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IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT,
aro! IN AND FOR ALACHUA COUNTY, FLORIDA
CIVIL DIVISION
KENNETH T. LICCIARDI
Plaintiff,
VS. Case No. 01-06-CA-4350
RANDY DEEHL
Defendant
/
NOTICE OF FILING AFFIDAVIT OF ZACHARY D. MESSA, ESQ.
SUPPORT OF DEFENDANT’S MOTION TO DISMISS FOR IMPROPER
VENUE, OR IN THE ALTERNATIVE TO TRANSFER VENUE
COMES NOW, the Defendant, RANDY DEEHL, by and through his undersigned
attorney, and files this Notice of Filing attaching the Affidavit of Zachary D. Messa. Esq.,
in Support of Defendant’s Motion to Dismiss for Improper Venue, or in the Alternative to
Transfer Venue.
Apu. |
|
En
BrddleyJ. Wood
BradleyJ. Wood, P.A.
P.O. Drawer 76387
St. Petersburg, FL 33734-6387
PH: (727) 895-1991; FAX (727)8 Base =
Attorney for Defendant
Fla. Bar No. 999245
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing has been furnished by U.S.
Mail and facsimile transmission this |S lay of January, 2007 to: D. Andrew
Vloedman, Esq., 2790 NW 43rd Street, Gainesville, FL 32606; fax #(352) 372-0770
Bradl J. Wood
(Cadi chomneann 2
IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT,
IN AND FOR ALACHUA COUNTY, FLORIDA
CIVIL DIVISION
KENNETH T. LICCIARDI,
Plaintiff,
vs. Case No. 01-06-CA-4350
RANDY DEEHL
Defendant.
/
AFFIDAVIT
BEFORE ME, the undersigned authority, personally appeared, ZACHARY D.
MESSA, ESQ., who, after being first duly sworn, deposes and says:
1 I am an attorney, licensed to practice law in Florida, and during all times
pertinent hereto, was an active member of the Florida Bar, practicing with the firm of
Johnson Pope Bokor Ruppel & Burns, L.L.P., in their office located in Tampa, Florida in
Hillsborough County. I have personal knowledge of the facts stated herein.
2. I represented Randy Deehl (DEEHL) in business dealings between
DEEHL and Plaintiff which are the subject of this lawsuit.
3 Steven A. Scott, Esq. contacted me via telephone at my office located on
403 E. Madison St., Suite 400, Tampa, Florida 33602 to discuss the severance of the
business relationship between DEEHL and Plaintiff. All of my conversations with Mr.
Scott were via telephone with the exception of an in person meeting that occurred at my
offices of Johnson Pope Bokor Ruppel & Burns, located at 911 Chestnut Street,
Clearwater, Florida 33756.
4. Affiant is aware that at all time pertinent hereto, Defendant DEEHL $s
resided in Hillsborough County, Florida. Qc
eax
mw
5 All incidents described in the Plaintiffs complaint which reference: any act
or activity by the me occurred during my representation of DEEHL and occurred in
Hillsborough County, Florida, with the exception of the aforementioned meeting wi
Plaintiffs counsel, which occurred in Clearwater.
z
6 I am not aware of any actions taken by Defendant DEEHL which are
relative to this action which occurred in any location other than Hillsborough County,
Florida.
7. This Affidavit is being given in support of the Defendant’s Motion to
dismiss for Improper Venue, or in the Alternative to Transfer Venue. /
Further Affiant sayeth naught.
Zachary, essa, Esq.
STATE OF FLORIDA
COUNTY OF HILLSBOROUGH
The foregoing instrument was acknowledged before me this la day of
January, 2007, by ZACHARY D. MESSA, ESQ., who is i personally known to me or
{ ] has produced as identification.
\ \
My Commission Expires: VR
=|
ae a _ lotary Public
Mo
ne= MY COMMIS!
464364
2008
‘EXPIRES: Noverv1,er
Bona!
