Preview
id: 54
Charlotte County Clerk
1164192 Date : 08/26/00 - 08:27:33
Case#: 00000017CA Pages: 0002
MAU
WILKINS, FROHLICH,
JONES, HEVIA,
RUSSELL & SUTTER
PROFESSIONAL ASSOCIATION
ATTORNEYS AT LAW
PORT CHARLOTTE, FLORIDA
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA CIVIL DIVISION
PAULINE GAY, trustee for THE
JAMES B. GAY and PAULINE T.
GAY TRUST,
Plaintiff, pap
vs. Case No. 206267
mt
3%,
ae
R. JOHN ZAVODNY, et. al., 3
gas
Ra 12 Sav 00
Defendants. ZAG
@ 68
‘3
REQUEST FOR PRODUCTION OF DOCUMENTS and THING:
‘TO: Robert M. Pretschner, Esq.,
Hodges, Avrutis & Pretschner, P.A.
889 N. Washington Blvd.
Sarasota, Florida 34236
: Plaintiff, PAULINE GAY, trustee for The James B. Gay and Pauline T. Gay Trust,
pursuant to Rule 1.350, Fla. R. Civ. P., request the Defendant, JZ MORGAN-TIDES
IVILLAGE, LTD, to produce to the Plaintiff at the law offices of WILKINS, FROHLICH,
JONES, HEVIA, RUSSELL & SUTTER, P.A., 18501 Murdock Circle, Sixth Floor, Port |
Charlotte, Florida 33948, within thirty 30 days from the service of this request, for the »
purposes of inspecting, copying or testing.
1. Please produce all correspondence by any individual associated with or working for
you sent to any Secured note holders or investors, including correspondence sent
to Plaintiff. i
2. Please produce any and all correspondence sent to you by any person holding a |
secured note issued by you. |
3. Please produce all any and all correspondence between you and Defendant, R.
John Zavodny, Bill Walker, Terry Morgan, and Defendant, Dean Sinibaldi.
4. Please produce all bank account records for any accounts owned or affiliated with
JZ Morgan-Tides Village, LTD., since 1995.
5. Produce alt payment records for each and every person issued a secured note, or
other security by you, including payments made by such individuals to you, and
payments made by you to such individuals.
pPWILKINS, FROALICH.
JONES, HEVIA,
RUSSELL & SUTTER
PROFESSIONAL ASSOCIATION
ATTORNEYS AT LAW
PORT CHARLOTTE, FLORIDA
6. Pease produce any documents or records associated with the registration of any
securities offered or issued by you, pursuant to Chapter 517, Florida Statutes.
7. Please produce any and all documents pertaining to the sale, transfer,
| encumbrance or other disposal of any property purchased or sold by you or Tides
: Development Company, at any time.
B. Please produce all records of payments of any kind made by you to Defendant
Dean Sinibaldi, Defendant R. John Zavodny, and Defendant JZ-Morgan Capital,
inc.
9. Please produce any documents pertaining to any liens or encumbrances on any
property owned by you, or formerly owned by you.
Plaintiffs would state that they have need to examine, copy and inspect said items
land are either unable to obtain said described items by other means, or are otherwise
lentitied to discover said items.
| | HEREBY CERTIFY that a true and correct copy of the foregoing Request for
Production of Documents and Things has been furnished to Robert M. Pretschner, Esq.,
Hodges, Avrutis & Pretschner, P.A., 889 N. Washington Blvd., Sarasota, FL 34236, MARK
IA. GRUWELL, 747 North Washington Boulevard, Sarasota, Florida 34236 by U.S. Mail,
lon this 23 day of August 2000.
WILKINS, FROHLICH, JONES,
HEVIA, RUSSELL & SUTTER, PA.
18501 Murdock Circle, Sixth Floor
Port Charlotte, Florida 33948
941-625-0700
Attorneys for Plaintiff
Preview
id: 54 Charlotte County Clerk 1164192 Date : 08/26/00 - 08:27:33 Case#: 00000017CA Pages: 0002 MAU WILKINS, FROHLICH, JONES, HEVIA, RUSSELL & SUTTER PROFESSIONAL ASSOCIATION ATTORNEYS AT LAW PORT CHARLOTTE, FLORIDA IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL DIVISION PAULINE GAY, trustee for THE JAMES B. GAY and PAULINE T. GAY TRUST, Plaintiff, pap vs. Case No. 206267 mt 3%, ae R. JOHN ZAVODNY, et. al., 3 gas Ra 12 Sav 00 Defendants. ZAG @ 68 ‘3 REQUEST FOR PRODUCTION OF DOCUMENTS and THING: ‘TO: Robert M. Pretschner, Esq., Hodges, Avrutis & Pretschner, P.A. 889 N. Washington Blvd. Sarasota, Florida 34236 : Plaintiff, PAULINE GAY, trustee for The James B. Gay and Pauline T. Gay Trust, pursuant to Rule 1.350, Fla. R. Civ. P., request the Defendant, JZ MORGAN-TIDES IVILLAGE, LTD, to produce to the Plaintiff at the law offices of WILKINS, FROHLICH, JONES, HEVIA, RUSSELL & SUTTER, P.A., 18501 Murdock Circle, Sixth Floor, Port | Charlotte, Florida 33948, within thirty 30 days from the service of this request, for the » purposes of inspecting, copying or testing. 1. Please produce all correspondence by any individual associated with or working for you sent to any Secured note holders or investors, including correspondence sent to Plaintiff. i 2. Please produce any and all correspondence sent to you by any person holding a | secured note issued by you. | 3. Please produce all any and all correspondence between you and Defendant, R. John Zavodny, Bill Walker, Terry Morgan, and Defendant, Dean Sinibaldi. 4. Please produce all bank account records for any accounts owned or affiliated with JZ Morgan-Tides Village, LTD., since 1995. 5. Produce alt payment records for each and every person issued a secured note, or other security by you, including payments made by such individuals to you, and payments made by you to such individuals. pPWILKINS, FROALICH. JONES, HEVIA, RUSSELL & SUTTER PROFESSIONAL ASSOCIATION ATTORNEYS AT LAW PORT CHARLOTTE, FLORIDA 6. Pease produce any documents or records associated with the registration of any securities offered or issued by you, pursuant to Chapter 517, Florida Statutes. 7. Please produce any and all documents pertaining to the sale, transfer, | encumbrance or other disposal of any property purchased or sold by you or Tides : Development Company, at any time. B. Please produce all records of payments of any kind made by you to Defendant Dean Sinibaldi, Defendant R. John Zavodny, and Defendant JZ-Morgan Capital, inc. 9. Please produce any documents pertaining to any liens or encumbrances on any property owned by you, or formerly owned by you. Plaintiffs would state that they have need to examine, copy and inspect said items land are either unable to obtain said described items by other means, or are otherwise lentitied to discover said items. | | HEREBY CERTIFY that a true and correct copy of the foregoing Request for Production of Documents and Things has been furnished to Robert M. Pretschner, Esq., Hodges, Avrutis & Pretschner, P.A., 889 N. Washington Blvd., Sarasota, FL 34236, MARK IA. GRUWELL, 747 North Washington Boulevard, Sarasota, Florida 34236 by U.S. Mail, lon this 23 day of August 2000. WILKINS, FROHLICH, JONES, HEVIA, RUSSELL & SUTTER, PA. 18501 Murdock Circle, Sixth Floor Port Charlotte, Florida 33948 941-625-0700 Attorneys for Plaintiff