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IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN
COUNTY, FLORIDA
AND FOR COLLIER
CIVIL ACTION
ELLIS HANSON and VELTA HANSON,
Plaintiffs,
v.
ALMA TETI,
Case No. 09-6515-CA
Defendant.
PLAINTIFF'S, ELLIS HANSON AND VELTA .
HLANSON, SECON!
D NOTICE OF TAKING VIDEOTAPED
DEPOSITION DUCES TECUM OF DEFENDANT, ALMA TETI
PLEASE TAKE NOTICE that pursuant to Rule 1.310, Florida Rules of Civil Procedure,
before an officer fully authorized by law to take depositions, the following deposition is
scheduled as follows:
DEPONENT:
o
BE
eo Tr
Alma Teti S 3 mn
DATE: September 3, 2010 a4 2h
TIME: 9:00 a.m. (Full-day) a3 a
S Cc
PLACE: At the law offices of: 4% 23
Grant, Fridkin, Pearson, Athan & Crown, P.A. 3 o S
5551 Ridgewood Drive, Suite 501 .
Naples, Florida 34108
(239) 514-1000
COURT
REPORTER:
Donovan Court Reporting
‘The deposition will be taken upon oral examination be!
any other notary public or officer authorized by law
fore Donovan Court Reporting or
The deponent is instructed to bring to the
to take depositions in the State of Florida.
deposition the items set forth in Exhibit “1” attached
hereto. The deposition will continue from day to day until completed. This deposition is being
taken for the purpose of discovery, for use at trial pursuant to section 90.803(22), Florida
Statutes, or for such other purposes as are permitted by the Florida Rules of Civil Proced
the Florida Evidence Code.
jure orThe deposition will be videotaped by a representative of Donovan Court Reporting, 2315
Stanford Court, Suite 301, Naples, FL 34112, or Coleman, Yovanovich & Koester, P.A., or a
professional videographer.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
by facsimile and regular U.S. mail to D. Keith Wickenden, Esq., Grant, Fridkin, Pearson, Athan
& Crown, P.A., 5551 Ridgewood Drive, Suite 501, Naples, Florida 34108 on this 6th day of
July, 2010.
Coleman, Yovanovich & Koester, P.A.
o:Ze aete Z24 —
Todd M. Rich
Florida Bar No. 51451
Edmond E. Koester
Florida Bar No. 87882
4001 Tamiami Trail North, Suite 300
Naples, FL 34103
239.435.3535
239.435.1218 Facsimile
Attorneys for Ellis and Velta HansonEXHIBIT “1”
Each document request is subject to and incorporates the definitions set forth in Exhibit
“2” attached hereto:
DOCUMENTS AND THINGS TO BE PRODUCED
1. All correspondence, documents, and/or communications exchanged by and between
Alma Teti and Ellis Hanson.
2. All voice recordings of Ellis Hanson, including, but not limited to, voice-mails.
3. All correspondence, documents, and/or communications exchanged by and between
Alma Teti and any person related in any way to the mental condition of Ellis Hanson.
4. All correspondence, documents, and/or communications exchanged by and between
Alma Teti and Raymond James related in any way to the funds obtained from Ellis
Hanson, which is the subject of this lawsuit.
5. All correspondence, documents, and/or communications exchanged by and between
Alma Teti and any person related in any way to the funds obtained from Ellis Hanson,
which is the subject of this lawsuit.
6. All correspondence, documents, and/or communications exchanged by and between
Alma Teti and any person discussing any of the allegations in this lawsuit.
None af the requests above include any documents protected by the attorney-client privilege.EXHIBIT “2”
DEFINITIONS
"Plaintiffs" means all of the Plaintiff(s) named in this lawsuit unless the proper
name of an individual Plaintiff is provided, and any employee, agent or attorney
of Plaintiff and any other person acting for or on behalf of Plaintiff or under
Plaintiff's authority and control.
"Defendants" means all the Defendants named in this lawsuit unless the proper
name of an individual Defendant is provided. "Defendants" or the proper name of
an individual Defendant includes any employee, agent or attorney of Defendants,
and any other person acting for or on behalf of Defendants or under Defendants'
authority or control individually, jointly, or in any capacity whatsoever with any
other entity of any kind, nature or type including all successors, assigns and
predecessors in right, title and interest.
