Preview
Filing # 84039032 E-Filed 01/29/2019 10:15:33 AM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT IN
AND FOR BROWARD COUNTY, FLORIDA
CASE NO. 18 00391 CACE
JEAN ROBERT LEBLANC,
Plaintiff,
VS.
A&A WEST INDIAN GROCERIES, INC.,
D/B/A A&A HALAL DISTRIBUTORS, JOSE
CARLOS BENITZ ORTEGA AND
MOHAMED AZAD ASSIM,
Defendants. /
NOTICE OF TAKING TELEPHONIC DEPOSITION DUCES TECUM
PLEASE TAKE NOTICE that the undersigned attorney will take the deposition of:
NAME: Records Custodian for Constant Aviation
DATE: Wednesday, February 6, 2019
TIME: 10:30 A.M.
PLACE: Kerr & Associates
c/o Veritext Court Reporting
1540 International Parkway, Suite 2000
Lake Mary, Fl 32746
You are commanded to bring with you:
Any and all records including, but not limited to, all applications for employment, all prior
employment verification information, all pre-employment background or health documentation,
applications for insurance, insurance forms, all physician or medical reports or records of any kind
pertaining to physical examination required for employment, continued employment or health or
disability insurance, all reports or records of job or other injury, attendance records, sick time
records, vacation records, payroll records, salary history, progress records, letters of complaint,
*** FILED: BROWARD COUNTY. FL BRENDA D. FORMAN, CLERK 1/29/2019 10:15:33 AM.****
letters of commendation, work description records, records reflecting reasons for absences from
work, lay-offs or termination for any and all times, occasions or reasons, pertaining to Jean Robert
LeBlanc (Date of Birth: 1956, Last four digits of Social Security Nc. =).
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. You may comply with this subpoena by providing legible copies of the
items to be produced to the attorney whose name appears on this subpoena on or before the
scheduled date of production. You may condition the preparation of the copies upon the payment
in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney
whose name appears on this subpoena and thereby eliminate your appearance at the time and place
specified above. You have the right to object to the production pursuant to this subpoena at any time
before production by giving written notice to the attorney whose name appears on this subpoena.
UPON ORAL EXAMINATION, before Kerr & Associates, Court Reporter, a Notary Public
in and for the State of Florida at Large, or some other officer duly authorized by law to take
depositions. The deposition duces tecum will continue from day to day until completed. At said
deposition, a review of documents/items/records that the above listed witness has been directed to
bring pursuant to a Notice of Taking Deposition Duces Tecum and or Subpoena Duces Tecum for
Deposition, will occur. The deposition duces tecum is being taken for the purpose of discovery, or
for use at trial, or both of the foregoing, or for such other purposes as are permitted under the
applicable and governing rules, pursuant to Florida Rules of Civil Procedure
CERTIFICATE OF SERVICE
IT HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by e-
Mail this 28 day of January, 2019, to Wilnar J. Julmiste, julmiste@asglaw.com;.
Attorneys for A&A West Indian Groceries, Inc.
Hankin & Giaramita, P.A.
7450 Griffin Road, Suite 270
Davie, FL 33314
(954) 318-3838
/s/ Joseph Giaramita
Joseph R. Giaramita
Florida Bar # 025968
Preview
Filing # 84039032 E-Filed 01/29/2019 10:15:33 AM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. 18 00391 CACE JEAN ROBERT LEBLANC, Plaintiff, VS. A&A WEST INDIAN GROCERIES, INC., D/B/A A&A HALAL DISTRIBUTORS, JOSE CARLOS BENITZ ORTEGA AND MOHAMED AZAD ASSIM, Defendants. / NOTICE OF TAKING TELEPHONIC DEPOSITION DUCES TECUM PLEASE TAKE NOTICE that the undersigned attorney will take the deposition of: NAME: Records Custodian for Constant Aviation DATE: Wednesday, February 6, 2019 TIME: 10:30 A.M. PLACE: Kerr & Associates c/o Veritext Court Reporting 1540 International Parkway, Suite 2000 Lake Mary, Fl 32746 You are commanded to bring with you: Any and all records including, but not limited to, all applications for employment, all prior employment verification information, all pre-employment background or health documentation, applications for insurance, insurance forms, all physician or medical reports or records of any kind pertaining to physical examination required for employment, continued employment or health or disability insurance, all reports or records of job or other injury, attendance records, sick time records, vacation records, payroll records, salary history, progress records, letters of complaint, *** FILED: BROWARD COUNTY. FL BRENDA D. FORMAN, CLERK 1/29/2019 10:15:33 AM.**** letters of commendation, work description records, records reflecting reasons for absences from work, lay-offs or termination for any and all times, occasions or reasons, pertaining to Jean Robert LeBlanc (Date of Birth: 1956, Last four digits of Social Security Nc. =). These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena. UPON ORAL EXAMINATION, before Kerr & Associates, Court Reporter, a Notary Public in and for the State of Florida at Large, or some other officer duly authorized by law to take depositions. The deposition duces tecum will continue from day to day until completed. At said deposition, a review of documents/items/records that the above listed witness has been directed to bring pursuant to a Notice of Taking Deposition Duces Tecum and or Subpoena Duces Tecum for Deposition, will occur. The deposition duces tecum is being taken for the purpose of discovery, or for use at trial, or both of the foregoing, or for such other purposes as are permitted under the applicable and governing rules, pursuant to Florida Rules of Civil Procedure CERTIFICATE OF SERVICE IT HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by e- Mail this 28 day of January, 2019, to Wilnar J. Julmiste, julmiste@asglaw.com;. Attorneys for A&A West Indian Groceries, Inc. Hankin & Giaramita, P.A. 7450 Griffin Road, Suite 270 Davie, FL 33314 (954) 318-3838 /s/ Joseph Giaramita Joseph R. Giaramita Florida Bar # 025968