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UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION

IN RE:

JILL TACIK, CASE NO. 19-14871

CHAPTER 13

Debtor.

_______________________/

JILL TACIK,

Plaintiff,

vs. CASE NO. 19-01156

6322 SEVEN SPRINGS TRUST C and

NERMINE HANNA, 

Defendants.

_______________________/

PLAINTIFF'S INITIAL DISCLOSURE OF WITNESSES AND DOCUMENTS

COMES NOW the Plaintiff, JILL TACIK, (the “Plaintiff”), pursuant to the Court's Order 

Setting Filing and Disclosure Requirements for Pretrial and Trial, Federal Rule of Civil Procedure 

26(a)(1), as made applicable by Federal Rule of Bankruptcy Procedure 7026 and Local Rule 7026-

1(A), hereby submits to Plaintiff its initial disclosure of the following witnesses and documents:

WITNESS LIST

Plaintiff states that the following witnesses may be called at trial in this matter:

1. Jill Tacik

2. Dean Ganelli

3. Steven E. Fisher, Fisher Appraisal Group, Inc.

1025 Gateway Blvd, Sutie 303-321

Boynton Beach, FL 33426

Plaintffstates that discovery is ongoing and incomplete and reserves the right to amend this list at any 

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time upon discovery of additional witnesses or a determination that such above listed witnesses are not 

necessary.

LIST OF DOCUMENTS

Plaintiff states that the following documents may be used at trial in this matter:

1. Appraisal

2. Quit Claim Deed.

3. All documents used by Defendants.

Plaintiffstates that discovery is ongoing and incomplete and reserves the right to amend or supplement 

this list of documents at any time prior to trial upon the discovery of additional relevant documents. 

I HEREBY CERTIFY that a copy of the foregoing was provided electronically to Jordan Rappaport, 

Esquire, Jordan@rorlawfirm.com, this _2nd___ day of June, 2020. 

 

I hereby certify that I am admitted to the Bar of the United States District Court for the 

Southern District of Florida and I am in compliance with the additional qualifications to practice in 

this court set forth in Local Rule 2090-1(A).

BRIAN K. MCMAHON, P.A.

1401 Forum Way, 6th Floor

West Palm Beach, FL 33401

Tel (561)478-2500

Fax (561)478-3111

briankmcmahon@gmail.com

s/ Brian K. McMahon

Brian K. McMahon

FL Bar No. 853704

REIFKIND, THOMPSON & RUDZINSKI, LLP

Attorneys for Defendant

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3333 W. Commercial Blvd., Suite 200B

Ft. Lauderdale, Florida 33309

Office: (954) 370-5152

Facsimile: (954) 370-1992

Email: Brian@rtrlaw.com 

Awilliams@rtrlaw.com

By: __/s Brian D. Gottlieb_______________

Brian D. Gottlieb, Esq.

Florida Bar No. 0015302

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that, on this _23rd___ day of February, 2018, I electronically filed the 

foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document 

is being served this day on all parties of record identified on the attached Service List in the manner 

specified.

By: __/s Brian K. McMahon_______________ 

Brian K. McMahon 

Florida Bar No. 853704

SERVICE LIST

Kenneth S. Rappaport, Esq.

Rappaport Osborne & Rappaport, PLLC

1300 North Federal Hwy.

Suite 203, Squires Building

Boca Raton, FL 33432

561.368.2200 Telephone

ATTORNEY FOR TRUSTEE

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