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Filing # 103333918 E-Filed 02/14/2020 12:40:18 PM
IN THE CIRCUIT COURT OF THE 17%
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
ATX MCA FUND I, LLC., CASE NO, CACE-19-026641
Plaintiff,
VS.
SEASONS RETAIL CONCEPTS, INC d/b/a
SEASONS RETAIL CONCEPTS,
and VALERIE E, PEREZ, individually,
Defendants.
E ‘CES TE E
TO: VALERIE E. PEREZ, Individually
5701 Sunsewt Drive, Apt. 286
South Miami, FL 33143
EVANGELIS NUNEZ as the President of SEASONS RETAIL CONCEPTS, INC d/b/a SEASONS
RETAIL CONCEPTS
13465 NW 19TH Lane
Miami, FL 33182
PLEASE TAKE NOTICE THAT on April 2, 2020 at 12:30 p.m., Plaintiff's Attorney in the above-styled cause
will take the deposition by oral examination in aid of execution of VALERIE E. PEREZ, Individually who shall bring
with her those documents and things on the attached Addendum.
PLEASE TAKE NOTICE THAT on April 2, 2020 at 1:00 p.m., Plaintiff's Attorney in the above-styled cause
will take the deposition by oral examination in aid of execution of EVANGELIS NUNEZ as the President of
SEASONS RETAIL CONCEPTS, INC d/b/a SEASONS RETAIL CONCEPTS who shall bring with her those
documents and things on the attached Addendum.
Said deposition will be taken before Esquire Deposition Solution at Emanuel & Zwiebel, PLLC, 7900 Peters
Road, Executive Court at Jacaranda, Building B, Suite 100, Plantation, FL 33324 or any other 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 parties and who is neither a relative nor employee of such attorney or counsel, and who is not
financially interested in this 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 and from day to day until completed,
THEREBY CERTIFY that a copy of the above Notice of was furnished to the named addressee(s) by mail this
y day of February, 2020.
EMANUEL & ZWIEBEL, PLLC
Executive Coury at Jacaranda
'
ERIC B. ZWIEBEL, ESQ. i
FBN. 476404
co: Esquire Deposition Solution
* PLEASE ADVISE IF AN INTERPRETER IS NECESSARY
* POR FAVOR NOTIFIQUENOS CON ANTERIORIDAD SI NECESITA UN INTERPRETE EN
ESPANOL.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/14/2020 12:40:19 PM.****ADDENDUM TO SUBPOENA DUCES TECUM FOR DOCUMENTS.
PERTAINING TO A CORPORATION
YOU ARE HEREBY REQUIRED TO BRING WITH YOU AND PRODUCE FOR INSPECTION AND/OR
PHOTOCOPYING THE FOLLOWING:
1.
Copies of income tax returns for the past 3 calendar years of the corporation known as SEASONS RETAIL.
CONCEPTS, INC d/b/a SEASONS RETAIL CONCEPTS
Income tax records for the current tax year, and copies of any estimated income tax returns filed for the current
year of the corporation.
All business bank statements, including canceled checks, for the 12 months immediately preceding the date of
the scheduled deposition.
All business accounts receivable ledgers for the 12 months immediately preceding the date of the scheduled
deposition.
All business accounts payable ledgers for the 12 months immediately preceding the date of the scheduled
deposition.
All deeds, leases, mortgages, or other written instruments evidencing an interest in or ownership ofreal property
at any time within the 24 months immediately preceding the date of this notice.
Bills of sale or other written evidence of any personal or real property purchased or sold during the 24 months
immediately preceding the date of the scheduled deposition,
Motor vehicle documents relating to any motor vehicles owned by the corporation including, but not limited
to, registrations and title certificates, during the last five (5) years from the date of the scheduled deposition.
Any and all financial statements as to the corporation's business assets and liabilities, prepared for or by the
corporation, within the last five (5) years from the date of the scheduled deposition.
Current schedule of all business furniture subject to lien,
Schedule of all business furniture, fixtures, furnishings, and equipment owned by the corporation as of the date
of the scheduled deposition.
All stock certificates or other evidence of ownership of stocks and bonds held by the corporation, including
copies of any stock brokerage accounts maintained in the 24 months immediately preceding the date of the
scheduled deposition.
All policies of insurance owned by the corporation, regardless of the insured or beneficiary.
Copies of all contracts on which the corporation is now performing services or rendering materials, or on which
someone is indebted to the corporation for services or materials already furnished.
Names and addresses of all employees who have worked for the corporation during the 12 months immediately
preceding the date of the scheduled deposition.
