Preview
Filing # 73431017 E-Filed 06/12/2018 12:43:28 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 TO COMPEL
PAYMENT AND BETTER RESPONSES TO DISCOVERY
COMES NOW, Plaintiffs WOLFPAKK, LLC, by and through undersigned counsel, and
hereby files this Motion to Compel Payment and Better Responses to Discovery, and states as
follows:
1. On April 11, 2018, Honorable Sandra Perlman ordered Defendants to pay
Plaintiff's court reporter costs for the cancellation of Janet Davis deposition. See attached
Exhibit A.
2. On April 12, 2018, counsel for Plaintiffs served Defendants with a Request for
Payment in the amount of $214.60 if paid before May 27, 2018 and $246.29 if paid after May 27,
2018. See attached Exhibit B. To date, Defendants have failed to remit payment.
3. On March 16, 2016, Plaintiffs served Defendants with Interrogatories and Request
for Production, hereto attached as Exhibit C.
4. On April 13, 2016 Defendants filed their “Answers and Objections to Plaintiff's
First Interrogatories” and “Response to First Request for Production,” hereto attached as Exhibit
D.
WHEREFORE, Plaintiffs seeks an Order compelling Defendants to render payment
within three (3) days and better responses to Interrogatories and Request for Production within
ten (10) days.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 6/12/2018 12:43:28 PM.****CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served via e-service
this 12" day of June, 2018 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@yourfightourbattle.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
PETER FELLOWS, ESQUIRE ATTORNEY FOR DEFENDANTS
Law Firm of Fellows & Associates, P.A. Theodore Muschette &
1031 Ives Dairy Road, Suite 228 PanFridays, LLC
Miami, FL 33179
Telephone: (305) 459-4452
Email: fellowslawfirm@yahoo.com
LEE FRIEDLAND, ESQUIRE ATTORNEY FOR PLAINTIFF
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,IN THE CIRCUIT COURT OF THE SEVENTEENTH
JUDICIAL CIRCUIT, INAND FOR BROWARD
COUNTY, FLORIDA
Wolf kt Lc et.al
case no: 28-7777
Plaintiff,
ve ORDER ON :
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THIS CAUSE was considered by the Court on the following Motion(s) fe Sine acl
HEARING was held on __““/¢#//F
THE COURT having considered the grounds for the Motion, taken testimony, heard argument and
considered the applicable law, itis,
ORDERED as follows:
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DONE AND ORDERED ON in BERL MAN Uterdale,
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Copies furnished: In Open Court
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BC/CA 118 (Rev 07/17)Filing # 70637839 E-Filed 04/12/2018 03:21:46 PM
IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
WOLFPAKK, LLC, et al, CASE NO. CACE02015-017977
Plaintiffs,
v.
PANFRIDAYS, LLC, et al,
Defendants.
PLAINTIFFS’ REQUEST FOR PAYMENT
Plaintiffs WOLFPAKK, LLC, et al., by and through undersigned counsel, hereby
requests Defendants PANFRIDAYS, LLC and THEADORE MUSCHETTE to provide the
undersigned with payment in the amount of Two Hundred Fourteen Dollars and Sixty Cents
($214.60) as per the invoice hereto attached as Exhibit A and pursuant to this Court’s Order
dated April 11, 2018 hereto attached as Exhibit B.
CERTIFICATE OF SERVICE
JHEREBY CERTIFY that a true and correct copy of the foregoing was served via e-service
this 12" day of April, 2018 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@yourfightourbattle.com
By: /s/ Lee Friedland
Lee Friedland, Esquire
Florida Bar No.: 991163SERVICE LIST
PETER FELLOWS, ESQUIRE ATTORNEY FOR DEFENDANTS
Law Firm of Fellows & Associates, P.A. Theodore Muschette &
1031 Ives Dairy Road, Suite 228 PanFridays, LLC
Miami, FL 33179
Telephone: (305) 459-4452
Email: fellowslawfirm@yahoo.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@vyourfightourbattle.com
Friedland & Associates, P.A.
4486 SW 64 Avenue
Davie, Florida 33314
954-321-8810; 954-321-8995INVOICE
U.S. Legal Support, Inc. Invoice No. Date
- Invo No.
100 Northeast Third Avenue = =
Suite 1050 120166089 4/12/2018 1720559
Fort Lauderdale FL 33301
Phone:954-463-2933 Fax:954-525-8919 eee ee eae es
4/6/2018 ‘CACE02015017977
Case Name
Wolfpakk, L.L.C. vs. PanFridays, LLC.
Nondeu Levy, Esquire
Friedland & Assocates Payment Terms
707 Northeast Third Avenue telah
Sulte 201
Fort Lauderdale FL 33304
ORIGINAL TRANSCRIPT OF:
Janette Davis 16.00 Pages @ 450 72.00
Attendance - First Hour 95.00 95.00
Processing & Handling 45.00 45.00
Janette Davis,
Exhibit 4.00. Pages @ 0.65 2.60
TOTAL DUE >>> $214.60
AFTER 5/27/2018 PAY $246.79
(-) Payments/Credits: 0.00
(+) Finance Charges/Debits: 0.00
(=) New Balance: $214.60
Tax ID: 76-0523238
Nondau Lewy, Esquire
Friedland & Associates
707 Northeast Third Avenue
Suite 201
Fort Lauderdale FL 33304
U.S. Legal Support, Inc.
P.O. Box 4772-12
Houston TX 77210-4772
Phone: 954-321-8810
Plecise detach bottom portion and remra with paveient
Invoice No. 120166089
Invoice Date 4/12/2018
Total Due : $214.60
Job No. 1720559
BUID S2-FT.LA
Case No. CACE02015017977
Fax:954-321-8995
Case Name Woltpakk, LLC. vs. Panky PLAINTIFF'S
EXHIBIT
AFiling # 38961864 E-Filed 03/14/2016 11:18:19 AM
IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
WOLFPAKK, LLC., a Florida Limited CASE NO.: CACE 15-017977 (04)
Liability Company, OSHANE MOODIE, an
individual, DAISON OSBORNE, an
individual, TRISTON THOMPSON, an
individual, ROMAINE SPENCE, an
individual, and DAMANI VASSELL, an
individual,
Plaintiffs,
v.
PANFRIDAYS, LLC, A Florida Limited
Liability Company, PANFRIDAYS EVENTS,
LLC, a Florida Limited Liability Company,
ADE ELLIS, an individual, and THEADORE
MUSCHETTE, an individual,
Defendants.
iH
NOTICE OF PLAINTIFFS FILING INTERROGATORIES TO DEFENDANTS
Plaintiffs, 'WOLFPAKK, LLC., et al., by and through the undersigned counsel, in
accordance with Fla. Civ. R. 1.340, propounds the attached Interrogatories to Defendants, to be
answered, in writing, under oath within thirty (30) days.
Respectfully submitted:
FRIEDLAND & ASSOCIATES
707 3" Avenue, Suite 201
Fort Lauderdale, Florida 33304
954-321-8810; 954-321-8995 (facsimile)
Pleadings@yourfightourbattle.com
Lee@yourfightourbattle.com
By: /s/ Lee Friedland
Lee Friedland, Esquire
Florida Bar No. 991163
lof2
Friedland & Bocksch
33 NE 2" Street, Suite 101, Fort Lauderdale, Florida 33301
954-321-8810; 954-321-8995 (Facsimile)CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served via e-service
this 14" day of March, 2016 to: Sunito M. Leslie, Esq., Sunito M. Leslie, P.A., 3350 SW 148"
Avenue, Suite 110, Miramar, FI. 33027; E-mail: sunito@smieslielaw.com and service@smleslielaw.com
/s/Lee Friedland
Lee Friedland
2 of2
Friedland & Bocksch
33 NE 2™ Street, Suite 101, Fort Lauderdale, Florida 33301
954-321-8810; 954-321-8995 (Facsimile)DEFINITIONS
Notwithstanding the specific definitions below, each word, term, or phrase used in these
Interrogatories should be given their most expansive and inclusive meaning. As used in these
Interrogatories, the following terms are to be interpreted in accordance with these definitions:
1. “All” includes “each and every.”
2. “And” and “Or” are to be construed both conjunctively and disjunctively, as necessary
to give each request its broadest possible meaning.
3. “Anyone acting on your behalf’ means all persons including your agents, employees,
insurance companies, attorneys, investigators, or consultants.
4. “Complaint” refers to each and every complaint, case, suit, or investigation whether or
not it was formal, informal, civil, criminal, filed in a court of law, settled, or dismissed.
5. “Defendant,” “you,” or “your” refers to Defendants Ade Ellis and Theadore Muschette.
The term also includes any of Defendants’ agents, enterprises, representatives, or anyone else
acting, or who has acted, on either of their behalf.
6. “Document” or “documents” includes any writing or other medium, including, but not
limited to, electronic, magnetic, or optical media, by which information is transmitted or
recorded. The terms also include all drafts, amendments, modifications, changes or side
correspondence, notes, or non-identical copies such as those that include marginalia or other
printed, stamped or handwritten revisions or notations.
7. “Marketing materials” means any document that markets or provides information to
others concerning your business or occupation. This includes, but is not limited to, print
advertisements, such as newspapers, fliers, signs, posters, business cards, or audio
advertisements, such as radio recordings, or video advertisements, such as television recordings.
1 of9
Friedland & Bocksch
33 NE 2 Street, Suite 101, Fort Lauderdale, Florida 33301
954-321-8810; 954-321-8995 (Facsimile)8. “Person” means any natural or artificial person, including business entities and other
legal entities.
9. ‘Relating to,” “relate to,” “related to,” and “relates to” means in any way concerning,
containing, describing, constituting, referring to, evidencing, mentioning, reflecting, identifying,
refuting, contradicting, supporting, connected with or in any way pertaining to the subject, in
whole or in part.
10. “Identify” means, in the case of an act, transaction, relationship, thing or occurrence:
a. Giving a detailed description, including complete references to: date, place, person
involved, and means employed;
b. Identifying your source of information concerning such act, transaction, thing or
occurrence, including the date you received such information; and
c. Identifying each person having knowledge of such act, transaction, thing or occurrence.
11. “Identify” means, when used in conjunction with the term “individual” or “person,”
or “identity” to state the person’s:
a. full legal name;
b. relationship to Plaintiffs or Defendants, e.g., friend, relative, employee;
¢. present or last known address and telephone number (business and residential);
d. name of employer, occupation, job title, business affiliation and/or nature of business.
12. “Identify” means, when used in conjunction with an entity, organization, or anything
other than a natural person, to state as much of the following information as is available to
Defendant:
a. the name under which it customarily does business;
b. the address of its principal place of business; and
11 of 9
Friedland & Associates
707 NE 3" Street, Suite 201, Fort Lauderdale, Florida 33304
954-321-8810; 954-321-8995 (Facsimile)c. the identity of the person in such organization who is believed to have the most
extensive knowledge of the matters in question.
13. “Identify” means, when used in conjunction with communications, to provide as
much of the following information as is available to Defendant:
a. the manner or type of the communication;
b. the date of and parties to the communication;
c. where the communication took place;
d. the substance of the communication; and
e. identify all documents describing or memorializing the communication.
