On May 30, 2014 a
Party Discovery
was filed
involving a dispute between
Evergreen Sweeteners, Inc.,
and
Custom Beverage Concepts, Inc.,
for Contract and Indebtedness
in the District Court of Broward County.
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Filing # 16684633 Electronically Filed 08/04/2014 02:57:47 PM.
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
OF THE STATE OF FLORIDA, IN AND FOR BROWARD COUNTY
CIVIL DIVISION
EVERGREEN SWEETNERS
INC., a Florida corporation,
Plaintiff,
vs.
14-CA-010427
CUSTOM BEVERAGE CONCEPTS,
INC., a foreign corporation,
Defendant.
/
RESPONSE AND OBJECTION TO INTERROGATORIES AND
REQUEST F UCT.
Defendant, CUSTOM BEVERAGE CONCEPTS, INC., a foreign corporation, by and
through its undersigned counsel, responds to and objects to the Interrogatories and Request for
Production submitted by as follows:
1. Discovery was submitted on June 17, 2014 by Plaintiff, EVERGREEN
SWEETNERS, INC., a Florida corporation.
2. As a result of Defendant’s pending motion to dismiss regarding lack of
jurisdiction as a result of the failure to establish minimum contacts with the state, Defendant
objects to discovery not related to the issues raised by the motion to dismiss until such time as
the motion to dismiss has been determined.
HOLCOMB & LEUNG, P.A.
3203 W. Cypress St.
Tampa, Florida 33607
(813) 258-5835
(813) 258-5124 - Facsimile
By: /s/ Brian A. Leung
BRIAN A. LEUNG
Florida Bar #14510
BrianLeung@holcomblaw.com
Secondary email:
michelle@holcomblaw.com
** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/4/2014 2:57:46 PM.****CERTIFICATE OF SERVICE
THEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
electronic mail to Kenneth J. Joyce at Ken. Joyce@lewisbrisbois.com,
Michael. Platner@lewisbrisbois.com, Stacy. Schwartz@lewisbrisbois.com,
filemaildesio@llbslaw.com, whose address is 200 SW 1“ Avenue, Suite 910, Fort Lauderdale,
FL 33301 this _4 day of August, 2014.
/s/ Brian A. Leung
Brian A. Leung
Document Filed Date
August 04, 2014
Case Filing Date
May 30, 2014
Category
Contract and Indebtedness
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Filing # 16684633 Electronically Filed 08/04/2014 02:57:47 PM. IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT OF THE STATE OF FLORIDA, IN AND FOR BROWARD COUNTY CIVIL DIVISION EVERGREEN SWEETNERS INC., a Florida corporation, Plaintiff, vs. 14-CA-010427 CUSTOM BEVERAGE CONCEPTS, INC., a foreign corporation, Defendant. / RESPONSE AND OBJECTION TO INTERROGATORIES AND REQUEST F UCT. Defendant, CUSTOM BEVERAGE CONCEPTS, INC., a foreign corporation, by and through its undersigned counsel, responds to and objects to the Interrogatories and Request for Production submitted by as follows: 1. Discovery was submitted on June 17, 2014 by Plaintiff, EVERGREEN SWEETNERS, INC., a Florida corporation. 2. As a result of Defendant’s pending motion to dismiss regarding lack of jurisdiction as a result of the failure to establish minimum contacts with the state, Defendant objects to discovery not related to the issues raised by the motion to dismiss until such time as the motion to dismiss has been determined. HOLCOMB & LEUNG, P.A. 3203 W. Cypress St. Tampa, Florida 33607 (813) 258-5835 (813) 258-5124 - Facsimile By: /s/ Brian A. Leung BRIAN A. LEUNG Florida Bar #14510 BrianLeung@holcomblaw.com Secondary email: michelle@holcomblaw.com ** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/4/2014 2:57:46 PM.****CERTIFICATE OF SERVICE THEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by electronic mail to Kenneth J. Joyce at Ken. Joyce@lewisbrisbois.com, Michael. Platner@lewisbrisbois.com, Stacy. Schwartz@lewisbrisbois.com, filemaildesio@llbslaw.com, whose address is 200 SW 1“ Avenue, Suite 910, Fort Lauderdale, FL 33301 this _4 day of August, 2014. /s/ Brian A. Leung Brian A. Leung