SUBPOENA - CASE NO. 07-661 CC 24o~62~G
N THE COUNTYCOURT IN AND
FOR DADE COUNTY FLORIDA
GENERAL DIVISION
Case No.: 07-661 CC 24
LINCOLN PALMS PROPERTIES, LLC, - ~"
Plaintiff,
:~ ~.. __.
vs. -
JEROME VICENTI, et al., . ~`~ ` `' - ` ` ` ~ ~ -
Defendant. EW Cz ,. _ i T ~r ti , ~.:^~.~rt cif
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
(** RECORDS MAY BE MAILED IN LIEU OF APPEARANCE**)
c?
STATE OF FLORIDA ~ ~ ~
s• ~
TO: CITY OF MIAMI BEACH ~~-- ~
Attn: Juan Andres Perez tT ~
1700 Convention Center Drive ~. °"'
Miami Beach, FL 33139 ~~ ~
YOU ARE HEREBY COMMANDED to appear at the Law Offices of Kaba & Assocs,~~' ~
P.A., 1840 West 49~' Street, Suite 235, Hialeah, Florida 33012, on Monday, August 15, 2007 ar d to `~
have with you at that time and place the following:
PLEASE PRODUCE ANY AND. ALL RECORDS, CORRESPONDENCE,
APLLICATIONS, PERMITS, LICENSES, -OPEN PERMITS, COMPLAINTS,
VIOLATIONS, NOTICES AND ANY AND ALL OTHER RECORDS PERTAINING
TO THE PROPERTY LOCATED AT 1610 MERIDIAN AVENUE PRESENTLY
OWNED BY LINCOLN PALMS PROPETIES, LLC FROM THE DATE. SOUTH
BEACH MERIDIAN INVESTORS' OWNED INTEREST IN THE PREVIOUSLY
MENTIONED PROPERTY CEASED UP TO THE PRESENT, INCLUDING BUT
NOT LIlVIITED TO THE FOLLOWING DOCUMENTATION:
1. LICENSING INFORMATION (Certificate of Use/Occupational License
Renewal Notice): Lincoln Palms Properties LLC pertaining to Building
1610 Meridian Avenue;
2. ACCOUNT INFORMATION: Account No. RL06002737;
3. ANY AND ALL CODE COMPLIANCE DOCUMENTS: Lincoln Palms
Properties LLC pertaining to Building 1610 Meridian Avenue.
~. ANY AND ALL VIOLATIONS THAT EXISTED ON LINCOLN
PALMS PROPERTY LLC AND SOUTH BEACH MERIDL~N
LN~'ESTORS FROM JANUARY 1, 2006 TO PRESElV"T;
5. ANY AND ALL VIOLATIONS THAT EXISTED ON 1610 MERIDIAN
AVENUE FROM JANUARY 1, 2006 TO PRESENT;
6. COMPLAINT HISTORY ON THE PROPERTY: Any and all documents
of complaints and violations on the property pertaining to 1610 Meridian
Avenue;
7. ALL COPIES AND DATES OF FIl2ST LICENSE THAT LINCOLN
PALMS PROPERTIES OBTAINED AND ANY AND ALL
SUBSEQUENT LICENSES THAT HAVE BEEN ISSUED, REVOKED
OR SUSPENDED;
8. ANY AND ALL CORRESPONDANCE BETWEEN CITY OF MIAMI
BEACH AND LINCOLN PALMS PROPERTIES LLC;
9. ANY AND ALL VIOLATIONS AND/OR COMPLAINTS RECEIVED
OR ISSUED PERTAINING TO: 1610 Meridian Avenue, Unit 3, Miami
Beach, Miami-Dade County, Florida 33139 against Lincoln Palms
Properties LLC FROM MARCH 1, 2006 TO PRESENT;
10. ANY AND ALL VIOLATIONS AND NON-COMPLIANCE NOTICES
SENT TO LINCOLN PALMS PROPERTIES LLC FROM JANUARY
2006 TO PRESENT;
11. ANY AND ALL SUSPENSIONS, REVOCATIONS, OR NOTICES
SENT TO LINCOLN PALMS PROPERTIES BY THE CITY OF
MIAMI BEACH FROM JANUARY 2006 TO PRESENT;
12. ANY AND ALL CERTIFICATES OF USE/OCCUPATIONAL
LICENSES LSSUED TO LINCOLN PALMS PROPERTIES LLC.
If you fail to appear, you may be in contempt of Court.
Unless you are excused by the
(I) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena.
You may be in contempt of court. You are subpoenaed by the attorney whose names
appear on this subpoena and unless excused from this subpoena by the attorneys or the Court, you
shall respond to this subpoena as directed.
Dated on: ~ ~ 3 ~ , 2007.
Kaba 8c Associates, P.A.
1840 West 49`h Street
Suite 235
Hialeah, Florida 33022
Phone: 786-394-8787
4. ' ~~~
BY: ~ ~-~
ises Kaba, lIl, Esq.
Florida Bar No.: 570125
MK/mb
1N THE COUNTYCOURT 1N AND
FOR DADS COUNTY FLORIDA
GENERAL DIVISION
Case No.: 07-b61 CC 24
LINCOLN PALMS PROPERTIES, LLC
Plaintiff,
vs.
JEROME VICENTI, et al.,
Defendant.
