DEFENDANTS SDC COMMUNITIES INC'S AND HENRY RODRIGUEZ'S RESPONSE TO PLAINTIFF'S THIRD REQUEST TO PRODUCE - 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

MecCANN HOLDINGS, LTD.,
Plaintiff,

V8. 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.

 

DEFENDANTS, SDC COMMUNITIES, INC.’S AND HENRY RODRIGUEZ’
RESPONSE TO PLAINTIFF’S THIRD REQUEST TO PRODUCE

&

      

     

Defendants, SDC COMMUNITIES, INC. and HENRY RODRIGUEZ (“Defendants”),
by and through their undersigned counsel, and pursuant to Florida Rule of Civil Procedure 1.350,
hereby respond to the Third Request for Production propounded on or about August 22, 2011 by
Plaintiff, McCANN HOLDINGS, LTD. (“Plaintiff”), and state:

l. Please see attached documents Bates-stamped Rod notebook 000001 through Rod
notebook 000425. These constitute the “black notebook” referenced at the October 26, 2010
hearing before the Sarasota County Board of County Commissioners. Please note that
documents Bates-stamped Rod …