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Filing# 149968161 E-Filed 05/19/2022 06:17:25 PM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO.: 21-007751
LAUREN HOCKENBERRY,
Plaintiff,
V.
RENAISSANCE LLC, M/Y
d/b/a
RENAISSANCE, and REX WITKAMP,
Defendant.
NOTICE OF TAKING VIDEOTAPED
DEPOSITION DUCES TECUM OF LAUREN HOCKENBERRY
PLEASE TAKE NOTICE that the undersigned, as attorney for Defendants,
RENAIANCE LLC, d/b/a M/Y RENAISSANCE and REX WITKAMP, will take the
videotaped deposition by oral examination pursuant to Florida Rules of Civil
Procedure of the following individual on the date, time and location below:
Deponent Date & Time Location
Lauren Hockenberry June 27,2022 @ ZOOM
10:OOAM
The oral examination will take place before VERITEXT LEGAL SOLUTIONS,
Court Reporters, a Notary Public or before some other officer duly authorized by law
to take depositions. The deposition is being taken for purposes of discovery, for use
at trial,or for such other purposes as permitted under the applicable Fla. R. Civ. P.
The deposition will continue from day-to-day until completed.
DUCES TECUM: The deponent is to have with him at the said time and place
the following items:
See Attached Schedule A
HAMILTON, MILLER, & BINTHISEL 1
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/19/2022 06:17:24 PM.****
Respectfully submitted,
/s/ David N. Gambach
David N. Gambach, Esq.
Florida Bar No. 8540
Evan S. Gutwein, Esq.
Florida Bar No. 58741
HAMILTON, MILLER & BIRTHISEL, LLP.
150 Southeast Second Avenue, Suite 1200
Miami, Florida 33131
Telephone 305-379-3686
Facsimile 305-379-3690
Dgambach@HamiltonMillerLaw.com
EGutwein@HamiltonMillerLaw.com
JFlorin@HamiltonMillerLaw.com
JMendez@HamiltonMillerLaw.com
Attorneys for Def. RENAISSANCE.
HAMILTON, MILLER, & BINTHISEL 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on May 19, 2022, I electronicallyfiled the
forgoing document with the Clerk of the Court via the Florida Courts E-Filing
Portal.
/s/ David N. Gambach
David N. Gambach, Esq.
Service List
Andrew N. Mescolotto Michael L. Buckner, Esquire
Florida Bar No. 106331
Florida Bar No.: 28141
BUCKNER LEGAL SELF-HELP PROGRAM, INC.
Fertig & Gramling 5224 NW 96'?th
Drive
200 SE 3rd Street Coral Springs,Florida 33076-2487
Lauderdale, FL 33316
Ft. Office:+ 1-954-347-0112
Facsimile:+ 1-954-513-4796
Telephone: (954) 763.5020
Fax: (954) 763-5412 michaelbucknerlaw@gmail.com
Counsel for Pl. Hockenberry
anm@fertig.com
Counsel for Renaissance, LLC
David E. Irwin, Esq.
IRWIN LAW FIRM
205 SW 12th Street
Ft.Lauderdale, FL 33315
Telephone: (954) 775-2301
Fax: (954) 775-2303
Counsel for Rex Witkamp
HAMILTON, MILLER, & BINTHISEL 3
SCHEDULE A
1. A copy-back and front-of your drivers' license.
2. A copy-back and front-of any and all identification cards for healthcare
insurance which covered you and were in effect at any time from ten years
before the earliest of the alleged incidents to-date.
3. Copies of all military records, retirement papers, orders, DD Forms 214 or
other discharge papers, veteran's claims, records of service-related disability
or other documents pertaining to military service by you, whether active,
reserve, or national guard.
4. Any and all documentation that is or shows your income, including but not
limited to, federal and state tax returns or similar documents and supporting
forms and data, from five years before the earliest of the alleged incidents to-
date.
5. Any and all contracts of employment that you had at the time of the incidents
described in your complaint.
6. All communications (including without limitation: letters, texts, messages,
memos, notes, emails, correspondence, faxes, and any other form of
communication) you had with Defendant Renaissance regarding the
incidents described in your Complaint and/or your alleged injuries,losses and
damages.
