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*** FILED: BROWARD COUNTY. FL HOWARD FORMAN, CLERK 6/18/2013 4:21:23 PM.*#***
ens
Electronically Filed 06/18/2015 0951.25 PM ET
IN THE COUNTY COURT IN AND
FOR BROWARD COUNTY, FLORIDA
CHAPEL TRAIL ASSOCIATES, LLC., a Florida
Limited Liability Company, CASE NO. 12-22491 COCE 52
Plaintiff,
v,
SOUTH BEACH CONCESSIONS
INCORPORATED, a Florida Corporation; and SUBPOENA FOR DEPOSITION
ERIC ADAMS, Individually. DUCES TECUM IN AID OF
EXECUTION.
Defendants. qe
p>
TO: ERIC ADAMS, Individually and as Authorized Agent of ole 3/1 3
SOUTH BEACH CONCESSIONS, INC. 7 Yop
2911 SW 187th Terr B)
Miramar, FL 33029
YOU ARE HEREBY COMMANDED to appear before a person authorized by law to
take depositions at The Law Office of Russell D. Kaplan, P.A., 750 S.E. 3" Avenue, Suite
100, Fort Lauderdale, Florida 33316, on Wednesday, July 17, 2013, at 1:00 p.m, for the
taking of your deposition in this action and to have with you at that time and place the
following:
See the Attached Exhibits “A" & “B”
IF YOU FAIL TO APPEAR, YOU MAY BE IN CONTEMPT OF COURT.
You are subpoenaed by the attorney whose name appears below on this subpoena
and unless excused from this subpoena by the attorney or the Court, you shall respond to
this subpoena as directed.
DATED THIS” ‘lay ont 2013.
RUSSELL D. KAPLAN, P.A.
Attorney for Plaintiff
750 S.E. 3% Avenue, Suite 100
Fort Lauderdale, Florida 33346
Tel: i) 763-7777ADDENDUM TO SUBPOENA DUCES TECUM FOR DOCUMENTS
PERTAINING TO INDIVIDUALS
YOU ARE HEREBY REQUIRED TO BRING WITH YOU AND PRODUCE FOR INSPECTION
AND/OR PHOTOCOPYING THE FOLLOWING:
1, Copies of all tax returns filed by you or on your behalf for the period of three years
prior to the filing of this subpoena.
2. All cancelled checks, check books and bank statements for all checking accounts,
savings accounts, money market accounts, IRA accounts, Keogh accounts, and any other bank
accounts in your name, either individually or with any other person (any account on which you are
a signatory) for the period of three years prior to the service of this subpoena.
3. Any and all cash receipt and cash disbursement ledgers and/or journals for you
individually or jointly with any other person for the period beginning three years prior to service of
this subpoena.
4. Any and all other books, records, or documents evidencing ownership of real or
personal property by you, either individually or with any other person, party, or corporation or
transfers of the same beginning three years prior to service of this subpoena. This should include
warranty deeds, mortgages, titles to automobiles and other vehicles, deeds of trust, and other
documents.
5. Copies of all life insurance policies on your life and any statements regarding said
policies which would show cash surrender value.
6. Any statements provided to you in the last three years regarding any interest you may
have in any stocks, bonds, government securities, or other corporations.
7, Copies of all financial statements you have provided to any person, institution,
corporation or other entity during the last three years.
8. All stock certificates or other evidence of ownership of stocks and bonds held by you,
individually or in conjunction with any other party, including copies of any stock brokerage accounts
maintained in the 36 months immediately preceding the date of this subpoena.
9. Copies of all litigation or settlement documents to which you are or have been a party
in the last 36 months, either as plaintiff or defendant.
10. Bills of sale or other written evidence of personal or real property purchased or sold
during the last 36 months immediately preceding the date of this subpoena.
Exhibit "A"ADDENDUM TO SUBPOENA DUCES TECUM FOR DOCUMENTS
PERTAINING TO ENTITY
lL Copies of Income Tax Returns for the past three (3) calendar years of the
corporation(s) known as South Beach Concessions, Inc.
