On February 01, 2021 a
Party Discovery
was filed
involving a dispute between
Fisher Vinson, Hillary,
Lund, Masha Malu,
Marrin, Brooke,
Pinder, Lucy,
Sears, Emily,
Voronina, Irina,
and
Gulf Coast Holdings Llc,
for INTELLECTUAL PROPERTY
in the District Court of Pinellas County.
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Filing # 134846446 E-Filed 09/17/2021 07:00:29 PM
IN THE CIRCUIT COURT OF THE 6TH JUDICIAL CIRCUIT
IN AND FOR PINELLAS COUNTY, FLORIDA
MASHA ÔMALUÕ LUND; HILLARY FISHER
VINSON a/k/a HILLARY HEPNER; LUCY
PINDER; IRINA VORONINA; BROOKE MARRIN
a/k/a BROOKE BANX and EMILY SEARS, Case No. 2021CA-000512XXCICI
PLAINTIFFS,
vs.
GULF COAST HOLDINGS, L.L.C. d/b/a
OZ THEE GENTLEMENS CLUB d/b/a
OZ LADIESÕ & GENTLEMENÕS NIGHTCLUB,
DEFENDANT.
___________________________________________/
PLAINTIFF IRINA VORONINAÕS RESPONSE TO DEFENDANTÕS REQUEST FOR
ADMISSIONS
Plaintiff, IRINA VORONINA, by and through the undersigned counsel, files her
Responses to DefendantÕs Request for Admissions.
Date: September 17, 2021. Respectfully submitted,
THE CASAS LAW FIRM, P.C
By: /s/ Ludmila Khomiak
Ludmila Khomiak, Esq.
Florida Bar No.: 91757
mila@talentrights.law
Brickell Bayview Center
80 S. W. 8th Street, Suite 2000
Miami, FL 33130
Attorney for Plaintiffs
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
Page 1 of 5
***ELECTRONICALLY FILED 09/17/2021 07:00:29 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
Electronic Mail on this 17th day of September, 2021 to:
David J. Kurland, Esq.
850 Clearwater-Largo Road South
Largo, Florida 33770-4470
david@davidkurland.corn
sheila@davidkurland.com
Attorney for Defendant
/s/ Ludmila Khomiak
Ludmila Khomiak, Esq.
Florida Bar No.: 91757
Page 2 of 5
PLAINTIFFÕS RESPONSE TO DEFENDANTÕS
REQUEST FOR ADMISSIONS
1. Admit that the Òsubject imageÓ does not suggest, imply, express, etc., that you Òattended or
will attend each event and has participated in or intends to participate in the activities adver-
tisedÓ as alleged in Paragraph 7 of your Complaint.
RESPONSE: Denied.
2. Admit that the Òsubject imageÓ does not identify you by name.
RESPONSE: Admit.
3. Admit that when the Òsubject imageÓ was originally taken, you relinquished all rights and/or
claims you had or may have had to that image to a third-party, either orally and/or in writing.
RESPONSE: Denied.
4. Admit that you have no knowledge and/or evidence that Defendant did not negotiate for the
use of the Òsubject imageÓ with the third-party to which you relinquished your rights and/or
claims.
RESPONSE: Denied.
5. Admit that the Òsubject imageÓ does not contain any means of gaining permission, entering
into negotiations, contracting with you and/or contacting you or any third-party in any way
regarding the use of the Òsubject image.Ó
RESPONSE: Denied.
6. Admit that the Òsubject imageÓ is not copyrighted, trademarked and/or identified in any way as
being protected and prohibited from being copied, displayed and/or published on the entirety
of the Internet.
Page 3 of 5
RESPONSE: Denied.
7. Admit that the number Ò69Ó depicted on the shirt you are wearing in the Òsubject imageÓ refers
to or implies a sexual position.
RESPONSE: Denied.
8. Admit that some of the magazines in which you have appeared; specifically, FHM, Maxim and
Playboy, are directed toward and/or contains sexually suggestive and/or explicit material.
RESPONSE: Denied.
9. Admit that some advertisements in which you appear depict you in a sexually suggestive and/
or explicit manner.
RESPONSE: Denied.
10.Admit that your image, brand and/or marketability suggests that you Òsupport and/or Òpartic-
ipate in the adult entertainment and/or striptease lifestyle.Ó
RESPONSE: Denied.
11.Admit that you never observed the Òsubject imageÓ on DefendantÕs social media, as alleged,
until informed by your attorney, law firm and/or its agents and/or third-parties acting on its
behalf.
RESPONSE: Denied.
12.Admit that you had no knowledge of the alleged use of the Òsubject imageÓ on DefendantÕs
social media until informed by your attorney, law firm and/or its agents and/or third parties
acting on its behalf.
RESPONSE: Denied.
