Enzyme Environmental Solutions Inc (EESO)

[mysterymeat]

K&L INTERNATIONAL ENTERPRISES, INC., SIGNATURE LEISURE, INC., SIGNATURE WORLDWIDE ADVISORS, LLC, STEPHEN W. CARNES, & LAWRENCE A. POWALISZ have filed their intial disclosure lists yesterday. I'm only posting 1 copy because they were all the same. JH & EESO have not filed theirs yet.

UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION
UNITED STATES SECURITIES AND
EXHANGE COMMISSION, Case No.
6:09-cv-1638-GAP-KRS
Plaintiff
v.
K&L INTERNATIONAL ENTERPRISES, INC.,
SIGNATURE LEISURE, INC., SIGNATURE
WORLDWIDE ADVISORS, LLC, STEPHEN W.
CARNES, LAWRENCE A. POWALISZ,
ENZYME ENVIRONMENTAL SOLUTIONS,
INC. and JARED E. HOCHSTEDLER,
Defendants.
__________________________________________/
DEFENDANT STEPHEN W. CARNES
RULE 26(a)(1) INITIAL DISCLOSURES
Defendant, Stephen W. Carnes, by the undersigned counsel, and pursuant to Federal
Rule of Civil Procedure 25(a)(1), hereby provides the following initial disclosures, as
follows:
Case 6:09-cv-01638-GAP-KRS Document 41 Filed 01/19/10 Page 1 of 5
1. “[T]he name and, if known, the address and telephone number of each individual
likely to have discoverable information – along with the subjects of that
information – that the disclosing party may use to support its claims or defenses,
unless the use would be solely for impeachment.” Fed.R.Civ.P. 26(a)(1)(A)(i).
• Each of the parties to this case.
• Each of the witnesses previously identified during the SEC’s pre-suit
investigation of this matter.
• Any witnesses identified by the SEC or by the other Defendants.
• Defendant anticipates that the above-referenced witnesses may have discoverable
information concerning the transactions referenced in the Complaint.
2. “[A] copy – or a description by category and location – of all documents,
electronically stored information, and tangible things that the disclosing party has
in its possession, custody, or control and may use to support its claims or
defenses, unless the use would be solely for impeachment.” Fed.R.Civ.P.
26(a)(1)(AS)(ii).
The Defendant may use the documents previously produced to the SEC during the
pre-suit investigation of this matter. Such documents are in the possession of the
SEC. The Defendant may also use, to the extent that it exists, electronically
stored information (“ESI) concerning the transactions at issue in the Complaint.
ESI may take the form of email messages sent to or from the Defendant with
regard to the transactions at issue in the complaint, if they exist.
3. “[A] computation of each category of damages claimed by the disclosing party –
who must make available for inspection and copying as under Rule 34 the
documents or other evidentiary material, unless privileged or protected from
disclosure, on which each computation is based, including materials bearing on
the nature and extent of injuries suffered.” Fed.R.Civ.P. 26(a)(1)(A)(iii).
None.
Case 6:09-cv-01638-GAP-KRS Document 41 Filed 01/19/10 Page 2 of 5
4. “[F]or inspection and copying as under Rule 34, any insurance agreement under
which an insurance business may be liable to satisfy all or part of a possible
judgment in the action or to indemnify or reimburse for payments made to satisfy
the judgment.” Fed.R.Civ.P. 26(a)(1)(A)(iv).
None.
Respectfully submitted this 19th day of January 2010.
/s/Irving M. Einhorn
IRVING M. EINHORN
Law Offices of Irving. M. Einhorn
1710-10th Street
Manhattan Beach, California 90266
[e-mail]
/s/Harrison T. Slaughter, Jr.
HARRISON T. SLAUGHTER, JR.
Florida Bar No. 194822
111 N. Orange Avenue, Suite 700
Orlando, Florida 32801
Telephone: [phone]
Facsimile: 407-843-3738
[e-mail]
CERTIFICATE OF SERVICE
I hereby certify that on the 13th day of January 2010, I electronically filed the foregoing
document with the Clerk of the Court by using the CM/ECF system, which will also send
a notice of electronic filing to the following:
Jonathan Stephen Polish
Case 6:09-cv-01638-GAP-KRS Document 41 Filed 01/19/10 Page 3 of 5
Securities & Exchange Commission
175 West Jackson Street, Suite 900
Chicago, Illinois 60604
Margaret Gembala Nelson
Securities & Exchange Commission
175 West Jackson Street, Suite 900
Chicago, Illinois 60604
Thomas J. Meier
Securities & Exchange Commission
175 West Jackson Street, Suite 900
Chicago, Illinois 60604
I further certify that I caused to be sent by electronic mail the foregoing document to the
following:
Thomas W. Farlow
Thomas E. Satrom
Frost Brown Todd LLC
201 N. Illinois Street, Suite 1900
Indianapolis, Indiana 46204
e-mail: [e-mail]
e-mail: [e-mail]
Charles M. Greene
Law Offices of Chares M. Greene, PA
28 E Washington Street
Orlando, Florida 32801
Case 6:09-cv-01638-GAP-KRS Document 41 Filed 01/19/10 Page 4 of 5
e-mail: [e-mail]
Daniel Bobilya
Bobilya & Reidy LLP
127 W. Berry Street
Suite 300
Fort Wayne, Indiana 46802
e-mail: [e-mail]
Dated: January 19/, 2010
Case 6:09-cv-01638-GAP-KRS Document 41 Filed 01/19/10 Page 5 of 5