On November 30, 2020 a
NOTICE OF TAKING DEPOSITION OF DR. ERIC GABRIEL 3/30/23 @11 AM VIA VIDEO CONFERENCE
was filed
involving a dispute between
Leisa Jones,
Mia Graham,
and
C&K Trucking, Llc,
John Morrisey,
Progressive Select Insurance Company,
for AUTO NEGLIGENCE CASE Division: CV-F
in the District Court of Duval County.
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Filing # 166418603 E-Filed 02/08/2023 04:04:32 PM
IN THE CIRCUIT COURT,
FOURTH JUDICIAL CIRCUIT, IN
AND FOR
DUVAL COUNTY, FLORIDA
CASE NO.: 2020-CA-6698
DIVISION: CV-F
LEISA JONES and MIA GRAHAM,
Plaintiff,
-vs-
JOHN MORRISEY; C&K TRUCKING, LLC.,
and PROGRESSIVE SELECT INSURANCE
COMPANY,
Defendants.
/
PLAINTIFF’S NOTICE OF TAKING DEPOSITION DUCES TECUM
OF DR. ERIC GABRIEL
Please take Notice that the undersigned attorney will take the deposition duces tecum
of Dr. Eric Gabriel, on Thursday, March 30, at 11:00 a. m. via video conference, upon
oral examination, before an officer authorized by law to take deposition. Said deposition will
be conducted pursuant to the Florida Rules of Civil Procedure for the purposes of discovery,
cross-examination, for use at trial, or for such other purposes as are permitted under the
applicable and governing rules.
Said deponent shall produce, at the time and place, the items on the attached
Exhibit A.
(Certificate of Service on following page)
CCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 02/08/2023 04:25:16 PM
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing has been furnished to all counsel of
record on this gin day of Febru. Jacy _, 2023.
FARAH & E H, P.A.
Matthew J. Grossman, Esq.
(BN: 111517)
10 West Adams Street
Jacksonville, FL 32202
(904) 515-6205
mgrossman@farahandfarah.com
Idubberly @farahandfarah.com
Attorney for Plaintiff
EXHIBIT “A”
1 A current curriculum vitae used or prepared by you.
2. A copy of any report prepared by you or at your direction relative to your involvement
in this case.
3 Copies of any notes made by you or provided to you upon which you may rely in
formulating your opinions or conclusions in this case.
4 Any photographs taken by you or provided to you by the defendant’s attorney or
anyone on behalf of the defendant or by any third party that you have observed and reviewed
in your involvement in this case.
5 Any deposition transcripts provided to you, or parts of deposition transcripts or any
other statements or written materials provided to you by defendant’s attorney or anyone on
behalf of the defendant or any third party which you have examined or will examine in the
formulation of your opinions and conclusions in this case.
6 Any diagrams or drawings made by you or provided to you by the defendant’s
attorney or on behalf of the defendant by and third party concerning the incident which is the
subject matter of this litigation.
7 Any documents prepared by you, provided to you, or obtained by you or reviewed by
you whether intended for your use or not in connection with this case which concern the
incident which is the subject matter of this lawsuit.
8 All literature and/or documents which you consider relevant to your assignment in this
case and which you considered in the development of your opinions or conclusions
concerning the subject matter of this lawsuit.
9. All documents prepared by you to illustrate or demonstrate any fact or opinion
considered relevant to the case and/or to your assignment, investigation or opinions.
10. Copies of any articles, books, papers or other publications prepared by you which
relate to facts similar to the facts surrounding the accident which is the subject matter of this
lawsuit.
ll. Any and all materials considered, consulted and used by you as a basis of predicate for
your opinions and conclusions, including but not limited to published reports by and private
or governmental agency, textbooks, articles, data or documents furnished by the party
engaging your services, or government or industry standards or regulations.
12. Any and all models or demonstrative tools upon which you have or plan to rely in the
formulation and expression of your opinions and conclusions concerning the subject matter of
this lawsuit.
13. Any and all documents, depositions, articles, web sites, medical records or tests, or
other information which each expert has reviewed and/or relied upon in forming his opinions
in this matter.
14. A list of matters in which you have testified as an expert witness by deposition during
the preceding three years for the Carr Allison law firm.
15. A list of matters in which you have testified as an expert witness by deposition during
the preceding three years.
16. A list of each case in which you have testified as an expert witness in trial during the
preceding three years for the Carr Allison law firm.
17. A list of each case in which you have testified as an expert witness in trial during the
preceding three years.
18. An accounting, copies of invoices or statements showing the amount of money you
have been paid during the preceding three years by the Carr Allison law firm.
