RESPONSE - DEFTS SDC COMMUNITIES INC AND HENRY RODRIGUEZ - TO PLTF FOURTH PRODUCTION REQUEST - MCCANN HOLDINGS LTD vs BENDERSON, RANDALL et al

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On May 16, 2011 a case was filed by Mccann Holdings Ltd, represented by Norse, Kristin Ann, against Benderson, Randall, Rodriguez, Henry, Sdc Communities Inc et al. represented by Bentley, Morgan, Sandridge, Hala A, and Vogler, Edward Ii, in the jurisdiction of Sarasota County. Judge MERCURIO, FREDERICK P presiding.

                        
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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.

 

S

    

DEFENDANTS, SDC COMMUNITIES, INC.’S AND HENRY RODRIGUEZ?

 

 

Defendants, SDC COMMUNITIES, INC.’s (“SDC”) and HENRY RODRIGUEZ
(“Rodriguez”), by and through their undersigned counsel, and pursuant to Florida Rule of Civil
Procedure 1,350, hereby respond to the Fourth Request for Production propounded on or about
September 20, 2012 by Plaintiff, MCCANN HOLDINGS, LTD. (“Plaintiff”), and state:

l. No responsive documents are in the possession of Defendants at this time. As
discussed with counsel, SDC and Rodriguez are awaiting responses from third-parties in order to
respond to this request. If and when these are received, SDC and Rodriguez will supplement
their response.

2. See attached documents Bates-number…