EXHIBIT 2 

 

Case 1:20-cv-22423-UU Document 42-2 Entered on FLSD Docket 10/01/2020 Page 1 of 20
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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 1:20-cv-22423-UU

SH GROUP GLOBAL IP HOLDINGS, L.L.C.,

Plaintiff,

v.

2399 COLLINS AVENUE CONDOMINIUM 

ASSOCIATION, INC. and JOHN P. BOSTANY,

Defendants.

DEFENDANT BOSTANY’S RESPONSES TO PLAINTIFF SH GROUP GLOBAL IP

HOLDINGS, L.L.C.’S FIRST SET OF REQUESTS FOR PRODUCTION TO 

DEFENDANT JOHN P. BOSTANY 

Pursuant to Rules 26 and 36 of the Federal Rules of Civil Procedure, and the Local Rules 

of the Southern District of Florida, Defendant John P. Bostany (“Bostany”) hereby responds to 

Plaintiff SH Group Global IP Holdings, L.L.C.’s First Set of Requests for Production as follows:

DOCUMENTS TO BE PRODUCED 

1. All DOCUMENTS CONCERNING or REFERRING OR RELATING TO YOUR 

and/or the ASSOCIATION’s consideration, selection and clearance of the ASSOCIATION’S 

CLAIMED MARK, and any alternatives of the ASSOCIATION’S CLAIMED MARK, in the 

United States, including but not limited to, searches, investigations, SURVEYS, MARKET 

RESEARCH, studies, research, polls, reports and opinions that the YOU or the ASSOCIATION 

has ever conducted, received, requested, or seen.

RESPONSE: Bostany objects to this request as vague, ambiguous, overly broad and unduly 

burdensome, and not proportional to the needs of the case, to the extent it seeks “[a]ll 

DOCUMENTS CONCERNING or REFERRING OR RELATING TO YOUR and/or the 

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ASSOCIATION’s consideration, selection and clearance of the ASSOCIATION’S CLAIMED 

MARK, and any alternatives of the ASSOCIATION’S CLAIMED MARK, in the United States, 

including but not limited to, searches, investigations, SURVEYS, MARKET RESEARCH, 

studies, research, polls, reports and opinions that the YOU or the ASSOCIATION has ever 

conducted, received, requested, or seen.” Bostany will make a reasonable search for documents 

and communications relating to the consideration, selection, and clearance of the 

ASSOCIATION’S CLAIMED MARK, and any alternatives of the ASSOCIATION’S CLAIMED 

MARK, and shall produce non-privileged documents, to the extent they exist.

2. All DOCUMENTS CONCERNING or REFERRING OR RELATING TO YOUR 

and/or the ASSOCIATION’s consideration, selection and clearance of any mark or term 

incorporating the term “1” in the United States, including but not limited to, searches, 

investigations, SURVEYS, MARKET RESEARCH, studies, research, polls, reports, and opinions 

that YOU or the ASSOCIATION has ever conducted, received, requested, or seen.

RESPONSE: Bostany objects to this request to the extent it seeks documents and information 

protected by attorney-client or work product privileges. Bostany will make a reasonable search for 

documents regarding the consideration, selection and clearance of any mark or term incorporating 

the term “1” and shall produce non-privileged documents, to the extent they exist.

3. All DOCUMENTS and COMMUNICATIONS CONCERNING or REFERRING 

OR RELATING TO the decision to adopt the ASSOCIATION’S CLAIMED MARK.

RESPONSE: Bostany objects to this request to the extent it seeks documents and information 

protected by attorney-client or work product privileges. Bostany will make a reasonable search for 

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documents and communications relating to the Association’s decision to adopt the Association’s 

1 HOMES mark and shall produce non-privileged documents, to the extent they exist.

4. All DOCUMENTS and COMMUNICATIONS CONCERNING or REFERRING 

OR RELATING TO the ASSOCIATION’s applications before the USPTO, or any other 

application within the United States, for the ASSOCIATION’S CLAIMED MARK.

