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Filing # 69769148 E-Filed 03/26/2018 09:26:53 AM
IN THE CIRCUIT COURT OF THE 17™
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CIVIL DIVISION
CASE NO. CACE-18-000953
Division 04
PARK PLAZA REALTY CORP.,
Plaintiff,
Vv.
EDWARD REISS, as Trustee of PARK
CITY PLAZA TRUST,
Defendant.
AMENDED NOTICE OF TAKING DEPOSITION DUCES TECUM!
PLEASE TAKE NOTICE that the undersigned attorney or an attorney of the firm will take
the deposition of:
Name: Records Custodian of CenterState Bank, N.A.
Date: April 26, 2018
Time: 10:00 a.m.
Place: Fowler White Burnett, P.A.
Northbridge Centre
515 North Flagler Drive
Suite 2100
West Palm Beach, Florida 33401
upon oral examination before US LEGAL SUPPORT, Notary Public, or any other notary public
or officer authorized by law to take depositions in the State of Florida. The oral examination will
continue from day to day until completed. This deposition is being taken for the purpose of
' This Amended Notice is filed only to amend the service address on the attached subpoena,
FOWLER WHITE BURNETT P.A. * BRICKELL ARCH, 1395 BRICKELL AVENUE, 147 FLOOR, MIAMI, FLORIDA 33131 * (305) 789-9200
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 3/26/2018 9:26:53 AM.****CASE NO. 12-49303 CA 02
discovery, for use at trial, or for such other purposes as are permitted under the rules of the Court.
The deponent is to have with him at the above time and place the documents listed in the Subpoena
Duces Tecum for Deposition attached hereto.
This notice is provided pursuant to Administrative Order No. 2.207-1/15. In
accordance with the American with Disabilities Act, if you are a person with a
disability who needs any accommodation in order to participate in this
proceeding or program, you are entitled, at no cost to you, to the provision of
certain assistance. Please contact the ADA Coordinator in the Administrative
Offices of the Court, Palm Beach County Courthouse, Room, 5.2400, West
Palm Beach, Florida 33401 as far in advance as possible, but preferably at least
seven (7) working days before your scheduled court appearance or other court
activity; or immediately upon receiving your notification if the time before the
scheduled appearance is less than seven (7) working days; the telephone
number is 561-355-4380. If you are hearing or voice impaired, call 1-800-955-
8771, Fax is 561-656-7662, E-mail at ADA@pbcgov.org.
Respectfully submitted,
/s/ Juan C. Zorrilla
Juan C. Zorrilla
Fla. Bar No. 381403
Email: jzorrilla@fowler-white.com
FOWLER WHITE BURNETT, P.A.
Brickell Arch, Fourteenth Floor
1395 Brickell Avenue
Miami, Florida 33131
Telephone: (305) 789-9200
Facsimile: (305) 789-9201
-2-
FOWLER WHITE BURNETT P.A. * BRICKELL ARCH, 1395 BRICKELL AVENUE, 147 FLOOR, MIAMI, FLORIDA 33131 * (305) 789-9200CASE NO. 12-49303 CA 02
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via email this
26th day of March 2018 to Eric P. Stein, Esq., DocService@epslaw.com.
/s/ Juan C. Zorrilla
Juan C. Zorrilla
Fla. Bar No. 381403
-2-
FOWLER WHITE BURNETT P.A. * BRICKELL ARCH, 1395 BRICKELL AVENUE, 147 FLOOR, MIAMI, FLORIDA 33131 * (305) 789-9200IN THE CIRCUIT COURT OF THE 17™
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CIVIL DIVISION
CASE NO. CACE-18-000953
Division 04
PARK PLAZA REALTY CORP.,
Plaintiff,
Vv.
EDWARD REISS, as Trustee of PARK
CITY PLAZA TRUST,
Defendant.
SUBPOENA DUCES TECUM FOR DEPOSITION
THE STATE OF FLORIDA:
TO: Records Custodian of CenterState Bank, N.A.
1515 N Federal Hwy
Suite 100
Boca Raton, FL 33432
YOU ARE COMMANDED to appear before a person authorized by law to take
depositions at Fowler White Burnett, P.A., Northbridge Centre, 515 North Flagler Drive,
Suite 2100, West Palm Beach, Florida 33401, on April 26, 2018 at 10:00 a.m., for the taking of
your deposition in this action and to have with you at that time and place the items on the attached
Schedule "A.”