14. “Identify” means, when used with respect to a meeting, to provide as much of the
following information as is available to Defendant:
a. the date or dates of the meeting;
b. the place of the meeting;
c. the persons attending the meeting;
d. the person who called the meeting;
e. what was said and by whom at the meeting;
f. what decisions were reached at the meeting; and
g. whether any notes, minutes, or other memoranda were made to record the proceedings
of such meeting, and, if so, the precise location of the document(s) and the identity of the
custodian.
15. “Identify” means, when used in conjunction with the term “document,” to provide as
much of the following information as is available to Defendant:
a. its author(s), sender(s), addressee(s), recipient(s);
11 of 9
Friedland & Associates
707 NE 3" Street, Suite 201, Fort Lauderdale, Florida 33304
954-321-8810; 954-321-8995 (Facsimile)b. its date;
c. type of document (e.g., letter, memorandum, report);
d. its subject matter;
e. the number of pages;
f. any attachments or appendices;
g. and the person(s) who is its custodian.
11 of 9
Friedland & Associates
707 NE 3" Street, Suite 201, Fort Lauderdale, Florida 33304
954-321-8810; 954-321-8995 (Facsimile)BREACH OF CONTRACT INTERROGATORIES
1. What is the name, address, and title of the individual who is answering these
interrogatories?
2. Please identify any and all individuals who were responsible for incorporating Pan
Fridays LLC and PanFridays Events, LLC ventures , to include all ventures related to the pop up
restaurant and party concept which is the subject of this litigation and was expressly a part of the
October 5, 2012 Wolfpakk, LLC contract, herein after (“Pan Fridays”).
3. Please identify any and all individuals with access to the Pan Fridays financial
accounts, to include checking accounts, savings accounts, lock boxes, cash boxes and operating
funds.
4, Please list all managers employed by Pan Fridays.
11 of 9
Friedland & Associates
707 NE 3" Street, Suite 201, Fort Lauderdale, Florida 33304
954-321-8810; 954-321-8995 (Facsimile)5. Please list all materials purchased and utilized by Pan Fridays.
6. Please list all the names, addresses, telephone numbers and titles of any Pan
Fridays’ employees or contractors, including paid or otherwise compensated promoters.
7. Were any payments made to Plaintiffs from Pan Fridays in the past ten (10) years?
If yes, please provide date, amount and recipient.
8. Were any payments made to Defendants from Pan Fridays in the past ten (10)
years? If yes, please provide date, amount and recipient.
11 of 9
Friedland & Associates
707 NE 3* Street, Suite 201, Fort Lauderdale, Florida 33304
954-321-8810; 954-321-8995 (Facsimile)9. Does a document expressly ending the Wolfpakk, LLC partnership venture exist?
If so, please provide a full and complete copy.
10. Did the Defendants propose to buy, outright or otherwise, the Pan Fridays venture?
Ifso, when, how, and to whom?
11. Did the Defendants propose Pan Fridays as a separate venture from that envisioned
and expressly written on the Wolfpakk, LLC contract? If so, when, how and to whom?
12. What was the response from the other co-venturers to these proposals?
11 of 9
Friedland & Associates
707 NE 3 Street, Suite 201, Fort Lauderdale, Florida 33304
954-321-8810; 954-321-8995 (Facsimile)13. | On what date did the Defendants cease business operations with Plaintiffs?
14. For what reason(s) did the Defendants cease business operations with Plaintiffs?
15. Did Defendants notify Plaintiffs of “split in Wolfpack”? If so, when, how and to
whom?
16. Are you now or were you ever in the last ten (10) years involved in any other form
of civil litigation or the subject of a civil complaint? If yes, please state who made the complaint,
when and where.
11 of 9
Friedland & Associates
707 NE 3" Street, Suite 201, Fort Lauderdale, Florida 33304
954-321-8810; 954-321-8995 (Facsimile)17. Please identify, in the last ten (10) years, any meetings between Defendants and
Plaintiffs, the co-venturers of Wolfpakk, LLC., regarding the Pan Fridays venture.
AFFIANT
STATE OF FLORIDA )
COUNTY OF )
BEFORE ME, the undersigned authority, personally appeared
who, after being first duly cautioned and sworn, deposes and states that he/she has read the above
Answers to Interrogatories and that he/she has set his/her hand and seal thereto for the purposes
therein expressed.
The foregoing instrument is acknowledged before me this day of
2016 by , on behalf of the
who is:
Personally known to me.
Who has produced the following as identification:
Who did/did not take an oath.
Given under my hand and official seal this day of. » 2016.
My Commission Expires:
NOTARY PUBLIC
Printed Name:
State of Florida at Large
Notary No.:
(Notary Seal)
11 of 9
Friedland & Associates
707 NE 3" Street, Suite 201, Fort Lauderdale, Florida 33304
954-321-8810; 954-321-8995 (Facsimile)Filing # 39077869 E-Filed 03/16/2016 11:24:30 AM
IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
WOLFPAKK, LLC., a Florida Limited CASE NO.: CACE 15-017977 (04)
Liability Company, OSHANE MOODIE, an
individual, DAISON OSBORNE, an
individual, TRISTON THOMPSON, an
individual, ROMAINE SPENCE, an
individual, and DAMANI VASSELL, an
individual,
Plaintiffs,
vs.
PANFRIDAYS, LLC, A Florida Limited
Liability Company, PANFRIDAYS EVENTS,
LLC, a Florida Limited Liability Company,
ADE ELLIS, an individual, and THEADORE
MUSCHETTE, an individual,
Defendants.
/
PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION TO DEFENDANTS
Plaintiffs, by and through undersigned counsel, serves upon Defendants, PANFRIDAYS,
LLC, PANFRIDAYS EVENTS, LLC, ADE ELLIS, THEADORE MUSCHETTE, to produce and
make available for inspection and duplication, in response to each numbered paragraph, all
documents specified herein which are in Defendants’ possession, custody or control, or in the
possession, custody or control of Defendants’ agents, accountants or attorneys. Defendants are
requested to make such production within thirty (30) days.
DEFINITIONS AND INSTRUCTIONS
i The terms "you," "your" and "Defendant" mean the party or parties to which this
request is addressed, including their agents, accountants, attorneys, and all other persons acting or
purporting to act on their behalf.2. As used herein, "relevant time period" shall mean October 5, 2011 - present.
3. The term "person" means any natural person, individual, proprietorship,
partnership, corporation, association, organization, joint venture, firm, other business enterprise,
governmental body, group of natural persons or other entity.
4. The term "document" means any written or graphic matter or other means of
preserving thought or expression and all tangible things from which information can be processed
or transcribed, including the originals and all non-identical copies, whether different from the
original by reason of any notation made on such copy or otherwise, including, but not limited to,
correspondence, memoranda, notes, messages, letters, telegrams, teletype, telefax, bulletins,
meetings or other communications, interoffice and intra-office telephone calls, diaries,
chronological data, minutes, books, reports, studies, summaries, pamphlets, bulletins, printed
matter, charts, ledgers, invoices, worksheets, receipts, returns, computer printouts, prospectuses,
financial statements, schedules, affidavits, contracts, cancelled checks, statements, transcripts,
statistics, surveys, magazine or newspaper articles, releases (and any and all drafts, alterations and
modifications, changes and amendments of any of the foregoing), graphic or aural records or
representations of any kind (including without limitation photographs, microfiche, microfilm,
videotape, records and motion pictures) and electronic, mechanical or electric records or
representations of any kind (including without limitation tapes, cassettes, discs and records).
5. The term "all documents" means every document or group of documents as above
defined that are known to you or that can be located or discovered by reasonably diligent efforts.
6. The terms "refer" or "relate to" mean to make a statement about, discuss, describe,
reflect, constitute, identify, deal with, consist of, establish, comprise, list, evidence, substantiate or
in any way pertain, in whole or in part, to the subject.7. The term "entity" means any natural person, individual, general or limited
partnership, corporation, association, organization, joint venture, firm or other business enterprise,
governmental body, group of natural persons or other entity.
8. 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.
9. When producing the documents, please keep all documents segregated by the file
in which the documents are contained and indicate the name of the file in which the documents
are contained and the name of the documents being produced.
10. In the event such file(s) or document(s) has (have) been removed for the purposes
of this action or for some other purpose, please state the name and address of the person who
removed the file, the title of the file and each subfile, if any, maintained within the file, and the
present location of the file.
11. Any request for production of a document shall be deemed to require production of
each and every such thing executed, created, prepared, received or in effect at any time to the
present, or during any other indicated period of time.
12. Any and all documents produced pursuant to this request must be segregated and
identified as being responsive to a specified numbered request.
13. If you choose to withhold any documents from production for inspection and
copying (on the basis of privilege or otherwise), please identify each document withheld and
provide its date, number of pages, author, recipient(s), a brief description of its subject matter, and
your basis for withholding the document from production.DOCUMENTS TO BE PRODUCED
lL. All e-mails, including attachments, exchanged between Defendants and Plaintiffs,
or anyone acting on Defendants’ or Plaintiffs’ behalf, during the relevant time period.
2. All other documents exchanged between Defendants and Plaintiffs, or anyone
acting on Defendants’ or Plaintiffs’ behalf, during the relevant time period.
3. All e-mails, including attachments, exchanged between Defendants, or anyone
acting on their behalf, during the relevant time period.
4. All other documents exchanged between Defendants, or anyone acting on their
behalf, during the relevant time period.
5. Defendants’ personal cell phone records for the calendar years 2011, 2012, 2013,
2014, 2015 and 2016 reflecting any call or text message activity between Defendants and
Plaintiffs.
6. Defendants’ personal cell phone records for the calendar years 2011, 2012, 2013,
2014, 2015 and 2016 reflecting any call or text message activity between Defendants.
7. All documents reflecting any gifts or loans of money to Defendants on behalf of
Wolfpakk, LLC.
8. All documents reflecting the accounting for the Pan Fridays venture (PanFridays,
LLC and PanFridays Events, LLC).
9. Any and all statements bearing on the knowledge of facts relevant and material to
the claim and defenses in the instant litigation.
10. Any and all documents and tangible things upon which your defenses and
affirmative defenses are based, including, but not limited to, writings, drawings, graphs, charts,photographs, movies, slides, film, video tape, phonograph records and other recording devices,
instruments, equipment, real and person property, objects, goods and vehicles.
11. Any and all ordinances, regulations, rules, statutes, customs and practices, and
publications upon which your defenses and/or counter-claims herein are made.
12. Any and all sworn testimony involving the subject matter of the instant litigation.
13. Any and all documents to which you referred in formulating your response to
Plaintiff's First Set of Interrogatories.
14. Any and all documents that support your Affirmative Defense(s).
Respectfully submitted:
FRIEDLAND & ASSOCIATES
Attorneys for Plaintiff
707 NE 3" Avenue, Suite 201
Fort Lauderdale, Florida 33304
954-321-8810; 954-321-8995 (facsimile)
Lee@yourfightourbattle.com
Pleadings@yourfightourbattle.com
By: 4/ Lee Friedland
LEE FRIEDLAND, ESQUIRE
FLORIDA BAR NO.: 991163
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served via e-service
this 16 day of March, 2016 to: Sunito M. Leslie, Esq., Sunito M. Leslie, P.A., 3350 SW 148"
Avenue, Suite 110, Miramar, FL 33027; E-mail: sunito@smleslielaw.com and service@smleslielaw.com
/s/Lee Friedland
Lee FriedlandIN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
WOLFPAKK, LLC, et al.