RESPONSE: Bostany objects to this request to the extent it seeks documents and information 

protected by attorney-client or work product privileges. Bostany further objects to the request as 

unduly burdensome because documents concerning the Association’s applications are of public 

record and may be equally accessible to Plaintiff. Bostany will make a reasonable search for and 

shall produce non-privileged documents, to the extent they exist.

5. All DOCUMENTS and COMMUNICATIONS CONCERNING or REFERRING 

OR RELATING TO YOUR and/or the ASSOCIATION’s knowledge of SH GROUP, SH 

GROUP’S MARKS, and/or SH GROUP’S GOODS AND SERVICES.

RESPONSE: Bostany objects to this request as vague, ambiguous, overly broad and unduly 

burdensome, and not proportional to the needs of the case, to the extent it seeks all documents and 

communications concerning, referring, or relating to the Bostany’s or the Association’s 

“knowledge of SH GROUP, SH GROUP’S MARKS, and/or SH GROUP’S GOODS AND 

SERVICES.” Bostany further objects to this request to the extent it seeks documents and 

information protected by attorney-client or work product privileges. Bostany will make a 

reasonable search for and shall produce non-privileged documents, to the extent they exist.

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6. DOCUMENTS sufficient to show all investors, shareholders, stakeholders, 

condominium association members, BOARD members, or others having an interest in the 

ASSOCIATION, the ASSOCIATION’S GOODS AND SERVICES, and/or the 

ASSOCIATION’S CLAIMED MARK.

RESPONSE: Bostnay further objects to this request as vague, ambiguous, overly broad and 

unduly burdensome, and not proportional to the needs of the case, to the extent it seeks documents 

“sufficient to show all investors, shareholders, stakeholders, condominium association members, 

BOARD members, or others having an interest in the ASSOCIATION, the ASSOCIATION’S 

GOODS AND SERVICES, and/or the ASSOCIATION’S CLAIMED MARK.” Bostany further

objects to this request as it seeks documents that are not within Bostany’s possession, custody, or 

control.

7. DOCUMENTS sufficient to show the founding or formation of the 

ASSOCIATION and the scope of its authority.

RESPONSE: Bostany objects to the request as unduly burdensome because documents 

concerning the Association’s formation are of public record and may be equally accessible to 

Plaintiff. Bostany further objects to this request as it seeks documents that are not within Bostany’s

possession, custody, or control.

8. All DOCUMENTS and COMMUNICATIONS CONCERNING or REFERRING 

OR RELATING TO the relatedness or lack of relatedness between SH GROUP’S GOODS AND 

SERVICES on the one hand and the ASSOCIATION’S GOODS AND SERVICES on the other 

hand.

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RESPONSE: Bostany objects to this request to the extent it seeks documents and information 

protected by attorney-client or work product privileges. Bostany will make a reasonable search for 

documents and communications concerning the relatedness or lack of relatedness between SH 

GROUP’S GOODS AND SERVICES on the one hand and the ASSOCIATION’S GOODS AND 

SERVICES on the other hand and shall produce non-privileged documents, to the extent they exist.

9. All DOCUMENTS and COMMUNICATIONS CONCERNING or REFERRING 

OR RELATING TO the similarity or lack of similarity between SH GROUP’S MARKS on the 

one hand and the ASSOCIATION’S CLAIMED MARK on the other hand.

RESPONSE: Bostany objects to this request to the extent it seeks documents and information 

protected by attorney-client or work product privileges Bostany will make a reasonable search for 

documents and communications concerning the similarity or lack of similarity between SH 

GROUP’S MARKS on the one hand and the ASSOCIATION’S CLAIMED MARK on the other 

hand and shall produce non-privileged documents, to the extent they exist.

10. All DOCUMENTS and COMMUNICATIONS CONCERNING or REFERRING 

OR RELATING TO YOUR and/or the ASSOCIATION’s actual, planned or contemplated use of 

the ASSOCIATION’S CLAIMED MARK or any other use of the term “1” in the United States.