7. All communications (including without limitation: letters,texts, messages,
memos, notes, emails, correspondence, faxes, and any other form of
communication) you had with Defendant Witkamp regarding the incidents
described in your Complaint and/or your alleged injuries, losses and
damages.
8. Any and all documents, records, notices, demands, letters,emails, texts, and
correspondence sent by you or on your behalf to any Defendant and/or their
agents, insurers and attorneys, since the date of the incident alleged.
9. Any and documentation, records, and correspondence received by you or
all
on your behalf from any Defendant and/ or their agents, insurers and
attorneys, since the date of the incident alleged.
10. Any and all documentation which relates to any personal injury claims made
by you within the ten (10) years preceding the alleged incident.
HAMILTON, MILLER, & BINTHISEL 4
11. Photographs, digitalimages, videos, drawings, sketches, and/or depictions of
the following:
a) The incidents at issue in this lawsuit;
b) The locations of the incidents at issue in this lawsuit;
c) The vessel involved in the subject incident;
d) Your injuries, illness and/or aggravation thereof allegedly
sustained in the incidents at issue in this lawsuit.
12. Photographs, digitalimages, and/or videos taken or made at any time while
you were aboard the vessel where the incidents are alleged to have happened.
13. Copies of all models, plats, maps, drawings, motion pictures, video tapes or
photographs pertaining to any fact or issue involved in this controversy in
your possession or in the possession of your attorneys and/or your testifying
expert witnesses.
14. All accident or incident reports prepared by any person, firm, company,
government entity, or corporation that are in your possession or in the
possession of your attorneys concerning the incident as described in your
claim.
15. Any and allstatements (regardless of format) that you obtained from any
person, party and/or entity relating in any way to this lawsuit.
16. All correspondence and communications with any of the Parties to this
lawsuit and/ or their agents, insurers and attorneys, regarding the incident,
the events underlying the incidents and/or your injuries, illness or
aggravation of pre-existing injuries or illness.
17. Any and postings you made on any social media platform, page, or blogs
all
from the three years preceding the incident to-date.
18. Copies of any assignments, payment guarantees, letters of protection, and/or
lien agreements made or issued by you or by your attorneys to any health
care provider with which you have treated for the injuries alleged by you.
19. Any and allmedical records (including without limitation: hospital records,
physicians' records and evaluations, psychologists records and evaluations,
psychiatrist'records and evaluations, mental health care practitioners'reports
HAMILTON, MILLER, & BINTHISEL 5
and evaluations, prescription records, reports of all diagnosticstudies and tests
of any kind, any and all laboratory reports, X-ray films/images and reports,
MRI films/images and reports, and CT Scans and reports) relative to any and
all medical care or treatment, physical or psychological,received by you in the
ten (10) years prior to the date of the incidents at issue.
20. Any and allmedical records (including without limitation: hospital records,
physicians' records and evaluations, psychologists records and evaluations,
psychiatrist'records and evaluations, mental health care practitioners'reports
and evaluations, prescription records, reports of all diagnosticstudies and tests
of any kind, laboratory reports, X-ray films/images and reports, MRI
films/images and reports, and CT Scans and reports) relative to any and all
medical care or treatment, physical or psychological,received by you for the
injuries you claim to have sustained in connection with the incidents
described in your complaint.
21. The billingrecords from each person or entity that provided you medical care
or treatment, including without limitation mental health care, for the injuries
claimed by you in this lawsuit. (This should be interpreted broadly to include
without limitation: invoices, account statements, charges, write-offs,
collection letters, notes, receipts, Explanation of Benefit forms from your
health insurer, health insurance claim forms, correspondence, demands, and
any other document, report, report or materials that is,addresses or reflects
the costs of your medical care and treatment.)
22. Any and all documentation that is or relates to prescriptions and expenses
incurred for medications prescribed by reason of any and all injuries,illness
and/or aggravation sustained by you as a result of the incidents at issue.