CASE NO.: CACE-15-017977
Plaintiffs, DIVISION: 04
vs.
PANFRIDAYS, LLC, et al.
Defendants.
DEFENDANTS’ ANSWERS AND OBJECTIONS TO
PLAINTIFFS’ FIRST INTERROGATORIES
Defendants, PANFRIDAYS, LLC; PANFRIDAYS EVENTS, LLC; ADE ELLIS; and
THEADORE MUSCHETTE, pursuant to Rules 1.280 and 1.340 of the Florida Rules of Civil Procedure,
hereby submit the following answers and objections to the First Interrogatories propounded by
Plaintiffs.
GENERAL OBJECTIONS
1. The following general objections are hereby incorporated into the answers and
objections to each interrogatory set forth herein, and to each and every amendment, supplement or
modification to these answers and objections hereinafter, whether or not expressly incorporated in each
individual answer or objection.
2. Defendants object to each interrogatory to the extent it seeks to impose obligations on
Defendants that are beyond, or inconsistent with, those set forth in the Florida Rules of Civil Procedure
or any other applicable rules, decisions or orders of the Court.
3. Defendants object to the “Definitions” section of Plaintiffs’ First Interrogatories to the
extent same seeks to strain the ordinary and common place meanings of the words defined therein.
4. Defendants object each interrogatory to the extent it seeks information or documents
protected by attorney-client privilege, the attorney work product privilege, or any other applicable
privilege, rule of privacy or confidentiality, or restriction that renders such information
non-discoverable.
1
SUNITO M. LESLIE, P.A.
3350 SW 148" AVENUE. SUITE 110 MIRAMAR, FL 33027 TeL: 954.369.5519 | Fax: 954.241.68915. Defendants object to each interrogatory to the extent it seeks information that is neither
relevant to the claims or defenses of any party in the litigation nor is reasonably calculated to lead to
the discovery of admissible evidence.
6. Defendants answer to each interrogatory based on information available as of the date
hereof and reserves the right to supplement its objections or answers to any of the interrogatories
pursuant to all appropriate rules, laws, statutes and regulations.
7. Defendants’ answers and objections to the each of the interrogatories are made without
in any way waiving or intending to waive their right to raise all questions as to competence, relevancy,
materiality, privilege and admissibility as evidence for any purpose.
Subject to and without waiving the foregoing general objections, Defendants provide the following
specific objections and answers.
SPECIFIC OBJECTIONS AND ANSWERS
1. What is the name, address, and title of the individual who is answering these
interrogatories?
ANSWER: The individual answering these interrogatories is Mr. Theadore Muschette,
having an address at 7183 W. Oakland Park Blvd., Lauderhill, FL 33313.
2. Please identify any and all individuals who were responsible for incorporating Pan
Fridays LLC and PanFridays Events, LLC ventures, to include all ventures related to the pop up
restaurant and party concept which is the subject of this litigation and was expressly a part of the
October 5, 2012 Wolfpakk, LLC contract, herein after (“Pan Fridays”).
ANSWER: Defendants object to this interrogatory on the grounds that it is vague and
ambiguous as to the “ventures” to which the term “Pan Fridays” refers. Defendants are without
knowledge as to the undefined “October 5, 2012 Wolfpakk, LLC contract”; and, therefore, are without
knowledge regarding the ventures “expressly” a part thereof. Accordingly, Defendants’ knowledge and
answers are limited to PanFridays, LLC; and PanFridays Events, LLC.
Subject to and without waiving the foregoing objections, Defendants answer as follows:
The identity of the individuals responsible for incorporating PanFridays, LLC are as follows:
q@ Theadore Muschette, having an address at 7183 W. Oakland Park Blvd., Lauderhill,
FL 33313 and the business telephone number: (954) 812-4279. Mr. Muschette is employed by
PanFridays, LLC in the position of a chef.
(ii) Sunito M. Leslie, Esq. of Sunito M. Leslie, P.A., attorney at law and counsel to
Defendants in the instant case, having an office address at 3350 SW 148th Avenue, Suite 110, Miramar,
2
SUNITO M. LESLIE, P.A.
3350 SW 1487 AveNUE. SUITE 110 MIRAMAR, FL 33027 TEL: 954.369.5519 | Fax: 954.241.6891FL 33027 and the business telephone number: (954) 369.5519.
As to PanFridays Events, LLC, the identity of the individuals responsible for incorporating
same are as follows:
0) Theadore Muschette, whose address, telephone number and name of employer,
occupation and job title are as set forth above in this interrogatory.
(ii) Ade Ellis, having an address at 7183 W. Oakland Park Blvd., Lauderhill, FL 33313 and
the business telephone number: (954) 812-4279. Mr. Ellis is employed by PanFridays, LLC in the
position of a chef.
(iii) | Sunito M. Leslie, Esq. of Sunito M. Leslie, P.A., attorney at law and counsel to
Defendants in the instant case, whose address, telephone number and name of employer, occupation
and job title are as set forth above in this interrogatory.
3. Please identify any and all individuals with access to the Pan Fridays financial
accounts, to include checking accounts, savings accounts, lock boxes, cash boxes and operating funds.
ANSWER: Defendants object to this interrogatory on the grounds that it is vague and
ambiguous as to the “ventures” to which the term “Pan Fridays” refers. Defendants are without
knowledge as to the undefined “October 5, 2012 Wolfpakk, LLC contract”; and, therefore, are without
knowledge regarding the iventures “expressly” a part thereof. Accordingly, Defendants’ knowledge
and answers are limited to PanFridays, LLC; and PanFridays Events, LLC.
Subject to and without waiving the foregoing objections, the identity of the individual having
access to the PanFridays, LLC financial accounts is as follows: Theadore Muschette, whose address,
telephone number, employer, occupation and job title are as set forth above in interrogatory no.2.
There are no financial accounts associated with PanFridays Events, LLC.
4. Please list all managers employed by Pan Fridays.
ANSWER: Defendants object to this interrogatory on the grounds that it is vague and
ambiguous as to the “ventures” to which the term “Pan Fridays” refers. Defendants are without
knowledge as to the undefined “October 5, 2012 Wolfpakk, LLC contract”; and, therefore, are without
knowledge regarding the ventures “expressly” a part thereof. Accordingly, Defendants’ knowledge and
answers are limited to PanFridays, LLC; and PanFridays Events, LLC.
Subject to and without waiving the foregoing objections, Defendants answer that neither
PanFridays, LLC or PanFridays Events, LLC employs any managers.
5. Please list all materials purchased and utilized by Pan Fridays.
ANSWER: Defendants object to this interrogatory on the grounds that it is vague and
ambiguous as to the “ventures” to which the term “Pan Fridays” refers. Defendants are without
knowledge as to the undefined “October 5, 2012 Wolfpakk, LLC contract”; and, therefore, are without
3
SUNITO M. LESLIE, P.A.
3350 SW 148" AVENUE, SUITE 110 MIRAMAR, FL33027 TEL: 954.369.5519 | FAx: 954.241.6891knowledge regarding the ventures “expressly” a part thereof. Accordingly, Defendants’ knowledge and
answers are limited to PanFridays, LLC; and PanFridays Events, LLC. Defendants further object to
this interrogatory on the grounds that the term “materials” is vague and ambiguous; and that this
interrogatory is overbroad, unduly burdensome, irrelevant to the claims and defenses of any party in
the litigation, and not reasonably calculated to lead to the discovery of admissible evidence.
6. Please list all the names, addresses, telephone numbers and titles of any Pan Fridays’
employees or contractors, including paid or otherwise compensated promoters.
ANSWER: Defendants object to this interrogatory on the grounds that it is vague and
ambiguous as to the “ventures” to which the term “Pan Fridays” refers. Defendants are without
knowledge as to the undefined “October 5, 2012 Wolfpakk, LLC contract”; and, therefore, are without
knowledge regarding the ventures “expressly” a part thereof. Accordingly, Defendants’ knowledge and
answers are limited to PanFridays, LLC; and PanFridays Events, LLC. Defendants further object to
this interrogatory as unduly burdensome, irrelevant to the claims and defenses of any party in the
litigation, and not reasonably calculated to lead to the discovery of admissible evidence.
7. Were any payments made to Plaintiffs from Pan Fridays in the past ten (10) years? If
yes, please provide date, amount and recipient.
ANSWER: Defendants object to this interrogatory on the grounds that it is vague and
ambiguous as to the “ventures” to which the term “Pan Fridays” refers. Defendants are without
knowledge as to the undefined “October 5, 2012 Wolfpakk, LLC contract”; and, therefore, are without
knowledge regarding the ventures “expressly” a part thereof. Accordingly, Defendants’ knowledge and
answers are limited to PanFridays, LLC; and PanFridays Events, LLC. Defendants further object that
this interrogatory is overbroad, requests information beyond the time period relevant to this action, and
not reasonably calculated to lead to the discovery of admissible evidence. Defendants further object
that this interrogatory seeks information provided as part of an equitable accounting, for which
Plaintiffs have brought a cause of action. Unless and until Plaintiffs have established the right to an
accounting , Plaintiffs are not entitled to discovery as to the information sought.
8. Were any payments made to Defendants from Pan Fridays in the past ten (10) years?
If yes, please provide date, amount and recipient.
ANSWER: Defendants object to this interrogatory on the grounds that it is vague and
ambiguous as to the “ventures” to which the term “Pan Fridays” refers. Defendants are without
knowledge as to the undefined “October 5, 2012 Wolfpakk, LLC contract”; and, therefore, are without
knowledge regarding any ventures “expressly” a part thereof. Accordingly, Defendants’ knowledge
and answers are limited to PanFridays, LLC; and PanFridays Events, LLC. Defendants further object
that this interrogatory is overbroad, requests information beyond the time period relevant to this action,
and not reasonably calculated to lead to the discovery of admissible evidence. Defendants further object
that this interrogatory seeks information provided as part of an equitable accounting, for which
4
SUNITO M, LESLIE, P.A.
3350 SW 148" AVENUE. SUITE 110 MIRAMAR, FL33027 TEL: 954.369.5519 | Fax: 954.241.6891Plaintiffs have brought a cause of action. Unless and until Plaintiffs have established the right to an
accounting, Plaintiffs are not entitled to discovery as to the information sought.
9. Does a document expressly ending the Wolfpakk, LLC partnership venture exist? If so,
please provide a full and complete copy.
ANSWER: Defendants are without knowledge of the existence of a “Wolfpakk, LLC
partnership” and are, therefore, are without knowledge of the existence of such a document.
10. Did the Defendants propose to buy, outright or otherwise, the Pan Fridays venture? If
so, when, how, and to whom?
ANSWER: Defendants object to this interrogatory on the grounds that it is vague and
ambiguous as to the “ventures” to which the term “Pan Fridays” refers. Defendants are without
knowledge as to the undefined “October 5, 2012 Wolfpakk, LLC contract”; and, therefore, are without
knowledge regarding any ventures “expressly” a part thereof. Accordingly, Defendants’ knowledge
and answers are limited to PanFridays, LLC; and PanFridays Events, LLC. Defendants further object
to this interrogatory on the grounds that it is vague and ambiguous, overbroad, irrelevant to the claims
and defenses of any party in the litigation, and not reasonably calculated to the discovery of admissible
evidence.