RESPONSE: Bostany objects to this request as vague, ambiguous, overly broad and unduly 

burdensome, and not proportional to the needs of the case, to the extent it seeks all documents and 

communications “CONCERNING or REFERRING OR RELATING TO the YOUR and/or the 

ASSOCIATION’s actual, planned or contemplated use of the ASSOCIATION’S CLAIMED 

MARK or use of the term ‘1’ in the United States.” Bostany will make a reasonable search for 

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documents and communications and shall produce non-privileged documents and 

communications, to the extent they exist.

11. All DOCUMENTS and COMMUNICATIONS CONCERNING or REFERRING 

OR RELATING TO any other PERSON’s actual, planned or contemplated use of the 

ASSOCIATION’S CLAIMED MARK or any other use of the term “1” in connection with real 

estate or related goods and services in the United States.

RESPONSE: Bostany objects to this request as vague, ambiguous, overly broad and unduly 

burdensome, and not proportional to the needs of the case, to the extent it seeks all documents and 

communications “CONCERNING or REFERRING OR RELATING TO any other PERSON’s

actual, planned or contemplated use of the ASSOCIATION’S CLAIMED MARK or use of the 

term ‘1’ in the United States.” Bostany further objects to this request to the extent it seeks 

documents and information protected by attorney-client or work product privileges. Subject to this 

objection, as understood, Bostany does not have any documents responsive to this request at this 

time.

12. All DOCUMENTS and COMMUNICATIONS CONCERNING or REFERRING 

OR RELATING TO the ASSOCIATION’s advertising, marketing or promotion of the 

ASSOCIATION’S GOODS AND SERVICES.

RESPONSE: Bostany objects to this request to the extent it seeks documents and information 

protected by attorney-client or work product privileges. Bostany will make a reasonable search for 

documents and communications concerning the Association’s advertising, marketing or promotion 

of its 1 Homes mark and shall produce non-privileged documents, to the extent they exist.

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13. DOCUMENTS sufficient to show all annual sales for the ASSOCIATION’S 

GOODS AND SERVICES in the United States.

RESPONSE: Bostany objects to this request as it seeks documents that are not within Bostany’s

possession, custody, or control.

14. DOCUMENTS sufficient to show all annual expenditures by the ASSOCIATION 

in connection with advertising, promoting, and/or marketing the ASSOCIATION’S GOODS AND 

SERVICES and/or the ASSOCIATION’S CLAIMED MARK.

RESPONSE: Bostany objects to this request as it seeks documents that are not within Bostany’s

possession, custody, or control.

15. All DOCUMENTS CONCERNING or REFERRING OR RELATING TO any 

MARKET RESEARCH or SURVEY CONCERNING or REFERRING OR RELATING TO the 

ASSOCIATION’S CLAIMED MARK, the term “1,” and/or SH GROUP’S MARKS in the United 

States.

RESPONSE: Bostany objects to this request as it seeks documents that are not within Bostany’s

possession, custody, or control.

16. All DOCUMENTS CONCERNING or REFERRING OR RELATING TO 

instances of actual or potential consumer confusion between the SH GROUP’S MARKS on the 

one hand, and the ASSOCIATION’S CLAIMED MARK on the other hand.

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RESPONSE: Bostany objects to this request as overly broad and not proportional to the needs of 

the case, to the extent it seeks “[a]ll DOCUMENTS CONCERNING or REFERRING OR 

RELATING TO instances of actual or potential consumer confusion between SH GROUP’S 

MARKS on the one hand, and the ASSOCIATION’S CLAIMED MARK on the other hand.”

Subject to this objection, as understood, Bostany does not have any documents responsive to this 

request at this time.

