Preview
Filing # 182233646 E-Filed 09/20/2023 12:43:40 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,
Plaintiffs,
vs.
JOHN MORRISEY and C&K TRUCKING, LLC,
Defendants.
_____________________________________
DEFENDANTS SECOND AMENDED NOTICE OF TAKING DEPOSITION DUCES TECUM OF
DR. FARHAD BOOESHAGHI
(via zoom)
YOU WILL PLEASE TAKE NOTICE that commencing on Thursday, September 28, 2023
at 1:00 p.m. ET, Defendants, C&K Trucking, LLC and John Morrisey, will take the deposition of
Dr. Farhad Booeshaghi via zoom, before Georgia Winegeart & Associates, Court Reporters, a
Notary Public, or before some other officer authorized by law to take depositions.
Said deposition is being taken for the purpose of discovery, for use as evidence at trial, or
both, pursuant to the applicable Rules of Civil Procedure and Statutes.
The deponent is directed to bring with him the documents listed as follows:
1. Any and all documents, materials, data, or items of any nature provided to you by
or on behalf of the plaintiff, Leisa Jones, in connection with your consideration of the issues in the
above-entitled cause.
2. Any and all documents, materials, data, or items of any nature provided to you
from any other source other than the plaintiff, Leisa Jones, in connection with your consideration
of the issues in the above-entitled cause.
3. Any compilations, calculations, photographs, videotapes, diagrams, drawings,
data, reports, correspondence, handwritten notes, or any other materials of any kind whatsoever,
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 09/21/2023 03:37:22 PM
prepared, generated, or gathered by you in connection with your analysis of the issues in the
above-entitled cause.
4. Your entire file in this matter, including any and all reports or other writings
containing any opinions or conclusions you have developed in connection with the above-entitled
case.
5. Your professional resume or curriculum vitae.
6. A list of all cases in which you have been retained as an expert witness and given
testimony for the last four years, either in deposition or trial or both, including the name of the
case, jurisdiction, and name of party or attorney who retained you.
7. All time and billing records for services rendered in this case.
8. All models, illustrations, or any other exhibits which you intend to use to explain,
illustrate, demonstrate, or support your testimony at trial.
[Certificate of Service on the following page]
2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 20th day of September 2023, I electronically filed the
foregoing with the Florida Courts E-Filing Portal, which will serve it on the following counsel of
record via electronic mail:
Wesley T. Ford
Frank Fratello
Matthew J. Grossman
Robert Gunn
FARAH & FARAH, P.A.
1534 Kingsley Avenue
Orange Park, Florida 32073
Primary: wford@farahandfarah.com
Primary: ffratello@farahandfarah.com
Primary: mgrossman@farahandfarah.com
Primary: rgunn@farahandfarah.com
Secondary email: seppling@farahandfarah.com
Secondary: mgoodbread@farahandfarah.com
Secondary: ldubberly@farahandfarah.com
Secondary: estone@farahandfarah.com
Attorneys for Plaintiff
/s/ L. Johnson Sarber, III___________
L. Johnson Sarber, III
Florida Bar No. 0104116
CARR ALLISON
Truist Tower
200 West Forsyth Street, Suite 600
Jacksonville, Florida 32202
Telephone: (904) 328-6456
Facsimile: (904) 328-6473
Email: jsarber@carrallison.com
Secondary Email: asparks@carrallison.com
Secondary Email: jihlenfeldt@carrallison.com
Attorneys for Defendants John Morrissey and
C&K Trucking, LLC
3
Preview
Filing # 182233646 E-Filed 09/20/2023 12:43:40 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, Plaintiffs, vs. JOHN MORRISEY and C&K TRUCKING, LLC, Defendants. _____________________________________ DEFENDANTS SECOND AMENDED NOTICE OF TAKING DEPOSITION DUCES TECUM OF DR. FARHAD BOOESHAGHI (via zoom) YOU WILL PLEASE TAKE NOTICE that commencing on Thursday, September 28, 2023 at 1:00 p.m. ET, Defendants, C&K Trucking, LLC and John Morrisey, will take the deposition of Dr. Farhad Booeshaghi via zoom, before Georgia Winegeart & Associates, Court Reporters, a Notary Public, or before some other officer authorized by law to take depositions. Said deposition is being taken for the purpose of discovery, for use as evidence at trial, or both, pursuant to the applicable Rules of Civil Procedure and Statutes. The deponent is directed to bring with him the documents listed as follows: 1. Any and all documents, materials, data, or items of any nature provided to you by or on behalf of the plaintiff, Leisa Jones, in connection with your consideration of the issues in the above-entitled cause. 2. Any and all documents, materials, data, or items of any nature provided to you from any other source other than the plaintiff, Leisa Jones, in connection with your consideration of the issues in the above-entitled cause. 3. Any compilations, calculations, photographs, videotapes, diagrams, drawings, data, reports, correspondence, handwritten notes, or any other materials of any kind whatsoever, ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 09/21/2023 03:37:22 PM prepared, generated, or gathered by you in connection with your analysis of the issues in the above-entitled cause. 4. Your entire file in this matter, including any and all reports or other writings containing any opinions or conclusions you have developed in connection with the above-entitled case. 5. Your professional resume or curriculum vitae. 6. A list of all cases in which you have been retained as an expert witness and given testimony for the last four years, either in deposition or trial or both, including the name of the case, jurisdiction, and name of party or attorney who retained you. 7. All time and billing records for services rendered in this case. 8. All models, illustrations, or any other exhibits which you intend to use to explain, illustrate, demonstrate, or support your testimony at trial. [Certificate of Service on the following page] 2 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 20th day of September 2023, I electronically filed the foregoing with the Florida Courts E-Filing Portal, which will serve it on the following counsel of record via electronic mail: Wesley T. Ford Frank Fratello Matthew J. Grossman Robert Gunn FARAH & FARAH, P.A. 1534 Kingsley Avenue Orange Park, Florida 32073 Primary: wford@farahandfarah.com Primary: ffratello@farahandfarah.com Primary: mgrossman@farahandfarah.com Primary: rgunn@farahandfarah.com Secondary email: seppling@farahandfarah.com Secondary: mgoodbread@farahandfarah.com Secondary: ldubberly@farahandfarah.com Secondary: estone@farahandfarah.com Attorneys for Plaintiff /s/ L. Johnson Sarber, III___________ L. Johnson Sarber, III Florida Bar No. 0104116 CARR ALLISON Truist Tower 200 West Forsyth Street, Suite 600 Jacksonville, Florida 32202 Telephone: (904) 328-6456 Facsimile: (904) 328-6473 Email: jsarber@carrallison.com Secondary Email: asparks@carrallison.com Secondary Email: jihlenfeldt@carrallison.com Attorneys for Defendants John Morrissey and C&K Trucking, LLC 3