On October 01, 2021 a
Party Discovery
was filed
involving a dispute between
Souto, Steven,
and
Gattorno, Giselle,
Iglesias, David,
for Auto Negligence
in the District Court of Miami-Dade County.
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Filing # 144133614 E-Filed 02/17/2022 02:39:12 PM
IN THE CIRCUIT COURT OF THE 11TH
JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
STEVEN SOUTO, CASE NO.: 2021-22353-CA-08
Plaintiff,
v.
GISELLE GATTORNO and
DAVID IGLESIAS,
Defendants.
________________________________/
RE-NOTICE OF TAKING DEPOSITION
(Please advise if an interpreter is needed)
PLEASE TAKE NOTICE that the undersigned attorney will take the deposition of
the following person:
DEPONENT DATE TIME LOCATION
Steven Souto 03/22/2022 2:00 p.m. Remote Audio-Video Conference*
The oral examination will be taken before any Notary Public, authorized court
reporter, or officer authorized by law to take depositions in the State of Florida. The oral
examination will continue from day to day until completed. The deposition is being taken
for the purpose of discovery, for use at trial, or for such other purposes as are permitted
under the rules of Court, including the applicable Rules of Civil Procedure.
* Please Take Further Notice that:
1. The deposition will be conducted remotely, using audio-visual conference technology;
2. The court reporter will report the deposition from a location separate from the witness;
3. Counsel for the parties and their clients will be participating from various, separate locations;
4. The court reporter will administer the oath to the witness remotely;
5. The witness will be required to provide government-issued identification satisfactory
to the court reporter, and this identification must be legible on camera;
6. Each participating attorney may be visible to all other participants, and their
COLE, SCOTT & KISSANE, P.A.
CASE NO.: 2021-22353-CA-08
statements will be audible to all participants;
7. All exhibits will be provided simultaneously and electronically to the witness
and all participants;
8. The court reporter will record the testimony;
9. The deposition may be recorded electronically; and
10. Counsel for all parties will be required to stipulate on the record:
a. Their consent to this manner of deposition; and
b. Their waiver of any objection to this manner of deposition, including any
objection to the admissibility at trial of this testimony based on this manner of
deposition.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 17th day of February, 2022, a true and correct copy of
the foregoing was filed with the Clerk of Miami-Dade County by using the Florida Courts
e-Filing Portal, which will send an automatic e-mail message to the following parties
registered with the e-Filing Portal system: Justin Schneider, Esq. and Glen B. Levine,
Esq., LAW OFFICES OF ANIDJAR & LEVINE, P.A, 300 SE 17th Street, Fort Lauderdale,
Florida 33316, pleadings@anl-law.com; Counsel for Plaintiff.
Cole Scott & Kissane, P.A.
Attorneys for Defendants GISELLE
GATTORNO and DAVID IGLESIAS
Dadeland Centre II
9150 So. Dadeland Blvd., Suite 1400
Miami, FL 33156
Tel: (786) 268-6408
Fax: (305) 373-2294
By:__s/ Lindsay K. Sweeley ______
Henry Salas Esq.,
FBN: 815268
Email: henry.salas@csklegal.com
Asst Email: leisy.martinez@csklegal.com
Page 2
COLE, SCOTT & KISSANE, P.A.
COLE, SCOTT & KISSANE BUILDING - 9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O. BOX 569015 - MIAMI, FLORIDA 33256 - (305) 350-5300 - (305) 373-2294 FAX
CASE NO.: 2021-22353-CA-08
Alejandro M. Cura, Esq.,
FBN: 87563
Email: alejandro.cura@csklegal.com
Asst Email: tracy.walker@csklegal.com
Lindsay K. Sweeley, Esq.,
FBN: 1032003
Email: Lindsay.sweeley@csklegal.com
Asst Email: elvia.gimenez@csklegal.com
0878.0014-00
cc: US Legal Support
Page 3
COLE, SCOTT & KISSANE, P.A.
