Preview
Filing # 79833995 E-Filed 10/24/2018 06:21:37 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR ORANGE COUNTY, FLORIDA
MOBOOKA, LLC, a Florida limited liability
company, CASE NO.: 2017-CA-004043
Plaintiff,
v.
JOHN HANCOCK, et. al.,
Defendants.
_________________________________/
PLAINTIFF’S MOTION TO COMPEL PRODUCTION OF DOCUMENTS AND
RESPONSES TO INTERROGATORIES AGAINST BOTH DEFENDANTS
COMES NOW, the Plaintiff, MOBOOKA, LLC, by and through its undersigned counsel,
and files this Motion to Compel against Defendants JOHN HANCOCK (“Hancock”) and FORSA
LLC (“Forsa”)(collectively, “Defendants”) and states as follows:
1. On July 6, 2018 the Plaintiff served discovery requests against both Defendants.
2. This discovery consisted of Requests for Production and Interrogatories.
3. Pursuant to the agreement of the parties, the parties agreed to an extension of time
until September 6, 2018. A true and correct copy of the email detailing the parties agreement is
attached hereto as Exhibit “A.”
4. Pursuant to the Court’s Order permitting Plaintiff’s counsel to withdraw, the
deadline was extended another thirty (30) days until October 6, 2018. A true and correct copy of
the Court’s Order is attached hereto as Exhibit “B.”
5. When Defendants failed to provide any response, the undersigned reached out in
an attempt to resolve the issue without court action.
6. Nevertheless, although Defendants were given additional time until October 15, to
Motion to Compel
Case No.: 2017-CA-004043
provide all responses and documents, none have been forthcoming.
7. The Court should compel responses to all outstanding discovery and sanction
Defendants based upon their uncooperative and dilatory conduct.
8. Pursuant to Fla. R. Civ. P. 1.380(a)(2), the undersigned hereby certifies that je
contacted Defendants in a good faith effort to resolve these production issues, however no
documents nor responses have been provided.
9. Moreover, the requests are relevant to the key issues presented by this case.
10. Finally, Plaintiff is entitled to its reasonable attorneys’ fees and costs in connection
with the relief sought herein. See Fla. R. Civ. P. 1.380(a)(4) (“If the motion is granted and after
opportunity for hearing, the court shall require the party or deponent whose conduct necessitated
the motion . . . to pay to the moving party the reasonable expenses incurred in obtaining the order
that may include attorneys’ fees . . . .” (emphasis added)).
WHEREFORE, the Plaintiff, Mobooka, LLC, respectfully requests that this Honorable
Court respectfully requests that this Honorable Court enter an order: (i) granting Plaintiff’s Motion
to Compel Production of Documents and Responses to Interrogatories Against Both Defendants
(ii) compelling Defendants to respond and to produce all responsive, non-privileged documents;
(iii) awarding Plaintiff its attorneys’ fees and expenses incurred in bringing this Motion pursuant
to Fla. R. Civ. P. 1.380(a)(4); and (iv) granting such other and further relief as this Honorable
Court deems necessary and proper.
[This Section Intentionally Left Blank – Certificate of Service Follows]
Page 2 of 3
EPGD Business Law
777 SW 37th Ave., Ste. 510, Miami, FL 33135 • T: (786) 837-6787 • F: (305) 718-0687 • www.epgdlaw.com
Motion to Compel
Case No.: 2017-CA-004043
Dated this 24th day of October, 2018.
Respectfully submitted,
EPGD BUSINESS LAW
Counsel for Plaintiff
777 SW 37th Street, Ste. 510
Miami, FL 33135
T: (786) 837-6787
F: (305) 718-0687
andres@epgdlaw.com
By: /s/ Samuel J. Gittle
Samuel J. Gittle, Esq.
Florida Bar No.: 99778
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing was furnished on this 24th day
of October 2018, via Email and U.S. Mail to John Hancock and Forsa LLC, 499 Hammock Drive,
Palm Harbor, FL 34683 (hancock.j.g@gmail.com).
By: /s/ Samuel J. Gittle______
Samuel J. Gittle, Esq.
Florida Bar No.: 99778
Page 3 of 3
EPGD Business Law
777 SW 37th Ave., Ste. 510, Miami, FL 33135 • T: (786) 837-6787 • F: (305) 718-0687 • www.epgdlaw.com
Exhibit “A”
10/24/2018 EPGD Attorneys at Law, P.A. Mail - SERVICE OF COURT DOCUMENT - CASE NO.: 2017-CA-004043 - Mobooka LLC, v. John Hancock, et al., DEFEN…
Samuel Gittle
SERVICE OF COURT DOCUMENT CASE NO.: 2017CA004043 Mobooka LLC, v.
