On December 16, 2019 a
Party Discovery
was filed
involving a dispute between
Rogers, Hilda,
Rogers, Joe Carl,
and
Acousti Engineering Company Of Florida,
Certainteed Corporation,
Honeywell International, Inc.,
J-M Manufacturing Company, Inc.,
Kaiser Gypsum Company, Inc.,
Mckesson Corporation,
Pfizer, Inc.,
Premix-Marbletite Manufacturing Co,
Supro Corporation,
Union Carbide Corporation,
Vanderbilt Minerals, Llc,
W.W. Gay Mechanical Construction Co.,
for Products Liability/Asbestos
in the District Court of Broward County.
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Filing # 122831943 E-Filed 03/10/2021 11:37:28 AM
IN THE CIRCUIT COURT OF THE 17%
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
JOE CARL ROGERS and
HILDA ROGERS, his wife, GENERAL JURISDICTION DIVISION
CASE NO.: CACE-19-025692
Plaintiffs,
Vv.
ACOUSTI ENGINEERING COMPANY
OF FLORIDA; et al.
Defendants.
/
NOTICE OF TAKING DEPOSITION
DUCES TECUM OF WILLIAM EWING
TO: ALL COUNSEL OF RECORD
PLEASE TAKE NOTICE that Defendant, J-M MANUFACTURING COMPANY, INC.,
will take the following deposition pursuant to Rule 1.310(b), Fla.R.Civ.P.
PERSON TO BE DEPOSED: William Ewing
DATE AND TIME: March 18, 2021 at 10:00 a.m. EST.
PLACE OF DEPOSITION: Via Teleconference
Dial-In Number: 855-675-3394
Attendee Passcode: 9402798122
OFFICER TAKING DEPOSITION: Huseby Global Litigation
MATERIAL TO BE
BROUGHT WITH DEPONENT: The deponent is required to have with him at said
time and place the following: See attached
Schedule “A”,
PURPOSE OF DEPOSITION: For discovery and/or use at trial and all other
purposes provided for under the Florida Rules of
Civil Procedure.
If you are a person with a disability who needs any accommodation in
order to participate in this proceeding, you are entitled, at no cost to you, to
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/10/2021 11:37:27 AM.****the provision of certain assistance. Please contact Jeffrey W. Kirsheman,
Esquire, at 390 North Orange Avenue, Suite 2200, P.O. Box 3753, Orlando,
Florida 32802-3753, telephone (407) 843-2111, at least 7 days before your
scheduled court appearance, or immediately upon receiving this notification if
the time before the scheduled appearance is less than 7 days; if you are
hearing or voice impaired, call 711.
CERTIFICATE OF SERVICE |
I HEREBY CERTIFY that on March 10, 2021, I electronically filed the foregoing with the
Clerk of the Courts by using the Florida Courts eFiling Portal which will provide notice to all
Counsel of Record.
/s/ Jeffrey W_ Kirsheman
JEFFREY W. KIRSHEMAN, ESQUIRE
Florida Bar No.0059341
Fisher Rushmer, P.A.
Post Office Box 3753
390 N. Orange Ave., #2200 (32801)
Orlando, FL 32802
407/843-2111; Fax 407/422-1080
Primary email: jkirsheman@fisherlawfirm.com
Secondary email: mmontanez@fisherlawfirm.com
Attorney for Defendant
L:’JWKUMM-Rogers\DEPOS\NOD- William Ewing 3-18-21 .docxSCHEDULE "A"
A current professional resume or curriculum vitae summarizing deponent’s professional
qualifications.
All time records, diaries, and bills prepared and rendered in connection with deponent’s
investigation and evaluation of the issues involved in this lawsuit.
Deponent’s complete file in connection with his/her investigation and evaluation of the
issues involved in this lawsuit, including, but not limited to:
a. All documents furnished to deponent by anyone;
b. All documents deponent reviewed, prepared, referred to or relied upon in
arriving at any of his/her opinions or conclusions concerning the issues involved in the
lawsuit; including, but not limited to, all scientific and technical articles, publications,
codes, standards, calculations, notes, computer printouts, diagrams, and other literature;
c All models, illustrations, photographs, or other exhibits or documents of
any kind which deponent intends or contemplates using to explain, illustrate, or support
testimony at trial; and
d. Copies of any and all notes, calculations or other data prepared by
deponent in formulating his/her opinions, or which deponent contends supports his/her
opinions in connection with this case.