2. Income tax records for the current tax year, and copies of any estimated income tax
return filed for the current year of the entity.
3. All bank books and savings books for accounts in institutions representing accounts
in which the entity has/have any legal or equitable interest.
4. All business bank statements including cancelled checks for the twelve (12) months
immediately preceding the date of this exhibit.
5. All business accounts receivable ledgers for the twelve (12) months immediately
preceding the date of this exhibit.
6. All business accounts payable ledgers for the twelve (12) months immediately
preceding the date of this exhibit.
7. All deeds, leases, mortgages or any other written instruments evidencing interest or
ownership in real property at any time within the twenty-four (24) months immediately preceding
the date of this notice.
8. Bills of sale or other written evidence of any personal or real property purchased or
sold during the twenty-four (24) months immediately preceding the date of this exhibit.
9. Motor vehicle documents relating to any motor vehicles owned by the entity.
10. Financial statements as to the entity's business assets and liabilities as of the date of
this exhibit.
11. Schedule of all business furniture subject to lien.
12. Schedule of all business furniture, fixtures, furnishings and equipment owned by theentity as of the date of this exhibit.
13. All stock certificates or other evidence of ownership of stocks and bonds held by the
entity, including copies of any stock brokerage accounts maintained in the twelve (12) months
immediately preceding the date of this exhibit.
14. Allpolicies of insurance owned by the entity, regardless of the insurance beneficiary.
15, Copies of all contracts on which the entity is/are now performing services or
rendering materials, or upon which someone is indebted to the entity for services or materials already
furnished.
16. | Names and addresses of all employees who have worked for the entity during the
twelve (12) months immediately preceding the date of this exhibit.
17. Copies of all litigation or settlement documents to which the entity is/are now a
party/parties, or has/have been a party/parties to, whether as the Plaintiff or Defendant, during the
twelve (12) months immediately preceding the date of this exhibit.
18. Names and addresses of all corporate officers and directors, past and present.
19. | Names and addresses of all stockholders in the entity and the number of shares owned
by each.
Exhibit "B"
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*** FILED: BROWARD COUNTY. FL HOWARD FORMAN, CLERK 6/18/2013 4:21:23 PM.*#*** ens Electronically Filed 06/18/2015 0951.25 PM ET IN THE COUNTY COURT IN AND FOR BROWARD COUNTY, FLORIDA CHAPEL TRAIL ASSOCIATES, LLC., a Florida Limited Liability Company, CASE NO. 12-22491 COCE 52 Plaintiff, v, SOUTH BEACH CONCESSIONS INCORPORATED, a Florida Corporation; and SUBPOENA FOR DEPOSITION ERIC ADAMS, Individually. DUCES TECUM IN AID OF EXECUTION. Defendants. qe p> TO: ERIC ADAMS, Individually and as Authorized Agent of ole 3/1 3 SOUTH BEACH CONCESSIONS, INC. 7 Yop 2911 SW 187th Terr B) Miramar, FL 33029 YOU ARE HEREBY COMMANDED to appear before a person authorized by law to take depositions at The Law Office of Russell D. Kaplan, P.A., 750 S.E. 3" Avenue, Suite 100, Fort Lauderdale, Florida 33316, on Wednesday, July 17, 2013, at 1:00 p.m, for the taking of your deposition in this action and to have with you at that time and place the following: See the Attached Exhibits “A" & “B” IF YOU FAIL TO APPEAR, YOU MAY BE IN CONTEMPT OF COURT. You are subpoenaed by the attorney whose name appears below on this subpoena and unless excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as directed. DATED THIS” ‘lay ont 2013. RUSSELL D. KAPLAN, P.A. Attorney for Plaintiff 750 S.E. 3% Avenue, Suite 100 Fort Lauderdale, Florida 33346 Tel: i) 763-7777ADDENDUM TO SUBPOENA DUCES TECUM FOR DOCUMENTS PERTAINING TO INDIVIDUALS YOU ARE HEREBY REQUIRED TO BRING WITH YOU AND PRODUCE FOR INSPECTION AND/OR PHOTOCOPYING THE FOLLOWING: 1, Copies of all tax returns filed by you or on your behalf for the period of three years prior to the filing of this subpoena. 2. All cancelled checks, check books and bank statements for all checking accounts, savings accounts, money market accounts, IRA accounts, Keogh accounts, and any other bank accounts in your name, either individually or with any other person (any account on which you are a signatory) for the period of three years prior to the service of this subpoena. 