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IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT
IN AND FOR SARASOTA COUNTY, FLORIDA
JAMES FINN,
Plaintiff,
VS. CASE NO: 2007 CA 000072 NC
TODD J. MCNALLY, individually;
ACCLAIM TITLE & SERVICES, LLC,
Na de ata Or = =
a Florida limited liability company; ae 7
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VH HOLDINGS, LLC, a Florida limited Theo2 =O
liability company, and DOES 1 =e a
THROUGH 50, oa, :
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—4-30 ——- cy
Defendants. Boxe = OC
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DEFENDANT, ACCLAIM TITLE & SERVICES, LLC’S, RESPONSE TO
PLAINTIFF’S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS
The Defendant, ACCLAIM TITLE & SERVICES, LLC, a Florida limited liability
company, by and through its undersigned counsel, and pursuant to Fla. R. Civ. P. 1.350, hereby
responds to Plaintiffs First Request for Production of Documents. The items objected to are the
subject of a Motion for Protective Order filed contemporaneously herewith.
1. Documents requested will be provided for inspection and copying at a time established
by the Court’s Order on Defendant’s Motion for Extension of Time.
2. Documents requested will be provided for inspection and copying at a time established
by the Court’s Order on Defendant’s Motion for Extension of Time.
3. Documents requested will be provided for inspection and copying at a time established
(ioby the Court’s Order on Defendant’s Motion for Extension of Time.
4. Documents requested will be provided for inspection and copying at a time established
by the Court’s Order on Defendant’s Motion for Extension of Time.
». Documents requested will be provided for inspection and copying at a time established
by the Court’s Order on Defendant’s Motion for Extension of Time.
6. Documents requested will be provided for inspection and copying at a time established
by the Court’s Order on Defendant’s Motion for Extension of Time.
7. Documents requested will be provided for inspection and copying at a time established
by the Court’s Order on Defendant’s Motion for Extension of Time.
8. Documents requested will be provided for inspection and copying at a time established
by the Court’s Order on Defendant’s Motion for Extension of Time.
9. Documents requested will be provided for inspection and copying at a time established
by the Court’s Order on Defendant’s Motion for Extension of Time.
10. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
11. The documents requested are private, confidential, privileged and proprietary and
request information unrelated to this action. The information requested is not reasonably
calculated to lead to the discovery of admissible evidence. The documents request information
regarding Defendant’s assets which is not discoverable prior to the entry of a final judgment, if
any, against Defendant.
12. The documents requested are private, confidential, privileged and proprietary and
request information unrelated to this action. The information requested is not reasonablycalculated to lead to the discovery of admissible evidence. The documents request information
regarding Defendant’s capital which is not discoverable prior to the entry of a final judgment, if
any, against Defendant.
13. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
14. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
15. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
16. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
17. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
18. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
19. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
20. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
21. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
22. Documents requested will be provided for inspection and copying at a timeestablished by the Court’s Order on Defendant’s Motion for Extension of Time.
23. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
24. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
25. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
26. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
27. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
28. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
29. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
30. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
31. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
32. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
33. Documents requested will be provided for inspection and copying at a timeestablished by the Court’s Order on Defendant’s Motion for Extension of Time.
34. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
35. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
36. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
37. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
38. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
39. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
40. . Objection. The information requested is protected by the attorney-client privilege.
A privilege log will be filed as soon as practicable.
41. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
42. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
43. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
44. Documents requested will be provided for inspection and copying at a timeestablished by the Court’s Order on Defendant’s Motion for Extension of Time.
45. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
46. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
47. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
48. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
49. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
50. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
51. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
52. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
53. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
54. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
55. Documents requested will be provided for inspection and copying at a timeestablished by the Court’s Order on Defendant’s Motion for Extension of Time.
56. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
57. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
58. Documents requested will be provided for inspection and copying at a time
established by the Court’s Order on Defendant’s Motion for Extension of Time.
59. Objection. The documents requested pertain to VH HOLDINGS, LLC and its
purchase of property known as South Bridge Crossing Center. Plaintiff's claim against VH
HOLDINGS, LLC is subject to a motion to dismiss on the grounds that there is no nexus
between the ownership of that property and the dispute involved in this lawsuit. The information
requested is unrelated to this action and is not reasonably calculated to lead to the discovery of
admissible evidence.
60. Objection. The documents requested pertain to VH HOLDINGS, LLC and its
purchase of property known as South Bridge Crossing Center. Plaintiff's claim against VH
HOLDINGS, LLC is subject to a motion to dismiss on the grounds that there 1s no nexus
between the ownership of that property and the dispute involved in this lawsuit. The information
requested is unrelated to this action and is not reasonably calculated to lead to the discovery of
admissible evidence.
