On August 30, 2018 a
Party Discovery
was filed
involving a dispute between
Cornerstone Technology Enterprises Inc,
and
Nvl Operations Llc,
for Circuit Civil
in the District Court of St. Lucie County.
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Filing # 98248152 E-Filed 11/01/2019 01:38:56 PM
IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT,
IN AND FOR ST. LUCIE COUNTY, FLORIDA
CASE NO.: 2018-CA-001610
CORNERSTONE TECHNOLOGY
ENTERPRISES, INC., a Colorado
Corporation,
Plaintiff,
vs.
NVL OPERATIONS, LLC,
a Foreign Limited Liability Company,
Defendant.
/
AMENDED NOTICE OF TAKING DEPOSITION DUCES TECUM IN AID OF EXECUTION
(As to date and time)
YOU are hereby notified that the undersigned will take the following deposition:
NAME: ALBERT HANNEMANN
DATE: December 11, 2019
TIME: 2:00 p.m. (Eastern Standard Time)
PLACE: Chase Litigation Services
Premier Workspaces
3655 Torrance Blvd., 3rd Floor
Torrance, CA 90503
Said deposition will be taken before Signature Court Reporting or any officer
authorized to administer oaths by the laws of the State of Florida, and a person who is
neither a relative, nor employee, nor attorney, nor counsel of any of the parities and
who is neither a relative nor employee or such attorney or counsel, and who is not
financially interested in the action.
Said deposition to be taken pursuant to the Florida Rules of Civil Procedure in
such cases provided. The said oral examination will continue from hour to hour andfrom day to day until completed and they are to have with them at that time and place,
the following:
1.
yn
SNMP
2
10.
11.
All Federal Tax Returns from 2015 through current date for NVL
Operations, LLC.
All Bank Statements for 2018 and 2019 for NVL Operations, LLC.
All the registrations and titles for all of the vehicles owned by the
Defendant.
All of the deeds for any real property owned by the Defendant.
All leases for any real property leased by the Defendant.
All equipment leases for property leased by the Defendant.
All cancelled checks for 2018 and 2019 for Defendant.
All documents regarding the sale or disposition of any assets in the
last 12 months by Defendant.
All applications for credit submitted on behalf of the Defendant for
2018 and 2019.
All statements of current accounts receivable for Defendant.
All records of payments to the shareholders of Defendant.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the foregoing was furnished
jamal tis _/ST day of bE 566 :
Via Email this sf day of , 2019 to: Albert Hannemann, 623 North Paulina
Avenue, Redondo Beach, CA 90277 ALB@thenvi.com.
ce: Signature
GLENN J. WEBBER, P.A.
Attorney for Plaintiff
101 SE Oc Boulevard, Suite 203
Webber, Esquire
ar No 356158
Courts@uisbberfl.com
Court Reporting
Scheduling@signaturecrs.com
Document Filed Date
November 01, 2019
Case Filing Date
August 30, 2018
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Filing # 98248152 E-Filed 11/01/2019 01:38:56 PM IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT, IN AND FOR ST. LUCIE COUNTY, FLORIDA CASE NO.: 2018-CA-001610 CORNERSTONE TECHNOLOGY ENTERPRISES, INC., a Colorado Corporation, Plaintiff, vs. NVL OPERATIONS, LLC, a Foreign Limited Liability Company, Defendant. / AMENDED NOTICE OF TAKING DEPOSITION DUCES TECUM IN AID OF EXECUTION (As to date and time) YOU are hereby notified that the undersigned will take the following deposition: NAME: ALBERT HANNEMANN DATE: December 11, 2019 TIME: 2:00 p.m. (Eastern Standard Time) PLACE: Chase Litigation Services Premier Workspaces 3655 Torrance Blvd., 3rd Floor Torrance, CA 90503 Said deposition will be taken before Signature Court Reporting or any officer authorized to administer oaths by the laws of the State of Florida, and a person who is neither a relative, nor employee, nor attorney, nor counsel of any of the parities and who is neither a relative nor employee or such attorney or counsel, and who is not financially interested in the action. Said deposition to be taken pursuant to the Florida Rules of Civil Procedure in such cases provided. The said oral examination will continue from hour to hour andfrom day to day until completed and they are to have with them at that time and place, the following: 1. yn SNMP 2 10. 11. All Federal Tax Returns from 2015 through current date for NVL Operations, LLC. All Bank Statements for 2018 and 2019 for NVL Operations, LLC. All the registrations and titles for all of the vehicles owned by the Defendant. All of the deeds for any real property owned by the Defendant. All leases for any real property leased by the Defendant. All equipment leases for property leased by the Defendant. All cancelled checks for 2018 and 2019 for Defendant. All documents regarding the sale or disposition of any assets in the last 12 months by Defendant. All applications for credit submitted on behalf of the Defendant for 2018 and 2019. All statements of current accounts receivable for Defendant. All records of payments to the shareholders of Defendant. CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the foregoing was furnished jamal tis _/ST day of bE 566 : Via Email this sf day of , 2019 to: Albert Hannemann, 623 North Paulina Avenue, Redondo Beach, CA 90277 ALB@thenvi.com. ce: Signature GLENN J. WEBBER, P.A. Attorney for Plaintiff 101 SE Oc Boulevard, Suite 203 Webber, Esquire ar No 356158 Courts@uisbberfl.com Court Reporting Scheduling@signaturecrs.com