17. All DOCUMENTS CONCERNING or REFERRING OR RELATING TO 

instances of actual or potential consumer confusion between SH GROUP’S GOODS AND 

SERVICES on the one hand, and the ASSOCIATION’S GOODS AND SERVICES on the other 

hand.

RESPONSE: Bostany objects to this request as overly broad and not proportional to the needs of 

the case, to the extent it seeks “[a]ll DOCUMENTS CONCERNING or REFERRING OR 

RELATING TO instances of actual or potential consumer confusion between SH GROUP’S 

GOODS AND SERVICES on the one hand, and the ASSOCIATION’S GOODS AND SERVICES 

on the other hand.” Subject to this objection, as understood, Bostany does not have any documents 

responsive to this request at this time.

18. All DOCUMENTS CONCERNING or REFERRING OR RELATING TO any 

expert witnesses in this proceeding.

RESPONSE: Bostany objects to this request as premature and to the extent it seeks information 

covered by the attorney-client privilege and/or work product doctrine. Subject to these objections 

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and the general objections set forth above, Bostany states that he will provide documents 

responsive to this request at the appropriate time in this litigation, should any exist.

19. All COMMUNICATIONS identified in Federal Rule of Civil Procedure 

26(b)(4)(C)(i)–(iii).

RESPONSE: Bostany objects to this request as premature and to the extent it seeks information 

covered by the attorney-client privilege and/or work product doctrine. Subject to these objections 

and the general objections set forth above, Bostany states that he will provide documents 

responsive to this request at the appropriate time in this litigation, should any exist.

21. All COMMUNICATIONS between or among the ASSOCIATION and YOU 

CONCERNING or REFERRING OR RELATING TO SH GROUP’S MARKS.

RESPONSE: Bostany objects to this request as overly broad and not proportional to the needs of 

the case, to the extent it seeks “[a]ll COMMUNICATIONS between or among the ASSOCIATION 

and YOU [BOSTANY] CONCERNING or REFERRING OR RELATING TO SH GROUP’S 

MARKS.” Bostany further objects to this request to the extent it seeks documents and information 

protected by attorney-client or work product privileges. Subject to this objection, as understood, 

Bostany will make a reasonable search for and shall produce documents non-privileged

documents, to the extent they exist.

22. All COMMUNICATIONS between or among the ASSOCIATION and YOU 

CONCERNING or REFERRING OR RELATING TO the ASSOCIATION’S CLAIMED MARK.

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RESPONSE: Bostany objects to this request as overly broad and not proportional to the needs of 

the case, to the extent it seeks “[a]ll COMMUNICATIONS between or among the ASSOCIATION 

and YOU [BOSTANY] CONCERNING or REFERRING OR RELATING TO the 

ASSOCIATION’S CLAIMED MARK.” Bostany further objects to this request to the extent it 

seeks documents and information protected by attorney-client or work product privileges. Subject 

to this objection, as understood, Bostany will make a reasonable search for and shall produce 

documents non-privileged documents, to the extent they exist.

23. All COMMUNICATIONS between or among the ASSOCIATION and YOU 

CONCERNING or REFERRING OR RELATING TO the TTAB PROCEEDING.

RESPONSE: Bostany objects to this request as overly broad and not proportional to the needs of 

the case, to the extent it seeks “[a]ll COMMUNICATIONS between or among the ASSOCIATION 

and YOU [BOSTANY] CONCERNING or REFERRING OR RELATING TO the TTAB 

PROCEEDING.” Bostany further objects to this request to the extent it seeks documents and 

information protected by attorney-client or work product privileges. Subject to this objection, as 

understood, Bostany will make a reasonable search for and shall produce documents nonprivileged documents, to the extent they exist.

24. All COMMUNICATIONS between or among the ASSOCIATION and YOU 

CONCERNING or REFERRING OR RELATING TO this LITIGATION.