61. Objection. The documents requested pertain to VH HOLDINGS, LLC and its
purchase of property known as South Bridge Crossing Center. Plaintiff's claim against VH
HOLDINGS, LLC is subject to a motion to dismiss on the grounds that there is no nexusbetween the ownership of that property and the dispute involved in this lawsuit. The information
requested is unrelated to this action and is not reasonably calculated to lead to the discovery of
admissible evidence.
62. Objection. The documents requested pertain to property known as South Bridge
Crossing Center. There is no nexus between that property and the dispute involved in this
lawsuit. The information requested is unrelated to this action and is not reasonably calculated to
lead to the discovery of admissible evidence.
63. Objection. The documents requested pertain to property known as South Bridge
Crossing Center. There is no nexus between that property and the dispute involved in this
lawsuit. The information requested is unrelated to this action and is not reasonably calculated to
lead to the discovery of admissible evidence.
64. Objection. The documents requested pertain to property known as South Bridge
Crossing Center. There is no nexus between the ownership of that property and the dispute
involved in this lawsuit. The information requested is unrelated to this action and is not
reasonably calculated to lead to the discovery of admissible evidence.
65. Objection. The documents requested pertain to VH HOLDINGS, LLC and its
purchase property known as South Bridge Crossing Center. Plaintiff's claim against VH
HOLDINGS, LLC is subject to a motion to dismiss on the grounds that there is no nexus
between the ownership of that property and the dispute involved in this lawsuit. The information
requested is unrelated to this action and is not reasonably calculated to lead to the discovery of
admissible evidence.
66. Objection. The documents requested pertain to VH HOLDINGS, LLC and itspurchase of property known as South Bridge Crossing Center. Plaintiff's claim against VH
HOLDINGS, LLC is subject to a motion to dismiss on the grounds that there is no nexus
between the ownership of that property and the dispute involved in this lawsuit. The information
requested is unrelated to this action and is not reasonably calculated to lead to the discovery of
admissible evidence.
67. Objection. The documents requested pertain to VH HOLDINGS, LLC and its
purchase of property known as South Bridge Crossing Center. Plaintiff's claim against VH
HOLDINGS, LLC is subject to a motion to dismiss on the grounds that there 1s no nexus
between the ownership of that property and the dispute involved in this lawsuit. The information
requested is not reasonably calculated to lead to the discovery of admissible evidence.
68. Objection. The documents requested pertain to VH HOLDINGS, LLC and its
purchase of property known as South Bridge Crossing Center. Plaintiff's claim against VH
HOLDINGS, LLC is subject to a motion to dismiss on the grounds that there 1s no nexus
between the ownership of that property and the dispute involved in this lawsuit. The information
requested is not reasonably calculated to lead to the discovery of admissible evidence.
69. Objection. The documents requested pertain to VH HOLDINGS, LLC and its
purchase of property known as South Bridge Crossing Center. Plaintiffs claim against VH
HOLDINGS, LLC is subject to a motion to dismiss on the grounds that there 1s no nexus
between the ownership of that property and the dispute involved in this lawsuit. The information
requested is not reasonably calculated to lead to the discovery of admissible evidence.
70. Objection. The documents requested pertain to VH HOLDINGS, LLC and its
purchase of property known as South Bridge Crossing Center. Plaintiffs claim against VHHOLDINGS, LLC is subject to a motion to dismiss on the grounds that there is no nexus
between the ownership of that property and the dispute involved in this lawsuit. The information
requested 1s not reasonably calculated to lead to the discovery of admissible evidence.
71. Objection. The documents requested pertain to VH HOLDINGS, LLC and its
purchase of property known as South Bridge Crossing Center. Plaintiff's claim against VH
HOLDINGS, LLC is subject to a motion to dismiss on the grounds that there 1s no nexus
between the ownership of that property and the dispute involved in this lawsuit. The information
requested is not reasonably calculated to lead to the discovery of admissible evidence.
