RESPONDENT'S RESPONSE TO REQUEST FOR PRODUCTION
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1 " BEFORE THE INVESTIGATIVE PANEL OF THE9 FLORIDA JUDICIAL QUALIFICATIONS COMMISSI STATE OF FLORIDA INQUIRY CONCERNING A JUDGE NO CASE NO: SC RE: ANA M. PANDO / RESPONDENT'S RESPONSE TO REQUEST FOR PRODUCTION Respondent, Honorable Ana M. Pando, by and through her undersigned counsel, hereby responds to the Florida Judicial Qualifications Commission's Request for Production, dated June 25, 2012, and states: REQUEST FOR PRODUCTION NO.1: All s, including attachments, exchanged between you and Mark Cereceda, or anyone acting on his behalf, during the relevant time period. REQUEST FOR PRODUCTION NO.2: All other documents exchanged between you and Mark Cereceda, or anyone acting on his behalf, during the relevant time period. 25 West Flagler Street, Suite 800, Miami, FL 33130, Miami Fax Fort Lauderdale
2 " CASE NO: SC REQUEST FOR PRODUCTION NO.3: All s, including attachments, exchanged between you and Roly Marante, or anyone acting on his behalf, during the relevant time period. The attached is believed to have been previously furnished but, out of an abundance of caution, a copy has been attached hereto. REQUEST FOR PRODUCTION NO.4: All other documents exchanged between you and Roly Marante, or anyone acting on his behalf, during the relevant time period. REQUEST FOR PRODUCTION NO.5: All s, including attachments, exchanged between you and Lester Barreras, or anyone acting on his behalf, during the relevant time period. REQUEST FOR PRODUCTION NO.6 All other documents exchanged between you and Lester Barreras, or anyone acting on his behalf, during the relevant time period West Flagler Street, Suite BOO, Miami, FL 33130, Miami Fax Fort Lauderdale
3 CASE NO: SC REQUEST FOR PRODUCTION NO.7: Your personal cell phone records for the calendar years 20 I 0, 2011, and 2012 reflecting any call or text message activity between you and Mark Cereceda. RESPONSE These documents have already been produced. REQUEST FOR PRODUCTION NO.8: Your personal cell phone records for the calendar years 2010, 2011, and 2012 reflecting any call or text message activity between you and Roly Marante. RESPONSE These documents have already been produced. REQUEST FOR PRODUCTION NO.9: Your personal cell phone records for the calendar years 2010, 2011, and 2012 reflecting any call or text message activity between you and Lester Barreras. RESPONSE These documents have already been produced. 2S West Flagler Street, Suite 800, Miami, FL 33130, Miami Fax Fort Lauderdale
4 CASE NO: SC REQUEST FOR PRODUCTION NO. 10: All documents reflecting any gifts or loans of money to you from Mark Cereceda (other than contributions to your judicial campaigns) from 2002 present. Dated this 31 st day of August, Respectfully submitted, PODHURST ORSECK, P.A. Attorneys for Respondent 25 West Flagler Street Suite 800 Miami, FL Phone: (305) Fax: (305) By: R1lb.A C~.,..1"""" \..v1<p& Robert C. Jose~ESq. 0 Florida Bar No: rjosefsbergca;podhurst.com 4 25 West Flagler Street, Suite 800, Miami, FL 33130, Miami Fax Fort Lauderdale
5 CASE NO: SC CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been furnished by and u.s. Mail as listed below on this 31st day of August, 2012, to the following: Michael L. Schneider, Esq. General Counsel Judicial Qualifications Commission UQC) 1110 Thomasville Road Tallahassee, FL (850) Fax: (850) mschneider@floridajqc.com Counsel for the Judicial Qualifications Commission and Lansing C. Scriven, Esq. Quarles and Brady, LLP Special Counsel 101 E. Kennedy Blvd., Suite 3400 Tampa, FL (813) Fax: (813) Lansing.scriven@:quarles.com Special Counsel to the Judicial Qualifications Commission and Honorable Paul Backman Florida Judicial Qualifications Commission 1110 Thomasville Road Tallahassee, FL (850) Fax: (850) Pback64040@aol.com Chair Hearing Panel, Judicial Qualifications Commission 5 25 West Flagler Street, Suite 800, Miami, FL 33130, Miami Fax Fort Lauderdale
6 CASE NO: SC and John Beranek, Esq. Ausley & McMullen P.O. Box 391 Tallahassee, FL (850) Fax: (850) Jberanek(a;ausley.com Counsel to the Hearing Panel, Judicial Qualifications Commission Michael A. Catalano, Esq NW 13 th Court Miami, FL Co-Counsel for Respondent Also, per Rules 9, and 10 of the Florida Judicial Qualifications Commission, all of our pleadings are being filed as follows: Original and 9 copies to the clerk of the Florida Supreme Court by US Mail, Florida Supreme Court Clerk, 500 South Duval Street, Tallahassee, FL An electronic copy will be sent to the Clerk of the Court per Supreme Court Rule: AOSC to: e-file@flcourts.org By: Robe C~~b.r t?jjf- Robert C. Jo fsberg, Esq West Flagler Street, Suite 800, Miami, FL 33130, Miami Fax Fort Lauderdale
7 MARY E. VALLEDOR From: Sent: To: Subject: Attachments: ROBERT C. JOSEFSBERG Monday, July 09, :10 PM MARY E. VALLEDOR Fwd: Reinstatement - Department of State Reinstatement of corporation.docx; A TTOOOO1.htm Sent from my iphone Begin forwarded message: From: Ani <pand0325(a ḷ aol.com> Date: July 9,20128:22:48 PM EDT To: <rjosefsberg@podhufslcom> Cc: <pand0325(maol.com> Subject: Fwd: Fw: Reinstatement - Department of State The only I found-not an person! Original message Subject: Fw: Reinstatement - Department of State From: "Mark Cereceda, DC" <marklzdhvrc.com> To: "pand0325(@aol.com" <pand0325rw.aol.com> CC: Sent on the Sprint Now Network from my BlackBerry From: Roly Marante <roly.maranteici:b'111ail.com> Date: Tue, 11 Oct :57: To: <pando325@,aol.com> Cc: Mark Cereceda, DC<mark0)tlwfc.com> Subject: Reinstatement - Department of State Dear Honorable Judge Pando, It was a pleasure to be able to speak to you this afternoon. Pursuant to our conversation, attached is a copy ofthe letter requesting relief and assistance in the reinstatement of a Florida corporation. As always, we appreciate your consideration with this most important matier. Please do not hesitate to contact me if I can be offurther assistance to you. Respectfully, 1
8
9 October 10, 2011 The Honorable Ana Maria Pando Judge Eleventh Judicial Circuit Hialeah Courthouse 11 East 6 th Street Hialeah, FL The Honorable Judge Pando: We respectfully request that you issue an order to the Florida Secretary of State, Division of Corporations to reinstate the following corporation: Florida Wellness & Rehabilitation Center, Inc. # that was involuntarily closed by my accountant on May 4,2011. Unfortunately, we made a major administrative oversight in ordering this corporation to be involuntarily dissolved and appreciate your immediate relief to correct this action. This order can be sent to the attention of: Jay Kassees, Division Director, Division of Corporations - Florida Secretary of State, The Clifton Building, 2661 Executive Center Circle, Tallahassee, FL jkasses@dos.state.f1.us. I thank you for your immediate consideration of this matter. Respectfully, Mark Cereceda President
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