John Hancock, et al., DEFENDANT'S Motion For Extension of Time to Respond to all
ok Pl. Discovery Requests, and Motion for Extension of Time to Respond to Second
Amended Complaint
Patrick Willis Wed, Aug 8, 2018 at 3:34 PM
To: Samuel Gittle , Lisa Quinones
Cc: Elizabeth Fernandez , "oscar@epgdlaw.com" ,
"paralegal@epgdlaw.com"
Sam,
September 6th is fine. Yes please send over a proposed order.
thanks,
Patrick H. Willis
2121 S. Hiawassee Road, Suite 116
Orlando, FL 328358762
(407) 9039939 (O)
(407) 9039929 (F)
www.willisoden.com
This e‐mail is intended only for the individual(s) or en
ty(s) named within the message. This e‐mail might contain legally privileged and confiden
al informa
on. If
you properly received this e‐mail as a client or retained expert, please hold it in confidence to protect the a
orney‐client or work product privileges. Should the
intended recipient forward or disclose this message to another person or party, that ac
on could constute a waiver of the a
orney‐client privilege. If the reader
of this message is not the intended recipient, or the agent responsible to deliver it to the intended recipient, you are hereby no
fied that any review,
disseminaon, distribu
on or copying of this communica
on is prohibited by the sender and to do so might cons
tute a viola
on of the Electronic
Communica ons Privacy Act, 18 U.S.C. sec
on 2510‐2521. If this communica
on was received in error we apologize for the intrusion. Please no
fy us by reply e‐
mail and delete the original message without reading same. Nothing in this e‐mail message shall, in and of itself, create an a
orney‐client rela
onship with the
https://mail.google.com/mail/u/0?ik=d0d8f18591&view=pt&search=all&permmsgid=msg-f%3A1608260633106616413&dsqt=1&simpl=msg-f%3A1608260633106…
1/5
10/24/2018 EPGD Attorneys at Law, P.A. Mail - SERVICE OF COURT DOCUMENT - CASE NO.: 2017-CA-004043 - Mobooka LLC, v. John Hancock, et al., DEFEN…
sender.
Disclaimer under Circular 230: Any statements regarding tax ma
ers made herein, including any a
achments, are not formal tax opinions by this firm, cannot be
relied upon or used by any person to avoid tax penal
es, and are not intended to be used or referred to in any marke
ng or promoonal materials.
From: Samuel Gittle [mailto:sam@epgdlaw.com]
Sent: Wednesday, August 08, 2018 3:24 PM
To: Lisa Quinones
Cc: Elizabeth Fernandez; oscar@epgdlaw.com; paralegal@epgdlaw.com; Patrick Willis
Subject: Re: SERVICE OF COURT DOCUMENT CASE NO.: 2017CA004043 Mobooka LLC, v. John Hancock, et al.,
DEFENDANT'S Motion For Extension of Time to Respond to all ok Pl. Discovery Requests, and Motion for Extension of
Time to Respond to Second Amended Complaint
Good Afternoon,
Please confirm the extension as per my previous email. We can draft a proposed order if needed as well.
Thank you,
Samuel J. Gittle, Esq.
Sr. Litigation Associate
Miami Office:
777 SW 37th Ave., Ste. 510
Miami, Florida 33135
Washington, D.C. Office:
1900 M Street NW, Ste. 600
Washington, D.C. 20036
Miami Tel: (786) 8376787
D.C. Tel: (202) 9002818
Fax: (305) 7180
687
sam@epgdlaw.com
https://mail.google.com/mail/u/0?ik=d0d8f18591&view=pt&search=all&permmsgid=msg-f%3A1608260633106616413&dsqt=1&simpl=msg-f%3A1608260633106…
2/5
10/24/2018 EPGD Attorneys at Law, P.A. Mail - SERVICE OF COURT DOCUMENT - CASE NO.: 2017-CA-004043 - Mobooka LLC, v. John Hancock, et al., DEFEN…
Skype: epgdlaw
Visit our Website, www.EPGDLaw.com
Follow us on Facebook and LinkedIn
Confidentiality Notice: This email, including any attachment(s), is intended for receipt and use by the intended
addressee(s), and may contain confidential and privileged information. If you are not an intended recipient of this e
mail, you are hereby notified that any unauthorized use or distribution of this email is strictly prohibited, and requested
to delete this communication and its attachment(s) without making any copies thereof and to contact the sender of this
email immediately.
