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Filing # 127444928 E-Filed 05/25/2021 07:42:42 AM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT,
IN AND FOR OSCEOLA COUNTY, FLORIDA
XIAO SHENG YUE,
Plaintiff,
CASE NO.: 2020-CA-1106AN
v.
CYNTHIA M. FOERSTER AND
CHAPP, INC.,
Defendants.
A
DEFENDANTS, CYNTHIA M. FOERSTER AND CHAPP, INC.’S
MOTION TO COMPEL DISCOVERY
COMES NOW, Defendants, CYNTHIA M. FOERSTER and CHAPP, INC.,
(“DEFENDANTS”), by and through undersigned counsel and pursuant to the Florida Rules of
Civil Procedure, hereby file this Motion to Compel Discovery served upon Plaintiff, XIAO
SHENG YUE (“PLAINTIFF”), and state:
1. On April 7, 2021, the Defendants served upon Plaintiff its Second Request for
Production (attached hereto as Exhibit “A”).
2. Pursuant to Fla.R.Civ.P.1.340, et seq., the Plaintiff's Requests for Production of
documents were due on or before May 7, 2021.
3. In a good faith effort, Counsel for the Defendants sent via-email to Plaintiff,
correspondence giving Plaintiff ten (10) days to provide his responses to Second Request for
Production (Exhibit B).
4. To date, Plaintiff has failed to respond or object to said request for production.
WHEREFORE, the Defendants, CYNTHIA M. FOERSTER and CHAPP, INC.,
respectfully move this Court to enter an order compelling the Plaintiff, XIAO SHENG YUE, to
provide responses to Second Requests for Production within ten (10) days of the date of the Court’s
Order and any other further relief as is just and proper.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that, on this 25th day of May, 2021, I electronically filed the
foregoing with the Clerk of the Court via the Florida Courts’ e-Filing Portal, pursuant to and in
compliance with Rule 2.516, Florida Rules of Judicial Administration, which completes service
by furnishing a true and correct copy of the foregoing via electronic mail to all counsel of record.
LAW OFFICES OF SANTEIRO & GARRISON
/s/ Jorge Santeiro, Jr.
Jorge Santeiro, Jr.
FBN 66230
6300 University Parkway
Suite 101
Sarasota, FL 34240
Tel: (800) 226-3224 Ext. 1021
Primary: jsanteiro(@icci-group.com
Secondary: ssmithS@tcci-group.com
Secondary: legalservice@icci-group.com
Attorney for Defendants
Filing # 124503987 E-Filed 04/07/2021 03:21:17 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT,
IN AND FOR OSCEOLA COUNTY, FLORIDA
XIAO SHENG YUE,
Plaintiff,
v. CASE NO.: 2020-CA-1106AN
CYNTHIA M. FOERSTER AND
CHAPP, INC.,
Defendants.
eee
DEFENDANTS, CYNTHIA M. FOERSTER AND CHAPP, INC.’S, SECOND REQUEST
FOR PRODUCTION TO PLAINTIFF, XIAO SHENG YUE
Defendants, CYNTHIA M. FOERSTER and CHAPP, INC., by and through the
undersigned counsel and pursuant to Fla. R. Civ. P. 1.350, hereby request that Plaintiff, XIAO
SHENG TUE, produce for inspection and/or copying the following documents, which shall be
produced at the office of the undersigned counsel within thirty (30) days from the date of service
of this Request:
1. Any and all records regarding or referring to any real estate properties you own in
whole or in part and/or that you help manage, including but not limited to any deeds, warranty
deeds, quit claim deeds, notes, mortgages, property tax records, applications, insurance records,
records of rental income, leases, rental agreements, landlord-tenant agreements, eviction notices,
management agreements, records of maintenance expenses, records of repair expenses, checks,
ledgers, records of maintenance expenses, and any bookkeeping and accounting records regarding
the management of the properties and the like.
2. Any and all documents referring to or evidencing costs to maintain any real estate
properties you own, in whole or in part, and/or that you help manage, including but not limited to
EXHIBIT "A"
any invoices or receipts from Lowes, Home Depot, Sam’s Club and/or any other retailer or
wholesaler.
3. Any and all documents referring to or evidencing any insurance policies issued
regarding any real estate properties you own, in whole or in part, and/or that you help manage,
including but not limited to any applications, policies, records of claims, claim notices, records of
claims payments, records of repairs, checks, invoices, and the like.
