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Filing # 128289572 E-Filed 06/08/2021 10:02:32 AM
IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
PABLO GORORDO and GLENDA
LUCIA SANTIAGO DE AGUILAR as Case No. CACE-21-010675 (12)
parent and natural guardian of D.A.S.
and J.A.S., minors,
Plaintiffs,
VS.
H&C INTERNATIONALTRADING LLC,
and CLARA ROBINSON, PA,
Defendants.
NOTICE OF TAKING DEPOSITION DUCES TECUM
(If necessary, please contact Plaintiffs counsel
to select another amicable date and time)
(PLEASE ADVISE IF INTERPRETER NEEDED)
PLEASE TAKE NOTICE that pursuant to Rule 1.310(b)(6) of the Florida Rules of
Civil Procedure, the undersigned will attorneys will take the deposition as follows:
NAME: H&C INTERNATIONAL TRADING LLC
DATE & TIME: August 24, 2021 @ 10:00am
LOCATION: VIA ZOOM -
LINK TO BE PROVIDED BY COURT
REPORTER
DUCES TECUM: See attached Schedule A
MATTERS ON WHICH THE EXAMINATION IS REQUESTED:
1. The condition of the ceiling on May 18, 2020.
2. The defendant's affirmative defenses to the Complaint.
3. Prior incidents wherein someone was injured on the same
property. This request is limited to incidents occurring in the
three years prior to May 18, 2020.
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/08/2021 10:02:32 AM.****
Said deposition will be taken before Universal Court Reporting, a Notary Public in
and for the State of Florida at Large, or some other officer duly authorized by law to take
depositions. The deposition will continue from day to day until completed. The
deposition is being taken for the purpose of discovery, for use at trial, or both of the
foregoing, or for such other purposes as are permitted under the applicable and
governing rules.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been
served to Defendant together with the Complaint and Summons in this matter.
M
DATED this 8 day of June, 2021.
THE LAW OFFICES OF
BERMAN & BERMAN, P.A.
Attorneys for Plaintiff
PO Box 272789
Boca Raton, FL 33427
Tel: (561) 826-5200
Fax: (561) 826-5201
BY. /S/nUSSEHT-F.BEMUM
Russell F. Berman, Esq.
Florida Bar No.: 731501
cc: Universal Court Reporting
SCHEDULE A
.1
DOCUMENTS TO BE PRODUCED
The originals of the following documents:
1. All documents which support defendant's affirmative defenses.
2. All documents regarding the subject incident as described in the
Complaint that were prepared in the ordinary course of Defendant's
business.
3. All documents regarding any repairs and/or work performed over the
last 5 years on the ceiling where the subject incident occurred as
described in the Complaint.
4. All documents regarding any repairs and/or work performed over the
last 5 years on the roof of the subject premises.
5- All documents which defendant intends to use at time of trial.
1
The term "document" or "documents" herein means any written, electronic or graphic matter, or other
means of preserving thought or expression, and all tangible things from which infonnation can be
processed or transcribed, including the originals and all non-identical copies, whether different from the
original by reason of any notation made on such copy or otherwise, including, but not limited to:
correspondence, e-mails, memoranda, notes, messages, letters, telegrams, facsimiles,bulletins, meetings
or other communications, inter and intra-office telephone calls, diaries, chronological data, minutes,
books, files, reports, studies, summaries, pamphlets, printed matter, charts, ledgers, invoices, worksheets,
receipts, returns, computer printouts, prospectuses, financial statements, canceled checks, check images,
wire infonnation, schedules, affidavits, contracts, closing statements, agreements, applications,
statements, transcripts, statistics, surveys, appraisals, estimates, magazine or newspaper articles, releases
(including any and all drafts, alterations or modifications, as well as changes and amendments to any of
the foregoing), graphic or spoken recordings or representations of any kind (including without limitation
photographs, microfiche,microfilm, videotape, CD's and DVD's), and electronic, computer or mechanical
records or data of any kind (including without limitation tapes, diskettes, computer discs, drives and
servers). ESI Production Format: Electronically stored infonnation should be produced in its native
fonnat. To the extent that the native format is not reasonably accessible due to undue burden or cost, then
electronically stored infonnation should be produced in the form in which it is maintained in the usual
course of business or in a reasonably useable form such as PDF files.
For all documents on which you claim privilege, a privilege log must be prepared and filed
pursuant to F.R.C.P. 1.280(b)(6).