Tru Notary Pl
meee -- GLING EC
(Affix Seal) Printed Name of Notary Public
Preview
, IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT, aro! IN AND FOR ALACHUA COUNTY, FLORIDA CIVIL DIVISION KENNETH T. LICCIARDI Plaintiff, VS. Case No. 01-06-CA-4350 RANDY DEEHL Defendant / NOTICE OF FILING AFFIDAVIT OF ZACHARY D. MESSA, ESQ. SUPPORT OF DEFENDANT’S MOTION TO DISMISS FOR IMPROPER VENUE, OR IN THE ALTERNATIVE TO TRANSFER VENUE COMES NOW, the Defendant, RANDY DEEHL, by and through his undersigned attorney, and files this Notice of Filing attaching the Affidavit of Zachary D. Messa. Esq., in Support of Defendant’s Motion to Dismiss for Improper Venue, or in the Alternative to Transfer Venue. Apu. | | En BrddleyJ. Wood BradleyJ. Wood, P.A. P.O. Drawer 76387 St. Petersburg, FL 33734-6387 PH: (727) 895-1991; FAX (727)8 Base = Attorney for Defendant Fla. Bar No. 999245 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been furnished by U.S. Mail and facsimile transmission this |S lay of January, 2007 to: D. Andrew Vloedman, Esq., 2790 NW 43rd Street, Gainesville, FL 32606; fax #(352) 372-0770 Bradl J. Wood (Cadi chomneann 2 IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT, IN AND FOR ALACHUA COUNTY, FLORIDA CIVIL DIVISION KENNETH T. LICCIARDI, Plaintiff, vs. Case No. 01-06-CA-4350 RANDY DEEHL Defendant. / AFFIDAVIT BEFORE ME, the undersigned authority, personally appeared, ZACHARY D. MESSA, ESQ., who, after being first duly sworn, deposes and says: 1 I am an attorney, licensed to practice law in Florida, and during all times pertinent hereto, was an active member of the Florida Bar, practicing with the firm of Johnson Pope Bokor Ruppel & Burns, L.L.P., in their office located in Tampa, Florida in Hillsborough County. I have personal knowledge of the facts stated herein. 2. I represented Randy Deehl (DEEHL) in business dealings between DEEHL and Plaintiff which are the subject of this lawsuit. 3 Steven A. Scott, Esq. contacted me via telephone at my office located on 403 E. Madison St., Suite 400, Tampa, Florida 33602 to discuss the severance of the business relationship between DEEHL and Plaintiff. All of my conversations with Mr. Scott were via telephone with the exception of an in person meeting that occurred at my offices of Johnson Pope Bokor Ruppel & Burns, located at 911 Chestnut Street, Clearwater, Florida 33756. 4. Affiant is aware that at all time pertinent hereto, Defendant DEEHL $s resided in Hillsborough County, Florida. Qc eax mw 5 All incidents described in the Plaintiffs complaint which reference: any act or activity by the me occurred during my representation of DEEHL and occurred in Hillsborough County, Florida, with the exception of the aforementioned meeting wi Plaintiffs counsel, which occurred in Clearwater. z 6 I am not aware of any actions taken by Defendant DEEHL which are relative to this action which occurred in any location other than Hillsborough County, Florida. 7. This Affidavit is being given in support of the Defendant’s Motion to dismiss for Improper Venue, or in the Alternative to Transfer Venue. / Further Affiant sayeth naught. Zachary, essa, Esq. STATE OF FLORIDA COUNTY OF HILLSBOROUGH The foregoing instrument was acknowledged before me this la day of January, 2007, by ZACHARY D. MESSA, ESQ., who is i personally known to me or { ] has produced as identification. \ \ My Commission Expires: VR =| ae a _ lotary Public Mo ne= MY COMMIS! 464364 2008 ‘EXPIRES: Noverv1,er Bona! Tru Notary Pl meee -- GLING EC (Affix Seal) Printed Name of Notary Public