SUBPOENA FOR TRIAL
DUCES TECUM
THE STATE OF FLORIDA:
TO: CITY OF MIAMI BEACH
Attn: Juan Andres Perez
1700 Convention Center Drive
Miami Beach, FL 33139
YOU ARE COMMANDED to appear before the Damn P. Gayles, a Judge Dade County
Courthouse, 73 West Flagler Street, Room 712, Miami, Florida, 33130 on the 24`" day of August
2007, at 1:30 p.m., to testify in this action. If you fail to appear, you may be in contempt of court.
Unless you are excused by the
(1) appear. as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena.
PLEASE PRODUCE ANY AND ALL RECORDS, CORRESPONDENCE,
APLLICATIONS, PERMITS, LICENSES, OPEN PERMITS, COMPLAINTS,
VIOLATIONS, NOTICES AND ANY AND ALL OTHER RECORDS PERTAINING
TO THE PROPERTY LOCATED. AT 1610 MERIDIAN AVENUE PRESENTLY
OWNED BY LINCOLN PALMS PROPETIES, LLC FROM JANUAY 1, 2006 UP
TO THE PRESENT, INCLUDING BUT NOT LIMITED TO THE FOLLOWING
DOCUMENTATION:
1. LICENSING INFORMATION (Certificate of Use/Occupational License
Renewal Notice): Lincoln Palms Properties LLC pertaining to Building
1610 Meridian Avenue;
2. ACCOUNT INFORMATION: Account No. RL06042737;
3. ANY AND ALL CODE COMPLIANCE DOCUMENTS: Lincoln Palms
Properties LLC pertaining to Building 1610 Meridian Avenue.
4. ANY AND ALL VIOLATIONS THAT EXISTED ON LINCOLN
PALMS PROPERTY LLC AND SOUTH BEACH MERIDIAN
INVESTORS FROM JANUARY i, 2006 TO PRESENT;
5. ANY AND ALL VIOLATIONS THAT EXISTED ON 1610 MERIDIArl
AVENUE FROM JANUARY 1, 2006 TO PRESENT;
6. COMPLAINT HISTORY ON THE PROPERTY: Any and all documents
of complaints and violations on the property pertaining to 1610 Meridian
Avenue;
7. ALL COPIES AND DATES OF FIRST LICENSE THAT LINCOLN
-PALMS PROPERTIES OBTAINED AND ANY AND ALL
SUBSEQUENT LICENSES THAT HAVE BEEN ISSUED, REVOKED
OR SUSPENDED;
8. ANY AND ALL CORRESPONDANCE BETWEEN CITY OF MIAMI
BEACH AND LINCOLN PALMS PROPERTIES LLC;
9. ANY AND ALL VIOLATIONS AND/OR COMPLAINTS RECEIVED
OR ISSUED PERTAINING TO: 1610 Meridian Avenue, Unit 3, Miami
Beach, Miami-Dade County, Florida 33139. against Lincoln Palms
Properties LLC FROM MARCH 1, 2006 TO PRESENT;
10. ANY AND ALL VIOLATIONS AND NON-COMPLIANCE NOTICES
SENT TO LINCOLN PALMS PROPERTIES LLC FROM JANUARY
2006 TO PRESENT;
11. ANY AND ALL SUSPENSIONS, REVOCATIONS, OR NOTICES
SENT TO LINCOLN PALMS PROPERTIES BY THE CITY OF
MIAMI BEACH FROM JANUARY 2006 TO PRESENT;
12. ANY AND ALL CERTIFICATES OF USE/OCCUPATIONAL
LICENSES ISSUED TO LINCOLN PALMS PROPERTIES LLC.
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.
Please contact Moises Kaba III, Esq. at (786) 394-8787 to confirm the trial date
and time.
WITNESS my hand and the seal on ~ day of August, 2007.
KABA & ASSOCIATES, P.A.
Attorney for Respondent
1840 West 49 Street
Suite 235
Hialeah, FL 33012
Telephone: (?86) 394-8787
By: ~'~
Mois Kaba III, Esq.
Florida Bar No.: 570125
MK/mb
IN THE COU?~ITYCOURT IN .4N-D
FOR DADS COUNTY FLORIDA
GENERAL DNISION
Case No.: 07-661 CC 24
LLNCOLN PALMS PROPERTIES, LLC,
Plaintiff,
vs.
JEROME VINCENTI, et al.,
Defendant.
CERTIFICATE OFNON-OBJECTION
I HEREBY CERTIFY that no objection to production under Rule 1.351, Fla, R. Civ. P.,
is being asserted by opposing counsel as per his agreement waiving the notice requirement of
Rule 1.351 and having no objections to the issuance of the intent to serve a subpoena directing the
production of documents or things without deposition upon the following:
1. RC: Betty Smith
2. RC: Juan Andres Perez
to produce the items at the time and piace specified in the subpoenas.
CERTIFICATE OF SERVICE
I HEI;.EBY CERTffY copy of the foregoing motion was forwarded via regular U.S. Mail
on this 3~ day of August, 2007 to Alexander E. Borell, Esq. 3211 Ponce de Leon Blvd., Suite
200, Coral Gables, FL 33134.
KABA & ASSOCIATES, P.A.
Attorney for Respondent
1840 West 49 Street
- ~ Suite 23~ - -
Hialeah, FL 33012
Telephone: (786) 3/94-8787
Moises Kaba III, Esq.
Florida Bar No.: 570125
MK/mb