Preview
Filing # 163357405 E-Filed 12/20/2022 09:06:56 AM
RETURN OF SERVICE
State of Florida County of Charlotte Circuit Court
Case Number: 21-000410-CA Court Date: 3/2/2023 2:00 pm
Plaintiff:
VENISSA DRIGGERS, As Personal Representative of the Estate of
DAVID B. FLICK, Deceased,
vs.
Defendants:
MARK BARCIA, HOOTERS OF PORT CHARLOTTE, INC., BWR NORTH
PORT, LLC d/b/a BUFFALO WINGS AND RINGS, ATLANTA
RESTAURANT PARTNERS, LLC d/b/a TGI FRIDAYS, AND JACKMONT
HOSPITALITY, INC, d/b/a TG] FRIDAYS,
For:
James E. Sposato
RITTER CHUSID, LLP.
Received by CAPLAN, CAPLAN & CAPLAN PROCESS SERVERS on the 15th day of December, 2022 at 1:37 pm
to be served on PIERRE RICHARD LOUIS, 21905 BEVERLY AVE, PORT CHARLOTTE, FL 33952.
|, Sally Susino, do hereby affirm that on the 15th day of December, 2022 at 3:02 pm, I:
SUBSTITUTE served by delivering a true copy of the RE-NOTICE OF TAKING DEPOSITION with the date and
hour of service endorsed thereon by me, to: LESMINTHA JEAN as FRIEND/ CO-RESIDENT at the address of:
21905 BEVERLY AVE, PORT CHARLOTTE, FL 33952, the within named person's usual place of Abode, who
tesides therein, who is fifteen (15) years of age or older and informed said person of the contents therein, in
compliance with state statutes.
Military Status: Based upon inquiry of party served, Defendant is not in the military service of the United States of
America.
Description of Person Served: Age: 32, Sex: F, Race/Skin Color: BLACK, Height: 5'6, Weight: 160, Hair:
BLACK, Glasses: N
| certify that | am over the age of 18, have no interest in the above action, and am a Certified Process Server, in
good standing, in the judicial circuit in which the process was served.
Sally gully assed
158080
CAPLAN, CAPLAN & CAPLAN PROCESS SERVERS
14160 Palmetto Frontage Road, Suite 105
Miami Lakes, FL 33016
(305) 374-3426
Our Job Serial Number: BLZ-202200047-
Ref: 39521
Copyright @ 1992-2011 Database Services, Inc. - Procass Server's Toolbox V6.5bFiling # 163029753 E-Filed 12/14/2022 12:25:54 PM
IN THE CIRCUIT COURT OF THE 20™ JUDICIAL CIRCUIT,
IN AND FOR CHARLOTTE COUNTY, FLORIDA
VENISSA DRIGGERS, as Personal Representative CASE NO.: 21-000410-CA
of the Estate of DAVID B. FLICK, Deceased,
Plaintiff,
vs,
MARK BARCIA, HOOTERS OF PORT CHARLOTTE,
INC., BWR NORTH PORT, LLC d/b/a BUFFALO
re
WINGS AND RINGS, ATLANTA RESTAURANT PAF LEE
PARTNERS, LLC d/b/a TGI FRIDAYS, AND
JACKMONT HOSPITALITY, INC. d/b/a TGI sar
FRIDAYS, ——44-__.
Defendants.
/
RE-NOTICE OF TAKING DEPOSITION
PLEASE TAKE NOTICE that the undersigned attorney will take the deposition of the
individual named below in the above-styled cause on the date and at the time indicated:
NAME: DATE AND TIME:
Pierre Richard Louis Thursday, March 2, 2023 at 2:00 p.m.
LOCATION:
Phipps Court Reporting
Via Zoom (Link will be Provided)
Said deposition is being taken upon oral examination before a Court Reporter who is duly authorized
to by law to take depositions in the State of Florida.
The oral examination will continue from day to day until completed. This deposition is being
taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted under
RITTER CHUSID, LLP, ATTORNEYS AT LAW
HERON BAY CORPORATE CENTER + 5850 CORAL RIDGE DRIVE, SUITE 20] + CORAL SPRINGS, FLORIDA 33076 = 954-340-2200 « FAX 954-340-2210the Rules of Court, including the applicable Florida Rules of Civil Procedure.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that on this 14" day of December, 2022, a true and correct copy
of the foregoing was filed with the Clerk 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 on
the attached Service List.
RITTER CHUSID, LLP
Counsel for Defendant, Hooters of Port Charlotte, Inc.
5850 Coral Ridge Drive, Suite 201
Coral Springs, Florida 33076
Telephone: (954) 340-2200
Facsimile: (954) 340-2210
By: /s/Michael Rubin
Mitchel Chusid, Esq.
Florida Bar No.: 879282
mehusid@ritterchusid.com
Joshua Brankamp, Esq.