4. Please complete and return the enclosed IRS release.
5. Any and all records, including but not limited to any and all deeds, warranty deeds,
quit claim deeds, notes, mortgages, property tax records, insurance records, records of rental
income, property and income tax records, leases, rental agreements, landlord-tenant agreements,
eviction notices, management agreements, records of maintenance expenses, records of repair
expenses, checks, ledgers, and any bookkeeping and accounting records and the like regarding the
following properties:
a. 4440 Philadelphia Circle, Kissimmee, FL
b. 4716 Hemingway House Street, Kissimmee, FL
c. 1197 S Beach Circle, Kissimmee, FL
d. 11644 Nimbus Lane, Orlando FL
6. Any and all insurance records, including but not limited to any applications,
policies, records of claims, claim notices, records of claims payments, records of repairs, checks,
invoices, and receipts regarding or referring to any the following properties:
a. 4440 Philadelphia Circle, Kissimmee, FL
b. 4716 Hemingway House Street, Kissimmee, FL
c. 1197 S Beach Circle, Kissimmee, FL
d. 11644 Nimbus Lane, Orlando FL
7. Any and all documents regarding or referring to the farm property located at 11010
Lake Hatchineha Road, Haines City, FL 33844, including but not limited to any deeds, warranty
deeds, quit claim deeds, notes, mortgages, property tax records, insurance records, bookkeeping
records, accounting records, profit and loss statements, balance statements, documents referencing
any assets, documents referencing any liabilities, documents referencing any inventory, livestock
records, building and zoning records, building and zoning complaints, business occupancy
permits/licenses, Department of Agriculture documents, licenses, any and all documents
referencing or regarding any improvements or repairs, animal feed invoices/receipts, harvesting
records, sales records, and the like.
8. Any and all non-privileged documents regarding or referring to any and all claims
for bodily injury you made arising out of any injuries from 2008 to the present, including but not
limited to any photos, estimates, medical records, radiological films/records, prescriptions,
EMT/ambulance/fire department records, health insurance records, automobile insurance records,
liens, medical bills, repair bills, invoices, claim notices, settlement documents, correspondence,
email communications, checks and the like.
9. Any and all non-privileged documents regarding or referring to any and all claims
for property damage you made from 2008 to the present, including but not limited to any photos,
estimates, repair bills, Exactimate documents, invoices, claim notices, liens, settlement documents,
correspondence, email communications, checks, and the like.
10. A true and complete copy of your passport, including all pages/stamps.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that, on this 7th day of April 2021, I electronically filed the
foregoing with the Clerk of the Court via the Florida Courts’ e-Filing Portal, pursuant to and in
compliance with Rule 2.516, Florida Rules of Judicial Administration, which completes service
by furnishing a true and correct copy of the foregoing via electronic mail to all counsel of record.
LAW OFFICES OF SANTEIRO & GARRISON
/s/ Jorge Santeiro, Jr.
Jorge Santeiro, Jr.
FBN 66230
6300 University Parkway
Suite 101
Sarasota, FL 34240
Tel: (800) 226-3224 Ext. 1021
Primary: jsanteiro@fecci-group.com
Secondary: ssmithS@fcci-group.com
Secondary: legalservice@icci-group.com
Attorney for Defendants
rom 4506 | Request for Copy of Tax Return |
Matmebar 2020) : b Oo not sign this form unless all applicable lines have been completed. | OMB Ne. 1s46-p400
: ' ® Request may be rejected if the form is Incomplete or Megible.
Department of he Treaniey | ‘ . eee ‘
Whenal Revenue Service | & Por more information about Form 4506, visi wwwirs.gav/fonnss06. i
ig. You may be able to get your tax return or return information trom other sources. Hf you had your tax return completed ‘by 4 paid preparer, they
should be able lo-provice. you. a copy ofthe return. The IRS can provide.a Tax Return Transoript for many returns. free. of charge: The tanscrint
provides most of the ine entries from the orginal tax retum and ustially coritains the information that-a third party (such as. a mortgage cornpani)
requires. Sée Form 4500-T, Request for Transcript of Tax Rehan, or you can quickly raquest transcripts by using our auiorated self-help service
tools. Please visit us atiRS.gov and click on “Get a Tax Transcript. or call 1-800-908-6048,
qa. Name shown on tax yeturn, Wf a joint return, enter the name shownfrst. qh First social security number on tax return,
individual taxpayer identification number, or
armployer identification nuraber (see Instructions}
2a ¥ a joint return, enter spouse's name shown on tax retin. 20 Second social securlly number or indivichial
: laxpayer ideniificalion number i jointtax return
i cae zi
2 Ourentname, address fincluding apt., room, or suite no.) chy, siete and ZIP code (see instructions)
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4. Previous aciiress shown on the last pelutri ied ff ditiorent from line 4 teee instructions)
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if the tax retum js io he maled to a third party Guch ae a morgage company),enter the third party's name, address. and lelephone number,
| Jorge Santee, bsu, The Law Olices of Bantewas Garten, 8300 University Pkwy, Suite 105. Sarasoie, Saeq 0
Gaution: if ine tax rotumn is being seni te the third party, ensure that lines $ through 7 are completed! belore signing. (gee Instructions).