Subject to and without waiving the foregoing objections, Defendants answers that it has never
proposed to buy, outright or otherwise, PanFridays, LLC or PanFridays Events, LLC.
11. Did the Defendants propose Pan Fridays as a separate venture from that envisioned and
expressly written on the Wolfpakk, LLC contract? If so, when, how and to whom?
ANSWER: Defendants object to this interrogatory on the grounds that it is vague and
ambiguous as to the “ventures” to which the term “Pan Fridays” refers. Defendants are without
knowledge as to the undefined “October 5, 2012 Wolfpakk, LLC contract”; and, therefore, are without
knowledge regarding any ventures “expressly” a part thereof. Accordingly, Defendants’ knowledge
and answers are limited to PanFridays, LLC; and PanFridays Events, LLC. Defendants further object
to this interrogatory on the grounds that it is vague and ambiguous as to term “envisioned”, irrelevant
to the claims and defenses of any party in the litigation and not reasonably calculated to lead to the
discovery of admissible evidence.
12. What was the response from the other co-venturers to these proposals?
ANSWER: Defendants object to this interrogatory on the grounds that it is vague,
ambiguous and subjecting to varying interpretations as to “co-venturers”. Defendants further object
that this interrogatory seeks information that is irrelevant to the claims and defenses of any party in the
litigation and not reasonably calculated to lead to the discovery of admissible evidence.
13. On what date did the Defendants cease business operations with Plaintiffs?
5
SUNITO M. LESLIE, P.A.
3350 SW 1487 AVENUE. SUITE 110 MIRAMAR, FL 33027 TEL: 954.369.5519 | Fax: 954.241.6891ANSWER: Defendants object to this interrogatory on the grounds that the term “business
operations” is vague, ambiguous and subject to varying interpretations.
14. For what reason(s) did the Defendants cease business operations with Plaintiffs?
ANSWER: Defendants object to this inlerrogatory on the grounds that the term “business
operations” is vague, ambiguous and subject to varying interpretations.
15. Did Defendants notify Plaintiffs of “split in Wolfpack”? Ifo, when, how and to whom?
ANSWER: Defendants is without knowledge of the “split in Wolfpack” and is, therefore,
unable to answer this interrogatory.
16. Are you now or were you ever in the last ten (10) years involved in any other form of
civil litigation or the subject of a civil complaint? If yes, please state who made the complaint, when
and where.
ANSWER: Defendants object to this interrogatory on the grounds that it is overbroad,
unduly burdensome, and requests information beyond the time period relevant to the claims and
defenses of any party in this litigation and not reasonably calculated to lead to the discovery of
admissible evidence. Defendants further object that this interrogatory requests information that is in
the possession, custody or control of Plaintiffs.
Subject to and without waiving the foregoing objections, in the last ten (10) years, neither
Defendant Theadore Muschette and Ade Ellis has been involved in any other form of civil litigation or
has been the subject of a civil complaint.
17. Please identify, in the last ten (10) years, any meetings between Defendants and
Plaintiffs, the co-venturers of Wolfpakk, LLC., regarding the Pan Fridays venture.
ANSWER: Defendants object to this interrogatory on the grounds that it is vague and
ambiguous as to the “ventures” to which the term “Pan Fridays” refers. Defendants are without
knowledge as to the undefined “October 5, 2012 Wolfpakk, LLC contract”; and, therefore, are without
knowledge regarding any ventures “expressly” a part thereof. Accordingly, Defendants’ knowledge
and answers are limited to PanFridays, LLC; and PanFridays Events, LLC. Defendants further object
to this interrogatory on the grounds that it is vague, ambiguous, and subject to varying interpretations
as to the term “co-venturers”; it is also overbroad, unduly burdensome, and requests information
beyond the time period relevant to the claims and defenses of any party in this litigation and not
reasonably calculated to lead to the discovery of admissible evidence. Defendants further object that
6
SUNITO M. LESLIE, P.A.
3350 SW 148” AVENUE, SUITE 110 MiraMaR, FL 33027 TeL: 954.369.5519 | Fax: 954.241.6891this interrogatory requests information that is in the possession, custody or control of Plaintiffs.
7
Respectfully Submitted,
SUNITO M. LESLIE, P.A
Attorney for Defendants
3350 SW 148" Avenue
Suite 110
Miramar, FL 33027
Telephone: 954.369.5519
Facsimile: 954.241.6891
/s/_ Sunito M. Leslie
Sunito M. Leslie
Florida Bar No. 0096943
Primary Email: sunito@smleslielaw.com
Secondary Email: service@smleslielaw.com
SUNITO M. LESLIE, P.A.
3350 SW 148" AVENUE, SUITE 110 MIRAMAR, FL 33027 TEL: 954.369.5519 | FAX: 954.241.6891VERIFICATION OF ANSWERS TO INTERROGATORIES
STATE OF FLORIDA )
COUNTY OF BROWARD )
Before me, the undersigned authority, personally appeared THEADORE MUSCHETTE, who [|
is personally known to me or [ 'Thas produced £ {do (Yard (cre “<=, as identification. and upon
being first sworn deposes and says that the answers written to each of the foregoing interrogatories are true
and correct to the best of his knowledge, information and belief. and subscribes his name hereto in
verification thereof.
wiry Loe
ane Mn -
My
se Notary Public, State of Florida
Printed Name:
My Commission Expires:
8
SUNITO M. LESLIE, P.A.
3350 SW 148" AVENUE, SUITE 110 MIRAMAR. FL33027 TEL: 954.369.5519 | FAX: 954.241.6891VERIFICATION OF ANSWERS TO INTERROGATORIES
STATE OF FLORIDA )
) SS:
COUNTY OF BROWARD )
Before me, the undersigned authority, personally appeared ADE ELLIS, who [__] is personally
known to me or | ] has produced #1 DeivesS Mc , as identification, and upon being first
sworn deposes and says that he has read the answers written to each of the foregoing interrogatories and
they are true and correct to the best of his knowledge, information and-betieand subscribes his name
hereto in verification thereof.
fia: ss
Notary Public, State of Florida
Printed Name:
ULL yyy, My Commission Expires:
si My, ly Pi
oh Wty,
s
s
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9
SUNITO M. LESLIE, P.A.
3350 SW 148" AVENUE. SUITE 110 MIRAMAR, FL 33027 TEL: 954 369.5519 | Fax: 954.241.6891CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
electronic mail this 13" day of April, 2016 to: Lee Friedland, Esq. of Lee Friedland, P.A., 707 NE 3
Street, Suite 201, Ft. Lauderdale, Florida; Email: lee@yourfightourbattle.com and at
pleadings@yourfightourbattle.com.
/s/_ Sunito M. Leslie
Sunito M. Leslie
Florida Bar No. 0096943
10
SUNITO M. LESLIE, PA.
3350 SW 1487 AVENUE. SUITE 110 MIRAMAR, FL33027 TEL: 954.369.5519 | Fax: 954.241.6891IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
WOLFPAKK, LLC, et al.
CASE NO.: CACE-15-017977
Plaintiffs, DIVISION: 04
vs.
PANFRIDAYS, LLC, et al.
Defendants.
DEFEND. 'S’? RESPONSE TO PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION
Defendants, PANFRIDAYS, LLC; PANFRIDAYS EVENTS, LLC; ADE ELLIS; and THEADORE
MUSCHETTE, by and through their undersigned counsel and pursuant to Rules 1.350 of the Florida
Rules of Civil Procedure, hereby respond to the First Request for Production propounded by Plaintiffs,
as follows:
GENERAL OBJECTIONS
1. The following general objections are hereby incorporated into the responses to each
request set forth herein, and to each and every amendment, supplement or modification to these responses,
whether or not expressly incorporated in each individual response.
2. Defendants object to the “Definitions and Instructions” section of Plaintiffs’ First
Request for Production and to each request to the extent it seeks to impose obligations on Defendants
that are beyond, or inconsistent with, those set forth in the Florida Rules of Civil Procedure or any other
applicable rules, decisions or orders of the Court.
3. Defendants object to the “Definitions” section of Plaintiffs’ First Request for Production
to the extent same seeks to strain the ordinary and common place meanings of the words defined therein.
4, Defendants object to each request to the extent that it seeks “all documents” or “any and
all” with respect to a certain subject matter on the grounds that it is overbroad and unduly burdensome
or that it is seeks redundant or duplicative information.
SUNITO M. LESLIE, P.A,
3350 SW 148" AVENUE, SUITE 110 MIRAMAR. FL33027 TEL: 954.369.5519 | Fax: 954.241.68915. Defendants object to each request to the extent it seeks information or documents
protected by attorney-client privilege, the attorney work product privilege, or any other applicable
privilege, rule of privacy or confidentiality, or restriction that renders such information non-discoverable.
6. Defendants object to each request to the extent that (i) it seeks information that does not
specifically refer to events which are the subject matter of this litigation; and (ii) it is neither relevant to
the claims or defenses of any party in this litigation nor is reasonably calculated to lead to the discovery
of admissible evidence.
7. Defendants’ responses and objections to each request is based on information available
as of the date hereof, and Defendants reserve the right to supplement its objections or responses to any
of the requests pursuant to all appropriate rules, laws, statutes and regulations. Further, Defendants’
responses and objections are given without prejudice to the right of Defendants to use or rely upon
subsequently discovered information or documents.
8. Defendants’ responses to the each of the requests are made without in any way waiving
or intending to waive their right to raise all questions as to competence, relevancy, materiality, privilege
and admissibility as evidence for any purpose.
Subject to and without waiving the foregoing general objections, Defendants provide the following
specific objections and responses.
SPECIFIC OBJECTIONS AND RESPONSES
1. All e-mails, including attachments, exchanged between Defendants and Plaintiffs,
or anyone acting on Defendants’ or Plaintiffs’ behalf, during the relevant time period.
RESPONSE: Defendants object on the grounds that this request is overbroad, unduly
burdensome, and amounts to harassment as it requests information in Plaintiffs’ possession, custody or
control, or information that is equally available to Plaintiffs. Defendants further object that this request
seeks information that is irrelevant to the claims and defenses of any party in this litigation and is not
reasonably calculated to lead to the discovery of admissible evidence.
2. All other documents exchanged between Defendants and Plaintiffs, or anyone
acting on Defendants’ or Plaintiffs’ behalf, during the relevant time period.
RESPONSE: Defendants object on the grounds that this request is overbroad, unduly
burdensome, irrelevant to the claims and defenses of any party in this litigation, and not reasonably
calculated to lead to the discovery of admissible evidence.
2
SUNITO M. LESLIE, P.A.
3350 SW 148™ AVENUE, SUITE 110 MIRAMAR, FL33027 TEL: 954.369.5519 | Fax: 954.241.68913. All e-mails, including attachments, exchanged between Defendants, or anyone
acting on their behalf, during the relevant time period.
RESPONSE: Defendants object on the grounds that this request is overbroad, unduly
burdensome, irrelevant to the claims and defenses of any party in this litigation, and not reasonably
calculated to lead to the discovery of admissible evidence.
4, All other documents exchanged between Defendants, or anyone acting on their
behalf, during the relevant time period.
RESPONSE: Defendants object on the grounds that this request is overbroad, unduly
burdensome, irrelevant to the claims and defenses of any party in this litigation, and not reasonably
calculated to lead to the discovery of admissible evidence.