Florida Bar No.: 31315
jbrankamp@ritterchusid.com
Michael Rubin, Esq.
cc: Phipps Reporting
RITTER CHUSID, LLP, ATTORNEYS AT LAW
HERON BAY CORPORATE CENTER + $850 CORAL RIDGE DRIVE, SUITE 201 « CORAL SPRINGS, FLORIDA 33076 + 954-340-2200 * FAX 954-340-2210
Preview
Filing # 163357405 E-Filed 12/20/2022 09:06:56 AM RETURN OF SERVICE State of Florida County of Charlotte Circuit Court Case Number: 21-000410-CA Court Date: 3/2/2023 2:00 pm Plaintiff: VENISSA DRIGGERS, As Personal Representative of the Estate of DAVID B. FLICK, Deceased, vs. Defendants: MARK BARCIA, HOOTERS OF PORT CHARLOTTE, INC., BWR NORTH PORT, LLC d/b/a BUFFALO WINGS AND RINGS, ATLANTA RESTAURANT PARTNERS, LLC d/b/a TGI FRIDAYS, AND JACKMONT HOSPITALITY, INC, d/b/a TG] FRIDAYS, For: James E. Sposato RITTER CHUSID, LLP. Received by CAPLAN, CAPLAN & CAPLAN PROCESS SERVERS on the 15th day of December, 2022 at 1:37 pm to be served on PIERRE RICHARD LOUIS, 21905 BEVERLY AVE, PORT CHARLOTTE, FL 33952. |, Sally Susino, do hereby affirm that on the 15th day of December, 2022 at 3:02 pm, I: SUBSTITUTE served by delivering a true copy of the RE-NOTICE OF TAKING DEPOSITION with the date and hour of service endorsed thereon by me, to: LESMINTHA JEAN as FRIEND/ CO-RESIDENT at the address of: 21905 BEVERLY AVE, PORT CHARLOTTE, FL 33952, the within named person's usual place of Abode, who tesides therein, who is fifteen (15) years of age or older and informed said person of the contents therein, in compliance with state statutes. Military Status: Based upon inquiry of party served, Defendant is not in the military service of the United States of America. Description of Person Served: Age: 32, Sex: F, Race/Skin Color: BLACK, Height: 5'6, Weight: 160, Hair: BLACK, Glasses: N | certify that | am over the age of 18, have no interest in the above action, and am a Certified Process Server, in good standing, in the judicial circuit in which the process was served. Sally gully assed 158080 CAPLAN, CAPLAN & CAPLAN PROCESS SERVERS 14160 Palmetto Frontage Road, Suite 105 Miami Lakes, FL 33016 (305) 374-3426 Our Job Serial Number: BLZ-202200047- Ref: 39521 Copyright @ 1992-2011 Database Services, Inc. - Procass Server's Toolbox V6.5bFiling # 163029753 E-Filed 12/14/2022 12:25:54 PM IN THE CIRCUIT COURT OF THE 20™ JUDICIAL CIRCUIT, IN AND FOR CHARLOTTE COUNTY, FLORIDA VENISSA DRIGGERS, as Personal Representative CASE NO.: 21-000410-CA of the Estate of DAVID B. FLICK, Deceased, Plaintiff, vs, MARK BARCIA, HOOTERS OF PORT CHARLOTTE, INC., BWR NORTH PORT, LLC d/b/a BUFFALO re WINGS AND RINGS, ATLANTA RESTAURANT PAF LEE PARTNERS, LLC d/b/a TGI FRIDAYS, AND JACKMONT HOSPITALITY, INC. d/b/a TGI sar FRIDAYS, ——44-__. Defendants. / RE-NOTICE OF TAKING DEPOSITION PLEASE TAKE NOTICE that the undersigned attorney will take the deposition of the individual named below in the above-styled cause on the date and at the time indicated: NAME: DATE AND TIME: Pierre Richard Louis Thursday, March 2, 2023 at 2:00 p.m. LOCATION: Phipps Court Reporting Via Zoom (Link will be Provided) Said deposition is being taken upon oral examination before a Court Reporter who is duly authorized to by law to take depositions in the State of Florida. The oral examination will continue from day to day until completed. This deposition is being taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted under RITTER CHUSID, LLP, ATTORNEYS AT LAW HERON BAY CORPORATE CENTER + 5850 CORAL RIDGE DRIVE, SUITE 20] + CORAL SPRINGS, FLORIDA 33076 = 954-340-2200 « FAX 954-340-2210the Rules of Court, including the applicable Florida Rules of Civil Procedure. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that on this 14" day of December, 2022, a true and correct copy of the foregoing was filed with the Clerk 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 on the attached Service List. RITTER CHUSID, LLP Counsel for Defendant, Hooters of Port Charlotte, Inc. 5850 Coral Ridge Drive, Suite 201 Coral Springs, Florida 33076 Telephone: (954) 340-2200 Facsimile: (954) 340-2210 By: /s/Michael Rubin Mitchel Chusid, Esq. Florida Bar No.: 879282 mehusid@ritterchusid.com Joshua Brankamp, Esq. Florida Bar No.: 31315 jbrankamp@ritterchusid.com Michael Rubin, Esq. cc: Phipps Reporting RITTER CHUSID, LLP, ATTORNEYS AT LAW HERON BAY CORPORATE CENTER + $850 CORAL RIDGE DRIVE, SUITE 201 « CORAL SPRINGS, FLORIDA 33076 + 954-340-2200 * FAX 954-340-2210