23. Any and all documentation that or relates to any expenses incurred by
is
reason of any and all injuries,illness, and/or aggravation, sustained by you
as a result of the incidents alleged and for which you are seeking
compensation.
24. Any and all communications, correspondence, messages, emails, texts,
photos, videos, and/or memes exchanged between you and Doug Meier from
September 1, 2020 to-date.
25. Any and all communications, correspondence, messages, emails, texts,
photos, videos, and/or memes exchanged between you and Rex Witkamp from
September 1, 2020 to-date.
26. Any and allcommunications, correspondence, messages, emails, texts,
photos, videos, and/or memes exchanged between you and Samantha
HAMILTON, MILLER, & BINTHISEL 6
Eastman from September 1, 2020 to-date.
27. Any and communications, correspondence, messages, emails, texts,
all
photos, videos, and/or memes exchanged between you and Caroline Manney
from September 1, 2020 to-date.
28. Any and communications, correspondence, messages, emails, texts,
all
memes exchanged between you and Mr. Sam Manney
photos, videos, and/or
from September 1, 2020 to-date.
29. Any and allcommunications, correspondence, messages, emails, texts,
photos, videos, and/or memes exchanged between you and Brooke Whitt from
September 1, 2020 to-date.
30. Any and communications, correspondence, messages, emails, texts,
all
photos, videos, and/or memes exchanged between you and Emily Cabanas
from September 1, 2020 to-date.
31. Any and communications, correspondence, messages, emails, texts,
all
photos, videos, and/or memes exchanged between you and Christopher
Connell from September 1, 2020 to-date.
32. Any and communications, correspondence, messages, emails, texts,
all
photos, videos, and/or memes exchanged between you and any other M/Y
Renaissance crewmember from September 1, 2020 to-date.
33. Any and communications, correspondence, messages, emails, texts,
all
memes exchanged between you and any employee of
photos, videos, and/or
Defendant Renaissance from September 1, 2020 to-date.
34. Any and all photos, digitalimages, or videos of Doug Meier from September
1, 2020 to-date.
35. Any and all photos, digitalimages, or videos of Rex Witkamp from September
1, 2020 to-date.
36. Any and all photos, digital images, or videos of Samantha Eastman from
September 1, 2020 to-date.
37. Any and all photos, digital images, or videos of Caroline Manney from
September 1, 2020 to-date.
38. Any and all photos, digitalimages, or videos of Sam Manney from September
1, 2020 to-date.
HAMILTON, MILLER, & BINTHISEL 7
39. Any and all photos, digitalimages, or videos of Brooke Whitt from September
1, 2020 to-date.
40. Any and all photos, digital images, or videos of Emily Cabanas from
September 1, 2020 to-date.
41. Any and all photos, digitalimages, or videos of Chris Connell from September
1, 2020 to-date.
42. Any and all photos, digitalimages, or videos that shows, reflects,depicts or
includes any M/Y Renaissance crewmember from September 1, 2020 to-date.
43. All records, reports, forms, intake forms, patient information forms,
documents, diagnostic studies, any and all tests and test results, progress
notes, treatment notes, correspondence, emails, messages, texts, bills,
invoices, receipts, account statements, and any other records pertaining to
your treatment by Dr. Susan J. Mendlesohn.
44. With respect each person (ifany) who you will call upon
to to testifyas an
expert witness at trial,please provide the following:
a) A resume for the testifying expert detailing his/her qualifications and
expertise as pertaining to this case.
b) A listing of the cases where the testifying expert has testified by
deposition, affidavit, or at trial as an expert witness in the past four
years.
c) The documents and materials that are or reflect the agreement for the
testifyingexpert's services in this matter.
CD All records, documents, and materials you, your agents or attorneys
provided to the testifyingexpert for their work in this matter.
e) All records, documents, and materials provided to you, your agents or
your attorneys by the testifyingexperts in connection with their work in
this matter.
f) All correspondence exchanged by and between you and the testifying
expert regarding this matter.
g) All correspondence exchanged by and between your attorneys and the
testifyingexpert regarding this matter.