5. Defendants’ personal cell phone records for the calendar years 2011, 2012, 2013,
2014, 2015 and 2016 reflecting any call or text message activity between Defendants and
Plaintiffs.
RESPONSE: Defendants object on the grounds that this request is overbroad and amounts to
harassment as it seeks information for which the complete records are in Plaintiffs’ possession, custody
or control, or information that is equally available to Plaintiffs. Defendants further object that this request
is irrelevant to the claims and defenses of any party in this litigation and is not reasonably calculated to
lead to the discovery of admissible evidence. Defendants further object that c
Preview
Filing # 73431017 E-Filed 06/12/2018 12:43:28 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 TO COMPEL PAYMENT AND BETTER RESPONSES TO DISCOVERY COMES NOW, Plaintiffs WOLFPAKK, LLC, by and through undersigned counsel, and hereby files this Motion to Compel Payment and Better Responses to Discovery, and states as follows: 1. On April 11, 2018, Honorable Sandra Perlman ordered Defendants to pay Plaintiff's court reporter costs for the cancellation of Janet Davis deposition. See attached Exhibit A. 2. On April 12, 2018, counsel for Plaintiffs served Defendants with a Request for Payment in the amount of $214.60 if paid before May 27, 2018 and $246.29 if paid after May 27, 2018. See attached Exhibit B. To date, Defendants have failed to remit payment. 3. On March 16, 2016, Plaintiffs served Defendants with Interrogatories and Request for Production, hereto attached as Exhibit C. 4. On April 13, 2016 Defendants filed their “Answers and Objections to Plaintiff's First Interrogatories” and “Response to First Request for Production,” hereto attached as Exhibit D. WHEREFORE, Plaintiffs seeks an Order compelling Defendants to render payment within three (3) days and better responses to Interrogatories and Request for Production within ten (10) days. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 6/12/2018 12:43:28 PM.****CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served via e-service this 12" day of June, 2018 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@yourfightourbattle.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 PETER FELLOWS, ESQUIRE ATTORNEY FOR DEFENDANTS Law Firm of Fellows & Associates, P.A. Theodore Muschette & 1031 Ives Dairy Road, Suite 228 PanFridays, LLC Miami, FL 33179 Telephone: (305) 459-4452 Email: fellowslawfirm@yahoo.com LEE FRIEDLAND, ESQUIRE ATTORNEY FOR PLAINTIFF 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,IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, INAND FOR BROWARD COUNTY, FLORIDA Wolf kt Lc et.al case no: 28-7777 Plaintiff, ve ORDER ON : 1 LLC ¢ ff Phew, Met un fry Cn thant Cen pee oye Defendant. THIS CAUSE was considered by the Court on the following Motion(s) fe Sine acl HEARING was held on __““/¢#//F THE COURT having considered the grounds for the Motion, taken testimony, heard argument and considered the applicable law, itis, ORDERED as follows: op Ga 7 l cl te 3 ere som él = gx te wl beni ben Segs ih gta hen ps gaan chr tech. lay: Lak A, oe AA eed ) wth & he 7 Poy. 7? / fie Lhe Me Cie! tn Yaa (e7 i Ws DONE AND ORDERED ON in BERL MAN Uterdale, Broward County, Florida. SANDRAPER! NRA 8 Copies furnished: In Open Court C1 By Mail 0 By E-mail/Efiling Portal BC/CA 118 (Rev 07/17)Filing # 70637839 E-Filed 04/12/2018 03:21:46 PM IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA WOLFPAKK, LLC, et al, CASE NO. CACE02015-017977 Plaintiffs, v. PANFRIDAYS, LLC, et al, Defendants. PLAINTIFFS’ REQUEST FOR PAYMENT Plaintiffs WOLFPAKK, LLC, et al., by and through undersigned counsel, hereby requests Defendants PANFRIDAYS, LLC and THEADORE MUSCHETTE to provide the undersigned with payment in the amount of Two Hundred Fourteen Dollars and Sixty Cents ($214.60) as per the invoice hereto attached as Exhibit A and pursuant to this Court’s Order dated April 11, 2018 hereto attached as Exhibit B. CERTIFICATE OF SERVICE JHEREBY CERTIFY that a true and correct copy of the foregoing was served via e-service this 12" day of April, 2018 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@yourfightourbattle.com By: /s/ Lee Friedland Lee Friedland, Esquire Florida Bar No.: 991163SERVICE LIST PETER FELLOWS, ESQUIRE ATTORNEY FOR DEFENDANTS Law Firm of Fellows & Associates, P.A. Theodore Muschette & 1031 Ives Dairy Road, Suite 228 PanFridays, LLC Miami, FL 33179 Telephone: (305) 459-4452 Email: fellowslawfirm@yahoo.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@vyourfightourbattle.com Friedland & Associates, P.A. 4486 SW 64 Avenue Davie, Florida 33314 954-321-8810; 954-321-8995INVOICE U.S. Legal Support, Inc. Invoice No. Date - Invo No. 100 Northeast Third Avenue = = Suite 1050 120166089 4/12/2018 1720559 Fort Lauderdale FL 33301 Phone:954-463-2933 Fax:954-525-8919 eee ee eae es 4/6/2018 ‘CACE02015017977 Case Name Wolfpakk, L.L.C. vs. PanFridays, LLC. Nondeu Levy, Esquire Friedland & Assocates Payment Terms 707 Northeast Third Avenue telah Sulte 201 Fort Lauderdale FL 33304 ORIGINAL TRANSCRIPT OF: Janette Davis 16.00 Pages @ 450 72.00 Attendance - First Hour 95.00 95.00 Processing & Handling 45.00 45.00 Janette Davis, Exhibit 4.00. Pages @ 0.65 2.60 TOTAL DUE >>> $214.60 AFTER 5/27/2018 PAY $246.79 (-) Payments/Credits: 0.00 (+) Finance Charges/Debits: 0.00 (=) New Balance: $214.60 Tax ID: 76-0523238 Nondau Lewy, Esquire Friedland & Associates 707 Northeast Third Avenue Suite 201 Fort Lauderdale FL 33304 U.S. Legal Support, Inc. P.O. Box 4772-12 Houston TX 77210-4772 Phone: 954-321-8810 Plecise detach bottom portion and remra with paveient Invoice No. 120166089 Invoice Date 4/12/2018 Total Due : $214.60 Job No. 1720559 BUID S2-FT.LA Case No. CACE02015017977 Fax:954-321-8995 Case Name Woltpakk, LLC. vs. Panky PLAINTIFF'S EXHIBIT AFiling # 38961864 E-Filed 03/14/2016 11:18:19 AM IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA WOLFPAKK, LLC., a Florida Limited CASE NO.: CACE 15-017977 (04) Liability Company, OSHANE MOODIE, an individual, DAISON OSBORNE, an individual, TRISTON THOMPSON, an individual, ROMAINE SPENCE, an individual, and DAMANI VASSELL, an individual, Plaintiffs, v. PANFRIDAYS, LLC, A Florida Limited Liability Company, PANFRIDAYS EVENTS, LLC, a Florida Limited Liability Company, ADE ELLIS, an individual, and THEADORE MUSCHETTE, an individual, Defendants. iH NOTICE OF PLAINTIFFS FILING INTERROGATORIES TO DEFENDANTS Plaintiffs, 'WOLFPAKK, LLC., et al., by and through the undersigned counsel, in accordance with Fla. Civ. R. 1.340, propounds the attached Interrogatories to Defendants, to be answered, in writing, under oath within thirty (30) days. Respectfully submitted: FRIEDLAND & ASSOCIATES 707 3" Avenue, Suite 201 Fort Lauderdale, Florida 33304 954-321-8810; 954-321-8995 (facsimile) Pleadings@yourfightourbattle.com Lee@yourfightourbattle.com By: /s/ Lee Friedland Lee Friedland, Esquire Florida Bar No. 991163 lof2 Friedland & Bocksch 33 NE 2" Street, Suite 101, Fort Lauderdale, Florida 33301 954-321-8810; 954-321-8995 (Facsimile)CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served via e-service this 14" day of March, 2016 to: Sunito M. Leslie, Esq., Sunito M. Leslie, P.A., 3350 SW 148" Avenue, Suite 110, Miramar, FI. 33027; E-mail: sunito@smieslielaw.com and service@smleslielaw.com /s/Lee Friedland Lee Friedland 2 of2 Friedland & Bocksch 33 NE 2™ Street, Suite 101, Fort Lauderdale, Florida 33301 954-321-8810; 954-321-8995 (Facsimile)DEFINITIONS Notwithstanding the specific definitions below, each word, term, or phrase used in these Interrogatories should be given their most expansive and inclusive meaning. As used in these Interrogatories, the following terms are to be interpreted in accordance with these definitions: 1. “All” includes “each and every.” 2. “And” and “Or” are to be construed both conjunctively and disjunctively, as necessary to give each request its broadest possible meaning. 3. “Anyone acting on your behalf’ means all persons including your agents, employees, insurance companies, attorneys, investigators, or consultants. 4. “Complaint” refers to each and every complaint, case, suit, or investigation whether or not it was formal, informal, civil, criminal, filed in a court of law, settled, or dismissed. 5. “Defendant,” “you,” or “your” refers to Defendants Ade Ellis and Theadore Muschette. The term also includes any of Defendants’ agents, enterprises, representatives, or anyone else acting, or who has acted, on either of their behalf. 6. “Document” or “documents” includes any writing or other medium, including, but not limited to, electronic, magnetic, or optical media, by which information is transmitted or recorded. The terms also include all drafts, amendments, modifications, changes or side correspondence, notes, or non-identical copies such as those that include marginalia or other printed, stamped or handwritten revisions or notations. 7. “Marketing materials” means any document that markets or provides information to others concerning your business or occupation. This includes, but is not limited to, print advertisements, such as newspapers, fliers, signs, posters, business cards, or audio advertisements, such as radio recordings, or video advertisements, such as television recordings. 1 of9 Friedland & Bocksch 33 NE 2 Street, Suite 101, Fort Lauderdale, Florida 33301 954-321-8810; 954-321-8995 (Facsimile)8. “Person” means any natural or artificial person, including business entities and other legal entities. 9. ‘Relating to,” “relate to,” “related to,” and “relates to” means in any way concerning, containing, describing, constituting, referring to, evidencing, mentioning, reflecting, identifying, refuting, contradicting, supporting, connected with or in any way pertaining to the subject, in whole or in part. 10. “Identify” means, in the case of an act, transaction, relationship, thing or occurrence: a. Giving a detailed description, including complete references to: date, place, person involved, and means employed; b. Identifying your source of information concerning such act, transaction, thing or occurrence, including the date you received such information; and c. Identifying each person having knowledge of such act, transaction, thing or occurrence. 11. “Identify” means, when used in conjunction with the term “individual” or “person,” or “identity” to state the person’s: a. full legal name; b. relationship to Plaintiffs or Defendants, e.g., friend, relative, employee; ¢. present or last known address and telephone number (business and residential); d. name of employer, occupation, job title, business affiliation and/or nature of business. 12. “Identify” means, when used in conjunction with an entity, organization, or anything other than a natural person, to state as much of the following information as is available to Defendant: a. the name under which it customarily does business; b. the address of its principal place of business; and 11 of 9 Friedland & Associates 707 NE 3" Street, Suite 201, Fort Lauderdale, Florida 33304 954-321-8810; 954-321-8995 (Facsimile)c. the identity of the person in such organization who is believed to have the most extensive knowledge of the matters in question. 13. “Identify” means, when used in conjunction with communications, to provide as much of the following information as is available to Defendant: a. the manner or type of the communication; b. the date of and parties to the communication; c. where the communication took place; d. the substance of the communication; and e. identify all documents describing or memorializing the communication. 14. “Identify” means, when used with respect to a meeting, to provide as much of the following information as is available to Defendant: a. the date or dates of the meeting; b. the place of the meeting; c. the persons attending the meeting; d. the person who called the meeting; e. what was said and by whom at the meeting; f. what decisions were reached at the meeting; and g. whether any notes, minutes, or other memoranda were made to record the proceedings of such meeting, and, if so, the precise location of the document(s) and the identity of the custodian. 