Preview
Filing # 124041997 E-Filed 03/30/2021 04:29:21 PM
IN THE CIRCUIT COURT OF THE 6TH JUDICIAL CIRCUIT
IN AND FOR PINELLAS COUNTY, FLORIDA
MASHA'MALU' LUND; HILLARY FISHER
VINSON a/k/a HILLARY HEPNER; LUCY
PINDER; IRINAVORONINA; BROOKE MARR-IN
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 LADIES' & GENTLEMEN'S NIGHTCLUB,
DEFENDANT.
i
PLAINTIFFS' FIRST REOUEST FOR PRODUCTION OF DOCUMENTS TO
DEFENDANT
PLAINTIFFS, 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, (herein collectively referred to as "Plaintiffs" or
"Models") by and through the undersigned counsel and pursuant to Rule 1.350 Florida Rules of
Civil Procedure, request the DEFENDANT, GULF COAST HOLDINGS, L.L.C. d/b/a OZ
THEE GENTLEMENS CLUB d/b/a OZ LADIES' & GENTLEMEN'S NIGHTCLUB
(hereinafter referred to as "Oz" or "Defendant"),to produce the following documents:
INSTRUCTIONS
A. You are requested to produce all documents in your custody, possession and/or control,
including all documents which are in the custody, possession and/or control of your employees,
The Casas Law Firm, RC.
Brickell Bayview Center 80 S.W. 8th Street, Suite 2000, Miami, FL 33130
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***ELECTRONICALLYFILED 03/30/2021 04:29:20 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
attorneys, consultants, accountants, or agents, regardless ofthe location of such documents.
B. If any document responsive to a specific request was, but no longer is, in your possession,
custody or control, please identify that document and state whether any such document (a) is
missing or lost; (b) has been destroyed; (c) has been transferred voluntarily or involuntarily; or
(d) has been otherwise disposed of, and, in each instance, please explain in detail the
circumstances surrounding any such disposition thereof.
C. All documents are to be produced in or with their original file folders, file jackets,
envelopes, or covers, and as they are kept in the usual course of business.
D. In answering these requests for production you are required to furnish all information,
documents and/or things that are available to you or
subject to your reasonable inquiry, including
information and things in the possession, custody or control of any of your representatives,
including, without limitation, your attorneys, accountants, advisors, agents, or other persons
directly or indirectly employed by or connected with you and anyone else otherwise subject to
your control.
E. Any document as to which a claim of privilege is or will be asserted should be identified
by author, signatory, descr*tion (i. e.,letter, memo, telefax), title (if any), dates, addresses (if
any), general subject matter, present location and custodian and a complete statement of the
grounds for the claim of privilege should be set forth.
DEFINITIONS
A. The term "you" and "your" means the party or parties to which this request is addressed,
including its divisions, departments, subsidiaries, affiliates, predecessors,present or former officers,
directors, owners, agents, accountants, attorneys, and all other persons acting or purporting to act
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on its behalf, as well as each partnership in which it isa partner and any other person or trust
entities in which you presently have or once had an interest, which partic*ated in, contributed to,
or which have knowledge ofthe subject matter or facts encompassed in the operativeComplaint.
B. The term "Defendant" means GULF COAST HOLDINGS, L.L.C. d/b/a OZ THEE
GENTLEMENS CLUB d/b/a OZ LADIES' & GENTLEMEN'S NIGHTCLUB, including its
agents, attorneys, accounts, and all other persons acting or purporting to act on its behalf. The
term "Defendant" also includes the party's divisions departments, subsidiaries, affiliates,
predecessors, present or former officers, directors, owners, agents, accountants, attorneys, and all
other persons acting or purporting to act on its behalf.
C. The term "Plaintiffs" means
professional models 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.
D. The term "related to", "relate to", or "refer to" means and includes mentioning, discussing,
including summarizing, describing, reflecting, containing, referring to, relating to, depicting,
connected with, embodying, evidencing, constituting, concerning, reporting, purporting, or
involving an act, occurrence, event, transaction, fact, thing or course of dealing.
