
Foreign Judgment (Civil)
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Filing # 39790524 E-Filed 04/04/2016 10:39:53 AM In the Circuit Court of the Seventeenth Judicial Circuit In and for Broward County, Florida Case No.: CACE-15-012730 Division: Civil Stephens Pipe & Steel, LLC f/k/a Stephens Pipe & Steel, Inc., Plaintiff, vs. Richard J. Young, and Action Fence Enterprises, Inc., Defendants. / PLAINTIFF’S REQUEST FOR PRODUCTION TO RICHARD J. YOUNG Pursuant to Fla. R. Civ. P. 1.350, Plaintiff requests Defendant, Richard J. Young, to produce the items on the attached list to LAWCRAFT™ at their offices located at 100 NW 70" Avenue, Suite 200, Plantation, Florida, 33317 at 10:00 AM on the first business day 30 days from the mailing date below. Instead of producing the documents at our office, you may mail copies of them to us at the following address: LAWCRAFT™, Post Office Box 19359, Plantation, Florida 33318. I certify that on APR 0 4 2016 a copy of this document was sent by mail to: Action Fence Enterprises, Inc., c/o Richard J. Young, 3516 51st Street East, Bradenton, FL. 34208 and Richard J. Young, 4632 Orlando Circle, Bradenton, FL. 34207. ML JERALYN SHELAN ni ® Florida Bar Number 932248 LAWCRAFT™ (Attorneys for Plaintiff # Matter Number 222011 PO BOX 19359, ion, FL 33318-0359 Phone: 954-587-1968 # Fax: (954) 587-2797 Primary Email: court@LAWCRAFTfirm.com Secondary Email: jeralyn@lawcraftfirm.com *** FILED: BROWARD COUNTY. FL HOWARD FORMAN, CLERK 4/4/2016 10:39:53 AM.****WHAT IS A REQUEST FOR PRODUCTION? We are trying to collect the judgment that was entered against you. Court rules allow us to ask you for documents about your financial situation and your assets. Send us copies of the requested documents in the next 30 days. You cannot refuse to send us a document just because you don’t want us to see it or think we don’t need it, like your tax returns. If you have a valid legal objection, write in your objection and send us whatever you don’t object to. You have to send us a document if you have it or can get it from someone else, such as your spouse or your bank. You may send an original or a clean copy. For each item on the list, check off whether it is attached or not. Mail this sheet and the documents to us at: LAWCRAFT™, Post Office Box 19359, Plantation, FL 33318. For reference, our file number is If you have any questions or want to make payments instead of sending us the documents, call us at (954) 587-1968, lL The last 3 months paystubs for your job. OC ATTACHED ONONE The last 6 months statements for any bank account your name is on. OATTACHED ONONE A blank (voided) check for any checking account your name is on. GATTACHED (NONE The last 3 months statements for any investment account your name is on. OATTACHED ONONE Documents for any medical or benefits you receive. O ATTACHED disability CS NONE Documents for any Social Security or other government benefits you receive. ATTACHED NONE The deed, mortgage, and lease for any real estate you own or lease. C ATTACHED “NONE 8. The title, finance agreement, and lease for any vehicle you own or lease. CATTACHED QONONE 9. Documents for any child support or alimony you pay or receive. OATTACHED ONONE 10. Your last 2 tax returns and W-2s. CATTACHED CNONE ll. The most recent tax return for any business you are an owner or officer of. Q ATTACHED ONONE 12. Your last 3 months household bills. MATTACHED ONONE 13. Your statements. 3 ATTACHED last 3 months credit card <= NONE 14, Any other judgments entered against you. ZT ATTACHED «NONE PRINT NAME: __