15. “Identify” means, when used in conjunction with the term “document,” to provide as much of the following information as is available to Defendant: a. its author(s), sender(s), addressee(s), recipient(s); 11 of 9 Friedland & Associates 707 NE 3" Street, Suite 201, Fort Lauderdale, Florida 33304 954-321-8810; 954-321-8995 (Facsimile)b. its date; c. type of document (e.g., letter, memorandum, report); d. its subject matter; e. the number of pages; f. any attachments or appendices; g. and the person(s) who is its custodian. 11 of 9 Friedland & Associates 707 NE 3" Street, Suite 201, Fort Lauderdale, Florida 33304 954-321-8810; 954-321-8995 (Facsimile)BREACH OF CONTRACT INTERROGATORIES 1. What is the name, address, and title of the individual who is answering these interrogatories? 2. Please identify any and all individuals who were responsible for incorporating Pan Fridays LLC and PanFridays Events, LLC ventures , to include all ventures related to the pop up restaurant and party concept which is the subject of this litigation and was expressly a part of the October 5, 2012 Wolfpakk, LLC contract, herein after (“Pan Fridays”). 3. Please identify any and all individuals with access to the Pan Fridays financial accounts, to include checking accounts, savings accounts, lock boxes, cash boxes and operating funds. 4, Please list all managers employed by Pan Fridays. 11 of 9 Friedland & Associates 707 NE 3" Street, Suite 201, Fort Lauderdale, Florida 33304 954-321-8810; 954-321-8995 (Facsimile)5. Please list all materials purchased and utilized by Pan Fridays. 6. Please list all the names, addresses, telephone numbers and titles of any Pan Fridays’ employees or contractors, including paid or otherwise compensated promoters. 7. Were any payments made to Plaintiffs from Pan Fridays in the past ten (10) years? If yes, please provide date, amount and recipient. 8. Were any payments made to Defendants from Pan Fridays in the past ten (10) years? If yes, please provide date, amount and recipient. 11 of 9 Friedland & Associates 707 NE 3* Street, Suite 201, Fort Lauderdale, Florida 33304 954-321-8810; 954-321-8995 (Facsimile)9. Does a document expressly ending the Wolfpakk, LLC partnership venture exist? If so, please provide a full and complete copy. 10. Did the Defendants propose to buy, outright or otherwise, the Pan Fridays venture? Ifso, when, how, and to whom? 11. Did the Defendants propose Pan Fridays as a separate venture from that envisioned and expressly written on the Wolfpakk, LLC contract? If so, when, how and to whom? 12. What was the response from the other co-venturers to these proposals? 11 of 9 Friedland & Associates 707 NE 3 Street, Suite 201, Fort Lauderdale, Florida 33304 954-321-8810; 954-321-8995 (Facsimile)13. | On what date did the Defendants cease business operations with Plaintiffs? 14. For what reason(s) did the Defendants cease business operations with Plaintiffs? 15. Did Defendants notify Plaintiffs of “split in Wolfpack”? If so, when, how and to whom? 16. Are you now or were you ever in the last ten (10) years involved in any other form of civil litigation or the subject of a civil complaint? If yes, please state who made the complaint, when and where. 11 of 9 Friedland & Associates 707 NE 3" Street, Suite 201, Fort Lauderdale, Florida 33304 954-321-8810; 954-321-8995 (Facsimile)17. Please identify, in the last ten (10) years, any meetings between Defendants and Plaintiffs, the co-venturers of Wolfpakk, LLC., regarding the Pan Fridays venture. AFFIANT STATE OF FLORIDA ) COUNTY OF ) BEFORE ME, the undersigned authority, personally appeared who, after being first duly cautioned and sworn, deposes and states that he/she has read the above Answers to Interrogatories and that he/she has set his/her hand and seal thereto for the purposes therein expressed. The foregoing instrument is acknowledged before me this day of 2016 by , on behalf of the who is: Personally known to me. Who has produced the following as identification: Who did/did not take an oath. Given under my hand and official seal this day of. » 2016. My Commission Expires: NOTARY PUBLIC Printed Name: State of Florida at Large Notary No.: (Notary Seal) 11 of 9 Friedland & Associates 707 NE 3" Street, Suite 201, Fort Lauderdale, Florida 33304 954-321-8810; 954-321-8995 (Facsimile)Filing # 39077869 E-Filed 03/16/2016 11:24:30 AM IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA WOLFPAKK, LLC., a Florida Limited CASE NO.: CACE 15-017977 (04) Liability Company, OSHANE MOODIE, an individual, DAISON OSBORNE, an individual, TRISTON THOMPSON, an individual, ROMAINE SPENCE, an individual, and DAMANI VASSELL, an individual, Plaintiffs, vs. PANFRIDAYS, LLC, A Florida Limited Liability Company, PANFRIDAYS EVENTS, LLC, a Florida Limited Liability Company, ADE ELLIS, an individual, and THEADORE MUSCHETTE, an individual, Defendants. / PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION TO DEFENDANTS Plaintiffs, by and through undersigned counsel, serves upon Defendants, PANFRIDAYS, LLC, PANFRIDAYS EVENTS, LLC, ADE ELLIS, THEADORE MUSCHETTE, to produce and make available for inspection and duplication, in response to each numbered paragraph, all documents specified herein which are in Defendants’ possession, custody or control, or in the possession, custody or control of Defendants’ agents, accountants or attorneys. Defendants are requested to make such production within thirty (30) days. DEFINITIONS AND INSTRUCTIONS i The terms "you," "your" and "Defendant" mean the party or parties to which this request is addressed, including their agents, accountants, attorneys, and all other persons acting or purporting to act on their behalf.2. As used herein, "relevant time period" shall mean October 5, 2011 - present. 3. The term "person" means any natural person, individual, proprietorship, partnership, corporation, association, organization, joint venture, firm, other business enterprise, governmental body, group of natural persons or other entity. 4. The term "document" means any written or graphic matter or other means of preserving thought or expression and all tangible things from which information can be processed or transcribed, including the originals and all non-identical copies, whether different from the original by reason of any notation made on such copy or otherwise, including, but not limited to, correspondence, memoranda, notes, messages, letters, telegrams, teletype, telefax, bulletins, meetings or other communications, interoffice and intra-office telephone calls, diaries, chronological data, minutes, books, reports, studies, summaries, pamphlets, bulletins, printed matter, charts, ledgers, invoices, worksheets, receipts, returns, computer printouts, prospectuses, financial statements, schedules, affidavits, contracts, cancelled checks, statements, transcripts, statistics, surveys, magazine or newspaper articles, releases (and any and all drafts, alterations and modifications, changes and amendments of any of the foregoing), graphic or aural records or representations of any kind (including without limitation photographs, microfiche, microfilm, videotape, records and motion pictures) and electronic, mechanical or electric records or representations of any kind (including without limitation tapes, cassettes, discs and records). 5. The term "all documents" means every document or group of documents as above defined that are known to you or that can be located or discovered by reasonably diligent efforts. 6. The terms "refer" or "relate to" mean to make a statement about, discuss, describe, reflect, constitute, identify, deal with, consist of, establish, comprise, list, evidence, substantiate or in any way pertain, in whole or in part, to the subject.7. The term "entity" means any natural person, individual, general or limited partnership, corporation, association, organization, joint venture, firm or other business enterprise, governmental body, group of natural persons or other entity. 8. 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. 9. When producing the documents, please keep all documents segregated by the file in which the documents are contained and indicate the name of the file in which the documents are contained and the name of the documents being produced. 10. In the event such file(s) or document(s) has (have) been removed for the purposes of this action or for some other purpose, please state the name and address of the person who removed the file, the title of the file and each subfile, if any, maintained within the file, and the present location of the file. 11. Any request for production of a document shall be deemed to require production of each and every such thing executed, created, prepared, received or in effect at any time to the present, or during any other indicated period of time. 12. Any and all documents produced pursuant to this request must be segregated and identified as being responsive to a specified numbered request. 13. If you choose to withhold any documents from production for inspection and copying (on the basis of privilege or otherwise), please identify each document withheld and provide its date, number of pages, author, recipient(s), a brief description of its subject matter, and your basis for withholding the document from production.DOCUMENTS TO BE PRODUCED lL. All e-mails, including attachments, exchanged between Defendants and Plaintiffs, or anyone acting on Defendants’ or Plaintiffs’ behalf, during the relevant time period. 2. All other documents exchanged between Defendants and Plaintiffs, or anyone acting on Defendants’ or Plaintiffs’ behalf, during the relevant time period. 3. All e-mails, including attachments, exchanged between Defendants, or anyone acting on their behalf, during the relevant time period. 4. All other documents exchanged between Defendants, or anyone acting on their behalf, during the relevant time period. 5. Defendants’ personal cell phone records for the calendar years 2011, 2012, 2013, 2014, 2015 and 2016 reflecting any call or text message activity between Defendants and Plaintiffs. 6. Defendants’ personal cell phone records for the calendar years 2011, 2012, 2013, 2014, 2015 and 2016 reflecting any call or text message activity between Defendants. 7. All documents reflecting any gifts or loans of money to Defendants on behalf of Wolfpakk, LLC. 8. All documents reflecting the accounting for the Pan Fridays venture (PanFridays, LLC and PanFridays Events, LLC). 9. Any and all statements bearing on the knowledge of facts relevant and material to the claim and defenses in the instant litigation. 10. Any and all documents and tangible things upon which your defenses and affirmative defenses are based, including, but not limited to, writings, drawings, graphs, charts,photographs, movies, slides, film, video tape, phonograph records and other recording devices, instruments, equipment, real and person property, objects, goods and vehicles. 11. Any and all ordinances, regulations, rules, statutes, customs and practices, and publications upon which your defenses and/or counter-claims herein are made. 12. Any and all sworn testimony involving the subject matter of the instant litigation. 13. Any and all documents to which you referred in formulating your response to Plaintiff's First Set of Interrogatories. 14. Any and all documents that support your Affirmative Defense(s). Respectfully submitted: FRIEDLAND & ASSOCIATES Attorneys for Plaintiff 707 NE 3" Avenue, Suite 201 Fort Lauderdale, Florida 33304 954-321-8810; 954-321-8995 (facsimile) Lee@yourfightourbattle.com Pleadings@yourfightourbattle.com By: 4/ Lee Friedland LEE FRIEDLAND, ESQUIRE FLORIDA BAR NO.: 991163 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served via e-service this 16 day of March, 2016 to: Sunito M. Leslie, Esq., Sunito M. Leslie, P.A., 3350 SW 148" Avenue, Suite 110, Miramar, FL 33027; E-mail: sunito@smleslielaw.com and service@smleslielaw.com /s/Lee Friedland Lee FriedlandIN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA WOLFPAKK, LLC, et al. CASE NO.: CACE-15-017977 Plaintiffs, DIVISION: 04 vs. PANFRIDAYS, LLC, et al. Defendants. DEFENDANTS’ ANSWERS AND OBJECTIONS TO PLAINTIFFS’ FIRST INTERROGATORIES Defendants, PANFRIDAYS, LLC; PANFRIDAYS EVENTS, LLC; ADE ELLIS; and THEADORE MUSCHETTE, pursuant to Rules 1.280 and 1.340 of the Florida Rules of Civil Procedure, hereby submit the following answers and objections to the First Interrogatories propounded by Plaintiffs. GENERAL OBJECTIONS 1. The following general objections are hereby incorporated into the answers and objections to each interrogatory set forth herein, and to each and every amendment, supplement or modification to these answers and objections hereinafter, whether or not expressly incorporated in each individual answer or objection. 