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Filing # 75349226 E-Filed 07/23/2018 12:56:37 PM
IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA
6654 NW 27 AVENUE, LLC,
Case No: 17CA13348 MB AH
Plaintiff,
v.
PINCUS CAPITAL LLC, MARK
BENUN, an individual, et. al.,
Defendant.
/
TerrAmM sama prATMmen Tan HNANTIOTIAN TO PT ATI
VEPRNVANL SO REYULOL PUR PRUUUL LIUIN LU PUALNLIEE
The Defendant PINCUS CAPITAL LLC, MARK BENUN, an individual, et. al., by and
through the undersigned counsel, files this its Request for Production as attached hereto.
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing has been served this 23"! day of July, 2018
via email uponAndrew G. Elliott, Randall K. Roger & Associates PA, 621 NW 53rd Street, Suite
300, Boca Raton, FL 33487, aelliott@randallkroger.com; Katherine C. Nuckolls, Randall K.
Roger & Associates PA, 621 NW 53rd Street, Suite 300, Boca Raton, FL 33487,
Knuckolls@randallkroger.com; marie@randallkroger.com; Ronald M Gache, Shapiro Fishman
& Gache, 2424 N Federal Hwy, Suite 360, Boca Raton, FL 33431, rgache@logs.com; Scott A.
Simon, Shapiro, Fishman & Gache LLP, 2424 N Federal Hwy, Suite 360, Boca Raton, FL
33431, ssimon@logs.com
SHIR LAW GROUP, P.A.
2295 N.W. Corporate Blvd, Suite 140
Boca Raton, Florida 33431
Phone: 561-999-5999
Fax: 561-893-0999
By: _/s/ Stuart J. Zoberg. Esq.
Stuart J. Zoberg, Esq., Fla Bar No. 611891
Email: szoberg@shirlawgroup.com
Service Email: office@shirlawgroup.com
CHEN. DAIAARECACU AAIINTY Cl CUADAND ANFY FLED N7IN2QINN1e 19.58.27 DAA
PILL. PALE BLAU VUUINE TT, FL, OHI. DUUN, ULLIAN, UliZueu lu 1Z.0U.08 Fivt17CA13348 MB AH
REQUESTS
1. Copies of all bank account statements for the last two years where the mortgage payments
were deposited.
2. All documents (which include emails) between you and the Lawrence Shapiro listed in your
morigage assignment ihai discuss ine home ai issue in ihis action at 6654 NW 27" avenue
(the “Home”).
3. All documents (including emails) that discuss any business dealings or other dealings or
other arrangement between Plaintiff and Lawrence Shapiro and that relate to the home at
issue in this action (the “Home”).
4. All documents (including emails) that you, Lawrence Shapiro, or your counsel sent to either
Defendant, including but not limited to any notices of default, or demands for payment.
5. Any agreements or other documents between the Plaintiff and Lawrence Shapiro detailing the
scope of the parties business relationship in connection with the home at 6654 NW 27"
avenue.
6. All ledger sheets, computer print-outs or other documents reflecting balance alleged to be
due, payment received, charges and costs incurred on owner’s account in connect with the
mortgage and loan sought to be foreclosed.
7. All correspondence, (including emails) concerning the loan which is the subject matter of this
lawsuit except those between the Plaintiff and her attorney.
8. All correspondence (including emails), concerning the home which is the subject matter of
this lawsuit except those between the Plaintiff and her attorney.
9. Copies of any and all appraisals done in the last ten years on the home at 6654 NW 27"
avenue.
Page 2 of 2
SHIR LAW GROUP, P.A.
2295 N.W. Corporate Boulevard, Suite 140
Boca Raton, FL 33431
Preview
Filing # 75349226 E-Filed 07/23/2018 12:56:37 PM IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA 6654 NW 27 AVENUE, LLC, Case No: 17CA13348 MB AH Plaintiff, v. PINCUS CAPITAL LLC, MARK BENUN, an individual, et. al., Defendant. / TerrAmM sama prATMmen Tan HNANTIOTIAN TO PT ATI VEPRNVANL SO REYULOL PUR PRUUUL LIUIN LU PUALNLIEE The Defendant PINCUS CAPITAL LLC, MARK BENUN, an individual, et. al., by and through the undersigned counsel, files this its Request for Production as attached hereto. CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been served this 23"! day of July, 2018 via email uponAndrew G. Elliott, Randall K. Roger & Associates PA, 621 NW 53rd Street, Suite 300, Boca Raton, FL 33487, aelliott@randallkroger.com; Katherine C. Nuckolls, Randall K. Roger & Associates PA, 621 NW 53rd Street, Suite 300, Boca Raton, FL 33487, Knuckolls@randallkroger.com; marie@randallkroger.com; Ronald M Gache, Shapiro Fishman & Gache, 2424 N Federal Hwy, Suite 360, Boca Raton, FL 33431, rgache@logs.com; Scott A. Simon, Shapiro, Fishman & Gache LLP, 2424 N Federal Hwy, Suite 360, Boca Raton, FL 33431, ssimon@logs.com SHIR LAW GROUP, P.A. 2295 N.W. Corporate Blvd, Suite 140 Boca Raton, Florida 33431 Phone: 561-999-5999 Fax: 561-893-0999 By: _/s/ Stuart J. Zoberg. Esq. Stuart J. Zoberg, Esq., Fla Bar No. 611891 Email: szoberg@shirlawgroup.com Service Email: office@shirlawgroup.com CHEN. DAIAARECACU AAIINTY Cl CUADAND ANFY FLED N7IN2QINN1e 19.58.27 DAA PILL. PALE BLAU VUUINE TT, FL, OHI. DUUN, ULLIAN, UliZueu lu 1Z.0U.08 Fivt17CA13348 MB AH REQUESTS 1. Copies of all bank account statements for the last two years where the mortgage payments were deposited. 2. All documents (which include emails) between you and the Lawrence Shapiro listed in your morigage assignment ihai discuss ine home ai issue in ihis action at 6654 NW 27" avenue (the “Home”). 3. All documents (including emails) that discuss any business dealings or other dealings or other arrangement between Plaintiff and Lawrence Shapiro and that relate to the home at issue in this action (the “Home”). 4. All documents (including emails) that you, Lawrence Shapiro, or your counsel sent to either Defendant, including but not limited to any notices of default, or demands for payment. 5. Any agreements or other documents between the Plaintiff and Lawrence Shapiro detailing the scope of the parties business relationship in connection with the home at 6654 NW 27" avenue. 6. All ledger sheets, computer print-outs or other documents reflecting balance alleged to be due, payment received, charges and costs incurred on owner’s account in connect with the mortgage and loan sought to be foreclosed. 7. All correspondence, (including emails) concerning the loan which is the subject matter of this lawsuit except those between the Plaintiff and her attorney. 8. All correspondence (including emails), concerning the home which is the subject matter of this lawsuit except those between the Plaintiff and her attorney. 9. Copies of any and all appraisals done in the last ten years on the home at 6654 NW 27" avenue. Page 2 of 2 SHIR LAW GROUP, P.A. 2295 N.W. Corporate Boulevard, Suite 140 Boca Raton, FL 33431