E. The term "identify" when used in reference to:
(a) a natural person means to provide the name(s), address(es), telephone
number(s), and any other information necessary to locate such person for the
purposes of service of subpoena to require attendance at any proceeding;
(b) a person other than a natural person means to provide the name(s),
address(es), telephonenumber(s), and type of entity of such person;
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(c) a document means to state its date, author, addressee, recipient, type of
document, and to identify its present custodian.
F. The term "communication" means any type of oral, written, or visual contact, between
two or more persons in which information, facts or opinions were exchanged, imparted or
received, including those facilitated by electronic transmission.
G. The term "statement" means any oral, written, stenographic, or recorded declaration of
any kind or description.
H. The term "document" means and includes any kind of written, typewritten, printed, or
recorded material whatsoever, regardless of the source or author thereof including,
without limitation, any writing, filed for reporting or other purposes with any federal,
state, or local agency, notes, memoranda, letters, telexes, telegrams, audited financial
statements, unaudited interim financial statements, financial ledgers, stock ledgers for all
forms and types of securities, minutes of directors, shareholders or committee meetings,
written communications with directors and shareholders, inter-office communications,
notices, circulates, bulletins, manuals, results of investigations, progress reports, studies
made for business use, loan progress charts, requests for payment, any other financial
reports, working papers, contracts, agreements, bills, books of account, vouchers, maps,
plats, evaluations, drawings, plans, pictures, tape recordings, transcriptions of
conversations of tape recordings, desk calendars, bank checks, invoices, charge slips,
hotel charges, receipts, expense accounts, freight bills, statistical records, cost sheets,
bids, abstracts of bids, journals, diaries, time sheets or logs, all computer-stored data, job
or transaction files, permits or licenses or applications therefor, appointment books,
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books, records and copies, extracts and summaries or other documents, and drafts of any
of the above, whether used or not, or any other writing or recording.
I. The term "marketing material" refers to the collection of media used to support the sales
or promotion of an establishment, product, or service. Marketing material includes
brochures, flyers, advertisements, billboards, social media posts, website posts, sell
sheets, follow-up mailers, white papers, newsletters, Web blogs, and/or any
communicationintended to make the sale effort easier and more effective for the business
or person disseminating the collection of media.
..
jO The term "person means any natural person, firm, company, corporation, partnersh*,
limited partnership, joint venture, or any other form of business entity. When the word
..
"person is used in the singular, the same shall be construed to also be used in the plural.
K. The term "imagels)" refers to any image, picture, photograph, likeness, or representation
that has been used for promotional,selling, marketing or advertising purposes, including
all Exhibits attached to Plaintiffs' operative Complaint and/or any other variation,
alteration, rendition, or other use of Plaintiffs' images.
L. The singular shall include the plural and vice versa; the terms "and," and "or," shall be
both conjunctive and disjunctive; the term "including" means "including without
..
limitation.
M. The term "date" shall mean the exact date, month, and year, if ascertainable or, if not, the
best approximation of the date (based upon relationship with other events).
N. The term "agent" shall mean any agent, employee, officer, director, attorney, independent
contractor or any other person acting under the direction of or on behalf of another.
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REOUEST FOR PRODUCTION TO DEFENDANT
1. All documents that refer to, reflect, or evidence any and all communications between
you, or anyone acting on your behalf, and any other person related to the creation,
distribution, or payment for the Images attached as Exhibits to Plaintiffs' operative
Complaint.
2. All documents that refer to, reflect, or evidence any and all agreements between you,
your representatives, agents, or anyone acting on your behalf, and any other person
related to the creation, distribution, or payment for the Images attached as Exhibits to
Plaintiffs' operative Complaint.
3. All reports, estimates, statements, invoices, bills, or receipts for earnings or profits related
to the events for which Plaintiffs' images were used as described in Plaintiffs' operative
Complaint.