The items will be inspected and may be copied at that time. You will not be required to
surrender the original items. You have the right to object to the production pursuant to this
subpoena at any time before production by giving written notice to the attorney whose name
appears on this subpoena.
FOWLER WHITE BURNETT P.A. * BRICKELL ARCH, 1395 BRICKELL AVENUE, 147 FLOOR, MIAMI, FLORIDA 33131 * (305) 789-9200CASE NO. 12-49303 CA 02
If you fail to appear as specified or object to this subpoena, you may be in contempt
of court. You are subpoenaed by the attorney whose name appears on this subpoena and
unless excused from this subpoena by the attorney or the Court, you shall respond to this
subpoena as directed.
This notice is provided pursuant to Administrative Order No. 2.207-1/15. In
accordance with the American with Disabilities Act, if you are a person with a
disability who needs any accommodation in order to participate in this
proceeding or program, you are entitled, at no cost to you, to the provision of
certain assistance. Please contact the ADA Coordinator in the Administrative
Offices of the Court, Palm Beach County Courthouse, Room, 5.2400, West
Palm Beach, Florida 33401 as far in advance as possible, but preferably at least
seven (7) working days before your scheduled court appearance or other court
activity; or immediately upon receiving your notification if the time before the
scheduled appearance is less than seven (7) working days; the telephone
number is 561-355-4380. If you are hearing or voice impaired, call 1-800-955-
8771, Fax is 561-656-7662, E-mail at ADA@pbcgov.org.
DATED: March 26, 2018.
Juan C. Zorrilla, Esq.
for the Court
/s/ Juan C. Zorrilla
Juan C. Zorrilla, Esq.
Fla. Bar No. 381403
Email: jzorrilla@fowler-white.com
FOWLER WHITE BURNETT, P.A.
Brickell Arch, Fourteenth Floor
1395 Brickell Avenue
Miami, Florida 33131
Telephone: (305) 789-9200
Facsimile: (305) 789-9201
Attorneys for Plaintiff
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FOWLER WHITE BURNETT P.A. * BRICKELL ARCH, 1395 BRICKELL AVENUE, 147 FLOOR, MIAMI, FLORIDA 33131 * (305) 789-9200STATEMENT REGARDING THE DOCUMENTS SUBJECT TO THE SUBPOENA
The documents subject to the subpoena only relate to Green Light Enterprises, Inc.'s and/or
its principals’ request to CenterState Bank (the "Bank") for a loan in the amount of $2,200,000.00
(the "Loan") to purchase the property located at 8600-8630 SR 74 in Davie, Florida (the "Subject
Property"), the Bank's commitment letter dated November 1, 2017 (the "Commitment Letter") and
the Bank's review, evaluation and decision regarding the request for the loan.
DOCUMENTS TO BE PRODUCED
1. The application (or request for a loan) of Green Light Enterprises, Inc. and/or its
principals for a loan to finance the acquisition of the Subject Property.
2. The documents (including, but not limited to, correspondence, emails, facsimiles,
and text messages) reflecting communications between the Bank and Green Light Enterprises, Inc.
and/or its principals relating to the financial and other information the Bank required in order to
issue the Commitment Letter.
3. The documents (including the check or other payment method used) reflecting the
payment of the commitment fee for the loan.
4. The documents Green Light Enterprises, Inc. and/or its principals submitted to the
Bank to support the loan application prior to the date of the Commitment Letter.
5. A copy of any appraisal (including drafts thereof) provided to the Bank in
connection with the request for the Loan.
6. The documents (including any appraisal reviews) reflecting the Bank’s review and
approval of the appraisal(s).
7. The documents (including, but not limited to, correspondence, emails, facsimiles,
and text messages) reflecting communications between the Bank and the appraiser(s) or between
the Bank and Green Light Enterprises, Inc. regarding the appraisal(s).
SCHEDULE "A"
FOWLER WHITE BURNETT P.A. * BRICKELL ARCH, 1395 BRICKELL AVENUE, 147 FLOOR, MIAMI, FLORIDA 33131 * (305) 789-9200CASE NO. 12-49303 CA 02
8. A copy of any environmental assessment report (including drafts thereof) provided
to or obtained by the Bank in connection with the request for the Loan.
9. The documents reflecting the Bank’s review and approval of the environmental
assessment report(s).
10. The documents (including, but not limited to, correspondence, emails, facsimiles,
and text messages) reflecting communications between the Bank and the person(s) preparing the
environmental assessment report(s) or between the Bank and Green Light Enterprises, Inc.
regarding the environmental assessment report(s).
ll. A copy of any lease provided to the Bank in connection with the request for the
Loan.