Any and all test data, test documents, test papers, photographs, filings, video tapes,
memoranda or other writings prepared by deponent pursuant to deponent’s employment
in this case.
All photographs viewed and/or taken by or for deponent in connection with this case.
Copies of any reports prepared by deponent and furnished to Plaintiff or Plaintiff's
attorney.
A list of all cases in which deponent testified either via deposition or in trial, or both, in
any jurisdiction, under any circumstances, before any court, tribunal or arbitration
proceedings, during the past five (5) years.
A list of all published articles of deponents or which deponent co-authored or to which
deponent contributed.
Preview
Filing # 122831943 E-Filed 03/10/2021 11:37:28 AM IN THE CIRCUIT COURT OF THE 17% JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA JOE CARL ROGERS and HILDA ROGERS, his wife, GENERAL JURISDICTION DIVISION CASE NO.: CACE-19-025692 Plaintiffs, Vv. ACOUSTI ENGINEERING COMPANY OF FLORIDA; et al. Defendants. / NOTICE OF TAKING DEPOSITION DUCES TECUM OF WILLIAM EWING TO: ALL COUNSEL OF RECORD PLEASE TAKE NOTICE that Defendant, J-M MANUFACTURING COMPANY, INC., will take the following deposition pursuant to Rule 1.310(b), Fla.R.Civ.P. PERSON TO BE DEPOSED: William Ewing DATE AND TIME: March 18, 2021 at 10:00 a.m. EST. PLACE OF DEPOSITION: Via Teleconference Dial-In Number: 855-675-3394 Attendee Passcode: 9402798122 OFFICER TAKING DEPOSITION: Huseby Global Litigation MATERIAL TO BE BROUGHT WITH DEPONENT: The deponent is required to have with him at said time and place the following: See attached Schedule “A”, PURPOSE OF DEPOSITION: For discovery and/or use at trial and all other purposes provided for under the Florida Rules of Civil Procedure. If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/10/2021 11:37:27 AM.****the provision of certain assistance. Please contact Jeffrey W. Kirsheman, Esquire, at 390 North Orange Avenue, Suite 2200, P.O. Box 3753, Orlando, Florida 32802-3753, telephone (407) 843-2111, at least 7 days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711. CERTIFICATE OF SERVICE | I HEREBY CERTIFY that on March 10, 2021, I electronically filed the foregoing with the Clerk of the Courts by using the Florida Courts eFiling Portal which will provide notice to all Counsel of Record. /s/ Jeffrey W_ Kirsheman JEFFREY W. KIRSHEMAN, ESQUIRE Florida Bar No.0059341 Fisher Rushmer, P.A. Post Office Box 3753 390 N. Orange Ave., #2200 (32801) Orlando, FL 32802 407/843-2111; Fax 407/422-1080 Primary email: jkirsheman@fisherlawfirm.com Secondary email: mmontanez@fisherlawfirm.com Attorney for Defendant L:’JWKUMM-Rogers\DEPOS\NOD- William Ewing 3-18-21 .docxSCHEDULE "A" A current professional resume or curriculum vitae summarizing deponent’s professional qualifications. All time records, diaries, and bills prepared and rendered in connection with deponent’s investigation and evaluation of the issues involved in this lawsuit. Deponent’s complete file in connection with his/her investigation and evaluation of the issues involved in this lawsuit, including, but not limited to: a. All documents furnished to deponent by anyone; b. All documents deponent reviewed, prepared, referred to or relied upon in arriving at any of his/her opinions or conclusions concerning the issues involved in the lawsuit; including, but not limited to, all scientific and technical articles, publications, codes, standards, calculations, notes, computer printouts, diagrams, and other literature; c All models, illustrations, photographs, or other exhibits or documents of any kind which deponent intends or contemplates using to explain, illustrate, or support testimony at trial; and d. Copies of any and all notes, calculations or other data prepared by deponent in formulating his/her opinions, or which deponent contends supports his/her opinions in connection with this case. Any and all test data, test documents, test papers, photographs, filings, video tapes, memoranda or other writings prepared by deponent pursuant to deponent’s employment in this case. All photographs viewed and/or taken by or for deponent in connection with this case. Copies of any reports prepared by deponent and furnished to Plaintiff or Plaintiff's attorney. A list of all cases in which deponent testified either via deposition or in trial, or both, in any jurisdiction, under any circumstances, before any court, tribunal or arbitration proceedings, during the past five (5) years. A list of all published articles of deponents or which deponent co-authored or to which deponent contributed.