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Extract to table / meet-and-confer-suncoast-records.docx
meet-and-confer-suncoast-records.docx
Parties
HARKNESS LLP
Crane LLP
Verimark Hospitality Group Inc
Coastal Palms Franchise Holdings LLC
Suncoast Room Management Inc
Plaintiff Verimark Hospitality Group Inc
M. Calloway
Gulf Breeze Hospitality LLC
Dates
September 8, 2022
September 6, 2022
June 17, 2022
June 14, 2022
September 15, 2022
July 11, 2022
January 1, 2013
December 31, 2021
August 22, 2022
June 20, 2022
Amounts
$197.8
Obligations
However, you contended that this overlapping control does not collapse the corporate distinction between the two entities for purposes of discovery obligations and that each entity must be treated independently
Verimark's Position — Why Suncoast Records Must Be Produced A
Under well-established Florida law, a party to litigation is required to produce documents that are within its "possession, custody, or control
As a party defendant, Suncoast has its own independent obligation to respond to discovery, and the assertion that Verimark must serve a subpoena on a named defendant is wholly without basis
Coastal Palms shall produce all responsive financial records of Suncoast Room Management Inc
Any such limitations must be agreed upon in writing by both parties