12. The documents reflecting the Bank’s review and approval of the lease(s).
13. The documents (including, but not limited to, correspondence, emails, facsimiles,
and text messages) reflecting communications between the Bank and Green Light Enterprises, Inc.
regarding the lease(s).
14. The “financial statements as of 12/31/16” referred to in paragraph 14 of the
Commitment Letter (subject to a Confidentiality Stipulation or Confidentiality Order) provided to
the Bank.
15. The documents reflecting the “Bank’s receipt of 2014, 2015, and 2016 K-1
statements for the entities owned by Guarantors” required under Paragraph 14(h) of the
Commitment Letter.
16. | The documents (subject to a Confidentiality Stipulation or Confidentiality Order)
reflecting the Bank’s review and evaluation of the “financial statements as of 12/31/16,” the “2014,
2015, and 2016 K-1s,” or any financial information provided.
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FOWLER WHITE BURNETT P.A. * BRICKELL ARCH, 1395 BRICKELL AVENUE, 147 FLOOR, MIAMI, FLORIDA 33131 * (305) 789-9200CASE NO. 12-49303 CA 02
17. The documents (subject to a Confidentiality Stipulation or Confidentiality Order)
reflecting the communications (including, but not limited to, correspondence, emails, facsimiles,
and text messages) between the Bank and Green Light Enterprises, Inc. and/or its principals
regarding the financial information provided to and evaluated by the Bank.
18. The documents (subject to a Confidentiality Stipulation or Confidentiality Order)
reflecting the Bank’s review, evaluation, and approval of the loans (including, but not limited to,
minutes of meetings of any committee and/or Board of Directors of the Bank).
19. The documents reflecting the communications (including, but not limited to,
correspondence, emails, facsimiles, and text messages) between the Bank and Green Light
Enterprises, Inc. and/or its principals regarding the Bank's decision regarding the Loan.
20. The documents reflecting the communications (including, but not limited to,
correspondence, emails, facsimiles, and text messages) between the Bank and Green Light
Enterprises, Inc. and/or its principals regarding the Bank’s review and approval of the conditions
precedent set forth in paragraphs 11, 12, 13, 14(b), 14(g), and 14(h) of the Bank's Commitment
Letter.
-3-
FOWLER WHITE BURNETT P.A. * BRICKELL ARCH, 1395 BRICKELL AVENUE, 147 FLOOR, MIAMI, FLORIDA 33131 * (305) 789-9200
Preview
Filing # 69769148 E-Filed 03/26/2018 09:26:53 AM IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIVIL DIVISION CASE NO. CACE-18-000953 Division 04 PARK PLAZA REALTY CORP., Plaintiff, Vv. EDWARD REISS, as Trustee of PARK CITY PLAZA TRUST, Defendant. AMENDED NOTICE OF TAKING DEPOSITION DUCES TECUM! PLEASE TAKE NOTICE that the undersigned attorney or an attorney of the firm will take the deposition of: Name: Records Custodian of CenterState Bank, N.A. Date: April 26, 2018 Time: 10:00 a.m. Place: Fowler White Burnett, P.A. Northbridge Centre 515 North Flagler Drive Suite 2100 West Palm Beach, Florida 33401 upon oral examination before US LEGAL SUPPORT, Notary Public, or any other notary public or officer authorized by law to take depositions in the State of Florida. The oral examination will continue from day to day until completed. This deposition is being taken for the purpose of ' This Amended Notice is filed only to amend the service address on the attached subpoena, FOWLER WHITE BURNETT P.A. * BRICKELL ARCH, 1395 BRICKELL AVENUE, 147 FLOOR, MIAMI, FLORIDA 33131 * (305) 789-9200 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 3/26/2018 9:26:53 AM.****CASE NO. 12-49303 CA 02 discovery, for use at trial, or for such other purposes as are permitted under the rules of the Court. The deponent is to have with him at the above time and place the documents listed in the Subpoena Duces Tecum for Deposition attached hereto. This notice is provided pursuant to Administrative Order No. 2.207-1/15. In accordance with the American with Disabilities Act, if you are a person with a disability who needs any accommodation in order to participate in this proceeding or program, you are entitled, at no cost to you, to the provision of certain assistance. Please contact the ADA Coordinator in the Administrative Offices of the Court, Palm Beach County Courthouse, Room, 5.2400, West Palm Beach, Florida 33401 as