COMPOSITE

EXHIBIT A 

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CIRCUIT COURT, ELEVENTH JUDICIAL

CIRCUIT, IN AND FOR MIAMI-DADE

COUNTY, FLORIDA

CASE NO.:

EQUITY ONE (FLORIDA PORTFOLIO) LLC, a Florida

limited liability company,

Plaintiff, 

v.

C.S.C. ENTERPRISES, INC. /dba/ SCULLY’S, a Florida

corporation, CHRIS HIRSH and CASSANDRA HIRSH,

jointly and severally,

Defendants./

REQUEST FOR PRODUCTION

Plaintiff, EQUITY ONE (FLORIDA PORTFOLIO) LLC, by and through its undersigned counsel,

requests Defendant, C.S.C. ENTERPRISES, INC. /dba/ SCULLY’S, CHRIS HIRSH and CASSANDRA

HIRSH, in accordance with the applicable Fla.R.Civ.P., Rule 1.350, to produce at the office of the

undersigned attorney within forty-five (45) days hereof, the original and all copies of the following

documents described below as are in the possession, custody or control of Defendant, or as are in the

possession, custody or control of any agent, servant or representative of Defendant.

DEFINITIONS

Unless otherwise specifically indicated, the following definitions shall apply throughout this request

for production:

1. The word "document" means any written or graphic matter or other means of preserving

thought or expression, and all tangible things from which information can be processed or transcribed,

including the originals and all nonidentical copies, whether different from the original by reason of any

notation made on such copy or otherwise, including but not limited to, records, correspondence, memoranda,

notes, messages, letters, reports, appointment books, diaries, journals, telegrams, teletypes, facsimiles,

bulletins, notes of meetings or other communications, interoffice telephone call charts, ledgers, invoices,

worksheets, receipts, returns, computer printouts, documents stored in computers or word processing

equipment, prospectuses, financial statements, schedules, affidavits, contracts, canceled checks,

computations, transcripts, statistics, surveys, magazine or newspaper articles, releases, transcripts, bills,

calendars (any and all drafts, alterations and modifications, changes and amendments of any of the

foregoing), graphs or aural records or representations of any kind, including without limitation, photographs,

charts, graphs, microfiche, microfilm, videotape, recordings, motion pictures and electronic, mechanical or

electric recordings or representations of any kind (including without limitation, tapes, cassettes, discs and

recordings), and including files and file covers.

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2. The term "all documents" means every document or group of documents for communication

as above-defined known to you and every such document or communication which can be located or

discovered by reasonably diligent effort.

3. The term "you" and "your" means the party to whom this request is addressed, including the

party's employees, agents, attorneys and all other persons acting or purporting to act on the party's behalf.

4. "Person" means any natural person, individual, proprietorship, partnership, corporation,

association, organization, joint venture, firm or other business enterprise, governmental agency or body,

group of natural persons, or other organization or legal or business entity.

5. "And" and "Or" shall be construed disjunctively or conjunctively as necessary in order to

bring within the scope of each request all documents which otherwise would be construed to be outside its

scope.

6. "Relating in any way to" shall also mean concerning, respecting, referring to, summarizing,

digesting, embodying, reflecting, establishing, tending to establish, derogating from, tending not to establish,

evidencing, not evidencing, comprising, connected with, commenting on, responding to, disagreeing with,

showing, describing, analyzing, representing, arising out of, or constituting, as necessary in order to bring

within the scope of each request all documents which otherwise would be construed to be outside its scope.

7. As used herein, the singular and masculine form of noun and pronoun shall embrace, and

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

8. The capitalized terms used herein shall have the meaning, respectively, ascribed to them in

Plaintiff’s Complaint. 

INSTRUCTIONS

1. In producing documents requested herein, you shall produce documents in full, without

abridgement, abbreviation or expurgation of any sort.

2. The documents or categories of documents that you contend are responsive to each separate

request and their location should be set forth in your written response pursuant to Fla.R.Civ.P., Rule

1.350(b). All documents responsive to each request should then be produced in the order in which they are

kept in the ordinary course of your business activities, or segregated in accordance with the numbered and

lettered paragraphs and subparagraphs herein.

3. If you object in part to any request for production, please produce the portion of documents

requested to which you do not object and state your objection to the remainder.

4. If privilege is claimed with respect to any document, please provide the following

information:

a. date of the document.

b. author of the document.

c. addressee of the document.

d. citation of authority supporting claim of privilege.

e. statement of facts that you contend establish the document to be privileged.