HAMILTON, MILLER, & BINTHISEL 8
h) All reports stating, setting forth, or regarding the opinions of the
testifyingexpert in this matter.
i) The testifying expert's billing records for services in this matter,
including without limitation: time sheets, bills, invoices, receipts,
demands, and account statements.
HAMILTON, MILLER, & BINTHISEL 9
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Filing# 149968161 E-Filed 05/19/2022 06:17:25 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: 21-007751 LAUREN HOCKENBERRY, Plaintiff, V. RENAISSANCE LLC, M/Y d/b/a RENAISSANCE, and REX WITKAMP, Defendant. NOTICE OF TAKING VIDEOTAPED DEPOSITION DUCES TECUM OF LAUREN HOCKENBERRY PLEASE TAKE NOTICE that the undersigned, as attorney for Defendants, RENAIANCE LLC, d/b/a M/Y RENAISSANCE and REX WITKAMP, will take the videotaped deposition by oral examination pursuant to Florida Rules of Civil Procedure of the following individual on the date, time and location below: Deponent Date & Time Location Lauren Hockenberry June 27,2022 @ ZOOM 10:OOAM The oral examination will take place before VERITEXT LEGAL SOLUTIONS, Court Reporters, a Notary Public or before some other officer duly authorized by law to take depositions. The deposition is being taken for purposes of discovery, for use at trial,or for such other purposes as permitted under the applicable Fla. R. Civ. P. The deposition will continue from day-to-day until completed. DUCES TECUM: The deponent is to have with him at the said time and place the following items: See Attached Schedule A HAMILTON, MILLER, & BINTHISEL 1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/19/2022 06:17:24 PM.**** Respectfully submitted, /s/ David N. Gambach David N. Gambach, Esq. Florida Bar No. 8540 Evan S. Gutwein, Esq. Florida Bar No. 58741 HAMILTON, MILLER & BIRTHISEL, LLP. 150 Southeast Second Avenue, Suite 1200 Miami, Florida 33131 Telephone 305-379-3686 Facsimile 305-379-3690 Dgambach@HamiltonMillerLaw.com EGutwein@HamiltonMillerLaw.com JFlorin@HamiltonMillerLaw.com JMendez@HamiltonMillerLaw.com Attorneys for Def. RENAISSANCE. HAMILTON, MILLER, & BINTHISEL 2 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on May 19, 2022, I electronicallyfiled the forgoing document with the Clerk of the Court via the Florida Courts E-Filing Portal. /s/ David N. Gambach David N. Gambach, Esq. Service List Andrew N. Mescolotto Michael L. Buckner, Esquire Florida Bar No. 106331 Florida Bar No.: 28141 BUCKNER LEGAL SELF-HELP PROGRAM, INC. Fertig & Gramling 5224 NW 96'?th Drive 200 SE 3rd Street Coral Springs,Florida 33076-2487 Lauderdale, FL 33316 Ft. Office:+ 1-954-347-0112 Facsimile:+ 1-954-513-4796 Telephone: (954) 763.5020 Fax: (954) 763-5412 michaelbucknerlaw@gmail.com Counsel for Pl. Hockenberry anm@fertig.com Counsel for Renaissance, LLC David E. Irwin, Esq. IRWIN LAW FIRM 205 SW 12th Street Ft.Lauderdale, FL 33315 Telephone: (954) 775-2301 Fax: (954) 775-2303 Counsel for Rex Witkamp HAMILTON, MILLER, & BINTHISEL 3 SCHEDULE A 1. A copy-back and front-of your drivers' license. 2. A copy-back and front-of any and all identification cards for healthcare insurance which covered you and were in effect at any time from ten years before the earliest of the alleged incidents to-date. 3. Copies of all military records, retirement papers, orders, DD Forms 214 or other discharge papers, veteran's claims, records of service-related disability or other documents pertaining to military service by you, whether active, reserve, or national guard. 4. Any and all documentation that is or shows your income, including but not limited to, federal and state tax returns or similar documents and supporting forms and data, from five years before the earliest of the alleged incidents to- date. 5. Any and all contracts of employment that you had at the time of the incidents described in your complaint. 6. All communications (including without limitation: letters, texts, messages, memos, notes, emails, correspondence, faxes, and any other form of communication) you had with Defendant Renaissance regarding the incidents described in your Complaint and/or your alleged injuries,losses and damages. 7. All communications (including without limitation: letters,texts, messages, memos, notes, emails, correspondence, faxes, and any other form of communication) you had with Defendant Witkamp regarding the incidents described in your Complaint and/or your alleged injuries, losses and damages. 