On March 05, 2021 a
Party Discovery
was filed
involving a dispute between
Potter Linda Nolan,
and
Geico General Insurance Company,
Government Employees Insurance Company,
Jackson Emanuel,
United Services Automobile Association,
for AUTO NEGLIGENCE
in the District Court of Brevard County.
Preview
Filing # 144124666 E-Filed 02/17/2022 01:36:14 PM
IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT IN AND FOR
BREVARD COUNTY, FLORIDA
LINDA NOLAN POTTER,
CASE NO.: 05-2021-CA-019085-XXXX-XX
Plaintiff,
vs.
EMANUEL JACKSON, and UNITED SERVICES
AUTOMOBILE ASSOCIATION, a foreign for profit
corporation, and GEICO GENERAL INSURANCE
COMPANY, a foreign for profit corporation,
Defendants.
/
PLAINTIFF’S NOTICE OF TAKING DEPOSITION
Plaintiff will take the deposition noticed below before Angel Reporting or some other
Officer authorized to take depositions. The deposition is for use at trial, any Daubert hearing, and
any evidentiary hearing. See e.g., Henderson v. B&B Precast & Pipe, LLC, 2014 WL, 4063673
(N.D. Ga. Aug. 14, 2014); see also, e.g., Moyer v. Reynolds, 780 So. 2d 205 (Fla. 5" DCA 2001).
The deposition is being taken for the use as summary judgment evidence and Plaintiff will use the
deposition and its exhibits as summary judgment evidence in any summary judgment proceeding.
See Fed. R. Civ. P. 56; see also Fla. R. Civ. P. 1.510(c): see also State Farm Mut. Auto. Ins. Co. v.
Figler Family Chiro., P.A., 189 So. 34 970, 974 (Fla. 4" DCA 2016). The deposition is being taken
for all other purposes.
Location:
Zoom; link and meeting ID will be sent two days prior to the deposition
Date and Time:
May 4, 2022 at 1:30 p.m.
Deponent:
DAVID JACKSON
Filing 144124666 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been electronically
filed and served using the Florida Courts E-Filing portal to Sebastian C. Mejia, Esq., SCM-
KD@kubickidraper.com, on this 17" day of February, 2022.
GILLIN GILLIN & LINDBAEK, P.A.
Attorney for Plaintiff
222 N. Harbor City Blvd.
Melbourne, FL 32935
321-729-1444
321-729-9933 fax
eric@brevardjus ce.cOm
By: /s/ Eric §. Gillin
ERIC S. GILLIN, Esq.
Florida Bar #168629
Filing 144124666 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX
Document Filed Date
February 17, 2022
Case Filing Date
March 05, 2021
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Filing # 144124666 E-Filed 02/17/2022 01:36:14 PM IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT IN AND FOR BREVARD COUNTY, FLORIDA LINDA NOLAN POTTER, CASE NO.: 05-2021-CA-019085-XXXX-XX Plaintiff, vs. EMANUEL JACKSON, and UNITED SERVICES AUTOMOBILE ASSOCIATION, a foreign for profit corporation, and GEICO GENERAL INSURANCE COMPANY, a foreign for profit corporation, Defendants. / PLAINTIFF’S NOTICE OF TAKING DEPOSITION Plaintiff will take the deposition noticed below before Angel Reporting or some other Officer authorized to take depositions. The deposition is for use at trial, any Daubert hearing, and any evidentiary hearing. See e.g., Henderson v. B&B Precast & Pipe, LLC, 2014 WL, 4063673 (N.D. Ga. Aug. 14, 2014); see also, e.g., Moyer v. Reynolds, 780 So. 2d 205 (Fla. 5" DCA 2001). The deposition is being taken for the use as summary judgment evidence and Plaintiff will use the deposition and its exhibits as summary judgment evidence in any summary judgment proceeding. See Fed. R. Civ. P. 56; see also Fla. R. Civ. P. 1.510(c): see also State Farm Mut. Auto. Ins. Co. v. Figler Family Chiro., P.A., 189 So. 34 970, 974 (Fla. 4" DCA 2016). The deposition is being taken for all other purposes. Location: Zoom; link and meeting ID will be sent two days prior to the deposition Date and Time: May 4, 2022 at 1:30 p.m. Deponent: DAVID JACKSON Filing 144124666 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been electronically filed and served using the Florida Courts E-Filing portal to Sebastian C. Mejia, Esq., SCM- KD@kubickidraper.com, on this 17" day of February, 2022. GILLIN GILLIN & LINDBAEK, P.A. Attorney for Plaintiff 222 N. Harbor City Blvd. Melbourne, FL 32935 321-729-1444 321-729-9933 fax eric@brevardjus ce.cOm By: /s/ Eric §. Gillin ERIC S. GILLIN, Esq. Florida Bar #168629 Filing 144124666 L POTTER VS EMANUEL JACKSON 05-2021-CA-019085-XXXX-XX