Copies of all litigation or settlement documents to which the corporation is now a party, or has been a party,
whether as plaintiff or defendant, during the 24 months immediately preceding the date of the scheduled
deposition.
‘Names and addresses of all corporate officers and directors, past and present.
Names and addresses of al! stockholders in the corporation and the number of shares owned by each,ADDENDUM TO SUBPOENA DUCES TECUM FOR DOCUMENTS
PERTAINING TO INDIVIDUALS
YOU ARE HEREBY REQUIRED TO BRING WITH YOU AND PRODUCE FOR INSPECTION AND/OR
PHOTOCOPYING THE FOLLOWING:
1,
10,
12,
13.
14,
18.
19.
20.
Any and all documents and records of checking, savings, brokerage, or any other type of account, foreign or
domestic, maintained by you with any type of financial institution, including brokerages, during the last five
years, including but not limited to monthly account statements, checks, check registers, check stubs, cancelled
checks, and deposit slips.
All documents that refer to, relate to, reflect or concern any transfers made to or from any financial account held
for your benefit, by any third party, for the last five years,
Any and all signature cards that name you as an authorized signatory on any financial account, for any entity
or other third party, for the past five years,
Any and all documents submitted to any bank financial institution or any other person or entity, by yourself for
any loan or advance in any capacity (borrower, guarantor, or surety) for the past five years.
Any and all documents concerning any interest in, or claimed title to, any certificates of deposits, letters of
credit, money orders, cashier’s checks, traveler’s checks, bank deposits or escrow funds owned or held by you
in the past five years.
Any and all documents related to any account in which any of your earnings or other income have been.
deposited into in the past five years, whether you continued to have an interest in it or not.
Any and all documents evidencing you having authority to access any safe deposit box or other bank-secured
area, for the last five years.
Any and all documents evidencing any application signed by yourself, or on behalf of yourself, or your wife
and/or children, to open a foreign or offshore financial account in your name or any other entity.
Copies of IRA contracts for all IRA’s that you currently have.
Copies of any IRA or 401k’s that were “rolled over.”
Complete contribution and distribution records for any current or previous IRAs or 401ks during the last five
years.
Copies of any and all bills or living expenses paid for with your IRA or 401k distributions during the last five
years,
Copies of any loans taken against your IRA or 401k during the last five years.
Any and all documents that refer to, reflect, or relate to any real property you’ve owned in the past five years.
Any and all document that refer to, reflect or relate to encumbrances on any real property you own,
Any and all documents evidencing ownership of real property in which you currently enjoy a direct or indirect
beneficial interest.
Any and all checks, receipts, deeds or other evidence of sale of transfer of any real property in which you had
a legal or equitable ownership interest in, within the past five years.
Any and all lease agreements for real property in which you are the landlord, or have a beneficial interest in.
Any and all lease agreements for rea] property in which the you are the lessor or lessee,
Any and all documents that evidence your name being on any real property tax records, as payor or trustee for
the past five years.21.
22,
23.
24,
25.
26.
27.
28.
29.
30.
31.
32.
33.
34,
35,
36.
37.
38.
39.
40.
41.
Any and all deeds that title any real property to you as trustee for any other person or entity.
Any and all deeds of trust or mortgages held in your favor at present or owned during the past five years.
Any and all documents evidencing any time-shares that you own or enjoy the use of,
Copies of any appraisals or other forms of valuation for any property that you have an interest in or had an
interest in within the past five years.
Promissory Notes or Mortgages you've signed during the past six years,
Copies of all deeds/mortgages to which you hold property as tenants by the entireties, tenants in common or
joint tenants.
Certificates of title or other evidence of ownership of any boat, watercraft, motorcycle, four-wheeler,
recreational vehicle, go-kart, aircraft, agricultural equipment, or construction equipment owned by yourself or
in your possession , whether owned by yourself or an entity that you are affiliated with, or held in trust by
yourself,
Any and all note receivables, pledges or security interest your favor now, and in the past five years,
Copies of all homeowner’s insurance policies and any other insurance policies or riders that have insured any
property that you own or have the benefit of use of, for the past five years,
List of household furnishings and fixtures that have been purchased within the last year that had a purchase
price of $999.00 or more.
Copies of all dock slips or other documentation evidencing the right to dock any watercraft, which you have
a legal or beneficial interest in.
List and valuation of all collectibles (i.e. stamps, coins, sports cards, etc.) that you now owns or have owned
within the past five years.
Any and all documents that refer to, or relate to any guns, jewelry, antiques, art, paintings, or other similar
assets that you own or that are in your possession within the past five years.
Any and all documents evidencing any interest you may have in any patents, trademarks, copyrights, franchises,
royalties of any kind, oil and gas rights, timber rights, or mineral rights.
