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UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

In re:

Stuart Roy Miller, Case No. 20-22497-EPK

Debtor. Chapter 7

____________________________________/

NOTICE OF RULE 2004 REQUEST FOR DOCUMENTS

PLEASE TAKE NOTICE THAT creditor, Hill Country Hillside, Ltd (“Creditor”), by and 

through undersigned counsel, requests production of documents described on Schedule A from 

debtor Stuart Roy Miller pursuant to Rule 2004 of the Federal Rules of Bankruptcy Procedure and 

Local Rule 2004-1. Pursuant to Local Rule 2004-1 no order shall be necessary.

Stuart Roy Miller is directed to deliver to undersigned counsel for the Creditor documents 

responsive to the requests set forth in Schedule A attached hereto on or before 3:00 p.m. on January 

28, 2021; provided that, the documents responsive to the first request should be provided to 

undersigned counsel at the same time such documents are provided to Chad S. Pavia, the Chapter 

7 Trustee for Denials Recovery Group, Inc. which will be on or before January 27, 2021.

Dated: January 14, 2021 Respectfully submitted,

KOZYAK TROPIN & THROCKMORTON, LLP 

Counsel for Hill Country Hillside, Ltd

2525 Ponce de Leon, 9th Floor 

Coral Gables, FL 33134 

Telephone: (305) 372-1800 

Facsimile: (305) 372-3508 

By: /s/ Corali Lopez-Castro

Corali Lopez Castro

Florida Bar No. 863830

clc@kttlaw.com 

Bernice C. Lee 

Florida Bar No. 0073535 

blee@kttlaw.com

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CERTIFICATE OF SERVICE

 I HEREBY CERTIFY that on January 14, 2021, I electronically filed the foregoing 

document with the Clerk of the Court using CM/ECF. I also certify that a true and correct copy of 

the foregoing is being served this day (i) via transmission of Notice of Electronic Filing generated by 

CM/ECF on all counsel of record or pro se parties who are authorized to receive electronically Notices 

of Electronic Filing in this bankruptcy case and (ii) via U.S. Mail to all parties on the attached service 

list.

By: /s/ Corali Lopez-Castro 

Corali Lopez-Castro

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SERVICE LIST 

 

VIA U.S. MAIL

JRS Health Services LLC, 

c/o Stuart, Miller as Registered Agent 

3421 NW 25TH Terrace

Boca Raton, FL 33434

HMMSRM, LLC 

c/o Henry Miller as Registered Agent

3421 NW 25TH Terrace

Boca Raton, FL 33434

HMMCGM LLC

c/o Henry Miller as Registered Agent

3421 NW 25TH Terrace

Boca Raton, FL 33434

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SCHEDULE “A”

DEFINITIONS OF TERMS

1. “Debtor” means Stuart Roy Miller, and all of his agents, attorneys, accountants, 

employees, representatives, and any other person or entity acting or purporting to act on his behalf.

2. “Document” or “document” or “Documents” or “documents” is used in its broadest 

sense and refers to the original, or any copy thereof if the original is not available, in native format, 

of any electronically stored information (including accompanying system and file metadata), 

printed, written, typed, photocopied, photographic, or recorded matter, however produced or 

reproduced, of every kind and description, currently or formerly in the possession, custody, care, 

or control of you or your past and present attorneys. Representative examples of Documents 

include but are not limited to email correspondence, text messages, Word documents, Excel 

spreadsheets, QuickBooks files, paper documents, notebooks, voicemail recordings, photographs, 

video recordings, and system metadata associated with stored electronically stored information. 

The term “Document” or “Documents” also includes copies containing information in addition to 

that contained in the original, or similar copies of electronically stored information with differing 

metadata or SHA-1 or MD5 hash values. 

3. “DRG” means Denials Recovery Group, Inc.

4. “Person” or “Persons” means any natural person, company, corporation, 

partnership, proprietorship, trust, firm, association, company and joint venture whether public or 

private, as well as any governmental agency, division or department.

5. “You” and “your” refers to Stuart Roy Miller, and all of his agents, attorneys, 

accountants, employees, representatives, and any other person or entity acting or purporting to act 

on his behalf.