far in advance as possible, but preferably at least seven (7) working days before your scheduled court appearance or other court activity; or immediately upon receiving your notification if the time before the scheduled appearance is less than seven (7) working days; the telephone number is 561-355-4380. If you are hearing or voice impaired, call 1-800-955- 8771, Fax is 561-656-7662, E-mail at ADA@pbcgov.org. Respectfully submitted, /s/ Juan C. Zorrilla Juan C. Zorrilla Fla. Bar No. 381403 Email: jzorrilla@fowler-white.com FOWLER WHITE BURNETT, P.A. Brickell Arch, Fourteenth Floor 1395 Brickell Avenue Miami, Florida 33131 Telephone: (305) 789-9200 Facsimile: (305) 789-9201 -2- FOWLER WHITE BURNETT P.A. * BRICKELL ARCH, 1395 BRICKELL AVENUE, 147 FLOOR, MIAMI, FLORIDA 33131 * (305) 789-9200CASE NO. 12-49303 CA 02 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via email this 26th day of March 2018 to Eric P. Stein, Esq., DocService@epslaw.com. /s/ Juan C. Zorrilla Juan C. Zorrilla Fla. Bar No. 381403 -2- FOWLER WHITE BURNETT P.A. * BRICKELL ARCH, 1395 BRICKELL AVENUE, 147 FLOOR, MIAMI, FLORIDA 33131 * (305) 789-9200IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIVIL DIVISION CASE NO. CACE-18-000953 Division 04 PARK PLAZA REALTY CORP., Plaintiff, Vv. EDWARD REISS, as Trustee of PARK CITY PLAZA TRUST, Defendant. SUBPOENA DUCES TECUM FOR DEPOSITION THE STATE OF FLORIDA: TO: Records Custodian of CenterState Bank, N.A. 1515 N Federal Hwy Suite 100 Boca Raton, FL 33432 YOU ARE COMMANDED to appear before a person authorized by law to take depositions at Fowler White Burnett, P.A., Northbridge Centre, 515 North Flagler Drive, Suite 2100, West Palm Beach, Florida 33401, on April 26, 2018 at 10:00 a.m., for the taking of your deposition in this action and to have with you at that time and place the items on the attached Schedule "A.” The items will be inspected and may be copied at that time. You will not be required to surrender the original items. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena. FOWLER WHITE BURNETT P.A. * BRICKELL ARCH, 1395 BRICKELL AVENUE, 147 FLOOR, MIAMI, FLORIDA 33131 * (305) 789-9200CASE NO. 12-49303 CA 02 If you fail to appear as specified or object to this subpoena, you may be in contempt of court. You are subpoenaed by the attorney whose name appears on this subpoena and unless excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as directed. This notice is provided pursuant to Administrative Order No. 2.207-1/15. In accordance with the American with Disabilities Act, if you are a person with a disability who needs any accommodation in order to participate in this proceeding or program, you are entitled, at no cost to you, to the provision of certain assistance. Please contact the ADA Coordinator in the Administrative Offices of the Court, Palm Beach County Courthouse, Room, 5.2400, West Palm Beach, Florida 33401 as far in advance as possible, but preferably at least seven (7) working days before your scheduled court appearance or other court activity; or immediately upon receiving your notification if the time before the scheduled appearance is less than seven (7) working days; the telephone number is 561-355-4380. If you are hearing or voice impaired, call 1-800-955- 8771, Fax is 561-656-7662, E-mail at ADA@pbcgov.org. DATED: March 26, 2018. Juan C. Zorrilla, Esq. for the Court /s/ Juan C. Zorrilla Juan C. Zorrilla, Esq. Fla. Bar No. 381403 Email: jzorrilla@fowler-white.com FOWLER WHITE BURNETT, P.A. Brickell Arch, Fourteenth Floor 1395 Brickell Avenue Miami, Florida 33131 Telephone: (305) 789-9200 Facsimile: (305) 789-9201 Attorneys for Plaintiff -2- FOWLER WHITE BURNETT P.A. * BRICKELL ARCH, 1395 BRICKELL AVENUE, 147 FLOOR, MIAMI, FLORIDA 33131 * (305) 789-9200STATEMENT REGARDING THE DOCUMENTS SUBJECT TO THE SUBPOENA The documents subject to the subpoena only relate to Green Light Enterprises, Inc.'s and/or its principals’ request to CenterState Bank (the "Bank") for a loan in the amount of $2,200,000.00 (the "Loan") to purchase the property located at 8600-8630 SR 74 in Davie, Florida (the "Subject Property"), the Bank's commitment letter dated November 1, 2017 (the "Commitment Letter") and the Bank's review, evaluation and decision regarding the request for the loan. DOCUMENTS TO BE PRODUCED 1. The application (or request for a loan) of Green Light Enterprises, Inc. and/or its principals for a loan to finance the acquisition of the Subject Property. 