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Home My WebLink AboutPROJECT INFORMATIONSCANNED BY St. Lucie County December 20, 2021 Planning & Development Services Building & Code Regulation Attn: Building Dept. 2300 Virginia Avenue Fort Pierce, FL 34982 Gene courtroomsciences.com Date: -la�a, Time: _A2; --.SW—_PS#:. RE: Riverpointe of St. Lucie Property Owners Association, Inc. v. Coastal Pool and Pavers, Inc. 50 2020 CA 700 Dear Sir/Madam; Please take note that David Drahos of Kubicki Draper has commissioned our firm to obtain records in the above -referenced matter. Enclosed please find a legal request for copies of records. Please respond to this request by producing a legible copy of the requested records/information to our office via CD, USB, email, fax, mail, etc. on or before 12/30/2021. Should production of records results in a fee, CSI must receive an invoice in order to process payment Email: erecords@courtroomsciences.com Fax: (214) 744-2678 Mail: 4950 N. O'Connor Road, Suite 152, Irving, TX 75062-2778 If applicable, your response is to include a fully executed copy of the enclosed document(s) as indicated below. Should a notary be required, please be advised your bank may provide notary service free of charge. If you do not have access to a notary, call when records are ready and we will provide notary service. Affidavit x Certification/Declaration Direct Written Questions Questions? Call 972-719-5000 Option 2 or email us at records@courtroomsciences.com. Please respond whether you do or do not have any records. Thank you for your prompt attention in this matter. CSI Global Deposition Services Order No. R10717.005 CSI Global Deposition Services 4950 N. O'Connor Road Suite 152, Irving, TX 75062-2778 Email: erecords@courtroomsciences.com / Phone: (877)-784-0004/ Fax: (214)-744-2678 SCANNED BY St. Lucie County IN THE CIRCUIT COURT OF THE 19TH JUDICIAL CIRCUIT IN AND FOR INDIAN RIVER COUNTY, FLORIDA CASE NO.: 50 2020-CA-700 RIVERPOINTE OF ST. LUCIE PROPERTY OWNERS ASSOCIATION, INC, Plaintiff, V. SERVED: DATE: i�83�at COASTAL POOL AND PAVERS, INC., a BY: 5t,,) Florida corporation and CUSTOM POOL PLASTERING, INC., a Florida DESCRIPTION: Corporation, Defendants. TIME: (\:36 H SUBPOENA DUCES TECUM WITHOUT DEPOSITION TO: Custodian of Records for: Planning & Development Services Building & Code Regulation Division Attn: Building Dept. 2300 Virginia Avenue Fort Pierce, FL 34982 PS#: c�g•53 YOU ARE COMMANDED to furnish to Kubicki Draper c/o CSI Global Deposition Services, 4950 N. O'Connor Road, Suite 152, Irving TX 75062-2778 within ten (10) days of receipt of this Subpoena and to have with you at that time and place the following: Entire File, including any and all permits opened/permit applications, inspection reports for the pool located at 2035 Lynx Drive, Fort Pierce, FL 34949. HIPAA Certificate- This certifies that this subpoena has been issued in compliance with the Health Insurance Portability and Accountability Act of 1996, (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(1)(ii) as this subpoena has been issued pursuant to Rules 1.410 and 1.351, Fla. R. Civ. P. The Party issuing this subpoena has made a good faith attempt to provide written notice to the Plaintiff/Patient listed above by sending his/her attorney, a notice of the issuance of this subpoena which included sufficient information about the litigation to permit the Plaintiff/Patient to raise an objection to the court or administrative tribunal. The time for the Plaintiff/Patient to raise an objection pursuant to Rule 1.351, Fla. R. Civ: P. has expired and no objections were file& R10717.005 These items will be inspected and maybe copied at that time. You will not be required to surrender the original items. You may comply with 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 CSI Global Deposition Services, whose name appears on this subpoena and thereby eliminate the requirement of your appearance at this 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 and CSI Global Deposition Services, whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. WITNESS MY HAND, this 20th day of December, 2021. KUBICKI DRAPER Attorneys for Defendant 1700 Palm Beach Lakes Boulevard, Suite 800 West Palm Beach, Florida 33401 Direct Line: (561) 615-4332 Facsimile: (561) 640-0524 DMD-KD(@kubickidEaper.com /s/ David M. Drahos By: David M. Drahos, Esq. Florida Bar No.: 25907 Contempt. Failure by any person without adequate excuse to obey a subpoena served upon that person may he deemed in contempt of the court from which the subpoena is issued or a district court in the county in which the subpoena is served. R10717.005 Declaration of Custodian of Records for Planning & Development Services Building & Code Regulation Division Records Pertaining TO: Planning & Development Services Building & Code Regulation Division I declare under penalty of perjury that the following statements are true and correct: 1. My name is . I am of sound mind, capable of malting this declaration, and personally acquainted with the facts herein stated. 