Electronic Signature Notice: Nothing contained in the body and/or header of this email is intended as a signature or
intended to bind the addressor or any person represented by the addressor to the terms of any agreement that may be
the subject of this email or its attachment(s), except where such intent is expressly indicated.
Environmental Notice: Think Green Please consider the environment before printing this email.
On Tue, Aug 7, 2018 at 12:40 PM, Samuel Gittle wrote:
Good Afternoon,
We can agree to an extension until September 6. Please advise.
Thank you,
Samuel J. Gittle, Esq.
Sr. Litigation Associate
Miami Office:
777 SW 37th Ave., Ste. 510
Miami, Florida 33135
Washington, D.C. Office:
1900 M Street NW, Ste. 600
Washington, D.C. 20036
Miami Tel: (786) 8376787
D.C. Tel: (202) 9002818
https://mail.google.com/mail/u/0?ik=d0d8f18591&view=pt&search=all&permmsgid=msg-f%3A1608260633106616413&dsqt=1&simpl=msg-f%3A1608260633106…
3/5
10/24/2018 EPGD Attorneys at Law, P.A. Mail - SERVICE OF COURT DOCUMENT - CASE NO.: 2017-CA-004043 - Mobooka LLC, v. John Hancock, et al., DEFEN…
Fax: (305) 7180
687
sam@epgdlaw.com
Skype: epgdlaw
Visit our Website, www.EPGDLaw.com
Follow us on Facebook and LinkedIn
Confidentiality Notice: This email, including any attachment(s), is intended for receipt and use by the intended
addressee(s), and may contain confidential and privileged information. If you are not an intended recipient of this e
mail, you are hereby notified that any unauthorized use or distribution of this email is strictly prohibited, and requested
to delete this communication and its attachment(s) without making any copies thereof and to contact the sender of this
email immediately.
Electronic Signature Notice: Nothing contained in the body and/or header of this email is intended as a signature or
intended to bind the addressor or any person represented by the addressor to the terms of any agreement that may be
the subject of this email or its attachment(s), except where such intent is expressly indicated.
Environmental Notice: Think Green Please consider the environment before printing this email.
On Tue, Aug 7, 2018 at 11:56 AM, Lisa Quinones wrote:
Good Morning,
COURT: Orange Co. Circuit
CASE NUMBER: 2017CA004043
PLAINTIFF: Mobooka LLC.,
DEFENDANTS: John Hancock; et al.,
TITLE OF DOCUMENT(S): Motion for Extension of Time to Respond to all of Plaintiff’s Discovery Requests
and Motion for Extension of Time to Respond to
Plaintiff’s Second Amended Complaint.
Thank you.
Best Regards,
https://mail.google.com/mail/u/0?ik=d0d8f18591&view=pt&search=all&permmsgid=msg-f%3A1608260633106616413&dsqt=1&simpl=msg-f%3A1608260633106…
4/5
10/24/2018 EPGD Attorneys at Law, P.A. Mail - SERVICE OF COURT DOCUMENT - CASE NO.: 2017-CA-004043 - Mobooka LLC, v. John Hancock, et al., DEFEN…
LISA QUINONES I LEGAL ASSISTANT
2121 S. Hiawassee Road, Suite 116
Orlando, FL 328358762
(407) 9039939 (O)
(407) 9039929 (F)
www.willisoden.com
This electronic mail message contains CONFIDENTIAL information which is (a) ATTORNEY CLIENT PRIVILEGED, WORK PRODUCT,
PROPRIETARY IN NATURE, OR OTHERWISE PROTECTED BY LAW FROM DISCLOSURE, and (b) intended only for the use of the Addressee(s)
named herein. If you are not an Addressee, or the person responsible for delivering this to an Addressee, you are hereby notified that reading,
copying, or distributing this message is prohibited. If you have received this message in error, please reply to the sender and take the steps
necessary to delete the message completely from your computer system.
