On May 16, 2011 a
RESPONSE TO PLAINTIFFS NOTICE AND SUBPOENA FOR NON PARTY PRODUCTION TO BENTLEY AND BRUNING PA
was filed
involving a dispute between
Mccann Holdings Ltd,
and
Benderson, Randall,
Rodriguez, Henry,
Sdc Communities Inc,
Vott A Llc,
Vott B Llc,
Vott C Llc,
Vott D Llc,
in the District Court of Sarasota County.
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IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT
IN AND FOR SARASOTA COUNTY, FLORIDA
McCANN HOLDINGS, LTD..,
Plaintiff,
VS. CASE NO. 2011 CA 003897 NC
SDC COMMUNITIES, INC.,
VOTT-A, LLC, VOTT-B, LLC,
VOTT-C, LLC, VOTT-D, LLC, and
HENRY RODRIGUEZ,
Defendants.
__ /
RESPONSE TO PLAINTIFF’S NOTICE AND SUBPOENA
FOR NON-PARTY PRODUCTION TO BENTLEY & BRUNING, P.A.
Defendants, SDC COMMUNITIES, INC. and HENRY RODRIGUEZ, on behalf of
Bentley & Bruning, P.A. (“B&B”), by and through their undersigned counsel, respond to
Plaintiff, MCCANN HOLDINGS, LTD.’s (“McCann”) Notice and Subpoena for Non-Party
Production directed to Bentley & Bruning, P.A., which was propounded on or about February
21, 2013, and state:
1. Objection. Correspondence between two law firms regarding the same client is
protected under the attorney-client and work-product privileges. Such correspondence is not
provided.
Notwithstanding, please see attached documents Bates-numbered B&B 000001 through
B&B 000014.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
via e-mail to STEVEN D. HUTTON, ESQ., 240 South Pineapple Ave., Ste. 801, Sarasota, FL
Filed for Record 03/15/2013 02:36 PM - Karen E. Rushing, Clerk of the Circuit Court - Sarasota County, FL - 2011 CA 003897 NC Dkt-62794412 Page 1 of 234236 at the primary e-mail address of sdh@huttonlawfirm.com and the secondary e-mail
huttonlawfirm.com and noreen@huttonlawfirm.com and EDWARD
addresses of pdominko@
at edvogler@voglerashton.com this ( ck / ‘lay of March, 2013.
BENTLEY AND BRUNING, P.A.
[ORGAN R. BENTLEY, ESO.
Fla. Bar #0962287
Sarasota, Florida 34236
Telephone: (941) 556-9030
Facsimile: (941) 312-5316
Attorneys for SDC COMMUNITIES, INC. and
HENRY RODRIGUEZ
Primary Email: jupenvex
Filed for Record 03/15/2013 02:36 PM - Karen E. Rushing, Clerk of the Circuit Court - Sarasota County, FL - 2011 CA 003897 NC Dkt-62794412 Page 2 of 2
Document Filed Date
March 15, 2013
Case Filing Date
May 16, 2011
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IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR SARASOTA COUNTY, FLORIDA McCANN HOLDINGS, LTD.., Plaintiff, VS. CASE NO. 2011 CA 003897 NC SDC COMMUNITIES, INC., VOTT-A, LLC, VOTT-B, LLC, VOTT-C, LLC, VOTT-D, LLC, and HENRY RODRIGUEZ, Defendants. __ / RESPONSE TO PLAINTIFF’S NOTICE AND SUBPOENA FOR NON-PARTY PRODUCTION TO BENTLEY & BRUNING, P.A. Defendants, SDC COMMUNITIES, INC. and HENRY RODRIGUEZ, on behalf of Bentley & Bruning, P.A. (“B&B”), by and through their undersigned counsel, respond to Plaintiff, MCCANN HOLDINGS, LTD.’s (“McCann”) Notice and Subpoena for Non-Party Production directed to Bentley & Bruning, P.A., which was propounded on or about February 21, 2013, and state: 1. Objection. Correspondence between two law firms regarding the same client is protected under the attorney-client and work-product privileges. Such correspondence is not provided. Notwithstanding, please see attached documents Bates-numbered B&B 000001 through B&B 000014. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via e-mail to STEVEN D. HUTTON, ESQ., 240 South Pineapple Ave., Ste. 801, Sarasota, FL Filed for Record 03/15/2013 02:36 PM - Karen E. Rushing, Clerk of the Circuit Court - Sarasota County, FL - 2011 CA 003897 NC Dkt-62794412 Page 1 of 234236 at the primary e-mail address of sdh@huttonlawfirm.com and the secondary e-mail huttonlawfirm.com and noreen@huttonlawfirm.com and EDWARD addresses of pdominko@ at edvogler@voglerashton.com this ( ck / ‘lay of March, 2013. BENTLEY AND BRUNING, P.A. [ORGAN R. BENTLEY, ESO. Fla. Bar #0962287 Sarasota, Florida 34236 Telephone: (941) 556-9030 Facsimile: (941) 312-5316 Attorneys for SDC COMMUNITIES, INC. and HENRY RODRIGUEZ Primary Email: jupenvex Filed for Record 03/15/2013 02:36 PM - Karen E. Rushing, Clerk of the Circuit Court - Sarasota County, FL - 2011 CA 003897 NC Dkt-62794412 Page 2 of 2