Preview
Filing # 72642497 E-Filed 05/24/2018 03:38:18 PM
IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT,
IN AND FOR MIAMI-DADECOUNTY, FLORIDA
CASE NO: 2018-012296-CA-O1
CRSJ, INC,
Plaintiff,
VS.
A&S ENTERTAINMENT, LLC,
Defendant.
The Plaintiff, CRSJ, Inc., by and through his undersigned counsel hereby files his Motion
for Protective Order and in support thereof states as follows:
1. Currently pending before this Court are the parties’ eviction proceedings and
correspondent counterclaims
2. On May 15, 2018, the undersigned received a Re-Notice of Taking Deposition
Duces Tecum for New Wave Loans Residential, LLC (the “Notice”), together with a corresponding
Subpoena for Deposition Duces Tecum (the “Subpoena”). A copy of the Notice and Subpoena are
attached hereto as Exhibit “A.”
3. The Deposition was set by Defendant with no coordination with the undersigned
counsel and during a period of unavailability for Defendant’s counsel, Elias Hilal and Juan Martinez
pursuant to their own filing, attached hereto as Exhibit “B”. Accordingly, the undersigned contacted
Defendant’s counsel regarding these irregularities; Attorney Elias Hilal advised us that the reason
for the lack of coordination and the unimportance of his co-counsel’s availability was because it was
not an actual deposition and that only documents were being sought for inspection.
eovosenga ay
Rosenthal Rosenthal Rasco LLC
One Aventura, 20960 N.E. 36 Avenue, Suite 600, Aventura, Florida 33180
305.937.0300 / Fax: 305.937.1311CASE NO: 2018-012296-CA-01
Page 2 of 4
4, Florida Rule of Civil Procedure 1.351 govems the rule for production of documents
without depositions and it is evident that the Defendant is attempting to circumvent that rule.
5. Such rule requires that a party desiring production of documents by mail, shall
“serve notice on every other party of the intent to serve a Subpoena under this Rule, at least 10 days
before the Subpoena is issued, if service is by delivery and 15 days before the Subpoena is issued, if
service is by mail.”
6. The Defendant did not even attempt to comply with Florida Rule of Civil Procedure
1.351. Instead, its counsel served the subpoena without first serving the required Notice of Intent.
7. Moreover, the Defendant unilaterally scheduled the Deposition, without first
clearing the date with the undersigned counsel, Undersigned has a conflict with the date and time
unilaterally chosen by the Plaintiff counsel and will need to reschedule matters if he were required
to attend.
&. The documents requested from the third party deponent are completely excessive
and overbroad. It is apparent that the Defendant has authorized its counsel to go on a fishing
expedition to harass the Plaintiff.
9. Pursuant to the Subpoena the Defendant is requesting “All loan documents,
including but not limited to, the promissory note(s), mortgage(s), assignment(s) of rents,
amendments and modification agreements, thereto, payment histories, and default letters, relating
to CRSJ, Inc.” New Wave Loans is CRSJ’s lender and many of the loan documents contain
confidential financial information that are not relevant to the current proceedings.
11. It would be a violation of CRSJ and its principal, James Fulford’s, privacy to have
their personal financial records, including loan applications and credit information, brought into
these proceedings. These documents will not lead to any discoverable evidence and the
quosesens.2,
Rosenthal Rosenthal Rasco LLC
One Aventura, 20900 N.E, 30" Avenue, Suite 600, Aventura, Florida 33180
305.937.0300 / Fax: 305.937.1311CASE NO: 2018-012296-CA-01
Page 3 of 4
Defendant should not be permitted to inspect these records as they are irrelevant to these
proceedings.
12. The Defendant’s use of a Subpoena for Deposition Duces Tecum without proper
or lawful notice is an unlawful violation of the Rules of Civil Procedure intended to intimidate,
bully, harass, annoy and oppress the Plaintiff.
13. Florida Rule of Civil Procedure §1,280(c) states that upon Motion by a party or
by a person from whom discovery is sought and for good cause shown on the Court in which the
action is pending, the court may “make any order to protect a party or person from annoyance,
embarrassment, oppression, or undue burden or expense that justice requires, including one or
more of the following (1) that the discovery not be had; (2) that the discovery may be had only
on specified terms and conditions, including a designation of the time or place; (3) that the
discovery may be had only by a method of discovery other than that selected by the party
seeking discovery; (4) that certain matters not be inquired into, or that the scope of the discovery
be limited to certain matters;...”