8. Any and all documents, records, notices, demands, letters,emails, texts, and correspondence sent by you or on your behalf to any Defendant and/or their agents, insurers and attorneys, since the date of the incident alleged. 9. Any and documentation, records, and correspondence received by you or all on your behalf from any Defendant and/ or their agents, insurers and attorneys, since the date of the incident alleged. 10. Any and all documentation which relates to any personal injury claims made by you within the ten (10) years preceding the alleged incident. HAMILTON, MILLER, & BINTHISEL 4 11. Photographs, digitalimages, videos, drawings, sketches, and/or depictions of the following: a) The incidents at issue in this lawsuit; b) The locations of the incidents at issue in this lawsuit; c) The vessel involved in the subject incident; d) Your injuries, illness and/or aggravation thereof allegedly sustained in the incidents at issue in this lawsuit. 12. Photographs, digitalimages, and/or videos taken or made at any time while you were aboard the vessel where the incidents are alleged to have happened. 13. Copies of all models, plats, maps, drawings, motion pictures, video tapes or photographs pertaining to any fact or issue involved in this controversy in your possession or in the possession of your attorneys and/or your testifying expert witnesses. 14. All accident or incident reports prepared by any person, firm, company, government entity, or corporation that are in your possession or in the possession of your attorneys concerning the incident as described in your claim. 15. Any and allstatements (regardless of format) that you obtained from any person, party and/or entity relating in any way to this lawsuit. 16. All correspondence and communications with any of the Parties to this lawsuit and/ or their agents, insurers and attorneys, regarding the incident, the events underlying the incidents and/or your injuries, illness or aggravation of pre-existing injuries or illness. 17. Any and postings you made on any social media platform, page, or blogs all from the three years preceding the incident to-date. 18. Copies of any assignments, payment guarantees, letters of protection, and/or lien agreements made or issued by you or by your attorneys to any health care provider with which you have treated for the injuries alleged by you. 19. Any and allmedical records (including without limitation: hospital records, physicians' records and evaluations, psychologists records and evaluations, psychiatrist'records and evaluations, mental health care practitioners'reports HAMILTON, MILLER, & BINTHISEL 5 and evaluations, prescription records, reports of all diagnosticstudies and tests of any kind, any and all laboratory reports, X-ray films/images and reports, MRI films/images and reports, and CT Scans and reports) relative to any and all medical care or treatment, physical or psychological,received by you in the ten (10) years prior to the date of the incidents at issue. 20. Any and allmedical records (including without limitation: hospital records, physicians' records and evaluations, psychologists records and evaluations, psychiatrist'records and evaluations, mental health care practitioners'reports and evaluations, prescription records, reports of all diagnosticstudies and tests of any kind, laboratory reports, X-ray films/images and reports, MRI films/images and reports, and CT Scans and reports) relative to any and all medical care or treatment, physical or psychological,received by you for the injuries you claim to have sustained in connection with the incidents described in your complaint. 21. The billingrecords from each person or entity that provided you medical care or treatment, including without limitation mental health care, for the injuries claimed by you in this lawsuit. (This should be interpreted broadly to include without limitation: invoices, account statements, charges, write-offs, collection letters, notes, receipts, Explanation of Benefit forms from your health insurer, health insurance claim forms, correspondence, demands, and any other document, report, report or materials that is,addresses or reflects the costs of your medical care and treatment.) 22. Any and all documentation that is or relates to prescriptions and expenses incurred for medications prescribed by reason of any and all injuries,illness and/or aggravation sustained by you as a result of the incidents at issue. 23. Any and all documentation that or relates to any expenses incurred by is reason of any and all injuries,illness, and/or aggravation, sustained by you as a result of the incidents alleged and for which you are seeking compensation. 