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Filing # 141114790 E-Filed 12/29/2021 10:30:45 PM
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
V.C.A. UNITED, LLC, CASE NO. 502020CA007471XXXXMB
DIVISION: AE
Plaintiff,
v.
MELISSA L. HANSLER; and
INTEGRATED VASCULAR
IMAGING, LLC,
Defendants,
/
DEFENDANTS’ TRIAL EXHIBIT LIST
Defendants MELISSA L. HANSLER; and INTEGRATED VASCULAR IMAGING,
LLC, submit the following list of exhibits intended to be called at trial in the above captioned
matter:
Number | Description Admitted
1. Email from James Hansler dated June 2, 2019 to multiple parties,
with the subject heading: “VCA United Shutting Down”.
2. Statements for BankUnited account in the name of VCA United,
ending in #7609 for May 31, 2019
3. Articles of Organization for Florida Limited Liability Company
“Integrated Vascular Imaging, LLC”
4. Email from James Hansler to Channing and Kara of May 31, 2012
with subject: “VCA United Dissolution”.
5. Email from Melissa Hansler of May 31, 2019 to Mr. Issacs and Mr.
Cohan with subject “VCA United, LLC”
6. Temporary Relief Agreement signed by James Hansler and
Melissa Hansler and counsel for each party as per Mediation of
June 12, 2019.
*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 12/29/2021 10:30:45 PM ***7. Email correspondence between counsel for the parties, Markarian
and Telepman, of July, 2019 to January, 2020
8. VCA United LLC Detail General Ledger for the Month Ended
November 30, 2018.
9. Email from Melissa Hansler to Claudy Piersaint of May 7, 2019.
10. | The Office of VCA United Employee Manual for Claudy Piersaint.
11. | Email from Melissa Hansler to Wendy Chandler of May 22, 2019
with subject: “Please see attached agreement”.
12. | Exhibit I Business Associate Agreement (unexecuted) between
VCA United LLC and “Facility”, unidentified.
13. | Ultrasound Contract (unexecuted), of 2018 between “Company”
and “Guarantor” (unidentified), and VCA United LLC with a term
beginning June 3, 2019.
14. | Email from Melissa Hansler to James Hansler of May 29, 2019
with subject: “VCA liability insurance”.
15. | Email from Melissa Hansler to James Hansler of May 24, 2019
with subject: “Re: Living expenses”.
16. | Email from Melissa Hansler to James Hansler of May 25, 2019
with subject: “Support for girls”.
17. | Email from Melissa Hansler to James Hansler of May 25, 2019
with subject: “Very ill daughter”.
18. | Email from Melissa Hansler to James Hansler of May 26, 2019
with subject: “Support for the girls”.
19. | Email from James Hansler to Melissa Hansler of May 29, 2019
with subject: “MOU for Melissa”.
20. | Email from James Hansler to Melissa Hansler of June 1, 2019 with
subject: “Corrected MOU”.
21. | Memorandum of Understanding dated June 1, 2019 between
Melissa Hansler and James Hansler, executed by James Hansler.22. | Memorandum of Understanding dated May 31, 2019, between
Melissa Hansler and James Hansler, executed by both parties.
23. | Email from James Hansler to Melissa Hansler on June 2, 2019 with
subject: “Re: Girls.”
24. Articles of Organization of V.C.A. United LLC, filed March 20,
2018.
25. | Final Judgment of Dissolution of Marriage (Uncontested), entered
February 14, 2020.
26. | Petitioner/Husband’s Petition for Dissolution of Marriage and
Other Relief, efiled 5/8/2017
27. Marital Settlement Agreement dated February 13, 2020, executed
by both parties.
28. | V.C.A. United LLC Bank Account Records from May 2019.
29. | Order denying Plaintiff's Motion for Partial Summary Judgment,
entered 11/19/21 by The Honorable Bradley G. Harper.
30. | Any and all contracts entered into by V.C.A. United LLC.
31. | Any and all banking and/or accounting records for V.C.A. United
LLC.
32. | All proposed agreements and term sheets exchanged between the
parties during 2018 and 2019.
33. | All email correspondence between the parties and their attorneys
relating to any and all agreements, including proposed agreements.
34. | Term Sheet — Melissa Hansler and Scott Hansler
35. | Term Sheet — Melissa Hansler and Scott Hansler “Third Turn
12.6.18”
36. | Email from Dave Markarian to Jim Telepman and others of June
17, 2019 at 9:24 a.m. with subject: Hansler
37. | Absence of Records of Payment of Salary and Benefits to Melissa
Hansler.38. | Defendants reserve the right to rely on and utilize any exhibits that
Plaintiff has listed or may list in this matter or the consolidated
matter.
39. | Defendants adopt as their own, all exhibits listed on Plaintiff's
exhibit list.
40. | All records obtained by the Plaintiff in response to subpoenas for
records.
41. | Any and all depositions and any attachments or exhibits thereto,
taken in this matter or the consolidated matter.
42. | All pleadings and exhibits or attachments filed by either party in
this matter or the consolidated matter.
43. | All discovery responses, exhibits or attachments filed by either
party in this matter or the consolidated matter.
44. | Plaintiff's responses to Defendants’ Requests to Produce and
Interrogatories including all attachments.
45. | All caselaw or authorities in support of Motions or pleadings filed
by either party in this matter or the consolidated matter.
46. | All demonstrative exhibits.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
via Florida ePortal to all counsel of record on this 29" day of December 2021.