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5. All documents requested herein which have been destroyed, placed beyond your control, or

otherwise disposed of, shall be identified by:

a. date of the document.

b. author of the document.

c. addressee of the document.

d. type of document.

e. subject matter of the document.

f. number of pages for each document.

g. number of attachments or appendices to each document.

h. indicated or blind copies of each document.

i. all persons to whom distributed, shown or explained.

j. date of destruction or other disposition of each document.

k. reason for destruction or other disposition of each document.

l. person authorizing destruction or other disposition of each document.

m. person destroying or otherwise disposing of each document.

n. if not destroyed, person in possession of document otherwise disposed of.

PRODUCTION

1. Copies of any and all documents contained within any of Defendants’ files regarding the

Lease and the Guaranty which are the subject matter of this action.

2. Copies of any and all correspondence, internal memoranda, notes or documents which

discuss, mention or pertain to the Lease and/or Guaranty which are the subject of this action. If you claim

any such documents are privileged, provide a schedule listing the date and parties of all such privilege

documents and produce all other documents to which no privilege is asserted.

3. Copies of any and all statements, deposit receipts, canceled checks or other documents

regarding any and all transactions upon any and all business accounts maintained by Defendant from

January 1, 2017, to the present that relate to rental payments on the subject Lease.

I HEREBY CERTIFY that a true copy of the foregoing was furnished to a process server for service

on the Defendant together with the summons and complaint.

DATED: November 18, 2020.

COHEN LEGAL

By: /s/ Richard S. Cohen

RICHARD S. COHEN - FL Bar No. 329983

By: /s/ Jason L. Cohen

JASON L. COHEN - FL Bar No. 74340

Attorneys for Plaintiff

811-A North Olive Avenue

West Palm Beach, Florida 33401

Phone: 561-659-0901; Fax: 561-659-0902

E-mail: rscohen@rscohenesqlaw.com 

 jcohen@rscohenesqlaw.com 

 pleadings@rscohenesqlaw.com

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CIRCUIT COURT, ELEVENTH JUDICIAL

CIRCUIT, IN AND FOR MIAMI-DADE

COUNTY, FLORIDA

CASE NO.:

EQUITY ONE (FLORIDA PORTFOLIO) LLC, a

Florida limited liability company,

Plaintiff, 

v.

C.S.C. ENTERPRISES, INC. /dba/ SCULLY’S, a

Florida corporation, CHRIS HIRSH and

CASSANDRA HIRSH, jointly and severally,

Defendants./

REQUEST FOR ADMISSIONS

Plaintiff, EQUITY ONE (FLORIDA PORTFOLIO) LLC, by and through undersigned attorneys,

pursuant to Rule 1.370, Fla.R.Civ.P., requests Defendants, C.S.C. ENTERPRISES, INC. /dba/ SCULLY’S,

CHRIS HIRSH and CASSANDRA HIRSH, within forty-five (45) days from the date of this request, to make

the following admissions for the purposes of this action only: 

1. Each document attached to Plaintiff's Complaint is a true and correct copy of a genuine

original document. 

2. You signed the original of each document of which a copy is attached to Plaintiff's

Complaint and which bears your name. 

3. You received everything you expected to receive in consideration of, or in exchange for,

your signature upon each document of which a copy is attached to Plaintiff's Complaint. 

4. You have never notified or informed anyone of any reason why you are not obligated to pay

to Plaintiff the amounts sued for. 

5. You have never notified Plaintiff of any reason why you are not obligated to pay Plaintiff

the amounts sued for. 

6. The computations as to amount of interest sued for in Plaintiff's Complaint and attachments

thereto are correct. 

7. None of the agreements set forth in Plaintiff's Complaint and attachments thereto have been

subsequently modified or superseded.

8. Plaintiff is the lawful owner and holder of each document of which a copy is attached to

Plaintiff's Complaint. 

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9. The computation by which the principal balance claimed by Plaintiff were computed are

accurate.

10. The balance herein sued for is due and owing by Defendant to Plaintiff. 

11. Written demand has been made by Plaintiff upon Defendantfor payment of the claim herein

sued upon prior to date hereof. 

12. Except as may be shown in Plaintiff's complaint or attachments thereto, Defendant is not

entitled to any credits, offsets or deductions.

13. There are no documents, writings, letters, records or papers of any sort upon which

Defendant intend to utilize as evidence of or a basis for any defense in this action.

14. Interest on the claim asserted herein by Plaintiff is due in the amounts of established by

applicable law and by the charges shown in the attachments to Plaintiff's complaint. 