14. . The Plaintiff moves for a protective order pursuant to Florida Rules of Civil
Procedure 1.280(c)(1)(2)(3)and(4).
15. The Plaintiff has incurred reasonable attomeys’ fees and costs as a result of the
filing of this Motion and moves for the appropriate relief and sanctions.
16. Pursuant to the terms of the Lease and due to the improper procedure and abusive
tactics utilized by the Defendant, Plaintiff requests that the Court issue a Protective Order and
that the Defendant be ordered to pay attorneys fees and costs incurred by the Plaintiff.
(WO46S444.1)
Rosenthal Rosenthal Rasco LLC
One Aventura, 20900 N.E. 30" Avenue, Suite 600, Aventura, Florida 33180
305.937.0306 / Fax: 305.937.1311CASE NO: 2018-012296-CA-01
Page 4 of 4
WHEREFORE the Plaintiff, CRSJ, Inc., moves this Court for a protective order as to the
depositions scheduled for May 2%, 2018, for sanctions, to enter an award of attorney fees attendant
on this Motion and such other and further relief as this Court deems just and proper under the
circumstances,
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was mailed this
24" day of May, 2018 to ELIAS R. HILAL, ESQ., Williams Hilal Wigand Grande, PLLC, 633
SE 3rd Avenue, Suite 201, Fort Lauderdale, Florida 33301 — eliasé?whwlezal ; JUAN C.
MARTINEZ, ESQ., GrayRobinson, P.A., 333 SE 2nd Avenue, Suite 3200, Miami, Florida
‘obinson.com; and ANTHONY PEREZ, ESQ., Garcia-Menocal
4937 SW 74® Court, Unit #3, Miami, Florida 33155 — ajperezlaw@gmail.com
ROSENTHAL ROSENTHAL RASCO LLC
Attorney for Plaintiff
One Aventura — Suite 600
20900 N.E. 30th Ave.
Aventura, FL 33180
Tel. 305-937-0300
Fax, 305-937-1311
MELISSA GROISMAN, ESQ.
FLORIDA BAR NO. 46131
mesterrrlaw.com
{W0458444.0)
Rosenthal Rosenthal Raseo LLC
One Aventura, 20900 N.E. 30° Avenne, Suite 600, Aventura, Florida 33180
305.937.0300 / Fax: 305.937.1311EXHIBIT “A”Filing # 72164875 E-Filed 05/15/2018 01:58:51 PM
IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT
IN AND FOR MIAMIE-DADE COUNTY, FLORIDA
CASE NO: 2018-12296-CA-01
CRSJ, INC.,
Plaintiff,
V3.
A&S ENTERTAINMENT, LLC,
Defendants,
RE-NOTICE OF TAKING DEPOSITION DUCES TECUM FOR
NEW WAVE LOANS RESIDENTIAL, LLC
PLEASE TAKE NOTICE that the undersigned attorney or attorney of the firm will take the
deposition of:
Name: New Wave Loans Residential, LLC
Records Custodian
1835 NE Miami Gardens Drive, #451
North Miami Beach, Florida 33179
Date and Time: Tuesday, May 29, 2018 at 2:00 p.m.
Place: GrayRobinson, P.A.,
333 SE 2™ Ave, Suite 3200
Miami, FL 33131
upon oral examination before Steinotype, Inc., Notary Public, or any other notary public or officer
authorized by law to take the depositions in the State of Florida. The deponent is to bring with her
the documents listed in Exhibit “A” to the Subpoena for Deposition Duces Tecum attached hereto.
The oral examination will continue from day to day until completed. This deposition is being taken
for the purpose of discovery, for the use at trial, or for such other purposes as are permitted under the
rules of the Court.
Dated this_15" day of May, 2018.
Respectfully submitted,
By: 4
Elias R. Hilal, Esq.
Florida Bar No. 60337Elias R. Hilal, Esq.
Attomey for Defendant
Florida Bar Number: 60337
WILLIAMS HILAL WIGAND GRANDE, PLLC
633 Southeast Third Avenue, Suite 301
Fort Lauderdale, Florida 33301
Tel: (954) 463-2065 Fax: (954) 337-0117
E-Mai whwlezal.com
and
By:
Suan C. Martinez, Esq.
Florida Bar No. 009024
Juan C. Martinez, Esq.
Florida Bar No.: 009024
GRAYROBINSON, P.A.
