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Filing # 147600606 E-Filed 04/13/2022 10:41:43 AM
IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL
CIRCUIT IN AND FOR DUVAL COUNTY, FLORIDA
CASE NO. 2020-CA-002067
JOHN VALIS,
PLAINTIFF,
V.
CHRISTINE HITCHCOCK AND
USAA CASUALTY INSURANCE COMPANY,
DEFENDANTS.
/
DEFENDANT’S NOTICE OF TAKING DEPOSITION DUCES TECUM
TO Michael D. Marrese, Esquire
76 South Laura Street, Ste. 110
Jacksonville, FL 32202
PLEASE TAKE NOTICE that the undersigned attorney will take the depositions of:
NAME: DR. MARK FRISK
DATE: May 27, 2022
TIME: 3:30 P.M.
PLACE: By Zoom (link will be emailed)
upon oral examination before Veritext, Notary Public in and for the State of Florida at Large, or
some other officer duly authorized by law to take depositions. The deposition 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, pursuant to Florida Rules of Civil Procedure.
The Deponent is further commanded to bring with him, at the time and place noted
above, the following:
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 04/13/2022 11:40:53 AM
Any and all documents, concerning JOHN VALIS including, but not limited to, any and all
documents, memos, notes, diagrams, medical history, medical records, radiology films, billing
records, invoices, statements, hand written notes, opinions, reports or updated reports,
recordings for transcription, photographs, emails sent or received by anyone in your office,
records of any telephone calls made to you or by anyone in your office, letters, emails, text
messages, or other correspondence to and/or from attorneys, physicians and insurance
companies, current CV.
CERTIFICATE OF SERVICE
The document contains no confidential or sensitive information or that any such
confidential or sensitive language has been properly protected by complying with the provisions
of Rule 2.420 and 2.425. I HEREBY CERTIFY that a true and correct copy of the foregoing has
been furnished by electronic filing to Michael D. Marrese, Esquire, 76 South Laura Street, Ste.
110, Jacksonville, FL 32202, Mmarrese@forthepeople.com; jlow@forthepeople.com;
pceallaremi@forthepeople.com, Kathleen A. Carlson, Esquire, 200 West Forsyth St., Suite 1400,
Jacksonville, FL 32202, KACarlson@MDWCG.com; hahildebrand@MDWCG.com on this
13th_ day of April, 2022.
PAUL M. EZA, ESQUIRE
Fla. Bar No. 68708
Law Offices of Sonya S. Wesner
200 East Robinson Street, Suite 510
Orlando, FL 32801
Telephone: (407) 393-9100
Direct Dial: (904) 489-6585
Secretary: (407) 393-9410
Paralegal: (407) 393-9097
Fax: (877) 499-6079
Primary EMail:JAXSMAIL@nationwide.com
Attorneys for Defendants
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Filing # 147600606 E-Filed 04/13/2022 10:41:43 AM IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT IN AND FOR DUVAL COUNTY, FLORIDA CASE NO. 2020-CA-002067 JOHN VALIS, PLAINTIFF, V. CHRISTINE HITCHCOCK AND USAA CASUALTY INSURANCE COMPANY, DEFENDANTS. / DEFENDANT’S NOTICE OF TAKING DEPOSITION DUCES TECUM TO Michael D. Marrese, Esquire 76 South Laura Street, Ste. 110 Jacksonville, FL 32202 PLEASE TAKE NOTICE that the undersigned attorney will take the depositions of: NAME: DR. MARK FRISK DATE: May 27, 2022 TIME: 3:30 P.M. PLACE: By Zoom (link will be emailed) upon oral examination before Veritext, Notary Public in and for the State of Florida at Large, or some other officer duly authorized by law to take depositions. The deposition 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, pursuant to Florida Rules of Civil Procedure. The Deponent is further commanded to bring with him, at the time and place noted above, the following: ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 04/13/2022 11:40:53 AM Any and all documents, concerning JOHN VALIS including, but not limited to, any and all documents, memos, notes, diagrams, medical history, medical records, radiology films, billing records, invoices, statements, hand written notes, opinions, reports or updated reports, recordings for transcription, photographs, emails sent or received by anyone in your office, records of any telephone calls made to you or by anyone in your office, letters, emails, text messages, or other correspondence to and/or from attorneys, physicians and insurance companies, current CV. CERTIFICATE OF SERVICE The document contains no confidential or sensitive information or that any such confidential or sensitive language has been properly protected by complying with the provisions of Rule 2.420 and 2.425. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by electronic filing to Michael D. Marrese, Esquire, 76 South Laura Street, Ste. 110, Jacksonville, FL 32202, Mmarrese@forthepeople.com; jlow@forthepeople.com; pceallaremi@forthepeople.com, Kathleen A. Carlson, Esquire, 200 West Forsyth St., Suite 1400, Jacksonville, FL 32202, KACarlson@MDWCG.com; hahildebrand@MDWCG.com on this 13th_ day of April, 2022. PAUL M. EZA, ESQUIRE Fla. Bar No. 68708 Law Offices of Sonya S. Wesner 200 East Robinson Street, Suite 510 Orlando, FL 32801 Telephone: (407) 393-9100 Direct Dial: (904) 489-6585 Secretary: (407) 393-9410 Paralegal: (407) 393-9097 Fax: (877) 499-6079 Primary EMail:JAXSMAIL@nationwide.com Attorneys for Defendants