On October 07, 2015 a
Motion,Ex Parte
was filed
involving a dispute between
Moodie, Oshane,
Osborne, Daison,
Spence, Romaine,
Thompson, Triston,
Vassell , Damani,
Wolfpakk Llc,
and
Ellis, Ade,
Muschette, Theadore,
Panfridays Events Llc,
Panfridays Llc,
for Contract and Indebtedness
in the District Court of Broward County.
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Filing # 83376220 E-Filed 01/15/2019 02:26:39 PM
IN THE CIRCUIT COURT OF THE 17 JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
WOLFPAKK, LLC, et al, CASE NO. CACE-2015-017977
Plaintiffs,
v.
PANFRIDAYS, LLC, et al,
Defendants.
PLAINTIFFS’ MOTION FOR PROTECTIVE ORDERS
Plaintiffs Oshane Moodie, Daison Osborne, Romaine Spence, Triston Thompson, and
Wolfpakk, LLC, (collectively, the “Plaintiffs”), by and through counsel, pursuant to Florida Rule
of Civil Procedure 1.280(c), seeks protective orders prohibiting repeat discovery and depositions:
1. This case was filed in 2015. Discovery has been already been completed. The
Defendant’s motion for summary judgment was denied last year and this matter was scheduled for
trial in January 2019.
2. However, the Defendant’s attorney was disbarred shortly before trial. As a
courtesy, the Plaintiffs did not oppose briefly moving the trial so that the Defendant’s new counsel
could quickly get caught up to speed.
3. Trial is now set for March 2019 and again the Plaintiffs are prepared to go forward
on this simple case of unjust enrichment.
4. However, the Defendant now has propounded additional discovery, which has
already been answered and has also indicated wanting to re-depose the Plaintiffs.
5. Florida Rule of Civil Procedure 1.280(c) provides that, “the court... may make
any order to protect a party or person from annoyance, embarrassment, oppression, or undue
burden or expense that justice requires, including . . . that the discovery not be had; that the
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 1/15/2019 2:26:39 PM.****discovery may be had only on specified terms and conditions . . . [or] that certain matters not be
inquired into, or that the scope of the discovery be limited to certain matters.” Fla, R. Civ. P.
1.280(c).
6. The Plaintiffs object to any further delay in this matter and also object to having to
re-answer discovery and being re-deposed.
WHEREFORE, the Plaintiffs respectfully requests the Court grant their Motion for
Protective Orders, and grant any other relief deemed just and proper.
CERTIFICATE OF SERVICE
THEREBY CERTIFY that a true and correct copy of the foregoing was served via e-service
this 15" day of January, 2019 to all persons on the attached Service List.
Respectfully submitted,
FRIEDLAND & ASSOCIATES
707 NE 3™ Avenue, Suite 201
Fort Lauderdale, Florida 33304
Telephone: (954) 321-8810
Facsimile: (954) 321-8995
Email: pleadings@ yourtightourbattle.com
By: /s/ Lee Friedland
Lee Friedland, Esquire
Florida Bar No.: 991163
Friedland & Associates, P.A.
4486 SW 64" Avenue
Davie, Florida 33314
954-321-8810; 954-321-8995SERVICE LIST
HARRIS NIZEL, ESQUIRE ATTORNEY FOR DEFENDANTS
Nizel Law, P.A.
4700 Sheridan Street, Suite J
Hollywood, FL 33021
Telephone: (954) 653-8300
Email: harris(@nizel.com
Email: nizclscrvice@ gmail.com
LEE FRIEDLAND, ESQUIRE ATTORNEY FOR PLAINTIFFS
Friedland & Associates
707 NE 3™ Avenue, Suite 201
Fort Lauderdale, FL 33304
Telephone: (954) 321-8810
Facsimile: (954) 321-8995
Email: pleadings@ yourfightourbattle.com
Friedland & Associates, P.A.
4486 SW 64" Avenue
Davie, Florida 33314
954-321-8810; 954-321-8995
Preview
Filing # 83376220 E-Filed 01/15/2019 02:26:39 PM IN THE CIRCUIT COURT OF THE 17 JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA WOLFPAKK, LLC, et al, CASE NO. CACE-2015-017977 Plaintiffs, v. PANFRIDAYS, LLC, et al, Defendants. PLAINTIFFS’ MOTION FOR PROTECTIVE ORDERS Plaintiffs Oshane Moodie, Daison Osborne, Romaine Spence, Triston Thompson, and Wolfpakk, LLC, (collectively, the “Plaintiffs”), by and through counsel, pursuant to Florida Rule of Civil Procedure 1.280(c), seeks protective orders prohibiting repeat discovery and depositions: 1. This case was filed in 2015. Discovery has been already been completed. The Defendant’s motion for summary judgment was denied last year and this matter was scheduled for trial in January 2019. 2. However, the Defendant’s attorney was disbarred shortly before trial. As a courtesy, the Plaintiffs did not oppose briefly moving the trial so that the Defendant’s new counsel could quickly get caught up to speed. 3. Trial is now set for March 2019 and again the Plaintiffs are prepared to go forward on this simple case of unjust enrichment. 4. However, the Defendant now has propounded additional discovery, which has already been answered and has also indicated wanting to re-depose the Plaintiffs. 5. Florida Rule of Civil Procedure 1.280(c) provides that, “the court... may make any order to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense that justice requires, including . . . that the discovery not be had; that the *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 1/15/2019 2:26:39 PM.****discovery may be had only on specified terms and conditions . . . [or] that certain matters not be inquired into, or that the scope of the discovery be limited to certain matters.” Fla, R. Civ. P. 1.280(c). 6. The Plaintiffs object to any further delay in this matter and also object to having to re-answer discovery and being re-deposed. WHEREFORE, the Plaintiffs respectfully requests the Court grant their Motion for Protective Orders, and grant any other relief deemed just and proper. CERTIFICATE OF SERVICE THEREBY CERTIFY that a true and correct copy of the foregoing was served via e-service this 15" day of January, 2019 to all persons on the attached Service List. Respectfully submitted, FRIEDLAND & ASSOCIATES 707 NE 3™ Avenue, Suite 201 Fort Lauderdale, Florida 33304 Telephone: (954) 321-8810 Facsimile: (954) 321-8995 Email: pleadings@ yourtightourbattle.com By: /s/ Lee Friedland Lee Friedland, Esquire Florida Bar No.: 991163 Friedland & Associates, P.A. 4486 SW 64" Avenue Davie, Florida 33314 954-321-8810; 954-321-8995SERVICE LIST HARRIS NIZEL, ESQUIRE ATTORNEY FOR DEFENDANTS Nizel Law, P.A. 4700 Sheridan Street, Suite J Hollywood, FL 33021 Telephone: (954) 653-8300 Email: harris(@nizel.com Email: nizclscrvice@ gmail.com LEE FRIEDLAND, ESQUIRE ATTORNEY FOR PLAINTIFFS Friedland & Associates 707 NE 3™ Avenue, Suite 201 Fort Lauderdale, FL 33304 Telephone: (954) 321-8810 Facsimile: (954) 321-8995 Email: pleadings@ yourfightourbattle.com Friedland & Associates, P.A. 4486 SW 64" Avenue Davie, Florida 33314 954-321-8810; 954-321-8995