15. Every statement or allegation contained in Plaintiff's complaint is true and correct.

I HEREBY CERTIFY that a true copy of the foregoing was provided to a process server for service

upon the above named Defendants together with copies of the Summons and Complaint.

DATED: November 18, 2020.

COHEN LEGAL

By: /s/ Richard S. Cohen

RICHARD S. COHEN - FL Bar No. 329983

By: /s/ Jason L. Cohen

JASON L. COHEN - FL Bar No. 74340

Attorneys for Plaintiff

811-A North Olive Avenue

West Palm Beach, Florida 33401

Phone: 561-659-0901; Fax: 561-659-0902

E-mail: rscohen@rscohenesqlaw.com

 jcohen@rscohenesqlaw.com

 pleadings@rscohenesqlaw.com

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CIRCUIT COURT, ELEVENTH JUDICIAL

CIRCUIT, IN AND FOR MIAMI-DADE

COUNTY, FLORIDA

CASE NO.:

EQUITY ONE (FLORIDA PORTFOLIO) LLC, a Florida

limited liability company,

Plaintiff, 

v.

C.S.C. ENTERPRISES, INC. /dba/ SCULLY’S, a Florida

corporation, CHRIS HIRSH and CASSANDRA HIRSH,

jointly and severally,

Defendants./

INTERROGATORIES

TO: C.S.C. ENTERPRISES, INC./dba/ SCULLY’S

jCHRIS HIRSH, President

9733 SW 93 Street rd

Miami, Florida 33176

In accordance with the Florida Rules of Civil Procedure, the Defendant, C.S.C. ENTERPRISES,

INC. /dba/ SCULLY’S, is required within forty-five (45) days after service hereof to answer under oath and

in writing the attached interrogatories.

I HEREBY CERTIFY that the original and one copy of the interrogatories were provided to a process

server on November 18, 2020, for service upon the above named Defendant together with copies of the

summons and complaint.

DATED: November 18, 2020.

COHEN LEGAL

By: /s/ Richard S. Cohen

RICHARD S. COHEN - FL Bar No. 329983

By: /s/ Jason L. Cohen

JASON L. COHEN - FL Bar No. 74340

Attorneys for Plaintiff

811-A North Olive Avenue

West Palm Beach, Florida 33401

Phone: 561-659-0901; Fax: 561-659-0902

E-mail: rscohen@rscohenesqlaw.com 

 jcohen@rscohenesqlaw.com 

 pleadings@rscohenesqlaw.com

2020-024897-CA-01

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INTERROGATORIES

1. State the principal place of business of the corporation, C.S.C. ENTERPRISES, INC. /dba/

SCULLY’S (the “Company”).

2. State the Company's present, complete business address and all business addresses together

with telephone numbers where the Company's officers may be reached.

3. State the full name and present address of each person who is a Company officer, director,

member, manager, owner or stockholder and their designation beside their name.

4. If you assert that the claim herein sued upon is the obligation of anyone other than yourself,

then state the name and present address of each such person and/or corporation and all of the facts upon

which you rely in support of such position, including your relationship to such other person or persons and/or

corporation.

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5. State fully, completely and at length the factual basis of each and every defense which you

now assert or will assert in this action.

6. State the name, occupation, business address and telephone number, residence address and

telephone number of each witness you expect to call or rely upon the trial of this action, together with a

summary of the matters to be testified about within the knowledge of each such witness.

7. If you will do so without a request to produce, attach to your answers to these interrogatories

a copy of each and every document, writing, paper or letter which you intend to utilize as a basis or ground

for any defense in this action. If you will not so produce without a request to produce, then state at length

and verbatim, the contents of each and every such document, writing, paper or letter, additionally stating the

date and circumstances of preparation or receipt of each such item.

8. If you have not admitted any one or more of the Requests for Admissions served upon you

of even date herewith, then with respect to each such request not fully admitted, state all facts known to you

directly or indirectly, which you contend to be a basis for denial or refusal to admit each such request.

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9. Please state the name and address of the person(s) answering these interrogatories.

10. Please state the name, address and phone number of anyone who helped you answer these

interrogatories.

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C.S.C. ENTERPRISES, INC. /dba/ SCULLY’S

By: 

Name:

Title:

STATE OF )

) ss:

COUNTY OF )

Sworn to (or affirmed) and subscribed before me, by means of G physical presence or G online

notarization on , 2020,

by ________________________ the __________________________ of C.S.C. ENTERPRISES,

INC.SCULLY’S, who is G personally known to me or G who has produced the following identification: 

Notary Public, State of Florida

My Commission Expires: 

Commission No.