72. Objection. The documents requested pertain to VH HOLDINGS, LLC and its
purchase of property known as South Bridge Crossing Center. Plaintiff's claim against VH
HOLDINGS, LLC is subject to a motion to dismiss on the grounds that there is no nexus
between the ownership of that property and the dispute involved in this lawsuit. The information
requested is not reasonably calculated to lead to the discovery of admissible evidence.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been sent by
United States Mail, postage prepaid, to Jennifer Anne Gore Maglio, Esq., and William Garth
Christopher, Esq., MAGLIO CHRISTOPHER & TOALE LAW FIRM, 2480 Fruitville Road,
Suite 6, Sarasota, Florida 34237 and Stephen E. Foster, Esq. and Yvette Molinaro, Esq.,
MITCHELL SILBERBERG & KNUPP, LLP, 11377 West Olympic Boulevard, Los Angeles,
10California 90064-1683, on this | G day of March, 2007.
la. Bar No: 229652
3400 S. Tamiami Trail
Suite 201
Sarasota, Florida 34239
(941) 366-1388
ATTORNEY FOR DEFENDANTS
I]
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IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR SARASOTA COUNTY, FLORIDA JAMES FINN, Plaintiff, VS. CASE NO: 2007 CA 000072 NC TODD J. MCNALLY, individually; ACCLAIM TITLE & SERVICES, LLC, Na de ata Or = = a Florida limited liability company; ae 7 . . oe ye > _ VH HOLDINGS, LLC, a Florida limited Theo2 =O liability company, and DOES 1 =e a THROUGH 50, oa, : Ons 7 ae Fe rn a2 = & —4-30 ——- cy Defendants. Boxe = OC .-- atid 7 FE IGIC CGS C ICICI SII ISI ICICI I I ICICI ACK / mee oe as ~4 DEFENDANT, ACCLAIM TITLE & SERVICES, LLC’S, RESPONSE TO PLAINTIFF’S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS The Defendant, ACCLAIM TITLE & SERVICES, LLC, a Florida limited liability company, by and through its undersigned counsel, and pursuant to Fla. R. Civ. P. 1.350, hereby responds to Plaintiffs First Request for Production of Documents. The items objected to are the subject of a Motion for Protective Order filed contemporaneously herewith. 1. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 2. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 3. Documents requested will be provided for inspection and copying at a time established (ioby the Court’s Order on Defendant’s Motion for Extension of Time. 4. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. ». Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 6. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 7. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 8. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 9. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 10. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 11. The documents requested are private, confidential, privileged and proprietary and request information unrelated to this action. The information requested is not reasonably calculated to lead to the discovery of admissible evidence. The documents request information regarding Defendant’s assets which is not discoverable prior to the entry of a final judgment, if any, against Defendant. 12. The documents requested are private, confidential, privileged and proprietary and request information unrelated to this action. The information requested is not reasonablycalculated to lead to the discovery of admissible evidence. The documents request information regarding Defendant’s capital which is not discoverable prior to the entry of a final judgment, if any, against Defendant. 13. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 14. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 15. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 16. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 17. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 18. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 19. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 20. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 21. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 22. Documents requested will be provided for inspection and copying at a timeestablished by the Court’s Order on Defendant’s Motion for Extension of Time. 23. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 24. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 25. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 26. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 27. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 28. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 29. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 30. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 31. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 32. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 33. Documents requested will be provided for inspection and copying at a timeestablished by the Court’s Order on Defendant’s Motion for Extension of Time. 34. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 35. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 36. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 37. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 38. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 39. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 40. . Objection. The information requested is protected by the attorney-client privilege. A privilege log will be filed as soon as practicable. 41. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 42. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 43. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 44. Documents requested will be provided for inspection and copying at a timeestablished by the Court’s Order on Defendant’s Motion for Extension of Time. 45. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 46. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 47. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 48. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 49. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 50. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 51. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 52. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 53. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 54. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 55. Documents requested will be provided for inspection and copying at a timeestablished by the Court’s Order on Defendant’s Motion for Extension of Time. 56. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 57. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 58. Documents requested will be provided for inspection and copying at a time established by the Court’s Order on Defendant’s Motion for Extension of Time. 59. Objection. The documents requested pertain to VH HOLDINGS, LLC and its purchase of property known as South Bridge Crossing Center. Plaintiff's claim against VH HOLDINGS, LLC is subject to a motion to dismiss on the grounds that there is no nexus between the ownership of that property and the dispute involved in this lawsuit. The information requested is unrelated to this action and is not reasonably calculated to lead to the discovery of admissible evidence. 60. Objection. The documents requested pertain to VH HOLDINGS, LLC and its purchase of property known as South Bridge Crossing Center. Plaintiff's claim against VH HOLDINGS, LLC is subject to a motion to dismiss on the grounds that there 1s no nexus between the ownership of that property and the dispute involved in this lawsuit. The information requested is unrelated to this action and is not reasonably calculated to lead to the discovery of admissible evidence. 61. Objection. The documents requested pertain to VH HOLDINGS, LLC and its purchase of property known as South Bridge Crossing Center. Plaintiff's claim against VH HOLDINGS, LLC is subject to a motion to dismiss on the grounds that there is no nexusbetween the ownership of that property and the dispute involved in this lawsuit. The information requested is unrelated to this action and is not reasonably calculated to lead to the discovery of admissible evidence. 62. Objection. The documents requested pertain to property known as South Bridge Crossing Center. There is no nexus between that property and the dispute involved in this lawsuit. The information requested is unrelated to this action and is not reasonably calculated to lead to the discovery of admissible evidence. 63. Objection. The documents requested pertain to property known as South Bridge Crossing Center. There is no nexus between that property and the dispute involved in this lawsuit. The information requested is unrelated to this action and is not reasonably calculated to lead to the discovery of admissible evidence. 64. Objection. The documents requested pertain to property known as South Bridge Crossing Center. There is no nexus between the ownership of that property and the dispute involved in this lawsuit. The information requested is unrelated to this action and is not reasonably calculated to lead to the discovery of admissible evidence. 65. Objection. The documents requested pertain to VH HOLDINGS, LLC and its purchase property known as South Bridge Crossing Center. Plaintiff's claim against VH HOLDINGS, LLC is subject to a motion to dismiss on the grounds that there is no nexus between the ownership of that property and the dispute involved in this lawsuit. The information requested is unrelated to this action and is not reasonably calculated to lead to the discovery of admissible evidence. 66. Objection. The documents requested pertain to VH HOLDINGS, LLC and itspurchase of property known as South Bridge Crossing Center. Plaintiff's claim against VH HOLDINGS, LLC is subject to a motion to dismiss on the grounds that there is no nexus between the ownership of that property and the dispute involved in this lawsuit. The information requested is unrelated to this action and is not reasonably calculated to lead to the discovery of admissible evidence. 67. Objection. The documents requested pertain to VH HOLDINGS, LLC and its purchase of property known as South Bridge Crossing Center. Plaintiff's claim against VH HOLDINGS, LLC is subject to a motion to dismiss on the grounds that there 1s no nexus between the ownership of that property and the dispute involved in this lawsuit. The information requested is not reasonably calculated to lead to the discovery of admissible evidence. 68. Objection. The documents requested pertain to VH HOLDINGS, LLC and its purchase of property known as South Bridge Crossing Center. Plaintiff's claim against VH HOLDINGS, LLC is subject to a motion to dismiss on the grounds that there 1s no nexus between the ownership of that property and the dispute involved in this lawsuit. The information requested is not reasonably calculated to lead to the discovery of admissible evidence. 69. Objection. The documents requested pertain to VH HOLDINGS, LLC and its purchase of property known as South Bridge Crossing Center. Plaintiffs claim against VH HOLDINGS, LLC is subject to a motion to dismiss on the grounds that there 1s no nexus between the ownership of that property and the dispute involved in this lawsuit. The information requested is not reasonably calculated to lead to the discovery of admissible evidence. 70. Objection. The documents requested pertain to VH HOLDINGS, LLC and its purchase of property known as South Bridge Crossing Center. Plaintiffs claim against VHHOLDINGS, LLC is subject to a motion to dismiss on the grounds that there is no nexus between the ownership of that property and the dispute involved in this lawsuit. The information requested 1s not reasonably calculated to lead to the discovery of admissible evidence. 71. Objection. The documents requested pertain to VH HOLDINGS, LLC and its purchase of property known as South Bridge Crossing Center. Plaintiff's claim against VH HOLDINGS, LLC is subject to a motion to dismiss on the grounds that there 1s no nexus between the ownership of that property and the dispute involved in this lawsuit. The information requested is not reasonably calculated to lead to the discovery of admissible evidence. 72. Objection. The documents requested pertain to VH HOLDINGS, LLC and its purchase of property known as South Bridge Crossing Center. Plaintiff's claim against VH HOLDINGS, LLC is subject to a motion to dismiss on the grounds that there is no nexus between the ownership of that property and the dispute involved in this lawsuit. The information requested is not reasonably calculated to lead to the discovery of admissible evidence. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been sent by United States Mail, postage prepaid, to Jennifer Anne Gore Maglio, Esq., and William Garth Christopher, Esq., MAGLIO CHRISTOPHER & TOALE LAW FIRM, 2480 Fruitville Road, Suite 6, Sarasota, Florida 34237 and Stephen E. Foster, Esq. and Yvette Molinaro, Esq., MITCHELL SILBERBERG & KNUPP, LLP, 11377 West Olympic Boulevard, Los Angeles, 10California 90064-1683, on this | G day of March, 2007. la. Bar No: 229652 3400 S. Tamiami Trail Suite 201 Sarasota, Florida 34239 (941) 366-1388 ATTORNEY FOR DEFENDANTS I]