RESPONSE: Bostany objects to this request as overly broad and not proportional to the needs of 

the case, to the extent it seeks “[a]ll COMMUNICATIONS between or among the ASSOCIATION 

and YOU [BOSTANY] CONCERNING or REFERRING OR RELATING TO this 

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LITIGATION.” Bostany further objects to this request to the extent it seeks documents and 

information protected by attorney-client or work product privileges. Subject to this objection, as 

understood, Bostany will make a reasonable search for and shall produce non-privileged

documents, to the extent they exist.

25. All DOCUMENTS on which YOU intend to rely to support YOUR claims and 

defenses in this LITIGATION.

RESPONSE: Bostany objects to this request to the extent it seeks documents and information 

protected by attorney-client or work product privileges. Bostany will make a reasonable search for 

documents and shall produce non-privileged documents, to the extent they exist.

26. All DOCUMENTS CONCERNING or REFERRING OR RELATING TO 

contracts or agreements REFERRING OR RELATING TO SH GROUP’s trademarks and/or 

intellectual property, including but not limited to SH GROUP’S MARKS.

RESPONSE: Bostany objects to this request as overly broad and not proportional to the needs of 

the case, to the extent it seeks “[a]ll DOCUMENTS CONCERNING or REFERRING OR 

RELATING TO contracts or agreements REFERRING OR RELATING TO SH GROUP’s 

trademarks and/or other intellectual property, including but not limited to SH GROUP’S

MARKS.” Bostany further objects to this request to the extent it seeks documents and information 

protected by attorney-client or work product privileges. Bostany will make a reasonable search for 

documents and shall produce non-privileged documents, to the extent they exist.

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27. All DOCUMENTS CONCERNING or REFERRING OR RELATING TO the 

domain http://www.1homesmiami.com or any other domain or website owned, operated or 

controlled by YOU or the ASSOCIATION containing the term “1.”

RESPONSE: Bostany objects to this request to the extent it seeks documents and information 

protected by attorney-client or work product privileges. Subject to this objection, as understood, 

Bostany will make a reasonable search for and shall produce non-privileged documents, to the 

extent they exist.

28. All DOCUMENTS CONCERNING or REFERRING OR RELATING TO the use, 

challenge of, or interference with SH GROUP’S MARKS under the AGREEMENTS.

RESPONSE: Bostany objects to this request as vague, ambiguous, overly broad and unduly 

burdensome, and not proportional to the needs of the case, to the extent it seeks ”[a]ll 

DOCUMENTS CONCERNING or REFERRING OR RELATING TO the use, challenge of, or 

interference with SH GROUP’S MARKS under the AGREEMENTS.” Subject to this objection, 

as understood, Bostany does not have any documents responsive to this request at this time.

29. All DOCUMENTS CONCERNING or REFERRING OR RELATING TO any 

meeting convened by the ASSOCIATION or among its members, including but not limited to 

meetings of the BOARD, CONCERNING or REFERRING OR RELATING TO the 

ASSOCIATION’S CLAIMED MARK, SH GROUP’S MARKS, the TTAB PROCEEDING, 

and/or this LITIGATION, including but not limited to any meeting minutes and notes.

RESPONSE: Bostany objects to this request as overly broad and not proportional to the needs of 

the case, to the extent it seeks, without limitations as to time, “[a]ll DOCUMENTS 

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CONCERNING or REFERRING OR RELATING TO any meeting convened by the 

ASSOCIATION, including but not limited to meetings of the BOARD, CONCERNING or 

REFERRING OR RELATING TO the ASSOCIATION’S CLAIMED MARK, SH GROUP’S 

MARKS, the TTAB PROCEEDING, and/or this LITIGATION, including but not limited to any 

meeting minutes and notes.” Bostany objects to this request to the extent it seeks documents and 

information protected by attorney-client or work product privileges. Subject to this objection, as 

understood, Bostany will make a reasonable search for and shall produce non-privileged

documents, to the extent they exist.

30. All DOCUMENTS CONCERNING or REFERRING OR RELATING TO the 

ASSOCIATION’s contention that it has the right to use and register the ASSOCIATION’S 

CLAIMED MARK.