INSTRUCTIONS

1. In responding to this request, you must make a diligent search of your Documents, 

as defined above, and to furnish information that is available to you or subject to your reasonable 

inquiry. Please note that the definition of Documents expressly includes electronically stored 

information, papers or materials in you or your representatives’, agents’, attorneys’ or affiliates’ 

possession, custody, or control, and that you are required to search electronically stored 

information hosted on cloud networks, computers, email accounts, data systems, or social media 

as part of your reasonable inquiry.

2. “And” and “or” shall be construed disjunctively or conjunctively as necessary in 

order to bring within the scope of this request to produce all responses that might otherwise be 

construed to be outside its scope.

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3. The singular number and masculine gender as used herein shall embrace, and be 

read and applied as, the plural or the feminine or the neuter, as the circumstances may make 

appropriate, and in order to make the request inclusive rather than exclusive.

4. Documents produced in response to this request should reflect in some manner the 

numbered requests to which they are responsive. Documents called for by this request, but 

withheld because of a claim of privilege or other objection, must be identified in the following 

respects: (a) the numbered request to which the document is responsive; (b) the document’s title 

and general subject matter, along with a general description of the native format of the document 

(e.g., Word document, Excel spreadsheet, Adobe PDF file); (c) the document’s date of creation 

and last access; (d) the document’s author; (e) the person or persons for whom the document was 

prepared and/or the person or persons to whom the document was sent; and (f) the specific nature 

of the privilege or objection claimed.

5. This request for Documents is continuing and you are requested to supplement its 

responses hereto.

6. In the event that any document requested herein is not presently in your possession or 

subject to your control, please identify each person you have reason to believe had or has knowledge 

of its contents.

7. In the event that any document called for by a request has been destroyed or discarded, 

please identify that document by stating: (a) any address or any addressee; (b) any indicated or blind 

copies; (c) the document’s date, subject matter, number of pages, and attachments or appendices; (d) 

all persons to whom the document was distributed, shown or explained; (e) its date and destruction 

or discard, manner of destruction or discard, and reason for destruction or discard; and (f) the persons 

authorizing or carrying out such destruction or discard.

8. In producing Documents requested herein, you shall produce Documents in full, 

without abridgment, abbreviation, and expurgation of any sort.

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DOCUMENTS TO BE PRODUCED

1. All Documents and other items requested by Chad S. Pavia, Chapter 7 Trustee for 

DRG, in the Notice of Taking Rule 2004 Examination Duces Tecum filed on January 11, 2021 

[ECF No. 41].

2. All Documents relating to any payments provided to The Zarasai Group since 

November, 2016 through the present date, including but not limited to the two payments in the 

amount of $3,950 provided on or about September 8, 2020. 

3. All Documents relating to the Debtor’s ability to fund any proposed distributions 

under a chapter 11 plan, including but not limited to provide distributions on account of 

administrative claims, secured claims, priority claims, and unsecured claims. 

4. All bank statements, back-up for deposits and withdrawals of any kind, signature 

cards, and account agreements for any type of financial account on which JRS Health Services 

LLC, HMMSRM, LLC and/or HMMCGM LLC had or has any interest, legal or equitable, from 

November, 2016 through the present date.

5. All Documents, including but not limited to email correspondence between the 

Debtor and Richard Falcha and/or Jeffrey Bishop, regarding the formation and/or purpose of JRS 

Health Services LLC.

6. All Documents, including but not limited to email correspondence between the 

Debtor and Richard Falcha and/or Jeffrey Bishop, regarding the Debtor’s withdrawal or 

resignation as the managing member of JRS Health Services LLC.

7. All Documents, including but not limited to email correspondence, between the 

Debtor and any Person regarding the formation and/or purpose of HMMSRM, LLC.

8. All Documents, including but not limited to email correspondence between the 

Debtor and Howard Sperling, regarding the payment of attorneys’ fees for the Debtor relating to 

the above-referenced bankruptcy case and the bankruptcy case of DRG.

9. All Documents relating to any financial account on which the Debtor had or has 

any interest, legal or equitable, or otherwise used personally, during the period of two years prior 

to November 13, 2020, issued by the financial institution indicating that such account is closed, 

including but not limited to the Bank of America account ending in 4272, Chase account ending 

in 9893, and Seacoast accounts ending in 4336 and 7451.

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