Party Discovery: VENISSA DRIGGERS AS PERSONAL REPRESENTATIVE OF THE ESTATE OF DAVID FLICK DECEASED vs. BARCIA, MARK

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

VENISSA DRIGGERS, as Personal Representative of
the Estate of DAVID B. FLICK, Deceased,         CASE NO.              -410

        Plaintiffs,

vs.

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 TGI FRIDAYS,

     Defendants.
________________________________/

               PLAINTIFF’S SECOND AMENDED NOTICE OF TAKING VIDEOTELECONFERENCE
                                    VIDEOTAPED DEPOSITION


             PLEASE TAKE NOTICE that the undersigned will take the deposition of the following:

      Name and Address                        Date and Time                   Location

      Timothy Burgess                         March 8, 2023                   ZOOM
      (to be produced by defense counsel)     1:00 P.M. until completed       VIDEOTELECONFERENCE


             Upon oral examination, before PHIPPS REPORTING, a Notary Public, or any other Notary

      Public or officer duly authorized by law to take depositions. The oral examination will continue

      from day to day until completed. The deposition is being taken for the purpose of discovery,

      for use at trial, or both of the foregoing, or for such other purposes as are permitted under the

      applicable and governing rules.

             The deposition will be videotaped. The name of the operator is PHIPPS REPORTING.



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                                    CERTIFICATE OF SERVICE

       I HEREBY CERTIFY that a copy of the foregoing has been furnished by E-Mail on the 15 day

of December        , to Yasmine Kirollos, Esq., Conroy Simberg, 12730 New Brittany Blvd., Ste. 300,

Fort Myers, FL 33907; T.R. Unice, Jr., Esq., Unice Salzman Jensen, P.A., SouthState Bank Building,

Seconf Floor 1815 Little Road, Trinity, FL 34655; Howard W Holden, Esq, Luks, Santaniello, Petrillo

& Jones, 1422 Hendry St., 3rd Floor, Fort Myers, FL 33901; James F. Sposato, Esq., Ritter Chusid,

LLP, 5850 Coral Ridge Dr., Ste. 201, Coral Springs, FL 33076.

                                                      SPIVEY LAW FIRM
                                                      PERSONAL INJURY ATTORNEYS, P.A.
                                                      13400 Parker Commons Boulevard
                                                      Fort Myers,    33912
                                                      Phone: (239) 337-7483
                                                      Fax: (239) 337-7484




                                                      By
                                                            RANDALL L. SPIVEY
                                                            Florida Bar No. 0064742
                                                            Randall@spiveylaw.com

cc:    PHIPPS REPORTING

In accordance with the Americans with Disabilities Act of 1990, persons needing a special
accommodation to participate in this proceeding should contact Spivey Law Firm, Personal
Injury Attorneys, P.A., at (239) 337-7483 or (888) 477-4839, no later than seven days prior to
the proceeding.




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