4. All documents bearing any Plaintiffs' image, including subject Images and any other
images of Plaintiffs.
5. All policies of insurance for GULF COAST HOLDINGS, L.L.C. from February 1, 2017
to May 22,2019.
6. All employee handbooks, guidelines, or manuals of GULF COAST HOLDINGS, L.L.C.
that were in effect between January 1,2017 and May 30,2019.
7. All blank releases or waivers for employees, members, customers, performers, dancers,
and/or adult entertainersthat were in effect between January 1,2017 and May 30,2019.
8. All documents reflecting employees with knowledge of GULF COAST HOLDINGS,
L.L.C.'s marketing, advertising, and promotional practices between January 1, 2017 and
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May 30,2019, including their last known address, their dates of employment, if they are
no longer employed, and their position.
9. All documents that refer to, reflect, or evidence total gross profits for the last five (5)
years of GULF COAST HOLDINGS, L.L.C.
10. All documents that refer to, reflect, or evidence the amount of money spent on GULF
COAST HOLDINGS, L.L.C.'s website(s), social media accounts, print, advertising,
posters, videos, billboards, marquees, newspapers, flyers, or coupons for the last five (5)
years.
11. All documentsthat refer to, reflect, or evidence the payment of any monies by you to any
of the Plaintiffs related to the Images attached as Exhibits to Plaintiffs' operative
Complaint.
12. All correspondence between you or anyone acting on your behalf and Plaintiffs or anyone
on Plaintiffs' behalfregarding the claims, which are the subject ofthis lawsuit.
13. Any and all documents that refer to, reflect, or evidence that Plaintiffs are not entitled to
any compensation for your use oftheir Images.
14. Any and all documents concerning when, where, and how Plaintiffs' Images as depicted
in Plaintiffs' operative Complaint were first used in any of your marketing materials,
promotional materials, advertising materials, or products.
15. Any and all documents between you and any third party relating to the creation,
management, and/or maintenance o f all o f your social media accounts between January 1,
2017 and May 30, 2019.
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16. Any and all documents between you and any third party relating to the creation,
management, and/or maintenance of your websites between January 1, 2017 and May 30,
2019.
17. All contracts, assignments, agreements between you, your representatives, agents,
attorneys and any person or entity that has performed at GULF COAST HOLDINGS,
L.L.C. between January 1,2017 and May 30,2019.
18. All diagrams, photographs or videos taken or produced by you, your marketing team,
attorneys, representatives, agents or any person or entity on your behalf regarding and
related to the Images of Plaintiffs.
19. All photographs and videos depicting the interior of GULF COAST HOLDINGS, L.L.C.
between January 1, 2017 and May 30, 2019.
Dated: March 30,2021. Respectfully Submitted,
THE CASAS LAW FIRM, RC.
By: /s/ Ludmila Khomiak
Ludmila Khomiak, Esq.
Florida Bar No.. 91757
Brickell Bayview Center
80 S. W. 8th Street, Suite 2000
Miami, FL 33130
Phone: (786) 671-3244
Fax: (786) 671-3243
Attorney for Plaintiffs
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CERTIFICATE OF SERVICE
THE UNDERSIGNED HEREBY CERTIFIES that on March 30, 2021, the foregoing
document was electronically filed with the Clerk of the Court using the Florida Courts E-Filing
Portal and a true and correct copy of this document has been served on Defendant % David J.
Kurland, Esq., 850 Clearwater-Largo Road South, Largo, Florida 33770-4470
/s/Ludmila Khomiak
Ludmila Khomiak, Esq.
Florida Bar No.. 91757
The Casas Law Firm, RC.
