On January 16, 2018 a
Ex Parte Motion - TO COMPEL DISCOVERY RESPONSESParty: Plaintiff Impact Site Development of Florida LLC
was filed
involving a dispute between
Impact Site Development Of Florida Llc,
and
Constrology Llc,
Pp Omni Ventures Llc,
for Contract and Indebtedness
in the District Court of Broward County.
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Filing # 70864439 E-Filed 04/18/2018 09:23:53 AM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CASENO: — 18-001120-CACE-21
IMPACT SITE DEVELOPMENT
OF FLORIDA, LLC, a Florida limited
liability company,
Plaintiff,
v.
CONSTROLOGY, LLC, a Florida
limited liability company, and
PP OMNI VENTURES, LLC, a Florida
limited liability company,
Defendants.
IMPACT SITE DEVELOPMENT OF FLORIDA, LLC’S
EX PARTE MOTION TO COMPEL DISCOVERY RESPONSES FROM
CONSTROLOGY, LLC
Plaintiff, Impact Site Development of Florida, LLC (“Impact”), pursuant to Florida Rule
of Civil Procedure 1.370 and Local Rule 10A, requests that that this Court enter an Order
compelling Defendant, Constrology, LLC to respond to discovery within 10 days and states:
1. On March 12, 2018, Plaintiff served its Request for Admissions, First Set of
Interrogatories and Request for Production upon Defendant, Constrology, LLC (“Constrology”).
2. To date, Wells Fargo has completely failed to respond or object to said discovery.
WHEREFORE, for the reasons set forth above, Plaintiff, Impact Site Development of
Florida, LLC, respectfully requests that this Court compel Defendant, Constrology, LLC to
provide complete answers to Plaintiff's outstanding discovery within ten (10) days of the date of
the Order and provide such other and further relief as the Court deems just and proper.
*** FILED: BROWARD COUNTY. FL BRENDA D. FORMAN, CLERK 4/18/2018 9:23:53 AM.****CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on April 18, 2018, a true and correct copy of the foregoing was
filed electronically using the Court’s electronic filing system, which will send notice and a copy
of this filing to all counsel of record listed in the Florida Courts E-Filing Portal.
Respectfully submitted,
4s/ Michael J. Friedman
Michael J, Friedman
Florida Bar No. 650854
Nicole D. Moss
Florida Bar No. 1003075
Vezina, Lawrence & Piscitelli, P.A.
The Museum Building
300 SW First Avenue, Suite 150
Fort Lauderdale, Florida 33301
Telephone: (954) 728-1270
Facsimile: (954) 728-1271
mfriedman@vlplaw.com
ndowneymoss@vlIplaw.com
kmefadden@vlplaw.com
ealvarado@vlplaw.com
Attorneys for Impact Site Development
of Florida, LLC
Document Filed Date
April 18, 2018
Case Filing Date
January 16, 2018
Category
Contract and Indebtedness
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Filing # 70864439 E-Filed 04/18/2018 09:23:53 AM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASENO: — 18-001120-CACE-21 IMPACT SITE DEVELOPMENT OF FLORIDA, LLC, a Florida limited liability company, Plaintiff, v. CONSTROLOGY, LLC, a Florida limited liability company, and PP OMNI VENTURES, LLC, a Florida limited liability company, Defendants. IMPACT SITE DEVELOPMENT OF FLORIDA, LLC’S EX PARTE MOTION TO COMPEL DISCOVERY RESPONSES FROM CONSTROLOGY, LLC Plaintiff, Impact Site Development of Florida, LLC (“Impact”), pursuant to Florida Rule of Civil Procedure 1.370 and Local Rule 10A, requests that that this Court enter an Order compelling Defendant, Constrology, LLC to respond to discovery within 10 days and states: 1. On March 12, 2018, Plaintiff served its Request for Admissions, First Set of Interrogatories and Request for Production upon Defendant, Constrology, LLC (“Constrology”). 2. To date, Wells Fargo has completely failed to respond or object to said discovery. WHEREFORE, for the reasons set forth above, Plaintiff, Impact Site Development of Florida, LLC, respectfully requests that this Court compel Defendant, Constrology, LLC to provide complete answers to Plaintiff's outstanding discovery within ten (10) days of the date of the Order and provide such other and further relief as the Court deems just and proper. *** FILED: BROWARD COUNTY. FL BRENDA D. FORMAN, CLERK 4/18/2018 9:23:53 AM.****CERTIFICATE OF SERVICE I HEREBY CERTIFY that on April 18, 2018, a true and correct copy of the foregoing was filed electronically using the Court’s electronic filing system, which will send notice and a copy of this filing to all counsel of record listed in the Florida Courts E-Filing Portal. Respectfully submitted, 4s/ Michael J. Friedman Michael J, Friedman Florida Bar No. 650854 Nicole D. Moss Florida Bar No. 1003075 Vezina, Lawrence & Piscitelli, P.A. The Museum Building 300 SW First Avenue, Suite 150 Fort Lauderdale, Florida 33301 Telephone: (954) 728-1270 Facsimile: (954) 728-1271 mfriedman@vlplaw.com ndowneymoss@vlIplaw.com kmefadden@vlplaw.com ealvarado@vlplaw.com Attorneys for Impact Site Development of Florida, LLC