Winderting Investments, LLC v. Furnell, 144 So. 3d 598

KMPB Group USA, Inc. (KMPB) was a management company that operated the Imperial Swan Hotel; KFSL (later an LLC) owned the Hotel. Helen Kwok was affiliated with KMPB and KFSL and later Winderting Investments, LLC, which received the Hotel by deed in 2012.
Furnell, Braden, and Johnston obtained a $3,000,773 money judgment against KMPB after nonjury proceedings; the judgment remained largely unsatisfied and KMPB had few hard assets.
After discovering KFSL had transferred the Hotel to Winderting, the judgment creditors filed motions seeking remedies (including a receiver) and issued subpoenas duces tecum to three banks seeking KMPB records and extensive personal bank records of Mrs. Kwok.
Mrs. Kwok and Winderting moved for a protective order to block production of Mrs. Kwok’s personal financial records; the trial court denied the protective order and this certiorari petition followed.
The central factual gap: judgment creditors alleged alter-ego/fraud but offered no evidentiary predicate showing corporate formalities were disregarded or that corporate assets were diverted to Mrs. Kwok.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether judgment creditors may obtain a nonparty’s personal financial records postjudgment without a predicate showing	Creditors: Mrs. Kwok controls the related entities, transferred Hotel to frustrate collection; her accounts may reveal assets reachable to satisfy the judgment	Kwok/Winderting: Creditors failed to show relevance or that discovery would lead to assets; mere ownership/control and a transfer of unrelated title do not justify probing personal finances	Court: Denied discovery — creditors failed to show the records were relevant or reasonably calculated to lead to assets; must lay a proper predicate before probing nonparty finances
Whether certiorari review is appropriate for the nonparty discovery order	Creditors: Order should stand (implicit)	Kwok/Winderting: No adequate appellate remedy for compelled nonparty discovery; certiorari appropriate	Court: Certiorari review appropriate; nonparty has no adequate remedy by appeal, and the order departed from essential requirements of law

Dania Jai-Alai Palace, Inc. v. Sykes, 450 So. 2d 1114 (Fla. 1984) (piercing corporate veil principles and looking through corporate form where entity is mere instrumentality)
Advertects, Inc. v. Sawyer Indus., Inc., 84 So. 2d 21 (Fla. 1955) (requiring preliminary factual showing before subjecting stockholders to discovery or personal liability)
Jim Appley’s Tru-Arc, Inc. v. Liquid Extraction Sys. Ltd. P’ship, 526 So. 2d 177 (Fla. 2d DCA 1988) (broad postjudgment discovery into debtor’s finances is allowed but limited for nonparties absent a predicate)
Gen. Elec. Capital Corp. v. Nunziata, 124 So. 3d 940 (Fla. 2d DCA 2013) (nonparty financial discovery requires proper predicate that shows relevance to assets available for execution)
Regions Bank v. MDG Frank Helmerich, LLC, 118 So. 3d 968 (Fla. 2d DCA 2013) (postjudgment discovery aimed at locating assets or recent transfers is relevant)
Rowe v. Rodriguez-Schmidt, 89 So. 3d 1101 (Fla. 2d DCA 2012) (burden on party seeking discovery to show information sought is relevant or reasonably calculated to lead to admissible evidence)