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Filing # 132917758 E-Filed 08/18/2021 11:57:41 AM
IN THE CIRCUIT COURT FOR THE SIXTH JUDICIAL CIRCUIT
IN AND FOR PINELLAS COUNTY, FLORIDA
MASHA ‘MALU’ LUND; HILLARY :
FISHER VINSON a/k/a HILLARY HEPNER; :
LUCY PINDER; IRINA VORONINA; :
BROOKE MARRIN a/k/a BROOKE BANX :
and EMILY SEARS, :
:
Plaintiffs, :
: Case No: 21-000512-CI-020
vs. : UCN: 522021CA000512XXCICI
:
GULF COAST HOLDINGS, LLC, d/b/a OZ :
THEE GENTLEMEN’S CLUB d/b/a OZ :
LADIES’ & GENTLEMEN’S NIGHTCLUB, :
:
Defendant. :
:
DEFENDANT’S REQUEST TO PRODUCE TO PLAINTIFF, MASHA LUND
Defendant, GULF COAST HOLDINGS, LLC, in accordance with the applicable Rules of
Civil Procedure, requests the Plaintiff, MASHA “MALU” LUND, to produce to the Defendant, at
the offices of the Defendant’s attorney, DAVID J. KURLAND, ESQUIRE, at 850 Clearwater-Largo
Road S, Largo, Florida 33770-4470, on or before 4:00 o’clock P.M. on the 17th day of September
2021 or at such other reasonable time as might be mutually agreed upon by the parties prior to said
date, for the purpose of inspection and copying, the items listed on the attached Schedule “A.”
Defendant would state that it has the need to examine, copy and inspect said described items
and is unable to obtain said described items by other means; or, alternatively, Defendant is otherwise
entitled to said items under the applicable Rules of Civil Procedure and case law interpreting same.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Defendant’s Request
***ELECTRONICALLY FILED 08/18/2021 11:57:40 AM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
to Produce to Plaintiff, Masha Lund has been furnished by E-mail to LUDMILA KHOMIAK,
ESQUIRE, Attorney for Plaintiffs, at mila@talentrights.law this 18th day of August 2021.
LAW OFFICE OF DAVID J. KURLAND
By: /s/ David J. Kurland
DAVID J. KURLAND, ESQUIRE
850 Clearwater-Largo Road S
Largo, Florida 33770-4470
Telephone: (727) 461-3555
FAX: (727) 586-2731
Primary e-mail: david@davidkurland.com
Secondary e-mail: sheila@davidkurland.com
SPN: 00000144 FBN: 128042
Attorney for Defendant
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REQUEST TO PRODUCE TO PLAINTIFF, MASHA “MALU” LUND
1. Any and all contracts related to your image attached to the Complaint for Damages forming
the basis of your claim.
2. Any and all contracts into which you entered for your image, likeness, “brand,” etc., from
February 1, 2014 to current.
3. Tax returns for the tax years 2014 through current, including all schedules and attachments,
reflecting income derived from the use of your image, likeness, brand, etc.
4. Any and all documents reflecting income derived from the use of your image, likeness,
brand, etc., other than the request made in #3 above, for the years 2014 through current,
including but not limited to, W-2’s, 1099’s, K-1’s, royalties, contracts, etc.
5. Any and all images, photographs, videos, etc., of you from any and all magazines, printed
and/or internet based, where you are posing nude, partially nude, and/or in a sexually
suggestive and/or explicit manner.
6. Any and all music videos in which you have appeared.
7. Any and all posts made by you on any social media website which depict your image,
likeness and/or “brand” where you are posing nude, partially nude, and/or in a sexually
suggestive and/or explicit manner.
8. Any and all of your images, photographs, videos, etc., which were the subject of any lawsuit
in which you were the Plaintiff alleging your image, likeness, etc., was misappropriated
and/or exploited in any way.
9. Any and all of your images, photographs, videos, etc., utilized by each and every “adult
entertainment” and “striptease” outlet you promoted as alleged in Paragraph 29 of your
Complaint for Damages.
10. Any and all documents, e-mails, computer data, texts, or information from any source
evidencing the discovery of Defendant’s alleged use of the subject image.
11. Copies of any statements of any employee or agent of Defendant.
12. Copies of any statements of any witness or the name, address and identity, including the date
a statement may have been taken, of any witness.
13. Any and all documents, articles, writings, correspondence, recordings, memoranda, etc., that
you contend support any of the allegations set forth in your Complaint for Damages.
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14. Any and all documents evidencing any damages you allege to have suffered resulting from
Defendant’s alleged use of your image.
