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Filing # 148605938 E-Filed 04/28/2022 04:05:41 PM
IN THE CIRCUIT COURT OF THE
EIGHTEENTH JUDICIAL CIRCUIT IN
AND FOR BREVARD COUNTY, FL
CASE NO. 052020CA024628XXXXXX
ANTHONY DAVIS JR.,
Plaintiff,
Vv.
SECURITY FIRST INSURANCE COMPANY DBA SECURITY FIRST FLORIDA,
Defendant.
/
SUBPOENA DUCES TECUM FOR DEPOSITION
THE STATE OF FLORIDA
TO: Reinaldo Perez
Royal Plus Inc.
1150 Belle Ave
Winter Springs, FL 32708
YOU ARE HEREBY COMMANDED to appear before a person authorized by law to
take depositions virtual via Zoom:
httos://usO06web.zoom.us/i/87580697529?pwd=axZaV 2xraxXpY MkVid2ZXY 1izbWiEQTO9
Meeting ID: 875 8069 7529
Passcode: 940893
On May 9th, 2022 at 11:00 AM EST for the taking of your deposition in the above styled
cause and to have with you at said time and place the following:
1 Complete CV of witness.
2 Any and all correspondence or communication(s) from witness to any other
person or entity regarding this case, including but not limited to any
electronic communication.
Any and all correspondence or communication(s) to witness from any other
person or entity regarding this case, including but not limited to any
electronic communication.
Any report produced by the witness regarding this case.
Any notes, documents, memoranda, record, or any other means of
recording information regarding this case prepared by or for the witness.
Any documents of any kind reflecting charges by witness, witnesses’
employer, or any agent or principle of witness, regarding this case.
Filing 148605938 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX
All facts and data that support the witnesses’ opinions regarding this case.
Any documents of any kind reflecting payments to witness, witnesses’
employer, or any agent or principle of witness, regarding this case.
Any engagement letter or email regarding this case.
10 Any available lists itemizing charges or prices charged by the witness and/or
witness’ employer for any expert witness and/or consulting services provided
by or available from witness or witness’ employer; i.e. any price lists.
11 Any ledger(s), time sheets, or other record reflecting work done and time
spent on this case by witness and anybody employed at the witness’ firm
12 List of all cases in which the witness testified in deposition during the last
three years, including case name, case number, court in which case was
pending, Plaintiff's lawyer(s), Defendant’s lawyer(s), name of retaining
lawyer and name of lawyer requesting testimony.
13 List of all cases in which the witness testified at trial during the last three
years, including case name, case number, court in which case was pending,
Plaintiffs lawyer(s), Defendant’s lawyer(s), name of retaining lawyer and
name of lawyer requesting testimony.
14 Any and all materials reviewed by the witness, the witness’ agents or the
witness’ principles, in relation to this case.
15 Any and all materials received by the witness, the witness’ agents or the
witness’ principles, in relation to this case.
16 Any records, notes or other memorialization in any form of conferences,
telephone calls, meetings, or other non-written communication between
witness or any of witness’ agents or principals and any other person
regarding this case.
17 Copy of any presentation or outline regarding any speaking engagements or
speeches made by witness to any group or organization during the last three
years.
18 Entire file with reference to this claim, including but not limited to
photographs in their native digital format.
19, Any template used to prepare reports used by the witness during the last
three years.
20 List of all cases referred by Defendant's law firm or prior law firm during the
last three years.
21 List of all cases in which the witness did any work for the Defendant's law
firm or prior law firm during the last three years.
22 Any treatise(s) or publication(s) authored by the witness.
23. Any treatise(s) or other publication(s) relied on in any way by the witness
regarding this case.
24 Any treatise(s) or other publication(s) related to the subject matter of the
witness’ opinions in this case which the witness finds authoritative.
25. Any treatise(s) or other publication(s) related to the subject matter of the
witness’ opinions in this case which the witness finds reliable.
26 Any copies in possession of witness or Defendant’s lawyer(s) of sworn
testimony (affidavits, deposition transcripts or trial transcripts) offered by the
witness in any case during the last 5 years.
Filing 148605938 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX
27 Copies of any advertisements and any documents related to
advertisements by you or your firm or company for forensic and/or expert
witness services.
28. Any documents, tables, charts and data relied on and/or referenced by the
witness in this case.
If you fail to appear, you may be in contempt of Court.
You are subpoenaed to appear by the following attomeys and, unless excused
from this subpoena by these attorneys or the Court, you must respond to this subpoena as
directed.
DATED 4/28/2022
Ss Kimmel
GINA KIMMEL, ESQ., Esquire
Florida Bar No. 0121929
Morgan & Morgan, P.A.
20 N. Orange Avenue, 4” Floor
Post Office Box 4979
Orlando, Florida 32802-4979
Telephone: (407) 420-1414
Facsimile: (407) 245-3414
Primary email: Gkimmel@forthepeople.com
Secondary email:Smerillo@forthepeople.com
LRolon@forthepeople.com
Attorneys for Plaintiff
Any minor subpoenaed for testimony has the right to be accompanied by a parent or
guardian at all times during the taking of testimony notwithstanding the invocation of the
tule of sequestration of section 90.616, Florida Statutes, except on a showing that the
presence of a parent or guardian is likely to have a material, negative impact on the
credibility or accuracy of the minor’s testimony, or that the interests of the parent or
guardian are in actual or potential conflict with the interests of the minor.
If you are a person with a disability who needs any accommodation in order to
participate in this deposition, you are entitled, at no cost to you, to the provision
of certain assistance. Please contact [Gina Kimmel, Esquire, The Nation Law
Firm, LLP, 570 Crown Oak Centre Drive Longwood, FL 32750, (407) 339-1104, at
least 7 days before your scheduled deposition, or immediately upon receiving
this notification if the time before the scheduled appearance is less than 7 days; if
you are hearing or voice impaired, call 711.