333 S.E. 2nd Ave., Suite 3200
Miami, FL 33131
Tel: (305) 416-6880 Fax: (305) 416-6887
juan martinez: ‘obinson.com
CERTIMICATE OF SERVICE
1 HEREBY CERTIFY that on this 15" day of May, 2018, 1 electronically filed the
foregoing document with the Clerk of Court using the Florida Courts E-Filing Portal. I also certify
that the foregoing document is being served this day on all counsel of record and interested parties in
the manner identified on the below Service List, via transmission generated by the Florida Courts E-
Filing Portal or by U.S. Mail, pursuant to Rule 2.516, Florida Rules of Judicial Administration.
Service List:
Melissa Groisman, Esq.
Eduardo I. Rasco, Esq
éséJuan C. Marti
Juan C, Martinez, Esq.
Florida Bar No. 9024IN THE COUNTY COURT OF THE 11TH JUDICIAL CIRCUIT
IN AND FOR MIAMLDADE COUNTY, FLORIDA
Case No.: 2017-020761-CC-23
CRSJ,INC.,
Plaintiff,
VS.
A&S ENTERTAINMENT, LLC,
Defendants,
SUBPOENA FOR DEPOSITION DUCES TECUM
THE STATE OF FLORIDA:
TO: New Wave Loans Residential, LLC
Records Custodian
1835 NE Miami Gardens Drive, #451
North Miami Beach, Florida 33179
YOU ARE HEREBY COMMANDED to appear before the undersigned or any other
person authorized by law to take depositions at the Offices of GrayRobinson, P.A., 333 SE 2nd Ave,
Suite 3200, Miami, FL 33131 on Tuesday, May 29, 2018 at 2:00 p.m. for the taking of your
deposition in this action, and to have with you at that time and place the following:
SEE ATTACHED EXHIBIT “A”
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. You have the right to object to the production pursuant to this subpoena
at any time before production by giving written notice to the attorney whose name appears on this
subpoena.
Ifyou fail to:
(1) appear as specified; or
(2) object to this subpoena,you may be in contempt of Court. You are subpoenaed to appear by the following attorneys, and
unless excused from this subpoena by these attomeys or the Court, you shall respond to this
subpoena as directed.
Dated this 15th day of May, 2018.
Juan C, Martinez
Fla. Bar No.: 009024
GRAYROBINSON, P.A,
333 S.E. 2" Ave., Suite 3200
Miami, Florida 33131
Tele: (305) 416-6880
Fax: (305) 416-6887
Primary email:
Secondary ema:
obinson.com
tobinson.com
Juan C. Martinez, Esq.
For the CourtEXHIBIT “A”
L DOCUMENTS REQUESTED
L All loan documents, including but not limited to, the promissory note(s),
mortgage(s), assignment(s) of rents, amendments and modification agreements, thereto, payment
histories, and default letters, relating to CRSJ, Inc.EXHIBIT “B”Filing # 71745409 E-Filed 05/07/2018 10:43:26 AM
IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT
IN AND FOR MIAMI-DADE COUNTY, FLORIDA
CASE NO: 2018-12296-CA-O1
CRSI, INC,
Plaintiff,
vs.
A&S ENTERTAINMENT, LLC,
Defendants.
NOTICE OF UNAVAILABILITY
PLEASE TAKE NOTICE that the undersigned counsel will be unavailable from May 16,
2018 through and including May 30, 2018, and requests that no depositions, hearings, discovery,
or other matters be set or scheduled to take place during this time period. The filing and service
of this notice shall constitute an application and request for continuance, extension and/or for a
protective order, as appropriately required for the reasons set forth above.
Dated this 7” day of May, 2018,
Respectfully submitted,
Elias R. Hilal, Esq.
Florida Bar No. 60337
Elias R. Hilal, Esq.
Attorney for Defendant
Florida Bar Number: 60337
WILLIAMS HILAL WIGAND GRANDE, PLLC
633 Southeast Third Avenue, Suite 301
Fort Lauderdale, Florida 33301
Telephone: (954) 463-2065
Fax: (954) 337-0117
E-Mail: Eli
andFlorida Bar No. 009024
Juan C. Martinez, Esq.
Florida Bar No.: 009024
GRAYROBINSON, P.A.
333 S.E. 2nd Ave., Suite 3200
Miami, FL 33131
(305) 416-6880
(305) 416-6887
ecianellac!zray-robinson.com
CERTIFICATE OF SERVICE
1 HEREBY CERTIFY that on this 7th day of May, 2018, I electronically filed the
foregoing document with the Clerk of Court using the Florida Courts E-Filing Portal. I also
certify that the foregoing document is being served this day on all counsel of record and
interested parties in the manner identified on the below Service List, via transmission generated
by the Florida Courts E-Filing Portal or by U.S. Mail, pursuant to Rule 2.516, Florida Rules of
Judicial Administration.
