On October 19, 2020 a
Party Discovery
was filed
involving a dispute between
Moreno, Luis,
Ramos, Mary Beatrice,
and
Banta Properties, Inc.,,
Colonial Park Apartments, Llc,
for Neg - Premises Liability Residential
in the District Court of Broward County.
Preview
Filing# 145651470 E-Filed 03/14/2022 02:15:58 PM
IN THE CIRCUIT COURT OF THE ,th
17'
DISTRICT IN AND FOR BROWARD
COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO:
CACE-20-017319
LUIS MORENO and MARY BEATRICE
RAMOS, a married couple,
Plaintiffs,
VS.
BANTA PROPERTIES, INC., a Florida Profit
Corporation,and COLONIAL PARK
APARTMENTS, LLC, a Florida Limited Liability
Company,
Defendants.
i
AMENDED NOTICE OF TAKING DEPOSITION DUCES TECUM
PLEASE TAKE NOTICE that the undersignedattorneys will take the depositionof.
Deponent
I)ate/Time
Location
William Johnson
Thursday, March 17, 2022 at
**Zoom link to be provided
10:00 a.m.
by U.S. Legal
upon oral examination before U. S Legal Solutions or any other Notary Public or officer authorized
by law to take depositionsin the State of Florida. The oral examination will continue from day to
day until completed. The depositionis being taken for the purposes of discovery,for use at trial,
or for such other purposes as are permittedunder the applicableand governingrules. Failure to
appear may result in contempt of Court. YOU ARE TO BRING WITH YOU:
Any and all documents regarding this incident including but not limited to any and all
reports generated as a result of this incident.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/14/2022 02:15:57 PM.****
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true copy ofthe above and foregoingwas E-Filed and E-
Mailed this 2!Lday of February 2022 to: Genevieve P. Rupelli,Esq. and Lindsay A. Adler, Esq.,
Cole, Scott & Kissane, P.A. (Genevieve.rupelli@csklegal.com;
Lindsay.adler@csklegal.com;
Annette.habersham@csklegal.com).
Respectfullysubmitted,
THE LAW FIRM OF STUART H. SHARE, P.A.
Attorneys for Plaintiff
1000 Brickell Avenue
Suite 600
Miami, Florida 33131
Telephone:
(305) 371-8700
Facsimile:
(305) 749-8573
E-Mail:
Stuart@sharelawpa.com
Josh@sharelawpa.com
Amanda@sharelawpa.com
BY /SI Bae.+04.&hu
STUART H. SHARE
Fla. Bar No.. 511579
2
Document Filed Date
March 14, 2022
Case Filing Date
October 19, 2020
Category
Neg - Premises Liability Residential
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Filing# 145651470 E-Filed 03/14/2022 02:15:58 PM IN THE CIRCUIT COURT OF THE ,th 17' DISTRICT IN AND FOR BROWARD COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO: CACE-20-017319 LUIS MORENO and MARY BEATRICE RAMOS, a married couple, Plaintiffs, VS. BANTA PROPERTIES, INC., a Florida Profit Corporation,and COLONIAL PARK APARTMENTS, LLC, a Florida Limited Liability Company, Defendants. i AMENDED NOTICE OF TAKING DEPOSITION DUCES TECUM PLEASE TAKE NOTICE that the undersignedattorneys will take the depositionof. Deponent I)ate/Time Location William Johnson Thursday, March 17, 2022 at **Zoom link to be provided 10:00 a.m. by U.S. Legal upon oral examination before U. S Legal Solutions or any other Notary Public or officer authorized by law to take depositionsin the State of Florida. The oral examination will continue from day to day until completed. The depositionis being taken for the purposes of discovery,for use at trial, or for such other purposes as are permittedunder the applicableand governingrules. Failure to appear may result in contempt of Court. YOU ARE TO BRING WITH YOU: Any and all documents regarding this incident including but not limited to any and all reports generated as a result of this incident. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/14/2022 02:15:57 PM.**** CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true copy ofthe above and foregoingwas E-Filed and E- Mailed this 2!Lday of February 2022 to: Genevieve P. Rupelli,Esq. and Lindsay A. Adler, Esq., Cole, Scott & Kissane, P.A. (Genevieve.rupelli@csklegal.com; Lindsay.adler@csklegal.com; Annette.habersham@csklegal.com). Respectfullysubmitted, THE LAW FIRM OF STUART H. SHARE, P.A. Attorneys for Plaintiff 1000 Brickell Avenue Suite 600 Miami, Florida 33131 Telephone: (305) 371-8700 Facsimile: (305) 749-8573 E-Mail: Stuart@sharelawpa.com Josh@sharelawpa.com Amanda@sharelawpa.com BY /SI Bae.+04.&hu STUART H. SHARE Fla. Bar No.. 511579 2