Any and all documents that refer to, or relate to any professional sports tickets you own or have been in
possession of within the past five years,
All documents that identify the name and addresses of any person or entity that has employed you within the
past five years.
All documents that identify any person or entity that you have acted as an independent contractor for in the past
five years.
All documents referring in any way, directly or indirectly, to any and all business in which you are a
stockholder, partner, officer, director, owner or registered agent.
Any and all corporate charters, minutes of stockholders meetings, resolutions or recorded evidence of any kid
felating to the affairs of any corporation owned by yourself, or any subsidiary or other entity in which such
corporation holds an ownership interest during the past five years,
All locals, state and federal tax returns you have filed in the past five years, including all attachments, schedules,
W-2's, K-1's, 1099 and 1098 forms.
All documents referring, relating or pertaining to any records or salaries, commissions, bonuses, income from
employment, wages, pay stubs, dividends, royalties, allowances, expenses or other sums of money paid to you
within the past five years.42.
43.
45,
46.
47.
48,
49.
50.
51.
52.
53.
54,
55.
56.
57.
Any and all documents and records of stocks, bonds, mutual funds, debentures, certificates of deposits or any
other investment vehicle owned or held for your benefit.
Any and all documents relating to any retirement accounts or annuities, whether individual or employer-
sponsored, that are you own, or are being held for your benefit,
Any and all rent rolls for all properties in which you have had an ownership interest for the past five years.
Copies of all 1099-D’s or 1099-I’s issued to you within the past five years.
Any and all documents referring to any stock options or profit-sharing plans you hold or being held for your
benefit.
Any and all documents that evidence a cash value in any life insurance policy for you and copies of all policies
whether term, whole life or universal.
All documents evidencing any trusts or amendments to trusts in which you are a guarantor, settlor, or
beneficiary.
All documents evidencing any and all trusts or amendments to trusts that you have directly or indirectly
contributed any assets to within the past five years.
Copies of all pre and post-nuptial agreements, to include the lists of assets and liabilities to be held separately.
Copy of any wills including all amendments in which you have or were named as beneficiary.
Copies of all credit card statements, for all cards in which you are an authorized user, for the past year.
All documents referring or reflecting the name and address of any storage facility or mini-warehouse to which
you have access.
Copies of any and all financial statements that you have prepared for any lender or creditor in the past five
years.
Copies of any and all professional licenses you hold,
Copies of your driver’s license.
Copies of all divorce decrees and any financial affidavits submitted in or during those proceedings.
Preview
Filing # 103333918 E-Filed 02/14/2020 12:40:18 PM IN THE CIRCUIT COURT OF THE 17% JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA ATX MCA FUND I, LLC., CASE NO, CACE-19-026641 Plaintiff, VS. SEASONS RETAIL CONCEPTS, INC d/b/a SEASONS RETAIL CONCEPTS, and VALERIE E, PEREZ, individually, Defendants. E ‘CES TE E TO: VALERIE E. PEREZ, Individually 5701 Sunsewt Drive, Apt. 286 South Miami, FL 33143 EVANGELIS NUNEZ as the President of SEASONS RETAIL CONCEPTS, INC d/b/a SEASONS RETAIL CONCEPTS 13465 NW 19TH Lane Miami, FL 33182 PLEASE TAKE NOTICE THAT on April 2, 2020 at 12:30 p.m., Plaintiff's Attorney in the above-styled cause will take the deposition by oral examination in aid of execution of VALERIE E. PEREZ, Individually who shall bring with her those documents and things on the attached Addendum. PLEASE TAKE NOTICE THAT on April 2, 2020 at 1:00 p.m., Plaintiff's Attorney in the above-styled cause will take the deposition by oral examination in aid of execution of EVANGELIS NUNEZ as the President of SEASONS RETAIL CONCEPTS, INC d/b/a SEASONS RETAIL CONCEPTS who shall bring with her those documents and things on the attached Addendum. Said deposition will be taken before Esquire Deposition Solution at Emanuel & Zwiebel, PLLC, 7900 Peters Road, Executive Court at Jacaranda, Building B, Suite 100, Plantation, FL 33324 or any other 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 parties and who is neither a relative nor employee of such attorney or counsel, and who is not financially interested in this 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 and from day to day until completed, THEREBY CERTIFY that a copy of the above Notice of was furnished to the named addressee(s) by mail this y day of February, 2020. EMANUEL & ZWIEBEL, PLLC Executive Coury at Jacaranda ' ERIC B. ZWIEBEL, ESQ. i FBN. 476404 co: Esquire Deposition Solution * PLEASE ADVISE IF AN INTERPRETER IS NECESSARY * POR FAVOR NOTIFIQUENOS CON ANTERIORIDAD SI NECESITA UN INTERPRETE EN ESPANOL. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/14/2020 12:40:19 PM.****ADDENDUM TO SUBPOENA DUCES TECUM FOR DOCUMENTS. PERTAINING TO A CORPORATION YOU ARE HEREBY REQUIRED TO BRING WITH YOU AND PRODUCE FOR INSPECTION AND/OR PHOTOCOPYING THE FOLLOWING: 1. Copies of income tax returns for the past 3 calendar years of the corporation known as SEASONS RETAIL. CONCEPTS, INC d/b/a SEASONS RETAIL CONCEPTS Income tax records for the current tax year, and copies of any estimated income tax returns filed for the current year of the corporation. All business bank statements, including canceled checks, for the 12 months immediately preceding the date of the scheduled deposition. All business accounts receivable ledgers for the 12 months immediately preceding the date of the scheduled deposition. All business accounts payable ledgers for the 12 months immediately preceding the date of the scheduled deposition. All deeds, leases, mortgages, or other written instruments evidencing an interest in or ownership ofreal property at any time within the 24 months immediately preceding the date of this notice. Bills of sale or other written evidence of any personal or real property purchased or sold during the 24 months immediately preceding the date of the scheduled deposition, Motor vehicle documents relating to any motor vehicles owned by the corporation including, but not limited to, registrations and title certificates, during the last five (5) years from the date of the scheduled deposition. Any and all financial statements as to the corporation's business assets and liabilities, prepared for or by the corporation, within the last five (5) years from the date of the scheduled deposition. Current schedule of all business furniture subject to lien, Schedule of all business furniture, fixtures, furnishings, and equipment owned by the corporation as of the date of the scheduled deposition. All stock certificates or other evidence of ownership of stocks and bonds held by the corporation, including copies of any stock brokerage accounts maintained in the 24 months immediately preceding the date of the scheduled deposition. All policies of insurance owned by the corporation, regardless of the insured or beneficiary. Copies of all contracts on which the corporation is now performing services or rendering materials, or on which someone is indebted to the corporation for services or materials already furnished. Names and addresses of all employees who have worked for the corporation during the 12 months immediately preceding the date of the scheduled deposition. Copies of all litigation or settlement documents to which the corporation is now a party, or has been a party, whether as plaintiff or defendant, during the 24 months immediately preceding the date of the scheduled deposition. ‘Names and addresses of all corporate officers and directors, past and present. Names and addresses of al! stockholders in the corporation and the number of shares owned by each,ADDENDUM TO SUBPOENA DUCES TECUM FOR DOCUMENTS PERTAINING TO INDIVIDUALS YOU ARE HEREBY REQUIRED TO BRING WITH YOU AND PRODUCE FOR INSPECTION AND/OR PHOTOCOPYING THE FOLLOWING: 1, 10, 12, 13. 14, 18. 19. 20. Any and all documents and records of checking, savings, brokerage, or any other type of account, foreign or domestic, maintained by you with any type of financial institution, including brokerages, during the last five years, including but not limited to monthly account statements, checks, check registers, check stubs, cancelled checks, and deposit slips. All documents that refer to, relate to, reflect or concern any transfers made to or from any financial account held for your benefit, by any third party, for the last five years, Any and all signature cards that name you as an authorized signatory on any financial account, for any entity or other third party, for the past five years, Any and all documents submitted to any bank financial institution or any other person or entity, by yourself for any loan or advance in any capacity (borrower, guarantor, or surety) for the past five years. Any and all documents concerning any interest in, or claimed title to, any certificates of deposits, letters of credit, money orders, cashier’s checks, traveler’s checks, bank deposits or escrow funds owned or held by you in the past five years. Any and all documents related to any account in which any of your earnings or other income have been. deposited into in the past five years, whether you continued to have an interest in it or not. Any and all documents evidencing you having authority to access any safe deposit box or other bank-secured area, for the last five years. Any and all documents evidencing any application signed by yourself, or on behalf of yourself, or your wife and/or children, to open a foreign or offshore financial account in your name or any other entity. Copies of IRA contracts for all IRA’s that you currently have. Copies of any IRA or 401k’s that were “rolled over.” Complete contribution and distribution records for any current or previous IRAs or 401ks during the last five years. Copies of any and all bills or living expenses paid for with your IRA or 401k distributions during the last five years, Copies of any loans taken against your IRA or 401k during the last five years. Any and all documents that refer to, reflect, or relate to any real property you’ve owned in the past five years. Any and all document that refer to, reflect or relate to encumbrances on any real property you own, Any and all documents evidencing ownership of real property in which you currently enjoy a direct or indirect beneficial interest. Any and all checks, receipts, deeds or other evidence of sale of transfer of any real property in which you had a legal or equitable ownership interest in, within the past five years. Any and all lease agreements for real property in which you are the landlord, or have a beneficial interest in. Any and all lease agreements for rea] property in which the you are the lessor or lessee, Any and all documents that evidence your name being on any real property tax records, as payor or trustee for the past five years.21. 