"Document" means any written or graphic matter or other means of preserving
thought or expression and all tangible things from which information can be
processed or transcribed, including the originals and all non-identical copies,
whether different from the original by reason of any notation made on such copy
or otherwise, including but not limited to, correspondence, memoranda, notes,
messages, letters, telegrams, teletype, telefax, bulletins, meetings or other
communication, inter-office and intra-office, telephone calls, diaries,
chronological data, minutes, books, reports, charts, ledgers, invoices, worksheets,
receipts, returns, computer printouts, prospectuses, financial statements,
schedules, affidavits, contracts, canceled checks, transcripts, statistics, surveys,
magazine or newspaper articles, releases (and any and all drafts, alterations and
modifications, changes and amendments of any of the foregoing), graphs or aural
records or representations of any kind, including without limitation, photographs,
charts, graphs, microfiche, microfilm, video tape, recordings, motion pictures and
electronic, mechanical or electric recordings or representations of any kind
(including without limitation, tapes, cassettes, disk and records).
"Communication" means any written or oral statement, dialogue, colloquialism,
discussion, conversation or agreement.
The term "you" and "your" means the person to whom this Subpoena is
addressed, including their agents, employees, attorneys and all other persons
acting or purporting to act on their behalf.
"Person" means any natural person, individual, proprietorship, partnership,
corporation, association, organization, joint venture, firm, other business
enterprise, governmental body, and group of natural persons or other entities.
As used herein, the singular and masculine of noun and pronoun shall embrace® ®
and be read and applied as a plural or feminine, neuter, as circumstances may
appropriate.
"Refer to," "relate to" or "pertain in any manner to" shall mean to make a
statement about, discuss, describe, reflect, constitute, identify, deal with, consist
of, establish, compromise, list, evidence, substantiate or in any way pertain, in
whole or in part, to the subject.
The word "produce" means to make available the documents requested for
inspection and copying and to separate such documents in the categories set forth
in this Request. If you decline to produce any documents on the basis of any
asserted privilege or under the work-product doctrine, provide the following
written information pertaining to such documents:
a. Its date, or, if not dated, the date it was prepared or received.
b. The type of document (e.g, letter, memorandum, telegraph, photograph,
etc.).
c. The author and addressee.
d. Its present location.
e. The identity of the individual or person presently in custody of it.
f. The general description of its contents.
g. The identity of each person who received a copy of the document and the
relationship of such person to you.
h. Whether such document contains or relates to facts or opinions, or both.
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Ce
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“ S ®@ IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN COUNTY, FLORIDA AND FOR COLLIER CIVIL ACTION ELLIS HANSON and VELTA HANSON, Plaintiffs, v. ALMA TETI, Case No. 09-6515-CA Defendant. PLAINTIFF'S, ELLIS HANSON AND VELTA . HLANSON, SECON! D NOTICE OF TAKING VIDEOTAPED DEPOSITION DUCES TECUM OF DEFENDANT, ALMA TETI PLEASE TAKE NOTICE that pursuant to Rule 1.310, Florida Rules of Civil Procedure, before an officer fully authorized by law to take depositions, the following deposition is scheduled as follows: DEPONENT: o BE eo Tr Alma Teti S 3 mn DATE: September 3, 2010 a4 2h TIME: 9:00 a.m. (Full-day) a3 a S Cc PLACE: At the law offices of: 4% 23 Grant, Fridkin, Pearson, Athan & Crown, P.A. 3 o S 5551 Ridgewood Drive, Suite 501 . Naples, Florida 34108 (239) 514-1000 COURT REPORTER: Donovan Court Reporting ‘The deposition will be taken upon oral examination be! any other notary public or officer authorized by law fore Donovan Court Reporting or The deponent is instructed to bring to the to take depositions in the State of Florida. deposition the items set forth in Exhibit “1” attached hereto. The deposition will continue from day to day until completed. This deposition is being taken for the purpose of discovery, for use at trial pursuant to section 90.803(22), Florida Statutes, or for such other purposes as are permitted by the Florida Rules of Civil Proced the Florida Evidence Code. jure orThe deposition will be videotaped by a representative of Donovan Court Reporting, 2315 Stanford Court, Suite 301, Naples, FL 34112, or Coleman, Yovanovich & Koester, P.A., or a professional videographer. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by facsimile and regular U.S. mail to D. Keith Wickenden, Esq., Grant, Fridkin, Pearson, Athan & Crown, P.A., 5551 Ridgewood Drive, Suite 501, Naples, Florida 34108 on this 6th day of July, 2010. Coleman, Yovanovich & Koester, P.A. o:Ze aete Z24 — Todd M. Rich Florida Bar No. 51451 Edmond E. Koester Florida Bar No. 87882 4001 Tamiami Trail North, Suite 300 Naples, FL 34103 239.435.3535 239.435.1218 Facsimile Attorneys for Ellis and Velta HansonEXHIBIT “1” Each document request is subject to and incorporates the definitions set forth in Exhibit “2” attached hereto: DOCUMENTS AND THINGS TO BE PRODUCED 1. All correspondence, documents, and/or communications exchanged by and between Alma Teti and Ellis Hanson. 