Respectfully submitted,
THE MARKARIAN GROUP
Attorneys for Defendants
2925 PGA Blvd. Suite 204
Palm Beach Gardens, FL 33410
Telephone: (561) 626-4700
Facsimile: (561) 627-9479
By: /s/ David K. Markarian
David K. Markarian
Florida Bar No. 480691David R. Glickman
Florida Bar No. 118685
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Filing # 141114790 E-Filed 12/29/2021 10:30:45 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA V.C.A. UNITED, LLC, CASE NO. 502020CA007471XXXXMB DIVISION: AE Plaintiff, v. MELISSA L. HANSLER; and INTEGRATED VASCULAR IMAGING, LLC, Defendants, / DEFENDANTS’ TRIAL EXHIBIT LIST Defendants MELISSA L. HANSLER; and INTEGRATED VASCULAR IMAGING, LLC, submit the following list of exhibits intended to be called at trial in the above captioned matter: Number | Description Admitted 1. Email from James Hansler dated June 2, 2019 to multiple parties, with the subject heading: “VCA United Shutting Down”. 2. Statements for BankUnited account in the name of VCA United, ending in #7609 for May 31, 2019 3. Articles of Organization for Florida Limited Liability Company “Integrated Vascular Imaging, LLC” 4. Email from James Hansler to Channing and Kara of May 31, 2012 with subject: “VCA United Dissolution”. 5. Email from Melissa Hansler of May 31, 2019 to Mr. Issacs and Mr. Cohan with subject “VCA United, LLC” 6. Temporary Relief Agreement signed by James Hansler and Melissa Hansler and counsel for each party as per Mediation of June 12, 2019. *** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 12/29/2021 10:30:45 PM ***7. Email correspondence between counsel for the parties, Markarian and Telepman, of July, 2019 to January, 2020 8. VCA United LLC Detail General Ledger for the Month Ended November 30, 2018. 9. Email from Melissa Hansler to Claudy Piersaint of May 7, 2019. 10. | The Office of VCA United Employee Manual for Claudy Piersaint. 11. | Email from Melissa Hansler to Wendy Chandler of May 22, 2019 with subject: “Please see attached agreement”. 12. | Exhibit I Business Associate Agreement (unexecuted) between VCA United LLC and “Facility”, unidentified. 13. | Ultrasound Contract (unexecuted), of 2018 between “Company” and “Guarantor” (unidentified), and VCA United LLC with a term beginning June 3, 2019. 14. | Email from Melissa Hansler to James Hansler of May 29, 2019 with subject: “VCA liability insurance”. 15. | Email from Melissa Hansler to James Hansler of May 24, 2019 with subject: “Re: Living expenses”. 16. | Email from Melissa Hansler to James Hansler of May 25, 2019 with subject: “Support for girls”. 17. | Email from Melissa Hansler to James Hansler of May 25, 2019 with subject: “Very ill daughter”. 18. | Email from Melissa Hansler to James Hansler of May 26, 2019 with subject: “Support for the girls”. 19. | Email from James Hansler to Melissa Hansler of May 29, 2019 with subject: “MOU for Melissa”. 20. | Email from James Hansler to Melissa Hansler of June 1, 2019 with subject: “Corrected MOU”. 21. | Memorandum of Understanding dated June 1, 2019 between Melissa Hansler and James Hansler, executed by James Hansler.22. | Memorandum of Understanding dated May 31, 2019, between Melissa Hansler and James Hansler, executed by both parties. 23. | Email from James Hansler to Melissa Hansler on June 2, 2019 with subject: “Re: Girls.” 24. Articles of Organization of V.C.A. United LLC, filed March 20, 2018. 25. | Final Judgment of Dissolution of Marriage (Uncontested), entered February 14, 2020. 26. | Petitioner/Husband’s Petition for Dissolution of Marriage and Other Relief, efiled 5/8/2017 27. Marital Settlement Agreement dated February 13, 2020, executed by both parties. 28. | V.C.A. United LLC Bank Account Records from May 2019. 29. | Order denying Plaintiff's Motion for Partial Summary Judgment, entered 11/19/21 by The Honorable Bradley G. Harper. 30. | Any and all contracts entered into by V.C.A. United LLC. 31. | Any and all banking and/or accounting records for V.C.A. United LLC. 32. | All proposed agreements and term sheets exchanged between the parties during 2018 and 2019. 33. | All email correspondence between the parties and their attorneys relating to any and all agreements, including proposed agreements. 34. | Term Sheet — Melissa Hansler and Scott Hansler 35. | Term Sheet — Melissa Hansler and Scott Hansler “Third Turn 12.6.18” 36. | Email from Dave Markarian to Jim Telepman and others of June 17, 2019 at 9:24 a.m. with subject: Hansler 37. | Absence of Records of Payment of Salary and Benefits to Melissa Hansler.38. | Defendants reserve the right to rely on and utilize any exhibits that Plaintiff has listed or may list in this matter or the consolidated matter. 39. | Defendants adopt as their own, all exhibits listed on Plaintiff's exhibit list. 40. | All records obtained by the Plaintiff in response to subpoenas for records. 41. | Any and all depositions and any attachments or exhibits thereto, taken in this matter or the consolidated matter. 42. | All pleadings and exhibits or attachments filed by either party in this matter or the consolidated matter. 43. | All discovery responses, exhibits or attachments filed by either party in this matter or the consolidated matter. 44. | Plaintiff's responses to Defendants’ Requests to Produce and Interrogatories including all attachments. 45. | All caselaw or authorities in support of Motions or pleadings filed by either party in this matter or the consolidated matter. 46. | All demonstrative exhibits. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via Florida ePortal to all counsel of record on this 29" day of December 2021. Respectfully submitted, THE MARKARIAN GROUP Attorneys for Defendants 2925 PGA Blvd. Suite 204 Palm Beach Gardens, FL 33410 Telephone: (561) 626-4700 Facsimile: (561) 627-9479 By: /s/ David K. Markarian David K. Markarian Florida Bar No. 480691David R. Glickman Florida Bar No. 118685