éstJuan €. Martinez
Juan C. Martinez, Esq.
Florida Bar No. 9024
Service List:
Melissa Groisman, Esq.
Eduardo I. Rasco, Esq.
Preview
Filing # 72642497 E-Filed 05/24/2018 03:38:18 PM IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT, IN AND FOR MIAMI-DADECOUNTY, FLORIDA CASE NO: 2018-012296-CA-O1 CRSJ, INC, Plaintiff, VS. A&S ENTERTAINMENT, LLC, Defendant. The Plaintiff, CRSJ, Inc., by and through his undersigned counsel hereby files his Motion for Protective Order and in support thereof states as follows: 1. Currently pending before this Court are the parties’ eviction proceedings and correspondent counterclaims 2. On May 15, 2018, the undersigned received a Re-Notice of Taking Deposition Duces Tecum for New Wave Loans Residential, LLC (the “Notice”), together with a corresponding Subpoena for Deposition Duces Tecum (the “Subpoena”). A copy of the Notice and Subpoena are attached hereto as Exhibit “A.” 3. The Deposition was set by Defendant with no coordination with the undersigned counsel and during a period of unavailability for Defendant’s counsel, Elias Hilal and Juan Martinez pursuant to their own filing, attached hereto as Exhibit “B”. Accordingly, the undersigned contacted Defendant’s counsel regarding these irregularities; Attorney Elias Hilal advised us that the reason for the lack of coordination and the unimportance of his co-counsel’s availability was because it was not an actual deposition and that only documents were being sought for inspection. eovosenga ay Rosenthal Rosenthal Rasco LLC One Aventura, 20960 N.E. 36 Avenue, Suite 600, Aventura, Florida 33180 305.937.0300 / Fax: 305.937.1311CASE NO: 2018-012296-CA-01 Page 2 of 4 4, Florida Rule of Civil Procedure 1.351 govems the rule for production of documents without depositions and it is evident that the Defendant is attempting to circumvent that rule. 5. Such rule requires that a party desiring production of documents by mail, shall “serve notice on every other party of the intent to serve a Subpoena under this Rule, at least 10 days before the Subpoena is issued, if service is by delivery and 15 days before the Subpoena is issued, if service is by mail.” 6. The Defendant did not even attempt to comply with Florida Rule of Civil Procedure 1.351. Instead, its counsel served the subpoena without first serving the required Notice of Intent. 7. Moreover, the Defendant unilaterally scheduled the Deposition, without first clearing the date with the undersigned counsel, Undersigned has a conflict with the date and time unilaterally chosen by the Plaintiff counsel and will need to reschedule matters if he were required to attend. &. The documents requested from the third party deponent are completely excessive and overbroad. It is apparent that the Defendant has authorized its counsel to go on a fishing expedition to harass the Plaintiff. 9. Pursuant to the Subpoena the Defendant is requesting “All loan documents, including but not limited to, the promissory note(s), mortgage(s), assignment(s) of rents, amendments and modification agreements, thereto, payment histories, and default letters, relating to CRSJ, Inc.” New Wave Loans is CRSJ’s lender and many of the loan documents contain confidential financial information that are not relevant to the current proceedings. 11. It would be a violation of CRSJ and its principal, James Fulford’s, privacy to have their personal financial records, including loan applications and credit information, brought into these proceedings. These documents will not lead to any discoverable evidence and the quosesens.2, Rosenthal Rosenthal Rasco LLC One Aventura, 20900 N.E, 30" Avenue, Suite 600, Aventura, Florida 33180 305.937.0300 / Fax: 305.937.1311CASE NO: 2018-012296-CA-01 Page 3 of 4 Defendant should not be permitted to inspect these records as they are irrelevant to these proceedings. 12. The Defendant’s use of a Subpoena for Deposition Duces Tecum without proper or lawful notice is an unlawful violation of the Rules of Civil Procedure intended to intimidate, bully, harass, annoy and oppress the Plaintiff. 