{ G Tax pohen pequesied. Form. 1040. 7720, 94), sic. and al attachments ss orgingily aubmilied to the (AS) wicking Portis W-2,
schedules, or amended returis. Ooples of Forme 1040, 040A, and 104002 ae generally available tor 7 veers from Hiling before they are
destroyed by law. Other relurrs may be avallatile for a longer period of time. Enter only one return nuniber. ff you need more thar one
Qype of return, you must compiete another From 4506, > _— ee
Note: if the copies riust be certified for court or atininistrative proceedings, check here . 2. cc we we ew OD
i Year or period paquested. Evter ihe ending date of the tax year or peried using the movdd/yyyy fonmat (see instructions),
127 31 7 2013| Af SU 2014 12 4 81 7 2075| 32fS14 2018|
8 Z JSie? OTT t2. f mie, 2018 | 12 7 3 # 2019 . mcsa ia f 2020
& Fee, There is a $45 fee for each return requested. Full payment must be included with your request or Rwill
be rejected. Make your check or money order payable to “United States Treasury.” Enter your SSN, ITIN,
erEin and “Form 4506 request” on your check or money order.
| a Costfordachretm 60 6 ee ee e ee ee ee we BR AO
® Number ofretumsrequesied
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. 3 Hwecannot find the tax retum, We:wil felund:the fee.the refundShould go to the thingpartylisted oriling 5, check here ee be ry
Caution Do not sign this form unless all applicable lines have been completed.
Signature of taxpayer(s). | declare that am either the taxpayer whose name is shown.on line la or Za. or a person authorized toobtein ihe tex retum
requested. ihe request applies to a joint return, at jeast one spbuse must sign. If signed by a cornorate officer, 1 percent dr mora sharéliolder, partner,
managing member, guardian, fax matters nariner, exatulor, receiver, administrator, trusies, or party other than the taxpayer, | cerilfy that {have the authority to
execute For 4506 on behalf-of the taxpayer, Note: This form must be received by IRS within 120 days of ihe sighature dete,
(] Gignatery attests that he/stie has read the attestation clause and upon so reading ;
]: declaresthathe/shehastheauthoritytosigntheForm4506,SeeInstructions.
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For Privacy Act and Paperwork Reduction Act Notice, sea page 2. Cat, No AIPRIE Fomi 4506 mey. 11-2020)
e e 2
Law Offices of Santeiro & Garrison
Jorge Santeiro, Esq.
Mark Garrison, B.C.S.* “Florida Bar Certified in Civil Trial Law
Christine M. Hoke, Esq.** *“Fhorida Bar Goerd Ceariified in Construction Law
May 11, 2021
Via Email Only
mstefan@forthepeople.com
Iclaudio@forthepeople.com
Manuel Stefan, Esq.
Morgan & Morgan, P.A.
4495 South Semoran Blvd.
Orlando, FL 32822
Re: Yue, Xiao Sheng v. Cynthia M. Foerster and Chapp, Inc.
Dear Mr. Stefan:
Please allow this letter to serve as our ten (10) day notice for your client, Xiao Sheng Yue,
to respond to Defendants’ Second Request for Production, which was due May 7, 2021. If we do
not receive responses within ten (10) days, I will have no alternative but to file a Motion to Compel.
Should you have any questions or need additional information, please do not hesitate to
contact me.
Very Truly Yours,
Jorge Santeiro
Jorge Santeiro, Esq.