22, 23. 24, 25. 26. 27. 28. 29. 30. 31. 32. 33. 34, 35, 36. 37. 38. 39. 40. 41. Any and all deeds that title any real property to you as trustee for any other person or entity. Any and all deeds of trust or mortgages held in your favor at present or owned during the past five years. Any and all documents evidencing any time-shares that you own or enjoy the use of, Copies of any appraisals or other forms of valuation for any property that you have an interest in or had an interest in within the past five years. Promissory Notes or Mortgages you've signed during the past six years, Copies of all deeds/mortgages to which you hold property as tenants by the entireties, tenants in common or joint tenants. Certificates of title or other evidence of ownership of any boat, watercraft, motorcycle, four-wheeler, recreational vehicle, go-kart, aircraft, agricultural equipment, or construction equipment owned by yourself or in your possession , whether owned by yourself or an entity that you are affiliated with, or held in trust by yourself, Any and all note receivables, pledges or security interest your favor now, and in the past five years, Copies of all homeowner’s insurance policies and any other insurance policies or riders that have insured any property that you own or have the benefit of use of, for the past five years, List of household furnishings and fixtures that have been purchased within the last year that had a purchase price of $999.00 or more. Copies of all dock slips or other documentation evidencing the right to dock any watercraft, which you have a legal or beneficial interest in. List and valuation of all collectibles (i.e. stamps, coins, sports cards, etc.) that you now owns or have owned within the past five years. Any and all documents that refer to, or relate to any guns, jewelry, antiques, art, paintings, or other similar assets that you own or that are in your possession within the past five years. Any and all documents evidencing any interest you may have in any patents, trademarks, copyrights, franchises, royalties of any kind, oil and gas rights, timber rights, or mineral rights. Any and all documents that refer to, or relate to any professional sports tickets you own or have been in possession of within the past five years, All documents that identify the name and addresses of any person or entity that has employed you within the past five years. All documents that identify any person or entity that you have acted as an independent contractor for in the past five years. All documents referring in any way, directly or indirectly, to any and all business in which you are a stockholder, partner, officer, director, owner or registered agent. Any and all corporate charters, minutes of stockholders meetings, resolutions or recorded evidence of any kid felating to the affairs of any corporation owned by yourself, or any subsidiary or other entity in which such corporation holds an ownership interest during the past five years, All locals, state and federal tax returns you have filed in the past five years, including all attachments, schedules, W-2's, K-1's, 1099 and 1098 forms. All documents referring, relating or pertaining to any records or salaries, commissions, bonuses, income from employment, wages, pay stubs, dividends, royalties, allowances, expenses or other sums of money paid to you within the past five years.42. 43. 45, 46. 47. 48, 49. 50. 51. 52. 53. 54, 55. 56. 57. Any and all documents and records of stocks, bonds, mutual funds, debentures, certificates of deposits or any other investment vehicle owned or held for your benefit. Any and all documents relating to any retirement accounts or annuities, whether individual or employer- sponsored, that are you own, or are being held for your benefit, Any and all rent rolls for all properties in which you have had an ownership interest for the past five years. Copies of all 1099-D’s or 1099-I’s issued to you within the past five years. Any and all documents referring to any stock options or profit-sharing plans you hold or being held for your benefit. Any and all documents that evidence a cash value in any life insurance policy for you and copies of all policies whether term, whole life or universal. All documents evidencing any trusts or amendments to trusts in which you are a guarantor, settlor, or beneficiary. All documents evidencing any and all trusts or amendments to trusts that you have directly or indirectly contributed any assets to within the past five years. Copies of all pre and post-nuptial agreements, to include the lists of assets and liabilities to be held separately. Copy of any wills including all amendments in which you have or were named as beneficiary. Copies of all credit card statements, for all cards in which you are an authorized user, for the past year. All documents referring or reflecting the name and address of any storage facility or mini-warehouse to which you have access. Copies of any and all financial statements that you have prepared for any lender or creditor in the past five years. Copies of any and all professional licenses you hold, Copies of your driver’s license. Copies of all divorce decrees and any financial affidavits submitted in or during those proceedings.