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Filing # 100979230 E-Filed 12/31/2019 01:28:45 PM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
CHARLOTTE COUNTY, FLORIDA
HARRY BIEBERSTEIN,
Plaintiff,
Vv. Case No. 17-CA-917
GABRIEL KIRCHBERGER, CAROL
DEVILLE, SOUTHERN SHORES
ENTERPRISES, LLC, a Florida limited liability
company, and MOONSTONE HOLDINGS, LLC,
a Nevada limited liability company,
Defendants.
/
PROPOSED INTERVENORS, WALFRE AND NORA MONRROY’S
RESPONSE TO PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS
Proposed Intervenors, Walfre Monrroy and Nora Monrroy, by and through undersigned
counsel submit this response to Plaintiff, Harry Bieberstein’s First Request for Admissions to
Proposed Intervenors and state as follows:
1 Admitted that Plaintiff recorded a Notice of Lis Pendens; however, Denied that
Plaintiff was entitled to do so.
2 Admitted
3 Admitted.
4 Admitted.
5 Admitted; however, Denied that Proposed Intervenors were required to do so
based on their lack of knowiedge, notification or service of the complaint and/or lis pendens filed
and recorded in the instant action.
6 Denied.
7 Denied.
8 Admitted that the Warranty Deed transferring interest in the real property located
at 22243 Catherine Avenue, Port Charlotte, Florida 33952 was recorded on or about June 27,
2019; however, Denied as to the remaining allegations.
9 Admitted that Proposed Intervenors may have a claim against Moonstone
Holdings, LLC; however, Denied that this has any bearing on Proposed Intervenors’ status as
bona fide purchasers of the subject real property.
10. Admitted that Proposed Intervenors may have a claim against Moonstone
Holdings, LLC; however, Denied that this has any bearing on Proposed Intervenors’ status as
bona fide purchasers of the subject real property.
11. Admitted that Proposed Intervenors may have a claim against Moonstone
Holdings, LLC; however, Denied that this has any bearing on Proposed Intervenors’ status as
bona fide purchasers of the subject real property.
12. Admitted that Proposed Intervenors may have a claim against Moonstone
Holdings, LLC; however, Denied that this has any bearing on Proposed Intervenors’ status as
bona fide purchasers of the subject real property.
13. Proposed Intervenors can neither admit nor deny, The requested information is
subject to privacy and not relevant to the pending claims in the instant action.
14, Admitted that Proposed Intervenors received a title commitment on or about May
27, 2019.
15. Denied.
16. Proposed Intervenors can neither admit nor deny. The requested information is
subject to privacy and not relevant to the pending claims in the instant action.
bit el cee
Kristina Hager Snyderman, Esq.
Florida Bar No. 0089237
BARNES WALKER, GOETHE,
PERRON & SHEA, PLLC
3119 Manatee Avenue West
Bradenton, Florida 34205
ksnyderman@barneswalker.com — Primary
mfuller@barneswalker.com — Secondary
(941) 741-8224 - Telephone
(941) 741-8225 — Facsimile
CERTIFICATE OF SERVICE
I hereby certify that the foregoing document was electronically filed with the Clerk of
Circuit Court using the Florida Courts E-Filing Portal and served on all counsel of record via the
Portal, including Robert Segur, Esq., 2828 S McCall Rd, Pmb 56, Englewood, FL 34224, Ryan
Owen, Esq., 1515 Ringling Blvd., Ste. 700, Sarasota, FL 34236, David Oaks, Esq., 407 E Marion
Ave., Unit 101, Punta Gorda, FL 33950, Glenn Siegel, Esq., 17825 Murdock Cir., Unit A, Port
Charlotte, FL 33948, Christopher Klein, Esq., 100 Biscayne Blvd., Fl. 21, Miami, FL 33132,
which constitutes compliance with service requirements of Fla. R. Jud. Admin. 2.516, on this 31*
day of December, 2019.
ye
i
FULL lil { ult
Kristina Hager Snyderman, Esq.
Robert Segur, Esq.
Law Offices of Robert W. Segur, P.A.
Robert W. Segur, P.A.
2828 S McCall Rd, Pmb 56
Englewood, FL 34224-4869
Office: 941-473-8878
Fax: 941-473-8890
legai@segurlaw.net
Ryan Owen, Esq.
Adams and Reese LLP
1515 Ringling Blvd., Ste. 700
Sarasota, FL 34236-6720
Office: 941-316-7600
ryan.owen@arlaw.com
David Oaks, Esq.
David K. Oaks, P.A.
407 E Marion Ave., Unit 101
Punta Gorda, FL 33950-3801
Office: 941-639-7627
Fax: 941-575-0242
Email: doaksesq@comcast.net
Glenn Siegel, Esq.
Glenn N. Siegel, P.A.
17825 Murdock Cir., Unit A
Port Charlotte, FL 33948-4090
Office: 941-255-1235
Fax: 941-255-1223
gsiegel@glennsiegellaw.com.
Christopher Klein, Esq.
Baur & Klein, P.A.