15. Any and all evidence you intend to use at the trial in this cause.
16. Any and all written reports from any expert witness or consultant retained by you regarding
this matter.
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Filing # 132917758 E-Filed 08/18/2021 11:57:41 AM IN THE CIRCUIT COURT FOR THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA MASHA ‘MALU’ LUND; HILLARY : FISHER VINSON a/k/a HILLARY HEPNER; : LUCY PINDER; IRINA VORONINA; : BROOKE MARRIN a/k/a BROOKE BANX : and EMILY SEARS, : : Plaintiffs, : : Case No: 21-000512-CI-020 vs. : UCN: 522021CA000512XXCICI : GULF COAST HOLDINGS, LLC, d/b/a OZ : THEE GENTLEMEN’S CLUB d/b/a OZ : LADIES’ & GENTLEMEN’S NIGHTCLUB, : : Defendant. : : DEFENDANT’S REQUEST TO PRODUCE TO PLAINTIFF, MASHA LUND Defendant, GULF COAST HOLDINGS, LLC, in accordance with the applicable Rules of Civil Procedure, requests the Plaintiff, MASHA “MALU” LUND, to produce to the Defendant, at the offices of the Defendant’s attorney, DAVID J. KURLAND, ESQUIRE, at 850 Clearwater-Largo Road S, Largo, Florida 33770-4470, on or before 4:00 o’clock P.M. on the 17th day of September 2021 or at such other reasonable time as might be mutually agreed upon by the parties prior to said date, for the purpose of inspection and copying, the items listed on the attached Schedule “A.” Defendant would state that it has the need to examine, copy and inspect said described items and is unable to obtain said described items by other means; or, alternatively, Defendant is otherwise entitled to said items under the applicable Rules of Civil Procedure and case law interpreting same. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Defendant’s Request ***ELECTRONICALLY FILED 08/18/2021 11:57:40 AM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** to Produce to Plaintiff, Masha Lund has been furnished by E-mail to LUDMILA KHOMIAK, ESQUIRE, Attorney for Plaintiffs, at mila@talentrights.law this 18th day of August 2021. LAW OFFICE OF DAVID J. KURLAND By: /s/ David J. Kurland DAVID J. KURLAND, ESQUIRE 850 Clearwater-Largo Road S Largo, Florida 33770-4470 Telephone: (727) 461-3555 FAX: (727) 586-2731 Primary e-mail: david@davidkurland.com Secondary e-mail: sheila@davidkurland.com SPN: 00000144 FBN: 128042 Attorney for Defendant 2 REQUEST TO PRODUCE TO PLAINTIFF, MASHA “MALU” LUND 1. Any and all contracts related to your image attached to the Complaint for Damages forming the basis of your claim. 2. Any and all contracts into which you entered for your image, likeness, “brand,” etc., from February 1, 2014 to current. 3. Tax returns for the tax years 2014 through current, including all schedules and attachments, reflecting income derived from the use of your image, likeness, brand, etc. 4. Any and all documents reflecting income derived from the use of your image, likeness, brand, etc., other than the request made in #3 above, for the years 2014 through current, including but not limited to, W-2’s, 1099’s, K-1’s, royalties, contracts, etc. 5. Any and all images, photographs, videos, etc., of you from any and all magazines, printed and/or internet based, where you are posing nude, partially nude, and/or in a sexually suggestive and/or explicit manner. 6. Any and all music videos in which you have appeared. 7. Any and all posts made by you on any social media website which depict your image, likeness and/or “brand” where you are posing nude, partially nude, and/or in a sexually suggestive and/or explicit manner. 8. Any and all of your images, photographs, videos, etc., which were the subject of any lawsuit in which you were the Plaintiff alleging your image, likeness, etc., was misappropriated and/or exploited in any way. 9. Any and all of your images, photographs, videos, etc., utilized by each and every “adult entertainment” and “striptease” outlet you promoted as alleged in Paragraph 29 of your Complaint for Damages. 10. Any and all documents, e-mails, computer data, texts, or information from any source evidencing the discovery of Defendant’s alleged use of the subject image. 11. Copies of any statements of any employee or agent of Defendant. 12. Copies of any statements of any witness or the name, address and identity, including the date a statement may have been taken, of any witness. 13. Any and all documents, articles, writings, correspondence, recordings, memoranda, etc., that you contend support any of the allegations set forth in your Complaint for Damages. 3 14. Any and all documents evidencing any damages you allege to have suffered resulting from Defendant’s alleged use of your image. 15. Any and all evidence you intend to use at the trial in this cause. 16. Any and all written reports from any expert witness or consultant retained by you regarding this matter. 4