Response to Motion to Compel - TO DEFENDANT DEPOSITION AND DEMAND FOR ATTORNEY FEESParty: Plaintiff Katchmere, Vicki - Brett Katchmere Plaintiff vs. Francisco Colet, et al Defendant

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On April 15, 2021 a 3 case was filed by Brett Katchmere, and Katchmere, Vicki, represented by Holodak, Edward F, Esq., against Colet, Francisco, and Meadowbrook Lakes View Condominium Association A Inc, represented by Ashlock, Bryan, Esq., and Goldberg, Dylan Earle, in the jurisdiction of Broward County. Judge Haimes, David A. presiding.

                        
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                           Filing# 141491532 E-Filed 01/06/2022 02:04:15 PM
 IN THE CIRCUIT COURT OF THE 17TH
 JUDICIAL CIRCUIT IN AND FOR
 BROWARD COUNTY, FLORIDA
 CASE NO.:
 CACE-21-007713 (08)
 VICKI KATCHMERE,
 Plaintiff.
 V
 MEADOWBROOK LAKES VIEW
 CONDOMINIUM ASSOCIATION"A", INC.,
 a Florida Not-For-Profit Corporation,and
 FRANCISCO COLET,
 Defendants.
 I
 PLAINTIFF'S RESPONSE TO DEFENDANT'S MOTION TO COMPEL
 DEPOSITION AND DEMAND FOR ATTORNEY FEES
 Plaintiff Vicki Katchmere, by and through her undersignedcounsel,files this Response to
 Defendant Meadowbrook Lakes View Condominium Association "A", Inc's Motion to Compel
 Plaintiff's Deposition,and says:
 1.
 The day after Defendant noticed Plaintiff's deposition,Defendant then filed a Notice of
 Hearing on its Motion to Compel Plaintiff's deposition.Notice attached as Exhibit A.
 2.
 Surely,with the depositionscheduled and noticed,there is nothingto compel.
 3.
 Previously,Plaintiff Katchmere agreed to two different dates for her deposition.The
 first,
 …