( Notary Seal )

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CIRCUIT COURT, ELEVENTH JUDICIAL

CIRCUIT, IN AND FOR MIAMI-DADE

COUNTY, FLORIDA

CASE NO.:

EQUITY ONE (FLORIDA PORTFOLIO) LLC, a Florida

limited liability company,

Plaintiff, 

v.

C.S.C. ENTERPRISES, INC. /dba/ SCULLY’S, a Florida

corporation, CHRIS HIRSH and CASSANDRA HIRSH,

jointly and severally,

Defendants./

INTERROGATORIES

TO: CHRIS HIRSH

9733 SW 93 Street rd

Miami, Florida 33176

In accordance with the Florida Rules of Civil Procedure, the Defendant, CHRIS HIRSH, is required

within forty-five (45) days after service hereof to answer under oath and in writing the attached

interrogatories.

I HEREBY CERTIFY that the original and one copy of the interrogatories were provided to a process

server on November 18, 2020, for service upon the above named Defendant together with copies of the

summons and complaint.

DATED: November 18, 2020.

COHEN LEGAL

By: /s/ Richard S. Cohen

RICHARD S. COHEN - FL Bar No. 329983

By: /s/ Jason L. Cohen

JASON L. COHEN - FL Bar No. 74340

Attorneys for Plaintiff

811-A North Olive Avenue

West Palm Beach, Florida 33401

Phone: 561-659-0901; Fax: 561-659-0902

E-mail: rscohen@rscohenesqlaw.com 

 jcohen@rscohenesqlaw.com 

 pleadings@rscohenesqlaw.com

2020-024897-CA-01

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INTERROGATORIES

1. State the your name, residence and business addresses and phone numbers.

2. State the present, complete business address and all business addresses of C.S.C.

ENTERPRISES, INC. /dba/ SCULLY’S (the “Company”), together with telephone numbers where the

business’ officers may be reached.

3. Are you an officer, director, shareholder, member, owner or employee of the Company? If

so, please state whether you are an officer, director, shareholder, member, employee or owner of the

Company, the position you hold and the full names and present addresses of each person who is a corporate

officer, director, owner or stockholder and their designation beside their name.

4. Please state whether or not you entered into the Guaranty agreement with Plaintiff to promise

to pay for any liability of Defendant, C.S.C. ENTERPRISES, INC., a copy of which is attached to Plaintiff's

Complaint.

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5. If the answer to the preceding interrogatory is affirmative, please state:

a. The reason why the Guaranty was entered into; 

b. Whether any monies have been paid to Plaintiff by you under the Guaranty;

c. Whether the Guaranty was ever subsequently modified or supplemented;

d. Whether there was ever any satisfaction, discharge, release, novation or

accord in satisfaction with regard to the Guaranty; and

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e. Whether you have ever tendered payment to the Plaintiff in satisfaction of

the account of Defendant, C.S.C. ENTERPRISES.

6. If you assert that the claim herein sued upon is the obligation of anyone other than yourself,

then state the name and present address of each such person and/or corporation and all of the facts upon

which you rely in support of such position, including your relationship to such other person or persons and/or

corporation.

7. State fully, completely and at length the factual basis of each and every defense which you

now assert or will assert in this action.

8. State the name, occupation, business address and telephone number, residence address and

telephone number of each witness you expect to call or rely upon the trial of this action, together with a

summary of the matters to be testified about within the knowledge of each such witness.

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9. If you will do so without a request to produce, attach to your answers to these interrogatories

a copy of each and every document, writing, paper or letter which you intend to utilize as a basis or ground

for any defense in this action. If you will not so produce without a request to produce, then state at length

and verbatim, the contents of each and every such document, writing, paper or letter, additionally stating the

date and circumstances of preparation or receipt of each such item.

10. If you have not admitted any one or more of the Requests for Admissions served upon you

of even date herewith, then with respect to each such request not fully admitted, state all facts known to you

directly or indirectly, which you contend to be a basis for denial or refusal to admit each such request.

11. Please state the name, address and phone number of anyone who helped you answer these

interrogatories.

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By: 

CHRIS HIRSH

STATE OF )

) ss:

COUNTY OF )

Sworn to (or affirmed) and subscribed before me, by means of G physical presence or G online

notarization on , 2020,

 by CHRIS HIRSH, who is G personally known to me or G who produced the following identification: .

Notary Public, State of 

My Commission Expires: 

Commission No.

