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eFile Accepted: 10/09/2013 01:39 PM
Electronically Filed 10/09/2013 01:21:36 PM ET
IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT
OF THE STATE OF FLORIDA, IN AND FOR SARASOTA COUNTY, FLORIDA
McCANN HOLDINGS, LTD.,
Plaintiff, CASE NO: 2011-CA-3897NC
VS.
SDC COMMUNITIES, INC.,
VOTT-A, LLC, VOTT-B, LLC,
VOTT-C, LLC, VOTT-D, LLC,
And HENRY RODRIGUEZ,
Defendants.
/
RESPONSE TO PLAINTIFF’S FOURTH REQUEST FOR PRODUCTION OF
DOCUMENTS
VOTT-A, LLC, VOTT-B, LLC, VOTT-C, LLC, and VOTT-D, LLC (collectively
“VOTT”), submits the following responses to Plaintiff's Fourth Request For Production Of
Documents.
GENERAL OBJECTIONS
A. Plaintiff objects to providing any information that contains privileged information, including
without limitation, attorney-client communications, and attorney work product.
B. Plaintiff objects to providing any information that contains information prepared in anticipation
of litigation or for trial without the showing by Plaintiff required by the Florida Rules of Civil
Procedure, or any information that is confidential or proprietary.
C. Plaintiff objects to providing any information which is not relevant, or is beyond the scope of
permissible discovery as set forth in Rules 1.280 and 1.350 of the Florida Rules of Civil Procedure.
RESPONSES
1-11. Subject to the foregoing and to the extent such documentation exists and is in the
care, custody and control of VOTT, all non-privileged, responsive documents will be produced as
they are kept in the usual course of business at VOTT’s attorney’s offices in Bradenton, Florida at a
-|-mutually convenient time.
12. | VOTT objects to the request set forth in Paragraph 12 as it (1) is so vague and ambiguous that
a reasonable man would not know what documents are being requested, and (11) seeks to invade the
mental impressions of counsel for VOTT and violates the work product privilege.
13. Request acknowledged.
/s/ Edward Vogler II
EDWARD VOGLER II
Vogler Ashton, PLLC
2411-A Manatee Avenue West
Bradenton, FL 34205
Email: edvogler@voglerashton.com
(941) 388-9400 x104
(941) 866-7648 Fax
Florida Bar No. 0380970
Attorneys for VOTT and Benderson
edvogler@voglerashton.com
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished this
9th day of October, 2013, by Electronic Mail to: Steven D. Hutton, Esq., 240 S. Pineapple Avenue,
noreen@huttonlawfirm.com, and Morgan R. Bentley, Esq. 783 S. Orange Avenue, Suite 220,
Sarasota, Florida 34236 mbentley(@ bentleyandbruning.com, nwhite@bentleyandbruning.com, and
/s/ Edward Vogler I
EDWARD VOGLER II, ESQUIRE
Florida Bar No. 0380970
Vogler Ashton, PLLC
2411 —A Manatee Avenue West
Bradenton, Florida 34205
(941) 388-9400 x104
(941) 866-7648 Facsimile
Attorney For VOTT and Benderson
edvogler@voglerashton.com
Preview
eFile Accepted: 10/09/2013 01:39 PM Electronically Filed 10/09/2013 01:21:36 PM ET IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT OF THE STATE OF FLORIDA, IN AND FOR SARASOTA COUNTY, FLORIDA McCANN HOLDINGS, LTD., Plaintiff, CASE NO: 2011-CA-3897NC VS. SDC COMMUNITIES, INC., VOTT-A, LLC, VOTT-B, LLC, VOTT-C, LLC, VOTT-D, LLC, And HENRY RODRIGUEZ, Defendants. / RESPONSE TO PLAINTIFF’S FOURTH REQUEST FOR PRODUCTION OF DOCUMENTS VOTT-A, LLC, VOTT-B, LLC, VOTT-C, LLC, and VOTT-D, LLC (collectively “VOTT”), submits the following responses to Plaintiff's Fourth Request For Production Of Documents. GENERAL OBJECTIONS A. Plaintiff objects to providing any information that contains privileged information, including without limitation, attorney-client communications, and attorney work product. B. Plaintiff objects to providing any information that contains information prepared in anticipation of litigation or for trial without the showing by Plaintiff required by the Florida Rules of Civil Procedure, or any information that is confidential or proprietary. C. Plaintiff objects to providing any information which is not relevant, or is beyond the scope of permissible discovery as set forth in Rules 1.280 and 1.350 of the Florida Rules of Civil Procedure. RESPONSES 1-11. Subject to the foregoing and to the extent such documentation exists and is in the care, custody and control of VOTT, all non-privileged, responsive documents will be produced as they are kept in the usual course of business at VOTT’s attorney’s offices in Bradenton, Florida at a -|-mutually convenient time. 12. | VOTT objects to the request set forth in Paragraph 12 as it (1) is so vague and ambiguous that a reasonable man would not know what documents are being requested, and (11) seeks to invade the mental impressions of counsel for VOTT and violates the work product privilege. 13. Request acknowledged. /s/ Edward Vogler II EDWARD VOGLER II Vogler Ashton, PLLC 2411-A Manatee Avenue West Bradenton, FL 34205 Email: edvogler@voglerashton.com (941) 388-9400 x104 (941) 866-7648 Fax Florida Bar No. 0380970 Attorneys for VOTT and Benderson edvogler@voglerashton.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished this 9th day of October, 2013, by Electronic Mail to: Steven D. Hutton, Esq., 240 S. Pineapple Avenue, noreen@huttonlawfirm.com, and Morgan R. Bentley, Esq. 783 S. Orange Avenue, Suite 220, Sarasota, Florida 34236 mbentley(@ bentleyandbruning.com, nwhite@bentleyandbruning.com, and /s/ Edward Vogler I EDWARD VOGLER II, ESQUIRE Florida Bar No. 0380970 Vogler Ashton, PLLC 2411 —A Manatee Avenue West Bradenton, Florida 34205 (941) 388-9400 x104 (941) 866-7648 Facsimile Attorney For VOTT and Benderson edvogler@voglerashton.com