2. All voice recordings of Ellis Hanson, including, but not limited to, voice-mails. 3. All correspondence, documents, and/or communications exchanged by and between Alma Teti and any person related in any way to the mental condition of Ellis Hanson. 4. All correspondence, documents, and/or communications exchanged by and between Alma Teti and Raymond James related in any way to the funds obtained from Ellis Hanson, which is the subject of this lawsuit. 5. All correspondence, documents, and/or communications exchanged by and between Alma Teti and any person related in any way to the funds obtained from Ellis Hanson, which is the subject of this lawsuit. 6. All correspondence, documents, and/or communications exchanged by and between Alma Teti and any person discussing any of the allegations in this lawsuit. None af the requests above include any documents protected by the attorney-client privilege.EXHIBIT “2” DEFINITIONS "Plaintiffs" means all of the Plaintiff(s) named in this lawsuit unless the proper name of an individual Plaintiff is provided, and any employee, agent or attorney of Plaintiff and any other person acting for or on behalf of Plaintiff or under Plaintiff's authority and control. "Defendants" means all the Defendants named in this lawsuit unless the proper name of an individual Defendant is provided. "Defendants" or the proper name of an individual Defendant includes any employee, agent or attorney of Defendants, and any other person acting for or on behalf of Defendants or under Defendants' authority or control individually, jointly, or in any capacity whatsoever with any other entity of any kind, nature or type including all successors, assigns and predecessors in right, title and interest. "Document" means any written or graphic matter or other means of preserving thought or expression and all tangible things from which information can be processed or transcribed, including the originals and all non-identical copies, whether different from the original by reason of any notation made on such copy or otherwise, including but not limited to, correspondence, memoranda, notes, messages, letters, telegrams, teletype, telefax, bulletins, meetings or other communication, inter-office and intra-office, telephone calls, diaries, chronological data, minutes, books, reports, charts, ledgers, invoices, worksheets, receipts, returns, computer printouts, prospectuses, financial statements, schedules, affidavits, contracts, canceled checks, transcripts, statistics, surveys, magazine or newspaper articles, releases (and any and all drafts, alterations and modifications, changes and amendments of any of the foregoing), graphs or aural records or representations of any kind, including without limitation, photographs, charts, graphs, microfiche, microfilm, video tape, recordings, motion pictures and electronic, mechanical or electric recordings or representations of any kind (including without limitation, tapes, cassettes, disk and records). "Communication" means any written or oral statement, dialogue, colloquialism, discussion, conversation or agreement. The term "you" and "your" means the person to whom this Subpoena is addressed, including their agents, employees, attorneys and all other persons acting or purporting to act on their behalf. "Person" means any natural person, individual, proprietorship, partnership, corporation, association, organization, joint venture, firm, other business enterprise, governmental body, and group of natural persons or other entities. As used herein, the singular and masculine of noun and pronoun shall embrace® ® and be read and applied as a plural or feminine, neuter, as circumstances may appropriate. "Refer to," "relate to" or "pertain in any manner to" shall mean to make a statement about, discuss, describe, reflect, constitute, identify, deal with, consist of, establish, compromise, list, evidence, substantiate or in any way pertain, in whole or in part, to the subject. The word "produce" means to make available the documents requested for inspection and copying and to separate such documents in the categories set forth in this Request. If you decline to produce any documents on the basis of any asserted privilege or under the work-product doctrine, provide the following written information pertaining to such documents: a. Its date, or, if not dated, the date it was prepared or received. b. The type of document (e.g, letter, memorandum, telegraph, photograph, etc.). c. The author and addressee. d. Its present location. e. The identity of the individual or person presently in custody of it. f. The general description of its contents. g. The identity of each person who received a copy of the document and the relationship of such person to you. h. Whether such document contains or relates to facts or opinions, or both. -5- ~~ Ce