19. Documents evidencing the percentage income derived from serving as an expert
witness during the preceding three years.
20. Documents evidencing the percentage income derived from serving as an expert
witness during the preceding three years by the Carr Allison law firm.
Document Filed Date
February 08, 2023
Case Filing Date
November 30, 2020
Category
AUTO NEGLIGENCE CASE Division: CV-F
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Filing # 166418603 E-Filed 02/08/2023 04:04:32 PM IN THE CIRCUIT COURT, FOURTH JUDICIAL CIRCUIT, IN AND FOR DUVAL COUNTY, FLORIDA CASE NO.: 2020-CA-6698 DIVISION: CV-F LEISA JONES and MIA GRAHAM, Plaintiff, -vs- JOHN MORRISEY; C&K TRUCKING, LLC., and PROGRESSIVE SELECT INSURANCE COMPANY, Defendants. / PLAINTIFF’S NOTICE OF TAKING DEPOSITION DUCES TECUM OF DR. ERIC GABRIEL Please take Notice that the undersigned attorney will take the deposition duces tecum of Dr. Eric Gabriel, on Thursday, March 30, at 11:00 a. m. via video conference, upon oral examination, before an officer authorized by law to take deposition. Said deposition will be conducted pursuant to the Florida Rules of Civil Procedure for the purposes of discovery, cross-examination, for use at trial, or for such other purposes as are permitted under the applicable and governing rules. Said deponent shall produce, at the time and place, the items on the attached Exhibit A. (Certificate of Service on following page) CCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 02/08/2023 04:25:16 PM CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been furnished to all counsel of record on this gin day of Febru. Jacy _, 2023. FARAH & E H, P.A. Matthew J. Grossman, Esq. (BN: 111517) 10 West Adams Street Jacksonville, FL 32202 (904) 515-6205 mgrossman@farahandfarah.com Idubberly @farahandfarah.com Attorney for Plaintiff EXHIBIT “A” 1 A current curriculum vitae used or prepared by you. 2. A copy of any report prepared by you or at your direction relative to your involvement in this case. 3 Copies of any notes made by you or provided to you upon which you may rely in formulating your opinions or conclusions in this case. 4 Any photographs taken by you or provided to you by the defendant’s attorney or anyone on behalf of the defendant or by any third party that you have observed and reviewed in your involvement in this case. 5 Any deposition transcripts provided to you, or parts of deposition transcripts or any other statements or written materials provided to you by defendant’s attorney or anyone on behalf of the defendant or any third party which you have examined or will examine in the formulation of your opinions and conclusions in this case. 6 Any diagrams or drawings made by you or provided to you by the defendant’s attorney or on behalf of the defendant by and third party concerning the incident which is the subject matter of this litigation. 7 Any documents prepared by you, provided to you, or obtained by you or reviewed by you whether intended for your use or not in connection with this case which concern the incident which is the subject matter of this lawsuit. 8 All literature and/or documents which you consider relevant to your assignment in this case and which you considered in the development of your opinions or conclusions concerning the subject matter of this lawsuit. 9. All documents prepared by you to illustrate or demonstrate any fact or opinion considered relevant to the case and/or to your assignment, investigation or opinions. 10. Copies of any articles, books, papers or other publications prepared by you which relate to facts similar to the facts surrounding the accident which is the subject matter of this lawsuit. ll. Any and all materials considered, consulted and used by you as a basis of predicate for your opinions and conclusions, including but not limited to published reports by and private or governmental agency, textbooks, articles, data or documents furnished by the party engaging your services, or government or industry standards or regulations. 12. Any and all models or demonstrative tools upon which you have or plan to rely in the formulation and expression of your opinions and conclusions concerning the subject matter of this lawsuit. 13. Any and all documents, depositions, articles, web sites, medical records or tests, or other information which each expert has reviewed and/or relied upon in forming his opinions in this matter. 14. A list of matters in which you have testified as an expert witness by deposition during the preceding three years for the Carr Allison law firm. 15. A list of matters in which you have testified as an expert witness by deposition during the preceding three years. 16. A list of each case in which you have testified as an expert witness in trial during the preceding three years for the Carr Allison law firm. 17. A list of each case in which you have testified as an expert witness in trial during the preceding three years. 18. An accounting, copies of invoices or statements showing the amount of money you have been paid during the preceding three years by the Carr Allison law firm. 19. Documents evidencing the percentage income derived from serving as an expert witness during the preceding three years. 20. Documents evidencing the percentage income derived from serving as an expert witness during the preceding three years by the Carr Allison law firm.