2. I am the custodian of records for Planning & Development Services Building & Code Regulation Division. 3. Attached are records from Planning & Development Services Building & Code Regulation Division pertaining to 2035 Lynx Drive, Fort Pierce, FL 34949. These represent all records kept by Planning & Development Services Building & Code Regulation Division concerning 2035 Lynx Drive, Fort Pierce, FL 34949. 4. They are kept by Planning & Development Services Building& Code Regulation Division in the course of regularly conducted business activity. Also, it was the regular practice of that business activity for an employee or representative of Planning & Development Services Building & Code Regulation Division with knowledge of the act, event, condition, opinion, or diagnosis to make the record or to transmit information of the occurrence to be included in the records. The records attached to this declaration -were made at or near the time of the occurrence of the matters set forth by, or from information transmitted by, a person with knowledge of those matters, or were made reasonably soon thereafter. The records attached hereto are exact duplicates of the originals. Under penalty of perjury, I declare the foregoing statements in this Declaration are true and correct. Executed on . 2021. Records Custodian - Planning & Development Services Building & Code Regulation Division Order No. R10717.005 Filing # 140571601 E-Filed 12/17/2021 10:16:56 AM IN THE CIRCUIT COURT OF THE 19TH JUDICIAL CIRCUIT IN AND FOR INDIAN RIVER COUNTY, FLORIDA CASE NO.: 50 2020-CA-700 RIVERPOINTE OF ST. LUCIE PROPERTY OWNERS ASSOCIATION, INC, Plaintiff, V. SCANNED COASTAL POOL AND PAVERS, INC., a BY Florida corporation and CUSTOM St. Lucie COunty POOL PLASTERING, INC., a Florida Corporation, Defendants. CERTIFICATION OF NO OBJECTION WE HEREBY CERTIFY that no objections to production under Rule 1.351, Florida Rules of Civil Procedure, has been served upon the undersigned within ten (10) days of service of the notice given to every other party of the intent to serve a subpoena upon a person who is not a party, directing the production of documents or things without deposition, to wit: Leak Seekers of Florida, LLC (Business Records) 1704 33rd Avenue Vero Beach, FL 32963 Aquatic Surfaces of the Treasure Coast, Inc. (Business Records) 635 NW Buck Hendry Way Stuart, FL 34994 Schutt Property Management Company (Business Records) 1209 U.S. Hwy.1 Sebastian, FL 32958 EI-Sid Engineering, Inc. (Business Records) 139 Isle Verde Way Pahn Beach Gardens, FL 33418 R10717.001-009 Planning & Development Services Building & Code Regulation Division (Business Records) Attn: Building Dept 2300 Virginia Avenue Fort Pierce, FL 34982 Agua Vida Services, Inc. (Business Records) 1233 South US Hwy.1 Vero Beach, FL 32962 Ken's Pool & Spa Repair, LLC (Business Records) 310 28th Court SW Vero Beach, FL 32968 Coldwell Banker Paradise (Business Records) 4007 Florida North AlA Fort Pierce, FL 34949 Blue Dolphin Pool Service (Business Records) 4676 US Hwy.1 Vero Beach, FL 32967 R10717.001-009 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-service to: Michael J. Kissner, Esq. and K. Shayda Kayhani, Esq., Block & Scarps, P.A., 1515 Indian River Blvd., Suite A-220, Vero Beach, Florida 32960, mkissner(a),blockscama.com, sprince(ablockscarpa com Counsel for Plaintiff, and Anthony C. Soviero, Esq., 1025 w. Indiantown Road, Suite 106, Jupiter, Florida 33458 ton cu oviero.net Counsel for Defendant, Custom Pool Plastering, Inc., this 13th day of December, 2021. �GPN�EO 8� �Urty R10717.001-009 KUBICKI DRAPER Attorneys for Defendant 1700 Palm Beach Lakes Boulevard, Suite 800 West Palm Beach, Florida 33401 Direct Line: (561) 615-4332 Facsimile: (561) 640-0524 DMD-KD (a)kubickidraner. com Isl David M. Drahos By: David M. Drahos, Esq. Florida Bar No.: 25907