Brickell Bayview Center 80 S.W. 8th Street, Suite 2000, Miami, FL 33130
-9-
Preview
Filing # 124041997 E-Filed 03/30/2021 04:29:21 PM IN THE CIRCUIT COURT OF THE 6TH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA MASHA'MALU' LUND; HILLARY FISHER VINSON a/k/a HILLARY HEPNER; LUCY PINDER; IRINAVORONINA; BROOKE MARR-IN 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 LADIES' & GENTLEMEN'S NIGHTCLUB, DEFENDANT. i PLAINTIFFS' FIRST REOUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT PLAINTIFFS, 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, (herein collectively referred to as "Plaintiffs" or "Models") by and through the undersigned counsel and pursuant to Rule 1.350 Florida Rules of Civil Procedure, request the DEFENDANT, GULF COAST HOLDINGS, L.L.C. d/b/a OZ THEE GENTLEMENS CLUB d/b/a OZ LADIES' & GENTLEMEN'S NIGHTCLUB (hereinafter referred to as "Oz" or "Defendant"),to produce the following documents: INSTRUCTIONS A. You are requested to produce all documents in your custody, possession and/or control, including all documents which are in the custody, possession and/or control of your employees, The Casas Law Firm, RC. Brickell Bayview Center 80 S.W. 8th Street, Suite 2000, Miami, FL 33130 -l- ***ELECTRONICALLYFILED 03/30/2021 04:29:20 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** attorneys, consultants, accountants, or agents, regardless ofthe location of such documents. B. If any document responsive to a specific request was, but no longer is, in your possession, custody or control, please identify that document and state whether any such document (a) is missing or lost; (b) has been destroyed; (c) has been transferred voluntarily or involuntarily; or (d) has been otherwise disposed of, and, in each instance, please explain in detail the circumstances surrounding any such disposition thereof. C. All documents are to be produced in or with their original file folders, file jackets, envelopes, or covers, and as they are kept in the usual course of business. D. In answering these requests for production you are required to furnish all information, documents and/or things that are available to you or subject to your reasonable inquiry, including information and things in the possession, custody or control of any of your representatives, including, without limitation, your attorneys, accountants, advisors, agents, or other persons directly or indirectly employed by or connected with you and anyone else otherwise subject to your control. E. Any document as to which a claim of privilege is or will be asserted should be identified by author, signatory, descr*tion (i. e.,letter, memo, telefax), title (if any), dates, addresses (if any), general subject matter, present location and custodian and a complete statement of the grounds for the claim of privilege should be set forth. DEFINITIONS A. The term "you" and "your" means the party or parties to which this request is addressed, including its divisions, departments, subsidiaries, affiliates, predecessors,present or former officers, directors, owners, agents, accountants, attorneys, and all other persons acting or purporting to act The Casas Law Firm, RC. Brickell Bayview Center 80 S.W. 8th Street, Suite 2000, Miami, FL 33130 -2- on its behalf, as well as each partnership in which it isa partner and any other person or trust entities in which you presently have or once had an interest, which partic*ated in, contributed to, or which have knowledge ofthe subject matter or facts encompassed in the operativeComplaint. B. The term "Defendant" means GULF COAST HOLDINGS, L.L.C. d/b/a OZ THEE GENTLEMENS CLUB d/b/a OZ LADIES' & GENTLEMEN'S NIGHTCLUB, including its agents, attorneys, accounts, and all other persons acting or purporting to act on its behalf. The term "Defendant" also includes the party's divisions departments, subsidiaries, affiliates, predecessors, present or former officers, directors, owners, agents, accountants, attorneys, and all other persons acting or purporting to act on its behalf. C. The term "Plaintiffs" means professional models 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. D. The term "related to", "relate to", or "refer to" means and includes mentioning, discussing, including summarizing, describing, reflecting, containing, referring to, relating to, depicting, connected with, embodying, evidencing, constituting, concerning, reporting, purporting, or involving an act, occurrence, event, transaction, fact, thing or course of dealing. E. The term "identify" when used in reference to: (a) a natural person means to provide the name(s), address(es), telephone number(s), and any other information necessary to locate such person for the purposes of service of subpoena to require attendance at any proceeding; (b) a person other than a natural person means to provide the name(s), address(es), telephonenumber(s), and type of entity of such person; The Casas Law Firm, RC. Brickell Bayview Center 80 S.W. 8th Street, Suite 2000, Miami, FL 33130 -3- (c) a document means to state its date, author, addressee, recipient, type of document, and to identify its present custodian. F. The term "communication" means any type of oral, written, or visual contact, between two or more persons in which information, facts or opinions were exchanged, imparted or received, including those facilitated by electronic transmission. G. The term "statement" means any oral, written, stenographic, or recorded declaration of any kind or description. H. The term "document" means and includes any kind of written, typewritten, printed, or recorded material whatsoever, regardless of the source or author thereof including, without limitation, any writing, filed for reporting or other purposes with any federal, state, or local agency, notes, memoranda, letters, telexes, telegrams, audited financial statements, unaudited interim financial statements, financial ledgers, stock ledgers for all forms and types of securities, minutes of directors, shareholders or committee meetings, written communications with directors and shareholders, inter-office communications, notices, circulates, bulletins, manuals, results of investigations, progress reports, studies made for business use, loan progress charts, requests for payment, any other financial reports, working papers, contracts, agreements, bills, books of account, vouchers, maps, plats, evaluations, drawings, plans, pictures, tape recordings, transcriptions of conversations of tape recordings, desk calendars, bank checks, invoices, charge slips, hotel charges, receipts, expense accounts, freight bills, statistical records, cost sheets, bids, abstracts of bids, journals, diaries, time sheets or logs, all computer-stored data, job or transaction files, permits or licenses or applications therefor, appointment books, The Casas Law Firm, RC. Brickell Bayview Center 80 S.W. 8th Street, Suite 2000, Miami, FL 33130 -4- books, records and copies, extracts and summaries or other documents, and drafts of any of the above, whether used or not, or any other writing or recording. I. The term "marketing material" refers to the collection of media used to support the sales or promotion of an establishment, product, or service. Marketing material includes brochures, flyers, advertisements, billboards, social media posts, website posts, sell sheets, follow-up mailers, white papers, newsletters, Web blogs, and/or any communicationintended to make the sale effort easier and more effective for the business or person disseminating the collection of media. .. jO The term "person means any natural person, firm, company, corporation, partnersh*, limited partnership, joint venture, or any other form of business entity. When the word .. "person is used in the singular, the same shall be construed to also be used in the plural. K. The term "imagels)" refers to any image, picture, photograph, likeness, or representation that has been used for promotional,selling, marketing or advertising purposes, including all Exhibits attached to Plaintiffs' operative Complaint and/or any other variation, alteration, rendition, or other use of Plaintiffs' images. L. The singular shall include the plural and vice versa; the terms "and," and "or," shall be both conjunctive and disjunctive; the term "including" means "including without .. limitation. M. The term "date" shall mean the exact date, month, and year, if ascertainable or, if not, the best approximation of the date (based upon relationship with other events). N. The term "agent" shall mean any agent, employee, officer, director, attorney, independent contractor or any other person acting under the direction of or on behalf of another. The Casas Law Firm, RC. Brickell Bayview Center 80 S.W. 8th Street, Suite 2000, Miami, FL 33130 -5- REOUEST FOR PRODUCTION TO DEFENDANT 1. All documents that refer to, reflect, or evidence any and all communications between you, or anyone acting on your behalf, and any other person related to the creation, distribution, or payment for the Images attached as Exhibits to Plaintiffs' operative Complaint. 