IRS CIRCULAR 230 DISCLOSURE: Unless expressly stated otherwise, any U.S. federal tax advice contained in this email, including attachments,
is not intended to be used, and any such tax advice cannot be used for the purpose of avoiding penalties that may be imposed by the Internal
Revenue Service.
https://mail.google.com/mail/u/0?ik=d0d8f18591&view=pt&search=all&permmsgid=msg-f%3A1608260633106616413&dsqt=1&simpl=msg-f%3A1608260633106…
5/5
Exhibit “B”
Preview
Filing # 79833995 E-Filed 10/24/2018 06:21:37 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA MOBOOKA, LLC, a Florida limited liability company, CASE NO.: 2017-CA-004043 Plaintiff, v. JOHN HANCOCK, et. al., Defendants. _________________________________/ PLAINTIFF’S MOTION TO COMPEL PRODUCTION OF DOCUMENTS AND RESPONSES TO INTERROGATORIES AGAINST BOTH DEFENDANTS COMES NOW, the Plaintiff, MOBOOKA, LLC, by and through its undersigned counsel, and files this Motion to Compel against Defendants JOHN HANCOCK (“Hancock”) and FORSA LLC (“Forsa”)(collectively, “Defendants”) and states as follows: 1. On July 6, 2018 the Plaintiff served discovery requests against both Defendants. 2. This discovery consisted of Requests for Production and Interrogatories. 3. Pursuant to the agreement of the parties, the parties agreed to an extension of time until September 6, 2018. A true and correct copy of the email detailing the parties agreement is attached hereto as Exhibit “A.” 4. Pursuant to the Court’s Order permitting Plaintiff’s counsel to withdraw, the deadline was extended another thirty (30) days until October 6, 2018. A true and correct copy of the Court’s Order is attached hereto as Exhibit “B.” 5. When Defendants failed to provide any response, the undersigned reached out in an attempt to resolve the issue without court action. 6. Nevertheless, although Defendants were given additional time until October 15, to Motion to Compel Case No.: 2017-CA-004043 provide all responses and documents, none have been forthcoming. 7. The Court should compel responses to all outstanding discovery and sanction Defendants based upon their uncooperative and dilatory conduct. 8. Pursuant to Fla. R. Civ. P. 1.380(a)(2), the undersigned hereby certifies that je contacted Defendants in a good faith effort to resolve these production issues, however no documents nor responses have been provided. 9. Moreover, the requests are relevant to the key issues presented by this case. 10. Finally, Plaintiff is entitled to its reasonable attorneys’ fees and costs in connection with the relief sought herein. See Fla. R. Civ. P. 1.380(a)(4) (“If the motion is granted and after opportunity for hearing, the court shall require the party or deponent whose conduct necessitated the motion . . . to pay to the moving party the reasonable expenses incurred in obtaining the order that may include attorneys’ fees . . . .” (emphasis added)). WHEREFORE, the Plaintiff, Mobooka, LLC, respectfully requests that this Honorable Court respectfully requests that this Honorable Court enter an order: (i) granting Plaintiff’s Motion to Compel Production of Documents and Responses to Interrogatories Against Both Defendants (ii) compelling Defendants to respond and to produce all responsive, non-privileged documents; (iii) awarding Plaintiff its attorneys’ fees and expenses incurred in bringing this Motion pursuant to Fla. R. Civ. P. 1.380(a)(4); and (iv) granting such other and further relief as this Honorable Court deems necessary and proper. [This Section Intentionally Left Blank – Certificate of Service Follows] Page 2 of 3 EPGD Business Law 777 SW 37th Ave., Ste. 510, Miami, FL 33135 • T: (786) 837-6787 • F: (305) 718-0687 • www.epgdlaw.com Motion to Compel Case No.: 2017-CA-004043 Dated this 24th day of October, 2018. Respectfully submitted, EPGD BUSINESS LAW Counsel for Plaintiff 777 SW 37th Street, Ste. 510 Miami, FL 33135 T: (786) 837-6787 F: (305) 718-0687 andres@epgdlaw.com By: /s/ Samuel J. Gittle Samuel J. Gittle, Esq. Florida Bar No.: 99778 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was furnished on this 24th day of October 2018, via Email and U.S. Mail to John Hancock and Forsa LLC, 499 Hammock Drive, Palm Harbor, FL 34683 (hancock.j.g@gmail.com). By: /s/ Samuel J. Gittle______ Samuel J. Gittle, Esq. Florida Bar No.: 99778 Page 3 of 3 EPGD Business Law 777 SW 37th Ave., Ste. 510, Miami, FL 33135 • T: (786) 837-6787 • F: (305) 718-0687 • www.epgdlaw.com Exhibit “A” 10/24/2018 EPGD Attorneys at Law, P.A. Mail - SERVICE OF COURT DOCUMENT - CASE NO.: 2017-CA-004043 - Mobooka LLC, v. John Hancock, et al., DEFEN… Samuel Gittle SERVICE OF COURT DOCUMENT CASE NO.: 2017CA004043 Mobooka LLC, v. John Hancock, et al., DEFENDANT'S Motion For Extension of Time to Respond to all ok Pl. Discovery Requests, and Motion for Extension of Time to Respond to Second Amended Complaint Patrick Willis Wed, Aug 8, 2018 at 3:34 PM To: Samuel Gittle , Lisa Quinones Cc: Elizabeth Fernandez , "oscar@epgdlaw.com" , "paralegal@epgdlaw.com" Sam, September 6th is fine. Yes please send over a proposed order. thanks, Patrick H. Willis 2121 S. Hiawassee Road, Suite 116 Orlando, FL 328358762 (407) 9039939 (O) (407) 9039929 (F) www.willisoden.com This e‐mail is intended only for the individual(s) or en ty(s) named within the message. This e‐mail might contain legally privileged and confiden al informa on. If you properly received this e‐mail as a client or retained expert, please hold it in confidence to protect the a orney‐client or work product privileges. Should the intended recipient forward or disclose this message to another person or party, that ac on could constute a waiver of the a orney‐client privilege. If the reader of this message is not the intended recipient, or the agent responsible to deliver it to the intended recipient, you are hereby no fied that any review, disseminaon, distribu on or copying of this communica on is prohibited by the sender and to do so might cons tute a viola on of the Electronic Communica ons Privacy Act, 18 U.S.C. sec on 2510‐2521. If this communica on was received in error we apologize for the intrusion. Please no fy us by reply e‐ mail and delete the original message without reading same. Nothing in this e‐mail message shall, in and of itself, create an a orney‐client rela onship with the https://mail.google.com/mail/u/0?ik=d0d8f18591&view=pt&search=all&permmsgid=msg-f%3A1608260633106616413&dsqt=1&simpl=msg-f%3A1608260633106… 1/5 10/24/2018 EPGD Attorneys at Law, P.A. Mail - SERVICE OF COURT DOCUMENT - CASE NO.: 2017-CA-004043 - Mobooka LLC, v. John Hancock, et al., DEFEN… sender. Disclaimer under Circular 230: Any statements regarding tax ma ers made herein, including any a achments, are not formal tax opinions by this firm, cannot be relied upon or used by any person to avoid tax penal es, and are not intended to be used or referred to in any marke ng or promoonal materials. From: Samuel Gittle [mailto:sam@epgdlaw.com] Sent: Wednesday, August 08, 2018 3:24 PM To: Lisa Quinones Cc: Elizabeth Fernandez; oscar@epgdlaw.com; paralegal@epgdlaw.com; Patrick Willis Subject: Re: SERVICE OF COURT DOCUMENT CASE NO.: 2017CA004043 Mobooka LLC, v. John Hancock, et al., DEFENDANT'S Motion For Extension of Time to Respond to all ok Pl. Discovery Requests, and Motion for Extension of Time to Respond to Second Amended Complaint Good Afternoon, Please confirm the extension as per my previous email. We can draft a proposed order if needed as well. Thank you, Samuel J. Gittle, Esq. Sr. Litigation Associate Miami Office: 777 SW 37th Ave., Ste. 510 Miami, Florida 33135 Washington, D.C. Office: 1900 M Street NW, Ste. 600 Washington, D.C. 20036 Miami Tel: (786) 8376787 D.C. Tel: (202) 9002818 Fax: (305) 7180 687 sam@epgdlaw.com https://mail.google.com/mail/u/0?ik=d0d8f18591&view=pt&search=all&permmsgid=msg-f%3A1608260633106616413&dsqt=1&simpl=msg-f%3A1608260633106… 2/5 10/24/2018 EPGD Attorneys at Law, P.A. Mail - SERVICE OF COURT DOCUMENT - CASE NO.: 2017-CA-004043 - Mobooka LLC, v. John Hancock, et al., DEFEN… Skype: epgdlaw Visit our Website, www.EPGDLaw.com Follow us on Facebook and LinkedIn Confidentiality Notice: This email, including any attachment(s), is intended for receipt and use by the intended addressee(s), and may contain confidential and privileged information. If you are not an intended recipient of this e mail, you are hereby notified that any unauthorized