24. Any and all communications, correspondence, messages, emails, texts, photos, videos, and/or memes exchanged between you and Doug Meier from September 1, 2020 to-date. 25. Any and all communications, correspondence, messages, emails, texts, photos, videos, and/or memes exchanged between you and Rex Witkamp from September 1, 2020 to-date. 26. Any and allcommunications, correspondence, messages, emails, texts, photos, videos, and/or memes exchanged between you and Samantha HAMILTON, MILLER, & BINTHISEL 6 Eastman from September 1, 2020 to-date. 27. Any and communications, correspondence, messages, emails, texts, all photos, videos, and/or memes exchanged between you and Caroline Manney from September 1, 2020 to-date. 28. Any and communications, correspondence, messages, emails, texts, all memes exchanged between you and Mr. Sam Manney photos, videos, and/or from September 1, 2020 to-date. 29. Any and allcommunications, correspondence, messages, emails, texts, photos, videos, and/or memes exchanged between you and Brooke Whitt from September 1, 2020 to-date. 30. Any and communications, correspondence, messages, emails, texts, all photos, videos, and/or memes exchanged between you and Emily Cabanas from September 1, 2020 to-date. 31. Any and communications, correspondence, messages, emails, texts, all photos, videos, and/or memes exchanged between you and Christopher Connell from September 1, 2020 to-date. 32. Any and communications, correspondence, messages, emails, texts, all photos, videos, and/or memes exchanged between you and any other M/Y Renaissance crewmember from September 1, 2020 to-date. 33. Any and communications, correspondence, messages, emails, texts, all memes exchanged between you and any employee of photos, videos, and/or Defendant Renaissance from September 1, 2020 to-date. 34. Any and all photos, digitalimages, or videos of Doug Meier from September 1, 2020 to-date. 35. Any and all photos, digitalimages, or videos of Rex Witkamp from September 1, 2020 to-date. 36. Any and all photos, digital images, or videos of Samantha Eastman from September 1, 2020 to-date. 37. Any and all photos, digital images, or videos of Caroline Manney from September 1, 2020 to-date. 38. Any and all photos, digitalimages, or videos of Sam Manney from September 1, 2020 to-date. HAMILTON, MILLER, & BINTHISEL 7 39. Any and all photos, digitalimages, or videos of Brooke Whitt from September 1, 2020 to-date. 40. Any and all photos, digital images, or videos of Emily Cabanas from September 1, 2020 to-date. 41. Any and all photos, digitalimages, or videos of Chris Connell from September 1, 2020 to-date. 42. Any and all photos, digitalimages, or videos that shows, reflects,depicts or includes any M/Y Renaissance crewmember from September 1, 2020 to-date. 43. All records, reports, forms, intake forms, patient information forms, documents, diagnostic studies, any and all tests and test results, progress notes, treatment notes, correspondence, emails, messages, texts, bills, invoices, receipts, account statements, and any other records pertaining to your treatment by Dr. Susan J. Mendlesohn. 44. With respect each person (ifany) who you will call upon to to testifyas an expert witness at trial,please provide the following: a) A resume for the testifying expert detailing his/her qualifications and expertise as pertaining to this case. b) A listing of the cases where the testifying expert has testified by deposition, affidavit, or at trial as an expert witness in the past four years. c) The documents and materials that are or reflect the agreement for the testifyingexpert's services in this matter. CD All records, documents, and materials you, your agents or attorneys provided to the testifyingexpert for their work in this matter. e) All records, documents, and materials provided to you, your agents or your attorneys by the testifyingexperts in connection with their work in this matter. f) All correspondence exchanged by and between you and the testifying expert regarding this matter. g) All correspondence exchanged by and between your attorneys and the testifyingexpert regarding this matter. HAMILTON, MILLER, & BINTHISEL 8 h) All reports stating, setting forth, or regarding the opinions of the testifyingexpert in this matter. i) The testifying expert's billing records for services in this matter, including without limitation: time sheets, bills, invoices, receipts, demands, and account statements. HAMILTON, MILLER, & BINTHISEL 9