COLE, SCOTT & KISSANE BUILDING - 9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O. BOX 569015 - MIAMI, FLORIDA 33256 - (305) 350-5300 - (305) 373-2294 FAX
Document Filed Date
February 17, 2022
Case Filing Date
October 01, 2021
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Filing # 144133614 E-Filed 02/17/2022 02:39:12 PM IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA STEVEN SOUTO, CASE NO.: 2021-22353-CA-08 Plaintiff, v. GISELLE GATTORNO and DAVID IGLESIAS, Defendants. ________________________________/ RE-NOTICE OF TAKING DEPOSITION (Please advise if an interpreter is needed) PLEASE TAKE NOTICE that the undersigned attorney will take the deposition of the following person: DEPONENT DATE TIME LOCATION Steven Souto 03/22/2022 2:00 p.m. Remote Audio-Video Conference* The oral examination will be taken before any Notary Public, authorized court reporter, or officer authorized by law to take depositions in the State of Florida. The oral examination will continue from day to day until completed. The deposition is being taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted under the rules of Court, including the applicable Rules of Civil Procedure. * Please Take Further Notice that: 1. The deposition will be conducted remotely, using audio-visual conference technology; 2. The court reporter will report the deposition from a location separate from the witness; 3. Counsel for the parties and their clients will be participating from various, separate locations; 4. The court reporter will administer the oath to the witness remotely; 5. The witness will be required to provide government-issued identification satisfactory to the court reporter, and this identification must be legible on camera; 6. Each participating attorney may be visible to all other participants, and their COLE, SCOTT & KISSANE, P.A. CASE NO.: 2021-22353-CA-08 statements will be audible to all participants; 7. All exhibits will be provided simultaneously and electronically to the witness and all participants; 8. The court reporter will record the testimony; 9. The deposition may be recorded electronically; and 10. Counsel for all parties will be required to stipulate on the record: a. Their consent to this manner of deposition; and b. Their waiver of any objection to this manner of deposition, including any objection to the admissibility at trial of this testimony based on this manner of deposition. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 17th day of February, 2022, a true and correct copy of the foregoing was filed with the Clerk of Miami-Dade County by using the Florida Courts e-Filing Portal, which will send an automatic e-mail message to the following parties registered with the e-Filing Portal system: Justin Schneider, Esq. and Glen B. Levine, Esq., LAW OFFICES OF ANIDJAR & LEVINE, P.A, 300 SE 17th Street, Fort Lauderdale, Florida 33316, pleadings@anl-law.com; Counsel for Plaintiff. Cole Scott & Kissane, P.A. Attorneys for Defendants GISELLE GATTORNO and DAVID IGLESIAS Dadeland Centre II 9150 So. Dadeland Blvd., Suite 1400 Miami, FL 33156 Tel: (786) 268-6408 Fax: (305) 373-2294 By:__s/ Lindsay K. Sweeley ______ Henry Salas Esq., FBN: 815268 Email: henry.salas@csklegal.com Asst Email: leisy.martinez@csklegal.com Page 2 COLE, SCOTT & KISSANE, P.A. COLE, SCOTT & KISSANE BUILDING - 9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O. BOX 569015 - MIAMI, FLORIDA 33256 - (305) 350-5300 - (305) 373-2294 FAX CASE NO.: 2021-22353-CA-08 Alejandro M. Cura, Esq., FBN: 87563 Email: alejandro.cura@csklegal.com Asst Email: tracy.walker@csklegal.com Lindsay K. Sweeley, Esq., FBN: 1032003 Email: Lindsay.sweeley@csklegal.com Asst Email: elvia.gimenez@csklegal.com 0878.0014-00 cc: US Legal Support Page 3 COLE, SCOTT & KISSANE, P.A. COLE, SCOTT & KISSANE BUILDING - 9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O. BOX 569015 - MIAMI, FLORIDA 33256 - (305) 350-5300 - (305) 373-2294 FAX