( Notarial Seal )

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CIRCUIT COURT, ELEVENTH JUDICIAL

CIRCUIT, IN AND FOR MIAMI-DADE

COUNTY, FLORIDA

CASE NO.:

EQUITY ONE (FLORIDA PORTFOLIO) LLC, a Florida

limited liability company,

Plaintiff, 

v.

C.S.C. ENTERPRISES, INC. /dba/ SCULLY’S, a Florida

corporation, CHRIS HIRSH and CASSANDRA HIRSH,

jointly and severally,

Defendants./

INTERROGATORIES

TO: CASSANDRA HIRSH

9733 SW 93 Street rd

Miami, Florida 33176

In accordance with the Florida Rules of Civil Procedure, the Defendant, CASSANDRA HIRSH, is

required within forty-five (45) days after service hereof to answer under oath and in writing the attached

interrogatories.

I HEREBY CERTIFY that the original and one copy of the interrogatories were provided to a process

server on November 18, 2020, for service upon the above named Defendant together with copies of the

summons and complaint.

DATED: November 18, 2020.

COHEN LEGAL

By: /s/ Richard S. Cohen

RICHARD S. COHEN - FL Bar No. 329983

By: /s/ Jason L. Cohen

JASON L. COHEN - FL Bar No. 74340

Attorneys for Plaintiff

811-A North Olive Avenue

West Palm Beach, Florida 33401

Phone: 561-659-0901; Fax: 561-659-0902

E-mail: rscohen@rscohenesqlaw.com 

 jcohen@rscohenesqlaw.com 

 pleadings@rscohenesqlaw.com

2020-024897-CA-01

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INTERROGATORIES

1. State the your name, residence and business addresses and phone numbers.

2. State the present, complete business address and all business addresses of C.S.C.

ENTERPRISES, INC. /dba/ SCULLY’S (the “Company”), together with telephone numbers where the

business’ officers may be reached.

3. Are you an officer, director, shareholder, member, owner or employee of the Company? If

so, please state whether you are an officer, director, shareholder, member, employee or owner of the

Company, the position you hold and the full names and present addresses of each person who is a corporate

officer, director, owner or stockholder and their designation beside their name.

4. Please state whether or not you entered into the Guaranty agreement dated March 28, 2014,

with Plaintiff to promise to pay for any liability of Defendant, C.S.C. ENTERPRISES, INC., a copy of which

is attached to Plaintiff's Complaint.

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5. If the answer to the preceding interrogatory is affirmative, please state:

a. The reason why the March 28, 2014 Guaranty was entered into; 

b. Whether any monies have been paid to Plaintiff by you under the March 28,

2014 Guaranty;

c. Whether the March 28, 2014 Guaranty was ever subsequently modified or

supplemented;

d. Whether there was ever any satisfaction, discharge, release, novation or

accord in satisfaction with regard to the March 28, 2014 Guaranty; and

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e. Whether you have ever tendered payment to the Plaintiff in satisfaction of

the account of Defendant, C.S.C. ENTERPRISES.

6. If you assert that the claim herein sued upon is the obligation of anyone other than yourself,

then state the name and present address of each such person and/or corporation and all of the facts upon

which you rely in support of such position, including your relationship to such other person or persons and/or

corporation.

7. State fully, completely and at length the factual basis of each and every defense which you

now assert or will assert in this action.

8. State the name, occupation, business address and telephone number, residence address and

telephone number of each witness you expect to call or rely upon the trial of this action, together with a

summary of the matters to be testified about within the knowledge of each such witness.

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9. If you will do so without a request to produce, attach to your answers to these interrogatories

a copy of each and every document, writing, paper or letter which you intend to utilize as a basis or ground

for any defense in this action. If you will not so produce without a request to produce, then state at length

and verbatim, the contents of each and every such document, writing, paper or letter, additionally stating the

date and circumstances of preparation or receipt of each such item.

10. If you have not admitted any one or more of the Requests for Admissions served upon you

of even date herewith, then with respect to each such request not fully admitted, state all facts known to you

directly or indirectly, which you contend to be a basis for denial or refusal to admit each such request.

11. Please state the name, address and phone number of anyone who helped you answer these

interrogatories.

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By: 

CASSANDRA HIRSH

STATE OF )

) ss:

COUNTY OF )

Sworn to (or affirmed) and subscribed before me, by means of G physical presence or G online

notarization on , 2020,

 by CASSANDRA HIRSH, who is G personally known to me or G who produced the following

identification: .

Notary Public, State of 

My Commission Expires: 

Commission No.

( Notarial Seal )

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