RESPONSE: Bostany objects to this request as vague, ambiguous, overly broad and unduly 

burdensome, and not proportional to the needs of the case, to the extent it seeks “[a]ll 

DOCUMENTS CONCERNING or REFERRING OR RELATING TO the ASSOCIATION’s 

contention that it has the right to use and register the ASSOCIATION’S CLAIMED MARK.”

Bostany further objects to this request as it seeks documents that are not within Bostany’s

possession, custody, or control.

31. All DOCUMENTS CONCERNING or REFERRING OR RELATING TO the 

factual and legal basis for the claim in Paragraph 2 of the PETITION FOR CANCELLATION that 

“Petitioner has used the mark in commerce in connection with such services since at least as early 

as December 31, 2018.”

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RESPONSE: Bostany objects to this request to the extent it seeks documents and information 

protected by attorney-client or work product privileges. Subject to this objection, as understood, 

the Bostany will make a reasonable search for and shall produce non-privileged documents, to the 

extent they exist.

32. All DOCUMENTS CONCERNING or REFERRING OR RELATING TO the 

meaning of the ASSOCIATION’S CLAIMED MARK and each term included therein (i.e., “1” 

and “HOMES”).

RESPONSE: Bostany objects to this request to the extent it seeks documents and information 

protected by attorney-client or work product privileges. Subject to this objection, as understood, 

the Bostany will make a reasonable search for and shall produce non-privileged documents, to the 

extent they exist.

33. All DOCUMENTS CONCERNING or REFERRING OR RELATING TO any 

profits earned by the ASSOCIATION from the sale of goods and services under the 

ASSOCIATION’S CLAIMED MARK in the United States.

RESPONSE: Bostany objects to this request as it seeks documents that are not within Bostany’s

possession, custody, or control.

34. All DOCUMENTS CONCERNING or REFERRING OR RELATING TO this 

LITIGATION.

RESPONSE: Bostany objects to this request to the extent it seeks documents and information 

protected by attorney-client or work product privileges. Bostany further objects to the request as 

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unduly burdensome as documents concerning the litigation may be equally accessible to Plaintiff. 

Subject to these objections, as understood, Bostany will make a reasonable search for and shall 

produce non-privileged documents, to the extent they exist.

35. All DOCUMENTS CONCERNING or REFERRING OR RELATING TO the 

TTAB PROCEEDING.

RESPONSE: Bostany objects to the request as unduly burdensome as documents concerning the 

TTAB proceeding may be equally accessible to Plaintiff. Subject to these objections, as 

understood, Bostany will make a reasonable search for and shall produce non-privileged

documents, to the extent they exist.

36. All DOCUMENTS referenced, relied upon or otherwise consulted in preparing the 

PETITION FOR CANCELLATION.

RESPONSE: Bostany objects to this request to the extent it seeks documents and information 

protected by attorney-client or work product privileges. Bostany further objects to this request as 

it seeks documents that are not within Bostany’s possession, custody, or control.

37. All DOCUMENTS referenced, relied upon or otherwise consulted in preparing 

BOSTANY’S INTERROGATORY RESPONSES.

RESPONSE: Bostany objects to this request to the extent it seeks documents and information 

protected by attorney-client or work product privileges. Subject to these objections, as understood, 

the Bostany will make a reasonable search for and shall produce non-privileged documents, to the 

extent they exist.

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38. All DOCUMENTS referenced, relied upon or otherwise consulted in preparing 

BOSTANY’S ADMISSIONS.

RESPONSE: Bostany objects to this request to the extent it seeks documents and information 

protected by attorney-client or work product privileges. Subject to these objections, as understood, 

the Bostany will make a reasonable search for and shall produce non-privileged documents, to the 

extent they exist.

38. All DOCUMENTS referenced, relied upon or otherwise consulted in preparing 

BOSTANY’S INITIAL DISCLOSURES.

