Filing # 79066254 E-Filed 10/09/2018 12:03:01 PM IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR SARASOTA COUNTY, FLORIDA CIVIL DIVISION COUNTRY CLUB OF SARASOTA HOMEOWNERS ASSOCIATION, INC., a Florida corporation, Plaintiff, v. Case No.: 2016-CA-004181 NC SARASOTA TENNIS CLUB HOLDINGS, LLC, a Florida corporation, a/k/a SARASOTA TENNIS CLUB HOLDINGS, LLC a/k/a SARASOTA SPORTS CLUB, Defendants. / NOTICE OF SUBPOENA TO NON-PARTY BARBARA ZUPNIK PURSUANT TO RULE 1.351 Notice is hereby given that the Defendants, SARASOTA TENNIS CLUB HOLDINGS, LLC, a Florida corporation, a/k/a SARASOTA TENNIS CLUB HOLDINGS, LLC a/k/a SARASOTA SPORTS CLUB, by and through undersigned counsel, intend to serve the attached subpoena pursuant to Rule 1.351, Fla. R. Civ. P. The attached subpoena will be issued if no objections are served within the time frame provided by Rule. Date: October 9, 2018. EWUSIAK LAW, P.A. /s/ Fla. Bar No.: 0509361 6601 Memorial Highway, Suite 311 Tampa, FL 33615 T: 727.286.3559 1
F: 727.286.3219 E: joel@ewusiaklaw.com Counsel for Defendants CERTIFICATE OF SERVICE I HEREBY certify that, on October 9, 2018, the foregoing document was served via Email using the Florida Courts E-Filing Portal, which sends notice of electronic filing to all counsel of record. /s/ 2
IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR SARASOTA COUNTY, FLORIDA CIVIL DIVISION COUNTRY CLUB OF SARASOTA HOMEOWNERS ASSOCIATION, INC., a Florida corporation, Plaintiff, v. Case No.: 2016-CA-004181 NC SARASOTA TENNIS CLUB HOLDINGS, LLC, a Florida corporation, a/k/a SARASOTA TENNIS CLUB HOLDINGS, LLC a/k/a SARASOTA SPORTS CLUB, Defendants. / SUBPOENA DUCES TECUM THE STATE OF FLORIDA: TO: BARBARA ZUPNIK 3834 Torrey Pines Way Sarasota, FL 34238 YOU ARE COMMANDED to appear at 6601 Memorial Highway, Suite 311, in Tampa, Florida, on November, 2018, at 10:00 am, and to have with you at that time and place the following: 1. All communications relating to Eran Salu. 2. All communications relating to Sarasota Sports Club. 1
Club. 3. All communications relating to the potential purchase of Sarasota Sports 4. All communications with Sabal Bank, other than a bank statement. 5. All communications with Lee Wetherington Homes and West Coast Land Partners, LLC. 6. All communications relating to TPC Prestancia, other than a billing statement. 7. All communications with any of the following individuals relating to the HOA or the Board: Jim Brown, Jim Brown, Mary Louise Gerritsen, Richard Bronge, Steve Lloyd, Stan Valerga, Elaine Wells, Barbara Zupnik, Clive Burnett, Robert Anderson, Claude Boles, Clayton Thompson, Bill McCarthy, Marshall Pepe, Doc Glidwell, Kristina Moreland, Johanna Freeman, Jean & David Dunlop, Mike & Claudia Hurley, Tim Close, Lannon Walker, Sindy Carr, Debi Parisi, and Susan & Bill Miller. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. If you fail to: (1) appear as specified; or (2) furnish the records instead of appearing as provided above; or 2
(3) object to this subpoena, you may be in contempt of court. You are subpoenaed to appear by the following attorney, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. DATED on October, 2018 For the Court Ewusiak Law, P.A. Fla. Bar No.: 0509361 6601 Memorial Highway, Suite 311 Tampa, FL 33615 P: 727.286.3559 F: 727.286.3219 E: joel@ewusiaklaw.com Counsel for Defendants If you are a person with a disability who needs any accommodation in order to respond to this subpoena, you are entitled, at no cost to you, to the provision of certain assistance. Please contact, Ewusiak Law, P.A., 6601 Memorial Highway, Suite 311, Tampa, FL, 33615, Phone: 727.286.3559 at least 7 days before your scheduled appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711. 3