2. Defendants object to each interrogatory to the extent it seeks to impose obligations on Defendants that are beyond, or inconsistent with, those set forth in the Florida Rules of Civil Procedure or any other applicable rules, decisions or orders of the Court. 3. Defendants object to the “Definitions” section of Plaintiffs’ First Interrogatories to the extent same seeks to strain the ordinary and common place meanings of the words defined therein. 4. Defendants object each interrogatory to the extent it seeks information or documents protected by attorney-client privilege, the attorney work product privilege, or any other applicable privilege, rule of privacy or confidentiality, or restriction that renders such information non-discoverable. 1 SUNITO M. LESLIE, P.A. 3350 SW 148" AVENUE. SUITE 110 MIRAMAR, FL 33027 TeL: 954.369.5519 | Fax: 954.241.68915. Defendants object to each interrogatory to the extent it seeks information that is neither relevant to the claims or defenses of any party in the litigation nor is reasonably calculated to lead to the discovery of admissible evidence. 6. Defendants answer to each interrogatory based on information available as of the date hereof and reserves the right to supplement its objections or answers to any of the interrogatories pursuant to all appropriate rules, laws, statutes and regulations. 7. Defendants’ answers and objections to the each of the interrogatories are made without in any way waiving or intending to waive their right to raise all questions as to competence, relevancy, materiality, privilege and admissibility as evidence for any purpose. Subject to and without waiving the foregoing general objections, Defendants provide the following specific objections and answers. SPECIFIC OBJECTIONS AND ANSWERS 1. What is the name, address, and title of the individual who is answering these interrogatories? ANSWER: The individual answering these interrogatories is Mr. Theadore Muschette, having an address at 7183 W. Oakland Park Blvd., Lauderhill, FL 33313. 2. Please identify any and all individuals who were responsible for incorporating Pan Fridays LLC and PanFridays Events, LLC ventures, to include all ventures related to the pop up restaurant and party concept which is the subject of this litigation and was expressly a part of the October 5, 2012 Wolfpakk, LLC contract, herein after (“Pan Fridays”). ANSWER: Defendants object to this interrogatory on the grounds that it is vague and ambiguous as to the “ventures” to which the term “Pan Fridays” refers. Defendants are without knowledge as to the undefined “October 5, 2012 Wolfpakk, LLC contract”; and, therefore, are without knowledge regarding the ventures “expressly” a part thereof. Accordingly, Defendants’ knowledge and answers are limited to PanFridays, LLC; and PanFridays Events, LLC. Subject to and without waiving the foregoing objections, Defendants answer as follows: The identity of the individuals responsible for incorporating PanFridays, LLC are as follows: q@ Theadore Muschette, having an address at 7183 W. Oakland Park Blvd., Lauderhill, FL 33313 and the business telephone number: (954) 812-4279. Mr. Muschette is employed by PanFridays, LLC in the position of a chef. (ii) Sunito M. Leslie, Esq. of Sunito M. Leslie, P.A., attorney at law and counsel to Defendants in the instant case, having an office address at 3350 SW 148th Avenue, Suite 110, Miramar, 2 SUNITO M. LESLIE, P.A. 3350 SW 1487 AveNUE. SUITE 110 MIRAMAR, FL 33027 TEL: 954.369.5519 | Fax: 954.241.6891FL 33027 and the business telephone number: (954) 369.5519. As to PanFridays Events, LLC, the identity of the individuals responsible for incorporating same are as follows: 0) Theadore Muschette, whose address, telephone number and name of employer, occupation and job title are as set forth above in this interrogatory. (ii) Ade Ellis, having an address at 7183 W. Oakland Park Blvd., Lauderhill, FL 33313 and the business telephone number: (954) 812-4279. Mr. Ellis is employed by PanFridays, LLC in the position of a chef. (iii) | Sunito M. Leslie, Esq. of Sunito M. Leslie, P.A., attorney at law and counsel to Defendants in the instant case, whose address, telephone number and name of employer, occupation and job title are as set forth above in this interrogatory. 3. Please identify any and all individuals with access to the Pan Fridays financial accounts, to include checking accounts, savings accounts, lock boxes, cash boxes and operating funds. ANSWER: Defendants object to this interrogatory on the grounds that it is vague and ambiguous as to the “ventures” to which the term “Pan Fridays” refers. Defendants are without knowledge as to the undefined “October 5, 2012 Wolfpakk, LLC contract”; and, therefore, are without knowledge regarding the iventures “expressly” a part thereof. Accordingly, Defendants’ knowledge and answers are limited to PanFridays, LLC; and PanFridays Events, LLC. Subject to and without waiving the foregoing objections, the identity of the individual having access to the PanFridays, LLC financial accounts is as follows: Theadore Muschette, whose address, telephone number, employer, occupation and job title are as set forth above in interrogatory no.2. There are no financial accounts associated with PanFridays Events, LLC. 4. Please list all managers employed by Pan Fridays. ANSWER: Defendants object to this interrogatory on the grounds that it is vague and ambiguous as to the “ventures” to which the term “Pan Fridays” refers. Defendants are without knowledge as to the undefined “October 5, 2012 Wolfpakk, LLC contract”; and, therefore, are without knowledge regarding the ventures “expressly” a part thereof. Accordingly, Defendants’ knowledge and answers are limited to PanFridays, LLC; and PanFridays Events, LLC. Subject to and without waiving the foregoing objections, Defendants answer that neither PanFridays, LLC or PanFridays Events, LLC employs any managers. 5. Please list all materials purchased and utilized by Pan Fridays. ANSWER: Defendants object to this interrogatory on the grounds that it is vague and ambiguous as to the “ventures” to which the term “Pan Fridays” refers. Defendants are without knowledge as to the undefined “October 5, 2012 Wolfpakk, LLC contract”; and, therefore, are without 3 SUNITO M. LESLIE, P.A. 3350 SW 148" AVENUE, SUITE 110 MIRAMAR, FL33027 TEL: 954.369.5519 | FAx: 954.241.6891knowledge regarding the ventures “expressly” a part thereof. Accordingly, Defendants’ knowledge and answers are limited to PanFridays, LLC; and PanFridays Events, LLC. Defendants further object to this interrogatory on the grounds that the term “materials” is vague and ambiguous; and that this interrogatory is overbroad, unduly burdensome, irrelevant to the claims and defenses of any party in the litigation, and not reasonably calculated to lead to the discovery of admissible evidence. 6. Please list all the names, addresses, telephone numbers and titles of any Pan Fridays’ employees or contractors, including paid or otherwise compensated promoters. ANSWER: Defendants object to this interrogatory on the grounds that it is vague and ambiguous as to the “ventures” to which the term “Pan Fridays” refers. Defendants are without knowledge as to the undefined “October 5, 2012 Wolfpakk, LLC contract”; and, therefore, are without knowledge regarding the ventures “expressly” a part thereof. Accordingly, Defendants’ knowledge and answers are limited to PanFridays, LLC; and PanFridays Events, LLC. Defendants further object to this interrogatory as unduly burdensome, irrelevant to the claims and defenses of any party in the litigation, and not reasonably calculated to lead to the discovery of admissible evidence. 7. Were any payments made to Plaintiffs from Pan Fridays in the past ten (10) years? If yes, please provide date, amount and recipient. ANSWER: Defendants object to this interrogatory on the grounds that it is vague and ambiguous as to the “ventures” to which the term “Pan Fridays” refers. Defendants are without knowledge as to the undefined “October 5, 2012 Wolfpakk, LLC contract”; and, therefore, are without knowledge regarding the ventures “expressly” a part thereof. Accordingly, Defendants’ knowledge and answers are limited to PanFridays, LLC; and PanFridays Events, LLC. Defendants further object that this interrogatory is overbroad, requests information beyond the time period relevant to this action, and not reasonably calculated to lead to the discovery of admissible evidence. Defendants further object that this interrogatory seeks information provided as part of an equitable accounting, for which Plaintiffs have brought a cause of action. Unless and until Plaintiffs have established the right to an accounting , Plaintiffs are not entitled to discovery as to the information sought. 8. Were any payments made to Defendants from Pan Fridays in the past ten (10) years? If yes, please provide date, amount and recipient. ANSWER: Defendants object to this interrogatory on the grounds that it is vague and ambiguous as to the “ventures” to which the term “Pan Fridays” refers. Defendants are without knowledge as to the undefined “October 5, 2012 Wolfpakk, LLC contract”; and, therefore, are without knowledge regarding any ventures “expressly” a part thereof. Accordingly, Defendants’ knowledge and answers are limited to PanFridays, LLC; and PanFridays Events, LLC. Defendants further object that this interrogatory is overbroad, requests information beyond the time period relevant to this action, and not reasonably calculated to lead to the discovery of admissible evidence. Defendants further object that this interrogatory seeks information provided as part of an equitable accounting, for which 4 SUNITO M, LESLIE, P.A. 3350 SW 148" AVENUE. SUITE 110 MIRAMAR, FL33027 TEL: 954.369.5519 | Fax: 954.241.6891Plaintiffs have brought a cause of action. Unless and until Plaintiffs have established the right to an accounting, Plaintiffs are not entitled to discovery as to the information sought. 9. Does a document expressly ending the Wolfpakk, LLC partnership venture exist? If so, please provide a full and complete copy. ANSWER: Defendants are without knowledge of the existence of a “Wolfpakk, LLC partnership” and are, therefore, are without knowledge of the existence of such a document. 10. Did the Defendants propose to buy, outright or otherwise, the Pan Fridays venture? If so, when, how, and to whom? ANSWER: Defendants object to this interrogatory on the grounds that it is vague and ambiguous as to the “ventures” to which the term “Pan Fridays” refers. Defendants are without knowledge as to the undefined “October 5, 2012 Wolfpakk, LLC contract”; and, therefore, are without knowledge regarding any ventures “expressly” a part thereof. Accordingly, Defendants’ knowledge and answers are limited to PanFridays, LLC; and PanFridays Events, LLC. Defendants further object to this interrogatory on the grounds that it is vague and ambiguous, overbroad, irrelevant to the claims and defenses of any party in the litigation, and not reasonably calculated to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Defendants answers that it has never proposed to buy, outright or otherwise, PanFridays, LLC or PanFridays Events, LLC. 11. Did the Defendants propose Pan Fridays as a separate venture from that envisioned and expressly written on the Wolfpakk, LLC contract? If so, when, how and to whom? ANSWER: Defendants object to this interrogatory on the grounds that it is vague and ambiguous as to the “ventures” to which the term “Pan Fridays” refers. Defendants are without knowledge as to the undefined “October 5, 2012 Wolfpakk, LLC contract”; and, therefore, are without knowledge regarding any ventures “expressly” a part thereof. Accordingly, Defendants’ knowledge and answers are limited to PanFridays, LLC; and PanFridays Events, LLC. Defendants further object to this interrogatory on the grounds that it is vague and ambiguous as to term “envisioned”, irrelevant to the claims and defenses of any party in the litigation and not reasonably calculated to lead to the discovery of admissible evidence. 