13. Florida Rule of Civil Procedure §1,280(c) states that upon Motion by a party or by a person from whom discovery is sought and for good cause shown on the Court in which the action is pending, the court may “make any order to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense that justice requires, including one or more of the following (1) that the discovery not be had; (2) that the discovery may be had only on specified terms and conditions, including a designation of the time or place; (3) that the discovery may be had only by a method of discovery other than that selected by the party seeking discovery; (4) that certain matters not be inquired into, or that the scope of the discovery be limited to certain matters;...” 14. . The Plaintiff moves for a protective order pursuant to Florida Rules of Civil Procedure 1.280(c)(1)(2)(3)and(4). 15. The Plaintiff has incurred reasonable attomeys’ fees and costs as a result of the filing of this Motion and moves for the appropriate relief and sanctions. 16. Pursuant to the terms of the Lease and due to the improper procedure and abusive tactics utilized by the Defendant, Plaintiff requests that the Court issue a Protective Order and that the Defendant be ordered to pay attorneys fees and costs incurred by the Plaintiff. (WO46S444.1) Rosenthal Rosenthal Rasco LLC One Aventura, 20900 N.E. 30" Avenue, Suite 600, Aventura, Florida 33180 305.937.0306 / Fax: 305.937.1311CASE NO: 2018-012296-CA-01 Page 4 of 4 WHEREFORE the Plaintiff, CRSJ, Inc., moves this Court for a protective order as to the depositions scheduled for May 2%, 2018, for sanctions, to enter an award of attorney fees attendant on this Motion and such other and further relief as this Court deems just and proper under the circumstances, CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was mailed this 24" day of May, 2018 to ELIAS R. HILAL, ESQ., Williams Hilal Wigand Grande, PLLC, 633 SE 3rd Avenue, Suite 201, Fort Lauderdale, Florida 33301 — eliasé?whwlezal ; JUAN C. MARTINEZ, ESQ., GrayRobinson, P.A., 333 SE 2nd Avenue, Suite 3200, Miami, Florida ‘obinson.com; and ANTHONY PEREZ, ESQ., Garcia-Menocal 4937 SW 74® Court, Unit #3, Miami, Florida 33155 — ajperezlaw@gmail.com ROSENTHAL ROSENTHAL RASCO LLC Attorney for Plaintiff One Aventura — Suite 600 20900 N.E. 30th Ave. Aventura, FL 33180 Tel. 305-937-0300 Fax, 305-937-1311 MELISSA GROISMAN, ESQ. FLORIDA BAR NO. 46131 mesterrrlaw.com {W0458444.0) Rosenthal Rosenthal Raseo LLC One Aventura, 20900 N.E. 30° Avenne, Suite 600, Aventura, Florida 33180 305.937.0300 / Fax: 305.937.1311EXHIBIT “A”Filing # 72164875 E-Filed 05/15/2018 01:58:51 PM IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMIE-DADE COUNTY, FLORIDA CASE NO: 2018-12296-CA-01 CRSJ, INC., Plaintiff, V3. A&S ENTERTAINMENT, LLC, Defendants, RE-NOTICE OF TAKING DEPOSITION DUCES TECUM FOR NEW WAVE LOANS RESIDENTIAL, LLC PLEASE TAKE NOTICE that the undersigned attorney or attorney of the firm will take the deposition of: Name: New Wave Loans Residential, LLC Records Custodian 1835 NE Miami Gardens Drive, #451 North Miami Beach, Florida 33179 Date and Time: Tuesday, May 29, 2018 at 2:00 p.m. Place: GrayRobinson, P.A., 333 SE 2™ Ave, Suite 3200 Miami, FL 33131 upon oral examination before Steinotype, Inc., Notary Public, or any other notary public or officer authorized by law to take the depositions in the State of Florida. The deponent is to bring with her the documents listed in Exhibit “A” to the Subpoena for Deposition Duces Tecum attached hereto. The oral examination will continue from day to day until completed. This deposition is being taken for the purpose of discovery, for the use at trial, or for such other purposes as are permitted under the rules of the Court. Dated this_15" day of May, 2018. Respectfully submitted, By: 4 Elias R. Hilal, Esq. Florida Bar No. 60337Elias R. Hilal, Esq. Attomey for Defendant Florida Bar Number: 60337 WILLIAMS HILAL WIGAND GRANDE, PLLC 633 Southeast Third Avenue, Suite 301 Fort Lauderdale, Florida 33301 Tel: (954) 463-2065 Fax: (954) 337-0117 E-Mai whwlezal.com and By: Suan C. Martinez, Esq. Florida Bar No. 009024 Juan C. Martinez, Esq. Florida Bar No.: 009024 GRAYROBINSON, P.A. 333 S.E. 2nd