use or distribution of this email is strictly prohibited, and requested to delete this communication and its attachment(s) without making any copies thereof and to contact the sender of this email immediately. Electronic Signature Notice: Nothing contained in the body and/or header of this email is intended as a signature or intended to bind the addressor or any person represented by the addressor to the terms of any agreement that may be the subject of this email or its attachment(s), except where such intent is expressly indicated. Environmental Notice: Think Green Please consider the environment before printing this email. On Tue, Aug 7, 2018 at 12:40 PM, Samuel Gittle wrote: Good Afternoon, We can agree to an extension until September 6. Please advise. Thank you, Samuel J. Gittle, Esq. Sr. Litigation Associate Miami Office: 777 SW 37th Ave., Ste. 510 Miami, Florida 33135 Washington, D.C. Office: 1900 M Street NW, Ste. 600 Washington, D.C. 20036 Miami Tel: (786) 8376787 D.C. Tel: (202) 9002818 https://mail.google.com/mail/u/0?ik=d0d8f18591&view=pt&search=all&permmsgid=msg-f%3A1608260633106616413&dsqt=1&simpl=msg-f%3A1608260633106… 3/5 10/24/2018 EPGD Attorneys at Law, P.A. Mail - SERVICE OF COURT DOCUMENT - CASE NO.: 2017-CA-004043 - Mobooka LLC, v. John Hancock, et al., DEFEN… Fax: (305) 7180 687 sam@epgdlaw.com Skype: epgdlaw Visit our Website, www.EPGDLaw.com Follow us on Facebook and LinkedIn Confidentiality Notice: This email, including any attachment(s), is intended for receipt and use by the intended addressee(s), and may contain confidential and privileged information. If you are not an intended recipient of this e mail, you are hereby notified that any unauthorized use or distribution of this email is strictly prohibited, and requested to delete this communication and its attachment(s) without making any copies thereof and to contact the sender of this email immediately. Electronic Signature Notice: Nothing contained in the body and/or header of this email is intended as a signature or intended to bind the addressor or any person represented by the addressor to the terms of any agreement that may be the subject of this email or its attachment(s), except where such intent is expressly indicated. Environmental Notice: Think Green Please consider the environment before printing this email. On Tue, Aug 7, 2018 at 11:56 AM, Lisa Quinones wrote: Good Morning, COURT: Orange Co. Circuit CASE NUMBER: 2017CA004043 PLAINTIFF: Mobooka LLC., DEFENDANTS: John Hancock; et al., TITLE OF DOCUMENT(S): Motion for Extension of Time to Respond to all of Plaintiff’s Discovery Requests and Motion for Extension of Time to Respond to Plaintiff’s Second Amended Complaint. Thank you. Best Regards, https://mail.google.com/mail/u/0?ik=d0d8f18591&view=pt&search=all&permmsgid=msg-f%3A1608260633106616413&dsqt=1&simpl=msg-f%3A1608260633106… 4/5 10/24/2018 EPGD Attorneys at Law, P.A. Mail - SERVICE OF COURT DOCUMENT - CASE NO.: 2017-CA-004043 - Mobooka LLC, v. John Hancock, et al., DEFEN… LISA QUINONES I LEGAL ASSISTANT 2121 S. Hiawassee Road, Suite 116 Orlando, FL 328358762 (407) 9039939 (O) (407) 9039929 (F) www.willisoden.com This electronic mail message contains CONFIDENTIAL information which is (a) ATTORNEY CLIENT PRIVILEGED, WORK PRODUCT, PROPRIETARY IN NATURE, OR OTHERWISE PROTECTED BY LAW FROM DISCLOSURE, and (b) intended only for the use of the Addressee(s) named herein. If you are not an Addressee, or the person responsible for delivering this to an Addressee, you are hereby notified that reading, copying, or distributing this message is prohibited. If you have received this message in error, please reply to the sender and take the steps necessary to delete the message completely from your computer system. IRS CIRCULAR 230 DISCLOSURE: Unless expressly stated otherwise, any U.S. federal tax advice contained in this email, including attachments, is not intended to be used, and any such tax advice cannot be used for the purpose of avoiding penalties that may be imposed by the Internal Revenue Service. https://mail.google.com/mail/u/0?ik=d0d8f18591&view=pt&search=all&permmsgid=msg-f%3A1608260633106616413&dsqt=1&simpl=msg-f%3A1608260633106… 5/5 Exhibit “B”