100 Biscayne Blvd., Fl. 21
Miami, FL 33132-2304
Office: 305-377-3561
Fax: 305-371-4380
cklein@worldwidelaw.com
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Filing # 100979230 E-Filed 12/31/2019 01:28:45 PM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT CHARLOTTE COUNTY, FLORIDA HARRY BIEBERSTEIN, Plaintiff, Vv. Case No. 17-CA-917 GABRIEL KIRCHBERGER, CAROL DEVILLE, SOUTHERN SHORES ENTERPRISES, LLC, a Florida limited liability company, and MOONSTONE HOLDINGS, LLC, a Nevada limited liability company, Defendants. / PROPOSED INTERVENORS, WALFRE AND NORA MONRROY’S RESPONSE TO PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS Proposed Intervenors, Walfre Monrroy and Nora Monrroy, by and through undersigned counsel submit this response to Plaintiff, Harry Bieberstein’s First Request for Admissions to Proposed Intervenors and state as follows: 1 Admitted that Plaintiff recorded a Notice of Lis Pendens; however, Denied that Plaintiff was entitled to do so. 2 Admitted 3 Admitted. 4 Admitted. 5 Admitted; however, Denied that Proposed Intervenors were required to do so based on their lack of knowiedge, notification or service of the complaint and/or lis pendens filed and recorded in the instant action. 6 Denied. 7 Denied. 8 Admitted that the Warranty Deed transferring interest in the real property located at 22243 Catherine Avenue, Port Charlotte, Florida 33952 was recorded on or about June 27, 2019; however, Denied as to the remaining allegations. 9 Admitted that Proposed Intervenors may have a claim against Moonstone Holdings, LLC; however, Denied that this has any bearing on Proposed Intervenors’ status as bona fide purchasers of the subject real property. 10. Admitted that Proposed Intervenors may have a claim against Moonstone Holdings, LLC; however, Denied that this has any bearing on Proposed Intervenors’ status as bona fide purchasers of the subject real property. 11. Admitted that Proposed Intervenors may have a claim against Moonstone Holdings, LLC; however, Denied that this has any bearing on Proposed Intervenors’ status as bona fide purchasers of the subject real property. 12. Admitted that Proposed Intervenors may have a claim against Moonstone Holdings, LLC; however, Denied that this has any bearing on Proposed Intervenors’ status as bona fide purchasers of the subject real property. 13. Proposed Intervenors can neither admit nor deny, The requested information is subject to privacy and not relevant to the pending claims in the instant action. 14, Admitted that Proposed Intervenors received a title commitment on or about May 27, 2019. 15. Denied. 16. Proposed Intervenors can neither admit nor deny. The requested information is subject to privacy and not relevant to the pending claims in the instant action. bit el cee Kristina Hager Snyderman, Esq. Florida Bar No. 0089237 BARNES WALKER, GOETHE, PERRON & SHEA, PLLC 3119 Manatee Avenue West Bradenton, Florida 34205 ksnyderman@barneswalker.com — Primary mfuller@barneswalker.com — Secondary (941) 741-8224 - Telephone (941) 741-8225 — Facsimile CERTIFICATE OF SERVICE I hereby certify that the foregoing document was electronically filed with the Clerk of Circuit Court using the Florida Courts E-Filing Portal and served on all counsel of record via the Portal, including Robert Segur, Esq., 2828 S McCall Rd, Pmb 56, Englewood, FL 34224, Ryan Owen, Esq., 1515 Ringling Blvd., Ste. 700, Sarasota, FL 34236, David Oaks, Esq., 407 E Marion Ave., Unit 101, Punta Gorda, FL 33950, Glenn Siegel, Esq., 17825 Murdock Cir., Unit A, Port Charlotte, FL 33948, Christopher Klein, Esq., 100 Biscayne Blvd., Fl. 21, Miami, FL 33132, which constitutes compliance with service requirements of Fla. R. Jud. Admin. 2.516, on this 31* day of December, 2019. ye i FULL lil { ult Kristina Hager Snyderman, Esq. Robert Segur, Esq. Law Offices of Robert W. Segur, P.A. Robert W. Segur, P.A. 2828 S McCall Rd, Pmb 56 Englewood, FL 34224-4869 Office: 941-473-8878 Fax: 941-473-8890 legai@segurlaw.net Ryan Owen, Esq. Adams and Reese LLP 1515 Ringling Blvd., Ste. 700 Sarasota, FL 34236-6720 Office: 941-316-7600 ryan.owen@arlaw.com David Oaks, Esq. David K. Oaks, P.A. 407 E Marion Ave., Unit 101 Punta Gorda, FL 33950-3801 Office: 941-639-7627 Fax: 941-575-0242 Email: doaksesq@comcast.net Glenn Siegel, Esq. Glenn N. Siegel, P.A. 17825 Murdock Cir., Unit A Port Charlotte, FL 33948-4090 Office: 941-255-1235 Fax: 941-255-1223 gsiegel@glennsiegellaw.com. Christopher Klein, Esq. Baur & Klein, P.A. 100 Biscayne Blvd., Fl. 21 Miami, FL 33132-2304 Office: 305-377-3561 Fax: 305-371-4380 cklein@worldwidelaw.com