3. Any and all cash receipt and cash disbursement ledgers and/or journals for you individually or jointly with any other person for the period beginning three years prior to service of this subpoena. 4. Any and all other books, records, or documents evidencing ownership of real or personal property by you, either individually or with any other person, party, or corporation or transfers of the same beginning three years prior to service of this subpoena. This should include warranty deeds, mortgages, titles to automobiles and other vehicles, deeds of trust, and other documents. 5. Copies of all life insurance policies on your life and any statements regarding said policies which would show cash surrender value. 6. Any statements provided to you in the last three years regarding any interest you may have in any stocks, bonds, government securities, or other corporations. 7, Copies of all financial statements you have provided to any person, institution, corporation or other entity during the last three years. 8. All stock certificates or other evidence of ownership of stocks and bonds held by you, individually or in conjunction with any other party, including copies of any stock brokerage accounts maintained in the 36 months immediately preceding the date of this subpoena. 9. Copies of all litigation or settlement documents to which you are or have been a party in the last 36 months, either as plaintiff or defendant. 10. Bills of sale or other written evidence of personal or real property purchased or sold during the last 36 months immediately preceding the date of this subpoena. Exhibit "A"ADDENDUM TO SUBPOENA DUCES TECUM FOR DOCUMENTS PERTAINING TO ENTITY lL Copies of Income Tax Returns for the past three (3) calendar years of the corporation(s) known as South Beach Concessions, Inc. 2. Income tax records for the current tax year, and copies of any estimated income tax return filed for the current year of the entity. 3. All bank books and savings books for accounts in institutions representing accounts in which the entity has/have any legal or equitable interest. 4. All business bank statements including cancelled checks for the twelve (12) months immediately preceding the date of this exhibit. 5. All business accounts receivable ledgers for the twelve (12) months immediately preceding the date of this exhibit. 6. All business accounts payable ledgers for the twelve (12) months immediately preceding the date of this exhibit. 7. All deeds, leases, mortgages or any other written instruments evidencing interest or ownership in real property at any time within the twenty-four (24) months immediately preceding the date of this notice. 8. Bills of sale or other written evidence of any personal or real property purchased or sold during the twenty-four (24) months immediately preceding the date of this exhibit. 9. Motor vehicle documents relating to any motor vehicles owned by the entity. 10. Financial statements as to the entity's business assets and liabilities as of the date of this exhibit. 11. Schedule of all business furniture subject to lien. 12. Schedule of all business furniture, fixtures, furnishings and equipment owned by theentity as of the date of this exhibit. 13. All stock certificates or other evidence of ownership of stocks and bonds held by the entity, including copies of any stock brokerage accounts maintained in the twelve (12) months immediately preceding the date of this exhibit. 14. Allpolicies of insurance owned by the entity, regardless of the insurance beneficiary. 15, Copies of all contracts on which the entity is/are now performing services or rendering materials, or upon which someone is indebted to the entity for services or materials already furnished. 16. | Names and addresses of all employees who have worked for the entity during the twelve (12) months immediately preceding the date of this exhibit. 17. Copies of all litigation or settlement documents to which the entity is/are now a party/parties, or has/have been a party/parties to, whether as the Plaintiff or Defendant, during the twelve (12) months immediately preceding the date of this exhibit. 18. Names and addresses of all corporate officers and directors, past and present. 19. | Names and addresses of all stockholders in the entity and the number of shares owned by each. Exhibit "B"