On June 03, 135 a
No Value
was filed
involving a dispute between
Gonzalez, Barbara,
and
Edwards, Michael G,
Hhs Environmental Services, Llc,
for Other - Matters not within the Other Negligence Subcategories
in the District Court of Charlotte County.
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Filing # 165726030 E-Filed 01/30/2023 01:41:17 PM
IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIRCUIT CIVIL DIVISION
BARBARA GONZALEZ
Plaintiff,
CASE NO.: 21000968CA
vs.
MICHAEL G. EDWARDS and
HHS ENVIRONMENTAL SERVICES, LLC
Defendants.
/
PLAINTIFF’S NOTICE OF CANCELLATION
VIDEO-RECORDED DEPOSITION DUCES TECUM
PLEASE TAKE NOTICE that the undersigned attorney for Plaintiff, BARBARA
GONZALEZ, will cancel the VIDEO-RECORDED depositions by oral examination for the
purpose of discovery or evidence or both, pursuant to the Florida Rules of Civil Procedure and the
Florida Statutes, of the individuals listed below at the times, date, and location indicated below:
NAME DATE LOCATION
George Markovich, Friday, February 3, 2023
Kubicki Draper
M.D. TIME: 1:00 pm 13350 METRO PARKWAY,
SUITE 401
FORT MYERS, FL 33966
*TO BE PRODUCED
This deposition shall be taken before an associate or deputy court reporter and videographer
before their duly designated representative, who is not of counsel to the parties or interested in the
events of the cause.
This deposition is being taken for the purpose of discovery for use at trial, or for such other
purposes as are permitted under the Florida Rule of Civil Procedure.
1
This deposition shall continue until completed. Any cancellation and /or rescheduling of said
deposition must be confirmed in writing.
Said deponent is to have with him at the time and place aforesaid the following documents:
1 A current copy of his Curriculum Vitae.
2 All documents reviewed by you in the formulation of your opinion herein.
A copy of your statement for service rendered herein.
A list of cases in which you have previously testified either by deposition and/or by trial.
A copy of any reports, or similar documents, setting forth your opinion herein.
A copy of all notes, outlines, or similar writing prepared by you in the formulation of you
opinion herein.
A copy of any contract, or similar agreement, between you, those in privity with you, and
Defendant or Defendants’ counsel, herein relating to services being provided by you.
A copy of those portions of all texts, periodicals, or similar matters reviewed by you in
the formulation of your opinion herein.
9 A list of those attorney who have previously retained you as an expert.
10. A list of those attorneys whose clients you have previously testified against.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the forgoing has been furnished this 30" day of
January, 2023 by electronic mail to the following designated services e-mail address(es):
Francesca Ippolito-Craven, Esq. at fic@kubickidraper.com; fic-kd@kubickidraper.com
For the Clerk of the Court
/s/ Helen Stratigakos, Esg.
HELEN STRATIGAKOS, ESQ.
Florida Bar No.: 0893633
412 East Madison Street, Suite 814
Tampa, Florida 33606
(P): (813) 226-0067
(F): (813) 259-2505
helen stratigakoslaw.com
marty@stratigakoslaw.com
ATTORNEY FOR PLAINTIFF
4s/ Michael J. Rossi, Esq.
MICHAEL J. ROSSI, ESQ.
Michael J. Rossi, P.A.
Florida Bar No.: 0868000
115 South Albany Ave
Tampa, FL 33606
(P): (813) 253-3351
Michael@michaelrossilaw.com
Document Filed Date
January 03, 2024
Case Filing Date
June 03, 135
Category
Other - Matters not within the Other Negligence Subcategories
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Filing # 165726030 E-Filed 01/30/2023 01:41:17 PM IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIRCUIT CIVIL DIVISION BARBARA GONZALEZ Plaintiff, CASE NO.: 21000968CA vs. MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES, LLC Defendants. / PLAINTIFF’S NOTICE OF CANCELLATION VIDEO-RECORDED DEPOSITION DUCES TECUM PLEASE TAKE NOTICE that the undersigned attorney for Plaintiff, BARBARA GONZALEZ, will cancel the VIDEO-RECORDED depositions by oral examination for the purpose of discovery or evidence or both, pursuant to the Florida Rules of Civil Procedure and the Florida Statutes, of the individuals listed below at the times, date, and location indicated below: NAME DATE LOCATION George Markovich, Friday, February 3, 2023 Kubicki Draper M.D. TIME: 1:00 pm 13350 METRO PARKWAY, SUITE 401 FORT MYERS, FL 33966 *TO BE PRODUCED This deposition shall be taken before an associate or deputy court reporter and videographer before their duly designated representative, who is not of counsel to the parties or interested in the events of the cause. This deposition is being taken for the purpose of discovery for use at trial, or for such other purposes as are permitted under the Florida Rule of Civil Procedure. 1 This deposition shall continue until completed. Any cancellation and /or rescheduling of said deposition must be confirmed in writing. Said deponent is to have with him at the time and place aforesaid the following documents: 1 A current copy of his Curriculum Vitae. 2 All documents reviewed by you in the formulation of your opinion herein. A copy of your statement for service rendered herein. A list of cases in which you have previously testified either by deposition and/or by trial. A copy of any reports, or similar documents, setting forth your opinion herein. A copy of all notes, outlines, or similar writing prepared by you in the formulation of you opinion herein. A copy of any contract, or similar agreement, between you, those in privity with you, and Defendant or Defendants’ counsel, herein relating to services being provided by you. A copy of those portions of all texts, periodicals, or similar matters reviewed by you in the formulation of your opinion herein. 9 A list of those attorney who have previously retained you as an expert. 10. A list of those attorneys whose clients you have previously testified against. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the forgoing has been furnished this 30" day of January, 2023 by electronic mail to the following designated services e-mail address(es): Francesca Ippolito-Craven, Esq. at fic@kubickidraper.com; fic-kd@kubickidraper.com For the Clerk of the Court /s/ Helen Stratigakos, Esg. HELEN STRATIGAKOS, ESQ. Florida Bar No.: 0893633 412 East Madison Street, Suite 814 Tampa, Florida 33606 (P): (813) 226-0067 (F): (813) 259-2505 helen stratigakoslaw.com marty@stratigakoslaw.com ATTORNEY FOR PLAINTIFF 4s/ Michael J. Rossi, Esq. MICHAEL J. ROSSI, ESQ. Michael J. Rossi, P.A. Florida Bar No.: 0868000 115 South Albany Ave Tampa, FL 33606 (P): (813) 253-3351 Michael@michaelrossilaw.com