2. All documents that refer to, reflect, or evidence any and all agreements between you, your representatives, agents, or anyone acting on your behalf, and any other person related to the creation, distribution, or payment for the Images attached as Exhibits to Plaintiffs' operative Complaint. 3. All reports, estimates, statements, invoices, bills, or receipts for earnings or profits related to the events for which Plaintiffs' images were used as described in Plaintiffs' operative Complaint. 4. All documents bearing any Plaintiffs' image, including subject Images and any other images of Plaintiffs. 5. All policies of insurance for GULF COAST HOLDINGS, L.L.C. from February 1, 2017 to May 22,2019. 6. All employee handbooks, guidelines, or manuals of GULF COAST HOLDINGS, L.L.C. that were in effect between January 1,2017 and May 30,2019. 7. All blank releases or waivers for employees, members, customers, performers, dancers, and/or adult entertainersthat were in effect between January 1,2017 and May 30,2019. 8. All documents reflecting employees with knowledge of GULF COAST HOLDINGS, L.L.C.'s marketing, advertising, and promotional practices between January 1, 2017 and The Casas Law Firm, RC. Brickell Bayview Center 80 S.W. 8th Street, Suite 2000, Miami, FL 33130 -6- May 30,2019, including their last known address, their dates of employment, if they are no longer employed, and their position. 9. All documents that refer to, reflect, or evidence total gross profits for the last five (5) years of GULF COAST HOLDINGS, L.L.C. 10. All documents that refer to, reflect, or evidence the amount of money spent on GULF COAST HOLDINGS, L.L.C.'s website(s), social media accounts, print, advertising, posters, videos, billboards, marquees, newspapers, flyers, or coupons for the last five (5) years. 11. All documentsthat refer to, reflect, or evidence the payment of any monies by you to any of the Plaintiffs related to the Images attached as Exhibits to Plaintiffs' operative Complaint. 12. All correspondence between you or anyone acting on your behalf and Plaintiffs or anyone on Plaintiffs' behalfregarding the claims, which are the subject ofthis lawsuit. 13. Any and all documents that refer to, reflect, or evidence that Plaintiffs are not entitled to any compensation for your use oftheir Images. 14. Any and all documents concerning when, where, and how Plaintiffs' Images as depicted in Plaintiffs' operative Complaint were first used in any of your marketing materials, promotional materials, advertising materials, or products. 15. Any and all documents between you and any third party relating to the creation, management, and/or maintenance o f all o f your social media accounts between January 1, 2017 and May 30, 2019. The Casas Law Firm, RC. Brickell Bayview Center 80 S.W. 8th Street, Suite 2000, Miami, FL 33130 -7- 16. Any and all documents between you and any third party relating to the creation, management, and/or maintenance of your websites between January 1, 2017 and May 30, 2019. 17. All contracts, assignments, agreements between you, your representatives, agents, attorneys and any person or entity that has performed at GULF COAST HOLDINGS, L.L.C. between January 1,2017 and May 30,2019. 18. All diagrams, photographs or videos taken or produced by you, your marketing team, attorneys, representatives, agents or any person or entity on your behalf regarding and related to the Images of Plaintiffs. 19. All photographs and videos depicting the interior of GULF COAST HOLDINGS, L.L.C. between January 1, 2017 and May 30, 2019. Dated: March 30,2021. Respectfully Submitted, THE CASAS LAW FIRM, RC. By: /s/ Ludmila Khomiak Ludmila Khomiak, Esq. Florida Bar No.. 91757 Brickell Bayview Center 80 S. W. 8th Street, Suite 2000 Miami, FL 33130 Phone: (786) 671-3244 Fax: (786) 671-3243 Attorney for Plaintiffs The Casas Law Firm, RC. Brickell Bayview Center 80 S.W. 8th Street, Suite 2000, Miami, FL 33130 -8- CERTIFICATE OF SERVICE THE UNDERSIGNED HEREBY CERTIFIES that on March 30, 2021, the foregoing document was electronically filed with the Clerk of the Court using the Florida Courts E-Filing Portal and a true and correct copy of this document has been served on Defendant % David J. Kurland, Esq., 850 Clearwater-Largo Road South, Largo, Florida 33770-4470 /s/Ludmila Khomiak Ludmila Khomiak, Esq. Florida Bar No.. 91757 The Casas Law Firm, RC. Brickell Bayview Center 80 S.W. 8th Street, Suite 2000, Miami, FL 33130 -9-