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Filing # 128289572 E-Filed 06/08/2021 10:02:32 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA PABLO GORORDO and GLENDA LUCIA SANTIAGO DE AGUILAR as Case No. CACE-21-010675 (12) parent and natural guardian of D.A.S. and J.A.S., minors, Plaintiffs, VS. H&C INTERNATIONALTRADING LLC, and CLARA ROBINSON, PA, Defendants. NOTICE OF TAKING DEPOSITION DUCES TECUM (If necessary, please contact Plaintiffs counsel to select another amicable date and time) (PLEASE ADVISE IF INTERPRETER NEEDED) PLEASE TAKE NOTICE that pursuant to Rule 1.310(b)(6) of the Florida Rules of Civil Procedure, the undersigned will attorneys will take the deposition as follows: NAME: H&C INTERNATIONAL TRADING LLC DATE & TIME: August 24, 2021 @ 10:00am LOCATION: VIA ZOOM - LINK TO BE PROVIDED BY COURT REPORTER DUCES TECUM: See attached Schedule A MATTERS ON WHICH THE EXAMINATION IS REQUESTED: 1. The condition of the ceiling on May 18, 2020. 2. The defendant's affirmative defenses to the Complaint. 3. Prior incidents wherein someone was injured on the same property. This request is limited to incidents occurring in the three years prior to May 18, 2020. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/08/2021 10:02:32 AM.**** Said deposition will be taken before Universal Court Reporting, a Notary Public in and for the State of Florida at Large, or some other officer duly authorized by law to take depositions. The deposition will continue from day to day until completed. The deposition is being taken for the purpose of discovery, for use at trial, or both of the foregoing, or for such other purposes as are permitted under the applicable and governing rules. I HEREBY CERTIFY that a true and correct copy of the foregoing has been served to Defendant together with the Complaint and Summons in this matter. M DATED this 8 day of June, 2021. THE LAW OFFICES OF BERMAN & BERMAN, P.A. Attorneys for Plaintiff PO Box 272789 Boca Raton, FL 33427 Tel: (561) 826-5200 Fax: (561) 826-5201 BY. /S/nUSSEHT-F.BEMUM Russell F. Berman, Esq. Florida Bar No.: 731501 cc: Universal Court Reporting SCHEDULE A .1 DOCUMENTS TO BE PRODUCED The originals of the following documents: 1. All documents which support defendant's affirmative defenses. 2. All documents regarding the subject incident as described in the Complaint that were prepared in the ordinary course of Defendant's business. 3. All documents regarding any repairs and/or work performed over the last 5 years on the ceiling where the subject incident occurred as described in the Complaint. 4. All documents regarding any repairs and/or work performed over the last 5 years on the roof of the subject premises. 5- All documents which defendant intends to use at time of trial. 1 The term "document" or "documents" herein means any written, electronic or graphic matter, or other means of preserving thought or expression, and all tangible things from which infonnation can be processed or transcribed, including the originals and all non-identical copies, whether different from the original by reason of any notation made on such copy or otherwise, including, but not limited to: correspondence, e-mails, memoranda, notes, messages, letters, telegrams, facsimiles,bulletins, meetings or other communications, inter and intra-office telephone calls, diaries, chronological data, minutes, books, files, reports, studies, summaries, pamphlets, printed matter, charts, ledgers, invoices, worksheets, receipts, returns, computer printouts, prospectuses, financial statements, canceled checks, check images, wire infonnation, schedules, affidavits, contracts, closing statements, agreements, applications, statements, transcripts, statistics, surveys, appraisals, estimates, magazine or newspaper articles, releases (including any and all drafts, alterations or modifications, as well as changes and amendments to any of the foregoing), graphic or spoken recordings or representations of any kind (including without limitation photographs, microfiche,microfilm, videotape, CD's and DVD's), and electronic, computer or mechanical records or data of any kind (including without limitation tapes, diskettes, computer discs, drives and servers). ESI Production Format: Electronically stored infonnation should be produced in its native fonnat. To the extent that the native format is not reasonably accessible due to undue burden or cost, then electronically stored infonnation should be produced in the form in which it is maintained in the usual course of business or in a reasonably useable form such as PDF files. For all documents on which you claim privilege, a privilege log must be prepared and filed pursuant to F.R.C.P. 1.280(b)(6).