12. What was the response from the other co-venturers to these proposals? ANSWER: Defendants object to this interrogatory on the grounds that it is vague, ambiguous and subjecting to varying interpretations as to “co-venturers”. Defendants further object that this interrogatory seeks information that is irrelevant to the claims and defenses of any party in the litigation and not reasonably calculated to lead to the discovery of admissible evidence. 13. On what date did the Defendants cease business operations with Plaintiffs? 5 SUNITO M. LESLIE, P.A. 3350 SW 1487 AVENUE. SUITE 110 MIRAMAR, FL 33027 TEL: 954.369.5519 | Fax: 954.241.6891ANSWER: Defendants object to this interrogatory on the grounds that the term “business operations” is vague, ambiguous and subject to varying interpretations. 14. For what reason(s) did the Defendants cease business operations with Plaintiffs? ANSWER: Defendants object to this inlerrogatory on the grounds that the term “business operations” is vague, ambiguous and subject to varying interpretations. 15. Did Defendants notify Plaintiffs of “split in Wolfpack”? Ifo, when, how and to whom? ANSWER: Defendants is without knowledge of the “split in Wolfpack” and is, therefore, unable to answer this interrogatory. 16. Are you now or were you ever in the last ten (10) years involved in any other form of civil litigation or the subject of a civil complaint? If yes, please state who made the complaint, when and where. ANSWER: Defendants object to this interrogatory on the grounds that it is overbroad, unduly burdensome, and requests information beyond the time period relevant to the claims and defenses of any party in this litigation and not reasonably calculated to lead to the discovery of admissible evidence. Defendants further object that this interrogatory requests information that is in the possession, custody or control of Plaintiffs. Subject to and without waiving the foregoing objections, in the last ten (10) years, neither Defendant Theadore Muschette and Ade Ellis has been involved in any other form of civil litigation or has been the subject of a civil complaint. 17. Please identify, in the last ten (10) years, any meetings between Defendants and Plaintiffs, the co-venturers of Wolfpakk, LLC., regarding the Pan Fridays venture. ANSWER: Defendants object to this interrogatory on the grounds that it is vague and ambiguous as to the “ventures” to which the term “Pan Fridays” refers. Defendants are without knowledge as to the undefined “October 5, 2012 Wolfpakk, LLC contract”; and, therefore, are without knowledge regarding any ventures “expressly” a part thereof. Accordingly, Defendants’ knowledge and answers are limited to PanFridays, LLC; and PanFridays Events, LLC. Defendants further object to this interrogatory on the grounds that it is vague, ambiguous, and subject to varying interpretations as to the term “co-venturers”; it is also overbroad, unduly burdensome, and requests information beyond the time period relevant to the claims and defenses of any party in this litigation and not reasonably calculated to lead to the discovery of admissible evidence. Defendants further object that 6 SUNITO M. LESLIE, P.A. 3350 SW 148” AVENUE, SUITE 110 MiraMaR, FL 33027 TeL: 954.369.5519 | Fax: 954.241.6891this interrogatory requests information that is in the possession, custody or control of Plaintiffs. 7 Respectfully Submitted, SUNITO M. LESLIE, P.A Attorney for Defendants 3350 SW 148" Avenue Suite 110 Miramar, FL 33027 Telephone: 954.369.5519 Facsimile: 954.241.6891 /s/_ Sunito M. Leslie Sunito M. Leslie Florida Bar No. 0096943 Primary Email: sunito@smleslielaw.com Secondary Email: service@smleslielaw.com SUNITO M. LESLIE, P.A. 3350 SW 148" AVENUE, SUITE 110 MIRAMAR, FL 33027 TEL: 954.369.5519 | FAX: 954.241.6891VERIFICATION OF ANSWERS TO INTERROGATORIES STATE OF FLORIDA ) COUNTY OF BROWARD ) Before me, the undersigned authority, personally appeared THEADORE MUSCHETTE, who [| is personally known to me or [ 'Thas produced £ {do (Yard (cre “<=, as identification. and upon being first sworn deposes and says that the answers written to each of the foregoing interrogatories are true and correct to the best of his knowledge, information and belief. and subscribes his name hereto in verification thereof. wiry Loe ane Mn - My se Notary Public, State of Florida Printed Name: My Commission Expires: 8 SUNITO M. LESLIE, P.A. 3350 SW 148" AVENUE, SUITE 110 MIRAMAR. FL33027 TEL: 954.369.5519 | FAX: 954.241.6891VERIFICATION OF ANSWERS TO INTERROGATORIES STATE OF FLORIDA ) ) SS: COUNTY OF BROWARD ) Before me, the undersigned authority, personally appeared ADE ELLIS, who [__] is personally known to me or | ] has produced #1 DeivesS Mc , as identification, and upon being first sworn deposes and says that he has read the answers written to each of the foregoing interrogatories and they are true and correct to the best of his knowledge, information and-betieand subscribes his name hereto in verification thereof. fia: ss Notary Public, State of Florida Printed Name: ULL yyy, My Commission Expires: si My, ly Pi oh Wty, s s = 9 SUNITO M. LESLIE, P.A. 3350 SW 148" AVENUE. SUITE 110 MIRAMAR, FL 33027 TEL: 954 369.5519 | Fax: 954.241.6891CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by electronic mail this 13" day of April, 2016 to: Lee Friedland, Esq. of Lee Friedland, P.A., 707 NE 3 Street, Suite 201, Ft. Lauderdale, Florida; Email: lee@yourfightourbattle.com and at pleadings@yourfightourbattle.com. /s/_ Sunito M. Leslie Sunito M. Leslie Florida Bar No. 0096943 10 SUNITO M. LESLIE, PA. 3350 SW 1487 AVENUE. SUITE 110 MIRAMAR, FL33027 TEL: 954.369.5519 | Fax: 954.241.6891IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA WOLFPAKK, LLC, et al. CASE NO.: CACE-15-017977 Plaintiffs, DIVISION: 04 vs. PANFRIDAYS, LLC, et al. Defendants. DEFEND. 'S’? RESPONSE TO PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION Defendants, PANFRIDAYS, LLC; PANFRIDAYS EVENTS, LLC; ADE ELLIS; and THEADORE MUSCHETTE, by and through their undersigned counsel and pursuant to Rules 1.350 of the Florida Rules of Civil Procedure, hereby respond to the First Request for Production propounded by Plaintiffs, as follows: GENERAL OBJECTIONS 1. The following general objections are hereby incorporated into the responses to each request set forth herein, and to each and every amendment, supplement or modification to these responses, whether or not expressly incorporated in each individual response. 2. Defendants object to the “Definitions and Instructions” section of Plaintiffs’ First Request for Production and to each request to the extent it seeks to impose obligations on Defendants that are beyond, or inconsistent with, those set forth in the Florida Rules of Civil Procedure or any other applicable rules, decisions or orders of the Court. 3. Defendants object to the “Definitions” section of Plaintiffs’ First Request for Production to the extent same seeks to strain the ordinary and common place meanings of the words defined therein. 4, Defendants object to each request to the extent that it seeks “all documents” or “any and all” with respect to a certain subject matter on the grounds that it is overbroad and unduly burdensome or that it is seeks redundant or duplicative information. SUNITO M. LESLIE, P.A, 3350 SW 148" AVENUE, SUITE 110 MIRAMAR. FL33027 TEL: 954.369.5519 | Fax: 954.241.68915. Defendants object to each request to the extent it seeks information or documents protected by attorney-client privilege, the attorney work product privilege, or any other applicable privilege, rule of privacy or confidentiality, or restriction that renders such information non-discoverable. 6. Defendants object to each request to the extent that (i) it seeks information that does not specifically refer to events which are the subject matter of this litigation; and (ii) it is neither relevant to the claims or defenses of any party in this litigation nor is reasonably calculated to lead to the discovery of admissible evidence. 7. Defendants’ responses and objections to each request is based on information available as of the date hereof, and Defendants reserve the right to supplement its objections or responses to any of the requests pursuant to all appropriate rules, laws, statutes and regulations. Further, Defendants’ responses and objections are given without prejudice to the right of Defendants to use or rely upon subsequently discovered information or documents. 8. Defendants’ responses to the each of the requests are made without in any way waiving or intending to waive their right to raise all questions as to competence, relevancy, materiality, privilege and admissibility as evidence for any purpose. Subject to and without waiving the foregoing general objections, Defendants provide the following specific objections and responses. SPECIFIC OBJECTIONS AND RESPONSES 1. All e-mails, including attachments, exchanged between Defendants and Plaintiffs, or anyone acting on Defendants’ or Plaintiffs’ behalf, during the relevant time period. RESPONSE: Defendants object on the grounds that this request is overbroad, unduly burdensome, and amounts to harassment as it requests information in Plaintiffs’ possession, custody or control, or information that is equally available to Plaintiffs. Defendants further object that this request seeks information that is irrelevant to the claims and defenses of any party in this litigation and is not reasonably calculated to lead to the discovery of admissible evidence. 2. All other documents exchanged between Defendants and Plaintiffs, or anyone acting on Defendants’ or Plaintiffs’ behalf, during the relevant time period. RESPONSE: Defendants object on the grounds that this request is overbroad, unduly burdensome, irrelevant to the claims and defenses of any party in this litigation, and not reasonably calculated to lead to the discovery of admissible evidence. 2 SUNITO M. LESLIE, P.A. 3350 SW 148™ AVENUE, SUITE 110 MIRAMAR, FL33027 TEL: 954.369.5519 | Fax: 954.241.68913. All e-mails, including attachments, exchanged between Defendants, or anyone acting on their behalf, during the relevant time period. RESPONSE: Defendants object on the grounds that this request is overbroad, unduly burdensome, irrelevant to the claims and defenses of any party in this litigation, and not reasonably calculated to lead to the discovery of admissible evidence. 4, All other documents exchanged between Defendants, or anyone acting on their behalf, during the relevant time period. RESPONSE: Defendants object on the grounds that this request is overbroad, unduly burdensome, irrelevant to the claims and defenses of any party in this litigation, and not reasonably calculated to lead to the discovery of admissible evidence. 5. Defendants’ personal cell phone records for the calendar years 2011, 2012, 2013, 2014, 2015 and 2016 reflecting any call or text message activity between Defendants and Plaintiffs. RESPONSE: Defendants object on the grounds that this request is overbroad and amounts to harassment as it seeks information for which the complete records are in Plaintiffs’ possession, custody or control, or information that is equally available to Plaintiffs. Defendants further object that this request is irrelevant to the claims and defenses of any party in this litigation and is not reasonably calculated to lead to the discovery of admissible evidence. Defendants further object that c