JS/sas
*All attorneys and staff are employees of FCCI Services, Inc., a member of the FCCI Insurance Group
6300 University Parkway, Suite 101, Sarasota, Florida 34240, Telephone 800-226-3224, Ext. 1021
EXHIBIT "B"
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Filing # 127444928 E-Filed 05/25/2021 07:42:42 AM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA XIAO SHENG YUE, Plaintiff, CASE NO.: 2020-CA-1106AN v. CYNTHIA M. FOERSTER AND CHAPP, INC., Defendants. A DEFENDANTS, CYNTHIA M. FOERSTER AND CHAPP, INC.’S MOTION TO COMPEL DISCOVERY COMES NOW, Defendants, CYNTHIA M. FOERSTER and CHAPP, INC., (“DEFENDANTS”), by and through undersigned counsel and pursuant to the Florida Rules of Civil Procedure, hereby file this Motion to Compel Discovery served upon Plaintiff, XIAO SHENG YUE (“PLAINTIFF”), and state: 1. On April 7, 2021, the Defendants served upon Plaintiff its Second Request for Production (attached hereto as Exhibit “A”). 2. Pursuant to Fla.R.Civ.P.1.340, et seq., the Plaintiff's Requests for Production of documents were due on or before May 7, 2021. 3. In a good faith effort, Counsel for the Defendants sent via-email to Plaintiff, correspondence giving Plaintiff ten (10) days to provide his responses to Second Request for Production (Exhibit B). 4. To date, Plaintiff has failed to respond or object to said request for production. WHEREFORE, the Defendants, CYNTHIA M. FOERSTER and CHAPP, INC., respectfully move this Court to enter an order compelling the Plaintiff, XIAO SHENG YUE, to provide responses to Second Requests for Production within ten (10) days of the date of the Court’s Order and any other further relief as is just and proper. CERTIFICATE OF SERVICE I HEREBY CERTIFY that, on this 25th day of May, 2021, I electronically filed the foregoing with the Clerk of the Court via the Florida Courts’ e-Filing Portal, pursuant to and in compliance with Rule 2.516, Florida Rules of Judicial Administration, which completes service by furnishing a true and correct copy of the foregoing via electronic mail to all counsel of record. LAW OFFICES OF SANTEIRO & GARRISON /s/ Jorge Santeiro, Jr. Jorge Santeiro, Jr. FBN 66230 6300 University Parkway Suite 101 Sarasota, FL 34240 Tel: (800) 226-3224 Ext. 1021 Primary: jsanteiro(@icci-group.com Secondary: ssmithS@tcci-group.com Secondary: legalservice@icci-group.com Attorney for Defendants Filing # 124503987 E-Filed 04/07/2021 03:21:17 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA XIAO SHENG YUE, Plaintiff, v. CASE NO.: 2020-CA-1106AN CYNTHIA M. FOERSTER AND CHAPP, INC., Defendants. eee DEFENDANTS, CYNTHIA M. FOERSTER AND CHAPP, INC.’S, SECOND REQUEST FOR PRODUCTION TO PLAINTIFF, XIAO SHENG YUE Defendants, CYNTHIA M. FOERSTER and CHAPP, INC., by and through the undersigned counsel and pursuant to Fla. R. Civ. P. 1.350, hereby request that Plaintiff, XIAO SHENG TUE, produce for inspection and/or copying the following documents, which shall be produced at the office of the undersigned counsel within thirty (30) days from the date of service of this Request: 1. Any and all records regarding or referring to any real estate properties you own in whole or in part and/or that you help manage, including but not limited to any deeds, warranty deeds, quit claim deeds, notes, mortgages, property tax records, applications, insurance records, records of rental income, leases, rental agreements, landlord-tenant agreements, eviction notices, management agreements, records of maintenance expenses, records of repair expenses, checks, ledgers, records of maintenance expenses, and any bookkeeping and accounting records regarding the management of the properties and the like. 2. Any and all documents referring to or evidencing costs to maintain any real estate properties you own, in whole or in part, and/or that you help manage, including but not limited to EXHIBIT "A" any invoices or receipts from Lowes, Home Depot, Sam’s Club and/or any other retailer or wholesaler. 3. Any and all documents referring to or evidencing any insurance policies issued regarding any real estate properties you own, in whole or in part, and/or that you help manage, including but not limited to any applications, policies, records of claims, claim notices, records of claims payments, records of repairs, checks, invoices, and the like. 4. Please complete and return the enclosed IRS release. 