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Filing # 148787383 E-Filed 05/02/2022 03:57:28 PM
IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT,
IN AND FOR GADSDEN COUNTY, FLORIDA
REGINA DAVIS,
Plaintiff,
vs CASE NO. 21000024CAA
GADSDEN SENIOR
SERVICES, INC.,
Defendant
NOTICE OF DEPOSITION DUCES TECUM OF JAMES HINSON
PLEASE TAKE NOTICE that the undersigned attorneys for Plaintiff will take the
deposition of James Hinson, by oral examination and stenographic means before a Notary Public
authorized by law to take depositions on May 13, 2022 at 2:00pm, and will continue from day to
day until completed. The deposition may be videotaped, as well as a webcast to a remote location.
The deposition will be conducted via the Zoom webcast platform link at:
https://usO2web.zoom.us/j/89207079067?pwd=TkFINXRiNOIRUFMOTkNaOHkyNVRoUT09
Meeting ID: 892 0707 9067
Dial +1 646 876 9923
Password: 926233
If the witness and his or her attorney prefer to appear in person, they must arrange to attend
the in-person deposition at the offices of Phipps Reporting by contacting Phipps Reporting directly
and shall notify all parties of said arrangement. Phipps Reporting is located at 2894 Remington
Green Ln Suite A, Tallahassee, FL.THE WITNESS SHOULD HAVE A GOVERNMENT-ISSUED IDENTIFICATION TO
PROVIDE TO THE COURT REPORTER/NOTARY TO CONFIRM HIS/HER IDENTITY
AT THE COMMENCEMENT OF THE DEPOSITION AND BEFORE BEING SWORN.
This deposition is being taken for the purpose of discovery, for use as evidence, and for
such other uses and purposes as are permitted under the Florida Rules of Civil Procedure and other
applicable law and in accordance with Rules 1.300 and 1.330, Florida Rules of Civil Procedure.
The depositions will continue from day to day until completed.
The deponent is to produce at date and time of the deposition the following items (which
are not intended to and specifically do not include any attorney/client or work product privileged
materials.) Please bring with you:
1. Any and all documents listed in Exhibit A.
PLEASE GOVERN YOURSELVES ACCORDINGLY.
Dated this 2™ day of May, 2022.
/s/Jennifer Winegardner
Jennifer A. Winegardner (133930)
jennifer@flalawfirm.com
Amy B. Kirkpatrick (148725)
amy@flalawfirm.com
RAYBOUN WINEGARDNER, PLLC
1410 Piedmont Drive East, 2™ Floor
Tallahassee, FL 32308
Telephone: (850) 270-9064
Facsimile: (850) 422-0074
CERTIFICATE OF SERVICE
A copy of the foregoing was served on counsel of record through this Court’s e-filing portal
upon all parties of record on this 2"! day of May, 2022
A copy will also be furnished via email to Phipps Recording.
/s/ Jennifer A. Winegardner
JENNIFER A. WINEGARDNERExhibit A
1. All meeting notices, meeting minutes, agendas, handwritten notes, and transcripts for
Gadsden Senior Services, Inc. meetings — including board meetings, annual meetings, executive
sessions, workshops — from October 1, 2019, to March 1, 2020.
2. All reports, correspondence, notes, memoranda, letters, emails, text messages, regarding
Regina Davis.
3 All reports, correspondence, notes, memoranda, letters, emails, text messages, during the
period of October 1, 2019, to March 1, 2020, regarding:
A. license and certification of Gadsden Senior Services, Inc., staff
B compliments, comments, and complaints about the management, operation, and
function of Gadsden Senior Services, Inc.
Cc. any intended, anticipated, proposed, or scheduled meeting of the Gadsden Senior
Services, Inc., Board of Directors, or quorum thereof, on a weekend between
October 1, 2019, and March 1, 2020.
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Filing # 148787383 E-Filed 05/02/2022 03:57:28 PM IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT, IN AND FOR GADSDEN COUNTY, FLORIDA REGINA DAVIS, Plaintiff, vs CASE NO. 21000024CAA GADSDEN SENIOR SERVICES, INC., Defendant NOTICE OF DEPOSITION DUCES TECUM OF JAMES HINSON PLEASE TAKE NOTICE that the undersigned attorneys for Plaintiff will take the deposition of James Hinson, by oral examination and stenographic means before a Notary Public authorized by law to take depositions on May 13, 2022 at 2:00pm, and will continue from day to day until completed. The deposition may be videotaped, as well as a webcast to a remote location. The deposition will be conducted via the Zoom webcast platform link at: https://usO2web.zoom.us/j/89207079067?pwd=TkFINXRiNOIRUFMOTkNaOHkyNVRoUT09 Meeting ID: 892 0707 9067 Dial +1 646 876 9923 Password: 926233 If the witness and his or her attorney prefer to appear in person, they must arrange to attend the in-person deposition at the offices of Phipps Reporting by contacting Phipps Reporting directly and shall notify all parties of said arrangement. Phipps Reporting is located at 2894 Remington Green Ln Suite A, Tallahassee, FL.THE WITNESS SHOULD HAVE A GOVERNMENT-ISSUED IDENTIFICATION TO PROVIDE TO THE COURT REPORTER/NOTARY TO CONFIRM HIS/HER IDENTITY AT THE COMMENCEMENT OF THE DEPOSITION AND BEFORE BEING SWORN. This deposition is being taken for the purpose of discovery, for use as evidence, and for such other uses and purposes as are permitted under the Florida Rules of Civil Procedure and other applicable law and in accordance with Rules 1.300 and 1.330, Florida Rules of Civil Procedure. The depositions will continue from day to day until completed. The deponent is to produce at date and time of the deposition the following items (which are not intended to and specifically do not include any attorney/client or work product privileged materials.) Please bring with you: 1. Any and all documents listed in Exhibit A. PLEASE GOVERN YOURSELVES ACCORDINGLY. Dated this 2™ day of May, 2022. /s/Jennifer Winegardner Jennifer A. Winegardner (133930) jennifer@flalawfirm.com Amy B. Kirkpatrick (148725) amy@flalawfirm.com RAYBOUN WINEGARDNER, PLLC 1410 Piedmont Drive East, 2™ Floor Tallahassee, FL 32308 Telephone: (850) 270-9064 Facsimile: (850) 422-0074 CERTIFICATE OF SERVICE A copy of the foregoing was served on counsel of record through this Court’s e-filing portal upon all parties of record on this 2"! day of May, 2022 A copy will also be furnished via email to Phipps Recording. /s/ Jennifer A. Winegardner JENNIFER A. WINEGARDNERExhibit A 1. All meeting notices, meeting minutes, agendas, handwritten notes, and transcripts for Gadsden Senior Services, Inc. meetings — including board meetings, annual meetings, executive sessions, workshops — from October 1, 2019, to March 1, 2020. 2. All reports, correspondence, notes, memoranda, letters, emails, text messages, regarding Regina Davis. 3 All reports, correspondence, notes, memoranda, letters, emails, text messages, during the period of October 1, 2019, to March 1, 2020, regarding: A. license and certification of Gadsden Senior Services, Inc., staff B compliments, comments, and complaints about the management, operation, and function of Gadsden Senior Services, Inc. Cc. any intended, anticipated, proposed, or scheduled meeting of the Gadsden Senior Services, Inc., Board of Directors, or quorum thereof, on a weekend between October 1, 2019, and March 1, 2020.