Document for Emmatine Wallace Plaintiff vs. ARC Electric, Inc., et al Defendant

• 
• 
• 
• 

						
                                
Preview
                                Filing # 107831741 E-Filed 05/21/2020 06:18:19 PM

IN THE CIRCUIT COURT OF THE 17th
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA

EMMATINE WALLACE, CASE NO. 19-024724
Plaintiff,

vs.

ARC ELECTRIC, INC., a Florida Profit

Corporation and YOSBEL P. ALONSO,

Defendant(s).

NOTICE OF TAKING VIDEO DEPOSITION

PLEASE TAKE NOTICE that the undersigned, as attorney for the Plaintiff, on Monday, July 13
» 2020 at 12:00* p.m. (*or immediately following the 11:00a.m. deposition), at Esquire Deposition
Solutions, 515 E Las Olas Blvd Suite 1300, Fort Lauderdale, FL 33301, will take the video deposition
of:

Corporate Representative’ of Defendant, ARC ELECTRIC, INC., to testify on its
behalf about the following matters, known or reasonably available to the organization:

a. The subject crash;

b. Investigation following the subject crash;

c. Property damage to any of the subject vehicles;

d. Repair estimates, total loss information, and payments relating to property damage of
the subject 2013 Kenworth truck involved in the crash;

e. Statements made by any of the Parties;

f. | Employment, hiring, training and retention of YOSBEL P. ALONSO;

g. Ownership and/or right to control the subject 2013 Kenworth truck;

h. The driving history of YOSBEL P. ALONSO;

i. Job tasks and/or services provided by YOSBEL P. ALONSO on the date of the
subject crash;

j. Policies and procedures pertaining to driving safety; incident investigation; cell phone

use while driving; and/or
k. Maintenance of the subject 2013 Kenworth truck.

*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/21/2020 06:18:19 PM.****"Corporate Representative(s)" pursuant to Fla. R. Civ. P. 1.310(b)(6) means the person or persons

designated to speak for the organization and testify on its behalf as matters known and reasonably
available to the organization.

"The [organization] must prepare the designee to the extent matters are reasonably
available, whether from documents, past employees, or other sources." That preparation
must enable the designee to "give complete, knowledgeable and binding answers on
behalf of the corporation." If the deponent cannot answer questions regarding the
designated subject matter, “the corporation has failed to comply with its [Rule 1.310(b)
(6) ] obligation and may be subject to sanctions....”

Carriage Hills Condo., Inc. v. JBH Roofing & Constructors, Inc., 109 So.3d 329, 334 (Fla. 4th DCA
2013).

upon oral examination, pursuant to the Florida Rules of Civil Procedure and statutes of the State of Florida
before or some other Notary Public, who does not represent either of the parties and is not interested in

the outcome of the case. This video deposition is being taken for the purpose of discovery and for any
other purpose allowed by law.

PLEASE BE GOVERNED ACCORDINGLY.

CERTIFICATE OF SERVICE

Thereby Certify that a copy of the foregoing has been filed with the E-portal which will send notice

by email to: Francesca Ippolito-Craven, Esq., KUBICKI DRAPER FIC-KD@kubickidraper.com
this 21% day of May, 2020.

STEINGER, GREENE & FEINER,
P.A. 2727 NW 62" St. Fort
Lauderdale, FL 33309 Telephone:
(954) 491-7701
ychan@injurylawyers.com
Attorneys for Plaintiff

41 V cemee Chan, Esquire

Yeemee Chan, Esq.
Florida Bar No.: 58355