Motion For Protective Order For Deposition Of Ellis Hanson

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IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
COLLIER COUNTY, FLORIDA CIVIL ACTION

ELLIS HANSON and VELTA HANSON,

Plaintiffs,

v. Case No. 09-6515-CA
ALMA TETI,

Defendant. eo i“

 

 

Plaintiffs, Ellis Hanson and Velta Hanson, by and through the under figned Su a
pursuant to Rule 1.280(c), Florida Rules of Civil Procedure, Section 90.603, Florida sities
and Section 90.604, Florida Statutes, move this Court to grant a protective order to prevent the
deposition of Ellis Hanson (“Mr. Hanson”), and show:

I. BACKGROUND

1. On August 20, 2009, opposing counsel requested dates to take the deposition of
Mr. Hanson. A true and correct copy of the email is attached hereto as Exhibit “A.”

2. Mr. Hanson suffers from Alzheimer’s Disease. His symptoms from the
Alzheimer’s Disease include, but are not limited to, severe memory loss and cognitive deficits,
which have become progressively worse over time.
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