5. Any and all records, including but not limited to any and all deeds, warranty deeds, quit claim deeds, notes, mortgages, property tax records, insurance records, records of rental income, property and income tax records, leases, rental agreements, landlord-tenant agreements, eviction notices, management agreements, records of maintenance expenses, records of repair expenses, checks, ledgers, and any bookkeeping and accounting records and the like regarding the following properties: a. 4440 Philadelphia Circle, Kissimmee, FL b. 4716 Hemingway House Street, Kissimmee, FL c. 1197 S Beach Circle, Kissimmee, FL d. 11644 Nimbus Lane, Orlando FL 6. Any and all insurance records, including but not limited to any applications, policies, records of claims, claim notices, records of claims payments, records of repairs, checks, invoices, and receipts regarding or referring to any the following properties: a. 4440 Philadelphia Circle, Kissimmee, FL b. 4716 Hemingway House Street, Kissimmee, FL c. 1197 S Beach Circle, Kissimmee, FL d. 11644 Nimbus Lane, Orlando FL 7. Any and all documents regarding or referring to the farm property located at 11010 Lake Hatchineha Road, Haines City, FL 33844, including but not limited to any deeds, warranty deeds, quit claim deeds, notes, mortgages, property tax records, insurance records, bookkeeping records, accounting records, profit and loss statements, balance statements, documents referencing any assets, documents referencing any liabilities, documents referencing any inventory, livestock records, building and zoning records, building and zoning complaints, business occupancy permits/licenses, Department of Agriculture documents, licenses, any and all documents referencing or regarding any improvements or repairs, animal feed invoices/receipts, harvesting records, sales records, and the like. 8. Any and all non-privileged documents regarding or referring to any and all claims for bodily injury you made arising out of any injuries from 2008 to the present, including but not limited to any photos, estimates, medical records, radiological films/records, prescriptions, EMT/ambulance/fire department records, health insurance records, automobile insurance records, liens, medical bills, repair bills, invoices, claim notices, settlement documents, correspondence, email communications, checks and the like. 9. Any and all non-privileged documents regarding or referring to any and all claims for property damage you made from 2008 to the present, including but not limited to any photos, estimates, repair bills, Exactimate documents, invoices, claim notices, liens, settlement documents, correspondence, email communications, checks, and the like. 10. A true and complete copy of your passport, including all pages/stamps. CERTIFICATE OF SERVICE I HEREBY CERTIFY that, on this 7th day of April 2021, I electronically filed the foregoing with the Clerk of the Court via the Florida Courts’ e-Filing Portal, pursuant to and in compliance with Rule 2.516, Florida Rules of Judicial Administration, which completes service by furnishing a true and correct copy of the foregoing via electronic mail to all counsel of record. LAW OFFICES OF SANTEIRO & GARRISON /s/ Jorge Santeiro, Jr. Jorge Santeiro, Jr. FBN 66230 6300 University Parkway Suite 101 Sarasota, FL 34240 Tel: (800) 226-3224 Ext. 1021 Primary: jsanteiro@fecci-group.com Secondary: ssmithS@fcci-group.com Secondary: legalservice@icci-group.com Attorney for Defendants rom 4506 | Request for Copy of Tax Return | Matmebar 2020) : b Oo not sign this form unless all applicable lines have been completed. | OMB Ne. 1s46-p400 : ' ® Request may be rejected if the form is Incomplete or Megible. Department of he Treaniey | ‘ . eee ‘ Whenal Revenue Service | & Por more information about Form 4506, visi wwwirs.gav/fonnss06. i ig. You may be able to get your tax return or return information trom other sources. Hf you had your tax return completed ‘by 4 paid preparer, they should be able lo-provice. you. a copy ofthe return. The IRS can provide.a Tax Return Transoript for many returns. free. of charge: The tanscrint provides most of the ine entries from the orginal tax retum and ustially coritains the information that-a third party (such as. a mortgage cornpani) requires. Sée Form 4500-T, Request for Transcript of Tax Rehan, or you can quickly raquest transcripts by using our auiorated self-help service tools. Please visit us atiRS.gov and click on “Get a Tax Transcript. or call 1-800-908-6048, qa. Name shown on tax yeturn, Wf a joint return, enter the name shownfrst. qh First social security number on tax return, individual taxpayer identification number, or armployer identification nuraber (see Instructions} 2a ¥ a joint return, enter spouse's name shown on tax retin. 