2. The documents (including, but not limited to, correspondence, emails, facsimiles, and text messages) reflecting communications between the Bank and Green Light Enterprises, Inc. and/or its principals relating to the financial and other information the Bank required in order to issue the Commitment Letter. 3. The documents (including the check or other payment method used) reflecting the payment of the commitment fee for the loan. 4. The documents Green Light Enterprises, Inc. and/or its principals submitted to the Bank to support the loan application prior to the date of the Commitment Letter. 5. A copy of any appraisal (including drafts thereof) provided to the Bank in connection with the request for the Loan. 6. The documents (including any appraisal reviews) reflecting the Bank’s review and approval of the appraisal(s). 7. The documents (including, but not limited to, correspondence, emails, facsimiles, and text messages) reflecting communications between the Bank and the appraiser(s) or between the Bank and Green Light Enterprises, Inc. regarding the appraisal(s). SCHEDULE "A" FOWLER WHITE BURNETT P.A. * BRICKELL ARCH, 1395 BRICKELL AVENUE, 147 FLOOR, MIAMI, FLORIDA 33131 * (305) 789-9200CASE NO. 12-49303 CA 02 8. A copy of any environmental assessment report (including drafts thereof) provided to or obtained by the Bank in connection with the request for the Loan. 9. The documents reflecting the Bank’s review and approval of the environmental assessment report(s). 10. The documents (including, but not limited to, correspondence, emails, facsimiles, and text messages) reflecting communications between the Bank and the person(s) preparing the environmental assessment report(s) or between the Bank and Green Light Enterprises, Inc. regarding the environmental assessment report(s). ll. A copy of any lease provided to the Bank in connection with the request for the Loan. 12. The documents reflecting the Bank’s review and approval of the lease(s). 13. The documents (including, but not limited to, correspondence, emails, facsimiles, and text messages) reflecting communications between the Bank and Green Light Enterprises, Inc. regarding the lease(s). 14. The “financial statements as of 12/31/16” referred to in paragraph 14 of the Commitment Letter (subject to a Confidentiality Stipulation or Confidentiality Order) provided to the Bank. 15. The documents reflecting the “Bank’s receipt of 2014, 2015, and 2016 K-1 statements for the entities owned by Guarantors” required under Paragraph 14(h) of the Commitment Letter. 16. | The documents (subject to a Confidentiality Stipulation or Confidentiality Order) reflecting the Bank’s review and evaluation of the “financial statements as of 12/31/16,” the “2014, 2015, and 2016 K-1s,” or any financial information provided. -2- FOWLER WHITE BURNETT P.A. * BRICKELL ARCH, 1395 BRICKELL AVENUE, 147 FLOOR, MIAMI, FLORIDA 33131 * (305) 789-9200CASE NO. 12-49303 CA 02 17. The documents (subject to a Confidentiality Stipulation or Confidentiality Order) reflecting the communications (including, but not limited to, correspondence, emails, facsimiles, and text messages) between the Bank and Green Light Enterprises, Inc. and/or its principals regarding the financial information provided to and evaluated by the Bank. 18. The documents (subject to a Confidentiality Stipulation or Confidentiality Order) reflecting the Bank’s review, evaluation, and approval of the loans (including, but not limited to, minutes of meetings of any committee and/or Board of Directors of the Bank). 19. The documents reflecting the communications (including, but not limited to, correspondence, emails, facsimiles, and text messages) between the Bank and Green Light Enterprises, Inc. and/or its principals regarding the Bank's decision regarding the Loan. 20. The documents reflecting the communications (including, but not limited to, correspondence, emails, facsimiles, and text messages) between the Bank and Green Light Enterprises, Inc. and/or its principals regarding the Bank’s review and approval of the conditions precedent set forth in paragraphs 11, 12, 13, 14(b), 14(g), and 14(h) of the Bank's Commitment Letter. -3- FOWLER WHITE BURNETT P.A. * BRICKELL ARCH, 1395 BRICKELL AVENUE, 147 FLOOR, MIAMI, FLORIDA 33131 * (305) 789-9200