On September 30, 2021 a
Party Discovery
was filed
involving a dispute between
and
Torres, Michael A,
in the District Court of Indian River County.
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Filing # 147287268 E-Filed 04/07/2022 04:51:07 PM
*312021CF001142A*
IN THE CIRCUIT COURT
OF THE NINETEENTH JUDICIAL CIRCUIT
IN AND FOR INDIAN RIVER COUNTY, FLORIDA
STATE OF FLORIDA
Plaintiff,
vs. Case No. 312021CF001142A
Judge: Dan L. Vaughn
Michael A. Torres
Defendant.
TO: Jeffrey Davis, Assistant State Attorney
2000 16th AvenueSuite 329
Vero Beach, Florida 34960 Agency No. 2021-00127802
NOTICE OF TAKING DEPOSITION OF LAW ENFORCEMENT OFFICER
Please note, this deposition will not be taken in the office. Please be prepared to give your
deposition telephonically at the scheduled date/time. Please contact the Public Defender’s Office
the morning of the scheduled deposition to provide a contact number for the involved parties.
PLEASE TAKE NOTICE that on 05/17/2022 by TELEPHONE, the undersigned Assistant Public
Defender, pursuant to Fla.R.Cr.P. 3.220(h)(5), will take the deposition of the following law enforcement
officer(s):
05/17/2022, 3:15 PM DS Brandon Quintero, USE EMAIL ADDRESS,
*** PLEASE CALL THE PUBLIC DEFENDER'S OFFICE AT (772) 226-3340 ON THE
MORNING YOU ARE SCHEDULED TO APPEAR TO VERIFY YOUR APPOINTMENT.***
upon oral examinations; under oath for the purpose of discovery or such other purposes as are permitted
under the applicable Statutes or Rules of Criminal Procedure. The deposition will continue from day to day
until completed. This deposition is to be tape recorded by the Office of the Public Defender of the
Nineteenth Judicial Circuit.
NOTICE is hereby given that the undersigned intends to require the presence of a deputy clerk of
this court for the taking of said depositions, or in the alternative, to have an employee of the Public Defender
to swear all witnesses called for the taking of depositions as required by the Rules of Criminal Procedure.
Pursuant to Fla.R.Cr.P. 3.220(h)(5), any law enforcement officers who fail to appear for deposition
after being served this notice are subject to contempt proceedings.
The Defendant requests notice of any objections to the taking of this deposition to be served upon
the undersigned three (3) days prior to the date, this deposition is to be taken.
The undersigned hereby certifies that a good faith effort was made to coordinate the deposition
schedule.
I certify that the foregoing document has been furnished to Jeffrey Davis, Assistant
State Attorney, via SA19eService@sao19.org by Electronic Service on April 7, 2022.
Respectfully submitted,
DIAMOND R. LITTY
PUBLIC DEFENDER
BY: _ /s/ Michelle M Rhodeback____
Michelle M Rhodeback
Assistant Public Defender
Florida Bar Number 93791
Michelle.Rhodeback@PD19.org
2000 16th Avenue Suite 235
Vero Beach, Florida 32960
(772) 226-3340
Document Filed Date
April 07, 2022
Case Filing Date
September 30, 2021
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Filing # 147287268 E-Filed 04/07/2022 04:51:07 PM *312021CF001142A* IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR INDIAN RIVER COUNTY, FLORIDA STATE OF FLORIDA Plaintiff, vs. Case No. 312021CF001142A Judge: Dan L. Vaughn Michael A. Torres Defendant. TO: Jeffrey Davis, Assistant State Attorney 2000 16th AvenueSuite 329 Vero Beach, Florida 34960 Agency No. 2021-00127802 NOTICE OF TAKING DEPOSITION OF LAW ENFORCEMENT OFFICER Please note, this deposition will not be taken in the office. Please be prepared to give your deposition telephonically at the scheduled date/time. Please contact the Public Defender’s Office the morning of the scheduled deposition to provide a contact number for the involved parties. PLEASE TAKE NOTICE that on 05/17/2022 by TELEPHONE, the undersigned Assistant Public Defender, pursuant to Fla.R.Cr.P. 3.220(h)(5), will take the deposition of the following law enforcement officer(s): 05/17/2022, 3:15 PM DS Brandon Quintero, USE EMAIL ADDRESS, *** PLEASE CALL THE PUBLIC DEFENDER'S OFFICE AT (772) 226-3340 ON THE MORNING YOU ARE SCHEDULED TO APPEAR TO VERIFY YOUR APPOINTMENT.*** upon oral examinations; under oath for the purpose of discovery or such other purposes as are permitted under the applicable Statutes or Rules of Criminal Procedure. The deposition will continue from day to day until completed. This deposition is to be tape recorded by the Office of the Public Defender of the Nineteenth Judicial Circuit. NOTICE is hereby given that the undersigned intends to require the presence of a deputy clerk of this court for the taking of said depositions, or in the alternative, to have an employee of the Public Defender to swear all witnesses called for the taking of depositions as required by the Rules of Criminal Procedure. Pursuant to Fla.R.Cr.P. 3.220(h)(5), any law enforcement officers who fail to appear for deposition after being served this notice are subject to contempt proceedings. The Defendant requests notice of any objections to the taking of this deposition to be served upon the undersigned three (3) days prior to the date, this deposition is to be taken. The undersigned hereby certifies that a good faith effort was made to coordinate the deposition schedule. I certify that the foregoing document has been furnished to Jeffrey Davis, Assistant State Attorney, via SA19eService@sao19.org by Electronic Service on April 7, 2022. Respectfully submitted, DIAMOND R. LITTY PUBLIC DEFENDER BY: _ /s/ Michelle M Rhodeback____ Michelle M Rhodeback Assistant Public Defender Florida Bar Number 93791 Michelle.Rhodeback@PD19.org 2000 16th Avenue Suite 235 Vero Beach, Florida 32960 (772) 226-3340