RESPONSE: Bostany objects to this request to the extent it seeks documents and information 

protected by attorney-client or work product privileges. Subject to these objections, as understood, 

the Bostany will make a reasonable search for and shall produce non-privileged documents, to the 

extent they exist.

39. All DOCUMENTS referenced in BOSTANY’S INTERROGATORY 

RESPONSES.

RESPONSE: Bostany objects to this request to the extent it seeks documents and information 

protected by attorney-client or work product privileges. Subject to these objections, as understood, 

the Bostany will make a reasonable search for and shall produce non-privileged documents, to the 

extent they exist.

40. All DOCUMENTS referenced in BOSTANY’S INITIAL DISCLOSURES.

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RESPONSE: Bostany objects to this request to the extent it seeks documents and information 

protected by attorney-client or work product privileges. Subject to these objections, as understood, 

the Bostany will make a reasonable search for and shall produce non-privileged documents, to the 

extent they exist.

41. DOCUMENTS sufficient to show the YOUR document retention, collection, and 

production efforts in connection with this LITIGATION.

RESPONSE: Bostany objects to the request as unduly burdensome as such information is not 

reasonably calculated to lead to the discovery of admissible information.

42. All DOCUMENTS produced by any third party in response to any subpoena the 

ASSOCIATION or BOSTANY serves in this LITIGATION.

RESPONSE: Bostany objects to this request as premature. Subject to this objection, Bostany

states that he will provide documents responsive non-privileged documents in response to this 

request at the appropriate time in this litigation, should any exist.

43. All DOCUMENTS on which YOU intend to rely at any hearing or at trial in this 

LITIGATION.

RESPONSE: Bostany objects to this request as premature. Subject to this objection, Bostany

states that he will provide documents responsive non-privileged documents in response to this 

request at the appropriate time in this litigation, should any exist.

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Dated: August 10, 2020 /s/ Stephanie Vazquez 

Stephanie Vazquez, FL Bar #1011124

Email: svazquez@allendyer.com

ALLEN, DYER, DOPPELT + GILCHRIST, PA

1221 Brickell Ave., Suite 2400

Miami, Florida 33131

Telephone: (305) 374-8303

Facsimile: (305) 374-8306

Brian R. Gilchrist, Esq., FL Bar #774065

Email: bgilchrist@allendyer.com

ALLEN, DYER, DOPPELT + GILCHRIST, PA

255 South Orange Avenue, Suite 1401

Orlando, Florida 32801

Telephone: (407) 841-2330

Facsimile: (407) 841-2343

Counsel for Defendants/Counterclaimants

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that, on August 10, 2020, the foregoing was served by electronic 

(e-mail) transmission to all counsel of record on the Service List below. 

/s/ Stephanie Vazquez 

Stephanie Vazquez, FL Bar #1011124

SERVICE LIST

Gavin C. Gaukroger, FL Bar #76489

Email: ggaukroger@bergersingerman.com

BERGER SINGERMAN LLP 

350 East Las Olas Blvd., Ste 1000

Fort Lauderdale, FL 33301 

Telephone: (954) 525-9900 

Facsimile: (954) 523-2872 

Christina Michele Perry, FL Bar #1003098 

Email: cperry@bergersingerman.com

BERGER SINGERMAN LLP 

1450 Brickell Avenue, Ste. 1000 

Miami, FL 33131 

Telephone: 305-755-9500 

Facsimile: 305-714-4340 

Claudia Ray, Admitted Pro Hac Vice

Email: claudia.ray@kirkland.com

Dale M. Cendali, Admitted Pro Hac Vice

Email: dale.cendali@kirkland.com

Shanti Sadtler Conway, Admitted Pro Hac Vice

Email: shanti.conway@kirkland.com

Admitted Pro Hac Vice

KIRKLAND & ELLIS LLP 

601 Lexington Avenue 

New York, NY 10022 

Telephone: 212-446-4800 

Facsimile: 212-446-6460

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