13.But for the filing of this lawsuit, admit that upon learning of DefendantÕs alleged use of the
Page 4 of 5
Òsubject image,Ó you, nor any third-party acting on your behalf, took any action to inform and/
or prohibit Defendant from using the Òsubject image.Ó
RESPONSE: Admit.
Page 5 of 5
Document Filed Date
September 17, 2021
Case Filing Date
February 01, 2021
Category
INTELLECTUAL PROPERTY
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Filing # 134846446 E-Filed 09/17/2021 07:00:29 PM IN THE CIRCUIT COURT OF THE 6TH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA MASHA ÔMALUÕ LUND; HILLARY FISHER VINSON a/k/a HILLARY HEPNER; LUCY PINDER; IRINA VORONINA; BROOKE MARRIN a/k/a BROOKE BANX and EMILY SEARS, Case No. 2021CA-000512XXCICI PLAINTIFFS, vs. GULF COAST HOLDINGS, L.L.C. d/b/a OZ THEE GENTLEMENS CLUB d/b/a OZ LADIESÕ & GENTLEMENÕS NIGHTCLUB, DEFENDANT. ___________________________________________/ PLAINTIFF IRINA VORONINAÕS RESPONSE TO DEFENDANTÕS REQUEST FOR ADMISSIONS Plaintiff, IRINA VORONINA, by and through the undersigned counsel, files her Responses to DefendantÕs Request for Admissions. Date: September 17, 2021. Respectfully submitted, THE CASAS LAW FIRM, P.C By: /s/ Ludmila Khomiak Ludmila Khomiak, Esq. Florida Bar No.: 91757 mila@talentrights.law Brickell Bayview Center 80 S. W. 8th Street, Suite 2000 Miami, FL 33130 Attorney for Plaintiffs CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Page 1 of 5 ***ELECTRONICALLY FILED 09/17/2021 07:00:29 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** Electronic Mail on this 17th day of September, 2021 to: David J. Kurland, Esq. 850 Clearwater-Largo Road South Largo, Florida 33770-4470 david@davidkurland.corn sheila@davidkurland.com Attorney for Defendant /s/ Ludmila Khomiak Ludmila Khomiak, Esq. Florida Bar No.: 91757 Page 2 of 5 PLAINTIFFÕS RESPONSE TO DEFENDANTÕS REQUEST FOR ADMISSIONS 1. Admit that the Òsubject imageÓ does not suggest, imply, express, etc., that you Òattended or will attend each event and has participated in or intends to participate in the activities adver- tisedÓ as alleged in Paragraph 7 of your Complaint. RESPONSE: Denied. 2. Admit that the Òsubject imageÓ does not identify you by name. RESPONSE: Admit. 3. Admit that when the Òsubject imageÓ was originally taken, you relinquished all rights and/or claims you had or may have had to that image to a third-party, either orally and/or in writing. RESPONSE: Denied. 4. Admit that you have no knowledge and/or evidence that Defendant did not negotiate for the use of the Òsubject imageÓ with the third-party to which you relinquished your rights and/or claims. RESPONSE: Denied. 5. Admit that the Òsubject imageÓ does not contain any means of gaining permission, entering into negotiations, contracting with you and/or contacting you or any third-party in any way regarding the use of the Òsubject image.Ó RESPONSE: Denied. 6. Admit that the Òsubject imageÓ is not copyrighted, trademarked and/or identified in any way as being protected and prohibited from being copied, displayed and/or published on the entirety of the Internet. Page 3 of 5 RESPONSE: Denied. 7. Admit that the number Ò69Ó depicted on the shirt you are wearing in the Òsubject imageÓ refers to or implies a sexual position. RESPONSE: Denied. 8. Admit that some of the magazines in which you have appeared; specifically, FHM, Maxim and Playboy, are directed toward and/or contains sexually suggestive and/or explicit material. RESPONSE: Denied. 9. Admit that some advertisements in which you appear depict you in a sexually suggestive and/ or explicit manner. RESPONSE: Denied. 10.Admit that your image, brand and/or marketability suggests that you Òsupport and/or Òpartic- ipate in the adult entertainment and/or striptease lifestyle.Ó RESPONSE: Denied. 11.Admit that you never observed the Òsubject imageÓ on DefendantÕs social media, as alleged, until informed by your attorney, law firm and/or its agents and/or third-parties acting on its behalf. RESPONSE: Denied. 12.Admit that you had no knowledge of the alleged use of the Òsubject imageÓ on DefendantÕs social media until informed by your attorney, law firm and/or its agents and/or third parties acting on its behalf. RESPONSE: Denied. 13.But for the filing of this lawsuit, admit that upon learning of DefendantÕs alleged use of the Page 4 of 5 Òsubject image,Ó you, nor any third-party acting on your behalf, took any action to inform and/ or prohibit Defendant from using the Òsubject image.Ó RESPONSE: Admit. Page 5 of 5