20 Second social securlly number or indivichial : laxpayer ideniificalion number i jointtax return i cae zi 2 Ourentname, address fincluding apt., room, or suite no.) chy, siete and ZIP code (see instructions) . teed 4. Previous aciiress shown on the last pelutri ied ff ditiorent from line 4 teee instructions) ws if the tax retum js io he maled to a third party Guch ae a morgage company),enter the third party's name, address. and lelephone number, | Jorge Santee, bsu, The Law Olices of Bantewas Garten, 8300 University Pkwy, Suite 105. Sarasoie, Saeq 0 Gaution: if ine tax rotumn is being seni te the third party, ensure that lines $ through 7 are completed! belore signing. (gee Instructions). { G Tax pohen pequesied. Form. 1040. 7720, 94), sic. and al attachments ss orgingily aubmilied to the (AS) wicking Portis W-2, schedules, or amended returis. Ooples of Forme 1040, 040A, and 104002 ae generally available tor 7 veers from Hiling before they are destroyed by law. Other relurrs may be avallatile for a longer period of time. Enter only one return nuniber. ff you need more thar one Qype of return, you must compiete another From 4506, > _— ee Note: if the copies riust be certified for court or atininistrative proceedings, check here . 2. cc we we ew OD i Year or period paquested. Evter ihe ending date of the tax year or peried using the movdd/yyyy fonmat (see instructions), 127 31 7 2013| Af SU 2014 12 4 81 7 2075| 32fS14 2018| 8 Z JSie? OTT t2. f mie, 2018 | 12 7 3 # 2019 . mcsa ia f 2020 & Fee, There is a $45 fee for each return requested. Full payment must be included with your request or Rwill be rejected. Make your check or money order payable to “United States Treasury.” Enter your SSN, ITIN, erEin and “Form 4506 request” on your check or money order. | a Costfordachretm 60 6 ee ee e ee ee ee we BR AO ® Number ofretumsrequesied aniline ko. 6 2 be ka kw oe ¢ Total cost. Multipiyjine Sa by dine Sb 2 a a we Bw ee & . 3 Hwecannot find the tax retum, We:wil felund:the fee.the refundShould go to the thingpartylisted oriling 5, check here ee be ry Caution Do not sign this form unless all applicable lines have been completed. Signature of taxpayer(s). | declare that am either the taxpayer whose name is shown.on line la or Za. or a person authorized toobtein ihe tex retum requested. ihe request applies to a joint return, at jeast one spbuse must sign. If signed by a cornorate officer, 1 percent dr mora sharéliolder, partner, managing member, guardian, fax matters nariner, exatulor, receiver, administrator, trusies, or party other than the taxpayer, | cerilfy that {have the authority to execute For 4506 on behalf-of the taxpayer, Note: This form must be received by IRS within 120 days of ihe sighature dete, (] Gignatery attests that he/stie has read the attestation clause and upon so reading ; ]: declaresthathe/shehastheauthoritytosigntheForm4506,SeeInstructions. > SignatureGesinstuctions} —OSStC*~=“i~*=“‘S*S*S*S*S”SS”S”””!”” BR=of taxpayeronline ' Sign Here , Pal ives nalleGf ine 1a above ig a corporation, parinarsiip, esiale, ormua > Spose'ssignawe === == SSSSSSSSCS~CSst Sa b hocee eee eee ee eee ee eee eee eee ne For Privacy Act and Paperwork Reduction Act Notice, sea page 2. Cat, No AIPRIE Fomi 4506 mey. 11-2020) e e 2 Law Offices of Santeiro & Garrison Jorge Santeiro, Esq. Mark Garrison, B.C.S.* “Florida Bar Certified in Civil Trial Law Christine M. Hoke, Esq.** *“Fhorida Bar Goerd Ceariified in Construction Law May 11, 2021 Via Email Only mstefan@forthepeople.com Iclaudio@forthepeople.com Manuel Stefan, Esq. Morgan & Morgan, P.A. 4495 South Semoran Blvd. Orlando, FL 32822 Re: Yue, Xiao Sheng v. Cynthia M. Foerster and Chapp, Inc. Dear Mr. Stefan: Please allow this letter to serve as our ten (10) day notice for your client, Xiao Sheng Yue, to respond to Defendants’ Second Request for Production, which was due May 7, 2021. If we do not receive responses within ten (10) days, I will have no alternative but to file a Motion to Compel. Should you have any questions or need additional information, please do not hesitate to contact me. Very Truly Yours, Jorge Santeiro Jorge Santeiro, Esq. JS/sas *All attorneys and staff are employees of FCCI Services, Inc., a member of the FCCI Insurance Group 6300 University Parkway, Suite 101, Sarasota, Florida 34240, Telephone 800-226-3224, Ext. 1021 EXHIBIT "B"