Ave., Suite 3200 Miami, FL 33131 Tel: (305) 416-6880 Fax: (305) 416-6887 juan martinez: ‘obinson.com CERTIMICATE OF SERVICE 1 HEREBY CERTIFY that on this 15" day of May, 2018, 1 electronically filed the foregoing document with the Clerk of Court using the Florida Courts E-Filing Portal. I also certify that the foregoing document is being served this day on all counsel of record and interested parties in the manner identified on the below Service List, via transmission generated by the Florida Courts E- Filing Portal or by U.S. Mail, pursuant to Rule 2.516, Florida Rules of Judicial Administration. Service List: Melissa Groisman, Esq. Eduardo I. Rasco, Esq éséJuan C. Marti Juan C, Martinez, Esq. Florida Bar No. 9024IN THE COUNTY COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMLDADE COUNTY, FLORIDA Case No.: 2017-020761-CC-23 CRSJ,INC., Plaintiff, VS. A&S ENTERTAINMENT, LLC, Defendants, SUBPOENA FOR DEPOSITION DUCES TECUM THE STATE OF FLORIDA: TO: New Wave Loans Residential, LLC Records Custodian 1835 NE Miami Gardens Drive, #451 North Miami Beach, Florida 33179 YOU ARE HEREBY COMMANDED to appear before the undersigned or any other person authorized by law to take depositions at the Offices of GrayRobinson, P.A., 333 SE 2nd Ave, Suite 3200, Miami, FL 33131 on Tuesday, May 29, 2018 at 2:00 p.m. for the taking of your deposition in this action, and to have with you at that time and place the following: SEE ATTACHED EXHIBIT “A” These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena. Ifyou fail to: (1) appear as specified; or (2) object to this subpoena,you may be in contempt of Court. You are subpoenaed to appear by the following attorneys, and unless excused from this subpoena by these attomeys or the Court, you shall respond to this subpoena as directed. Dated this 15th day of May, 2018. Juan C, Martinez Fla. Bar No.: 009024 GRAYROBINSON, P.A, 333 S.E. 2" Ave., Suite 3200 Miami, Florida 33131 Tele: (305) 416-6880 Fax: (305) 416-6887 Primary email: Secondary ema: obinson.com tobinson.com Juan C. Martinez, Esq. For the CourtEXHIBIT “A” L DOCUMENTS REQUESTED L All loan documents, including but not limited to, the promissory note(s), mortgage(s), assignment(s) of rents, amendments and modification agreements, thereto, payment histories, and default letters, relating to CRSJ, Inc.EXHIBIT “B”Filing # 71745409 E-Filed 05/07/2018 10:43:26 AM IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NO: 2018-12296-CA-O1 CRSI, INC, Plaintiff, vs. A&S ENTERTAINMENT, LLC, Defendants. NOTICE OF UNAVAILABILITY PLEASE TAKE NOTICE that the undersigned counsel will be unavailable from May 16, 2018 through and including May 30, 2018, and requests that no depositions, hearings, discovery, or other matters be set or scheduled to take place during this time period. The filing and service of this notice shall constitute an application and request for continuance, extension and/or for a protective order, as appropriately required for the reasons set forth above. Dated this 7” day of May, 2018, Respectfully submitted, Elias R. Hilal, Esq. Florida Bar No. 60337 Elias R. Hilal, Esq. Attorney for Defendant Florida Bar Number: 60337 WILLIAMS HILAL WIGAND GRANDE, PLLC 633 Southeast Third Avenue, Suite 301 Fort Lauderdale, Florida 33301 Telephone: (954) 463-2065 Fax: (954) 337-0117 E-Mail: Eli andFlorida Bar No. 009024 Juan C. Martinez, Esq. Florida Bar No.: 009024 GRAYROBINSON, P.A. 333 S.E. 2nd Ave., Suite 3200 Miami, FL 33131 (305) 416-6880 (305) 416-6887 ecianellac!zray-robinson.com CERTIFICATE OF SERVICE 1 HEREBY CERTIFY that on this 7th day of May, 2018, I electronically filed the foregoing document with the Clerk of Court using the Florida Courts E-Filing Portal. I also certify that the foregoing document is being served this day on all counsel of record and interested parties in the manner identified on the below Service List, via transmission generated by the Florida Courts E-Filing Portal or by U.S. Mail, pursuant to Rule 2.516, Florida Rules of Judicial Administration. éstJuan €. Martinez Juan C. Martinez, Esq. Florida Bar No. 9024 Service List: Melissa Groisman, Esq. Eduardo I. Rasco, Esq.