Filing 148605938 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX
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Filing # 148605938 E-Filed 04/28/2022 04:05:41 PM IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT IN AND FOR BREVARD COUNTY, FL CASE NO. 052020CA024628XXXXXX ANTHONY DAVIS JR., Plaintiff, Vv. SECURITY FIRST INSURANCE COMPANY DBA SECURITY FIRST FLORIDA, Defendant. / SUBPOENA DUCES TECUM FOR DEPOSITION THE STATE OF FLORIDA TO: Reinaldo Perez Royal Plus Inc. 1150 Belle Ave Winter Springs, FL 32708 YOU ARE HEREBY COMMANDED to appear before a person authorized by law to take depositions virtual via Zoom: httos://usO06web.zoom.us/i/87580697529?pwd=axZaV 2xraxXpY MkVid2ZXY 1izbWiEQTO9 Meeting ID: 875 8069 7529 Passcode: 940893 On May 9th, 2022 at 11:00 AM EST for the taking of your deposition in the above styled cause and to have with you at said time and place the following: 1 Complete CV of witness. 2 Any and all correspondence or communication(s) from witness to any other person or entity regarding this case, including but not limited to any electronic communication. Any and all correspondence or communication(s) to witness from any other person or entity regarding this case, including but not limited to any electronic communication. Any report produced by the witness regarding this case. Any notes, documents, memoranda, record, or any other means of recording information regarding this case prepared by or for the witness. Any documents of any kind reflecting charges by witness, witnesses’ employer, or any agent or principle of witness, regarding this case. Filing 148605938 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX All facts and data that support the witnesses’ opinions regarding this case. Any documents of any kind reflecting payments to witness, witnesses’ employer, or any agent or principle of witness, regarding this case. Any engagement letter or email regarding this case. 10 Any available lists itemizing charges or prices charged by the witness and/or witness’ employer for any expert witness and/or consulting services provided by or available from witness or witness’ employer; i.e. any price lists. 11 Any ledger(s), time sheets, or other record reflecting work done and time spent on this case by witness and anybody employed at the witness’ firm 12 List of all cases in which the witness testified in deposition during the last three years, including case name, case number, court in which case was pending, Plaintiff's lawyer(s), Defendant’s lawyer(s), name of retaining lawyer and name of lawyer requesting testimony. 13 List of all cases in which the witness testified at trial during the last three years, including case name, case number, court in which case was pending, Plaintiffs lawyer(s), Defendant’s lawyer(s), name of retaining lawyer and name of lawyer requesting testimony. 14 Any and all materials reviewed by the witness, the witness’ agents or the witness’ principles, in relation to this case. 15 Any and all materials received by the witness, the witness’ agents or the witness’ principles, in relation to this case. 16 Any records, notes or other memorialization in any form of conferences, telephone calls, meetings, or other non-written communication between witness or any of witness’ agents or principals and any other person regarding this case. 17 Copy of any presentation or outline regarding any speaking engagements or speeches made by witness to any group or organization during the last three years. 18 Entire file with reference to this claim, including but not limited to photographs in their native digital format. 19, Any template used to prepare reports used by the witness during the last three years. 20 List of all cases referred by Defendant's law firm or prior law firm during the last three years. 21 List of all cases in which the witness did any work for the Defendant's law firm or prior law firm during the last three years. 22 Any treatise(s) or publication(s) authored by the witness. 23. Any treatise(s) or other publication(s) relied on in any way by the witness regarding this case. 24 Any treatise(s) or other publication(s) related to the subject matter of the witness’ opinions in this case which the witness finds authoritative. 25. Any treatise(s) or other publication(s) related to the subject matter of the witness’ opinions in this case which the witness finds reliable. 26 Any copies in possession of witness or Defendant’s lawyer(s) of sworn testimony (affidavits, deposition transcripts or trial transcripts) offered by the witness in any case during the last 5 years. Filing 148605938 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX 27 Copies of any advertisements and any documents related to advertisements by you or your firm or company for forensic and/or expert witness services. 28. Any documents, tables, charts and data relied on and/or referenced by the witness in this case. If you fail to appear, you may be in contempt of Court. You are subpoenaed to appear by the following attomeys and, unless excused from this subpoena by these attorneys or the Court, you must respond to this subpoena as directed. DATED 4/28/2022 Ss Kimmel GINA KIMMEL, ESQ., Esquire Florida Bar No. 0121929 Morgan & Morgan, P.A. 20 N. Orange Avenue, 4” Floor Post Office Box 4979 Orlando, Florida 32802-4979 Telephone: (407) 420-1414 Facsimile: (407) 245-3414 Primary email: Gkimmel@forthepeople.com Secondary email:Smerillo@forthepeople.com LRolon@forthepeople.com Attorneys for Plaintiff Any minor subpoenaed for testimony has the right to be accompanied by a parent or guardian at all times during the taking of testimony notwithstanding the invocation of the tule of sequestration of section 90.616, Florida Statutes, except on a showing that the presence of a parent or guardian is likely to have a material, negative impact on the credibility or accuracy of the minor’s testimony, or that the interests of the parent or guardian are in actual or potential conflict with the interests of the minor. If you are a person with a disability who needs any accommodation in order to participate in this deposition, you are entitled, at no cost to you, to the provision of certain assistance. Please contact [Gina Kimmel, Esquire, The Nation Law Firm, LLP, 570 Crown Oak Centre Drive Longwood, FL 32750, (407) 339-1104, at least 7 days before your scheduled deposition, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711. Filing 148605938 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX