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Filing# 170369334 E-Filed 04/05/2023 09:43:53 AM
IN THE CIRCUIT COURT IN THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE-21-008854
DIVISION: 21
THERMOSET ROOFING CORP.,
Plaintiff.
V
TURN TWO ELECTRIC, INC.,
a Florida Corporation,and
LASHAWN LATTIBEAUDIERE, an
individual,
Defendants.
i
PLAINTIFF'S AMENDED NOTICE OF TAKING VIDEOTAPED DEPOSITION
PLEASE TAKE NOTICE that the undersignedattorney will appear via video conference to
take the videotaped depositionof the person(s)described below at the location and on the date and
time indicated by and through the natural person designated,on the topics listed in the attached
Exhibit A before an officer duly authorized by law to take depositions.
NAME Mickey Bray, the City of Pompano Beach's Chief Electrical Inspector, pursuant to
Florida Rule of Civil Procedure 1.310(b)(6)to testifyabout the matters set forth on
Exhibit "A".
DATE 4/6/23 at 1:00 P.M
TIME
LOCATION https://magnals.zoom.us/j/98665661408?pwd=V3NlNVduOUZKaS9xNUp5elFab0psUT09
Meeting ID: 986 6566 1408
Password: 029229
One tap mobile
+16469313807,,98665661408# US (New York)
8558801246,,98665661408# US Toll-free
Dial by your locationl 646 931 3807 US (New York)
855 880 1246 US Toll-free
Meeting ID: 986 6566 1408
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/05/2023 09:43:52 AM.****
The depositionwill be taken pursuant to Florida Rule of Civil Procedure 1.310, and the
testimony shall be recorded by stenographicmeans, before an officer duly authorized to take
depositionsin the State of Florida.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on April 5,2023 a true and correct copy ofthe foregoinghas been
furnished by the Florida Courts E-Filing Portal System to all electronic with
filingparticipants
respect to this proceeding.
KELLEY KRONENBERG, PA
10360 West State Road 84
Fort Lauderdale, FL 33324
Telephone No.: (954) 370-9970
Facsimile No.: (954) 382-1988
By-./s/ Gary L. Brown
GARY L. BROWN
Florida Bar No.: 0054585
gbrown@kelleykronenberg.com
ygonzalo@kelleykronenberg.com
2
EXHIBIT A
DEFINITIONS
1 The terms "you" or "your or "City of Pompano" shall mean City of
the entity,
Pompano, includingits divisions,departments,subsidiaries,affiliates, present and
predecessors,
former officers,directors,owners, employees, representatives,
servants, insurers,contractors,
subcontractors,sub-subcontractors and/or agents and all other persons actingor purportingto act
on its behalf as well as each partnershipin which they are a partner.
2. The term "Thermoset" shall mean the THERMOSET
entity, ROOFING CORP.,
includingits divisions,departments,subsidiaries,
affiliates, present and former
predecessors,
officers,directors,owners, employees, representatives,
servants, insurers,contractors,
subcontractors,sub-subcontractors and/or agents and all other persons actingor purportingto act
on its behalf as well as each partnershipin which they are a partner.
3 The term"Holdings" shall mean the entity500 NW 12 HOLDINGS LLC, including
its divisions,departments,subsidiaries,
affiliates, present and former officers,
predecessors,
servants, insurers,contractors, subcontractors,sub-
directors,owners, employees,representatives,
subcontractors and/or agents and all other persons actingor purportingto act on its behalf as well
as each in which they are a partner.
partnership
4. The term "Turn Two" shall mean the entity TURN TWO ELECTRIC, INC., its
divisions,departments,subsidiaries,
affiliates, present and former officers,
predecessors, directors,
servants, insurers,contractors, subcontractors,sub-
owners, employees,representatives,
subcontractors and/or agents and all other persons actingor purportingto act on its behalf as well
as each partnershipin which they are a partner.
5. The term "Pacman" shall mean the entities PACMAN ENTERPRISES, LLC
D/B/A PACMAN ELECTRIC and/or PACMAN DATA VOICE & ELECTRIC, INC., as the
3
CASE NO.: CACE-21-008854
predecessors,present and
context permits, its divisions,departments, subsidiaries,affiliates,
former officers,directors,owners, employees, representatives,
servants, insurers, contractors,
subcontractors,sub-subcontractors and/or agents and all other persons actingor purportingto act
on its behalf as well as each partnershipin which they are a partner.
6. The term "Atech" shall mean the entity ATECH FIRE & SECURITY, INC., its
divisions,departments,subsidiaries, predecessors,present and former officers,directors,
affiliates,
servants, insurers,contractors, subcontractors,sub-
owners, employees,representatives,
subcontractors and/or agents and all other persons actingor purportingto act on its behalf as well
as each partnershipin which they are a partner.
7. The term "Kilowatt" shall mean the entity KILOWATT ELECTRIC, INC., its
divisions,departments,subsidiaries, predecessors,present and former officers,directors,
affiliates,
servants, insurers,contractors, subcontractors,sub-
owners, employees, representatives,
subcontractors and/or agents and all other persons actingor purportingto act on its behalf as well
as each partnershipin which they are a partner.
8 The term "documents" shall mean term "document" or "documents" is used in the
broadest sense and includes,without limitation,
the followingitems whether printedor recorded,
written or typed,reproduced by any mechanical, electronic,
or photographicprocess, or written or
produced by hand, all information stored or located on computer hardware or software, including
all Stored Information "ESI" as defined herein, and shall include
Electronically all drafts and
copiesof any such document (unlesssuch copy is identical in every respect with the original
or
copy thereof produced),namely agreements; communications, includingnewspaper or other
intra office communication; correspondence;telegrams;memoranda;
periodicalreports or articles;
records books' summaries or record oftelephoneconversations;telephonelogs;diaries;
calendars;
Page 4 of 8
CASE NO.: CACE-21-008854
day timers; telephone message pads; forecasts;financial statements; statistical statements;
management letters;accountants' or clients' work papers; manuals; graphs; charts; accounts;
analyticalrecords; minutes or records of meetings or conferences; reports and/or summaries of
interviews; reports and/or summaries of investigations;
opinions or reports of consultants;
reports or summaries of negotiations;
appraisals; brochures; pamphlets; circulars;trade letters;
press releases;mag cards; telex files;teletypes; marginal notations;
contracts; notes; projections;
securities ledgersor other records of original
photographs;drawings;specifications; entry; checks,
back and front;typed or stenographictranscripts
of any testimony given at a legalor investigative
and other documents or other writingsof
proceeding;drafts of any of the foregoing,if applicable;
whatever description, but not limited
including, to, any information contained in any computer
although not yet printedout, within your possession,custody or control or the possession,custody
or control of any agent, employee (includingwithout limitation,attorneys, accountants or
or other person actingor purportingto
advisors), act on your behalf; for any document related to
the matters described herein with is not in your possession,but which you know to exist,you are
requestedto identifyany such document and indicate to the best of your ability
that document's
present or last known location and custodian.
9. The term "Project"or "Property" shall mean the property located at 500 NW 12? ,th
Avenue, Pompano Beach, Florida in Broward County, which is the subjectofthe above styled
action.
AREAS OF INQUIRY
Your knowledge and understandingas to:
1 All permits,permit applications, permit approvals,and permit
permit inspections,
to the Projectunder permitnumber 20-1277.
fees,relating
Page 6 of 8
CASE NO.: CACE-21-008854
2. All permits,permit applications, permit approvals,and permit
permit inspections,
fees to the Projectunder permit number 20-5067.
relating
3 All correspondenceand communications of any kind exchanged by and/or between
You and Thermoset regardingpermit number 20-1277 and/or the Project.
4. All correspondenceand communications of any kind exchanged by and/or between
You and Holdings regardingpermit number 20-1277 and/or the Project
5. All correspondence and communications of any kind exchanged by and/or between
You and Turn Two, regardingPermit number 20-1277 and/or the Project.
6. All correspondenceand communications of any kind exchanged by and/or between
You and Thermoset, regardingPermit number 20-5067 and/or the Project.
7. All correspondenceand communications of any kind exchanged by and/or between
You and Holdings, regardingPermit number 20-5067 and/or the Project.
8 All correspondenceand communications of any kind exchanged by and/or between
You and Pacman regardingpermit number 20-5067 and/or the Project.
9. All correspondence and communications of any kind exchanged by and/or between
You and Atech regardingpermit number 20-5067 and/or the Project.
10. All correspondenceand communications of any kind exchanged by and/or between
You and Kilowatt regardingpermit number 20-5067 and/or the Project.
11. All correspondenceand communications of any kind exchanged by and/or between
You and Thermoset regardingpermit number 21-0868 and/or the Project.
12. All correspondenceand communications o f any kind exchanged by and/or between
You and Holdings,regardingPermit number 21-0868 and/or the Project.
Page 7 of 8
CASE NO.: CACE-21-008854
13. All correspondenceand communications of any kind exchanged by and/or between
You and Pacman regardingpermit number 21-0868 and/or the Project.
14. All correspondence and communications of any kind exchanged by and/or between
You and Turn Two, regardingPermit number 21-0868 and/or the Project.
15. All correspondenceand communications of any kind exchanged by and/or between
You and Thermoset regardingpermit number 21-3277 and/or the Project.
16. All correspondenceand communications of any kind exchanged by and/or between
You and Holdings regardingpermit number 21-3277 and/or the Project.
17. All correspondenceand communications of any kind exchanged by and/or between
You and Pacman regardingpermitnumber 21-3277 and/or the Project.
18. All internal correspondence and communications of any kind exchanged by and/or
between You and any other person at the City of Pompano Building Department regardingPermit
number 20-1277 and/or the Project.
19. All internal correspondence and communications of any kind exchanged by and/or
between You and any other person at the City of Pompano Building Department regardingPermit
number 20-5067 and/or the Project.
20. All internal correspondenceand communications of any kind exchanged by and/or
between You and any other person at the City o f Pompano BuildingDepartment regardingPermit
number 21-3277 and/or the Project.
21. All internal correspondenceand communications of any kind exchanged by and/or
between You and any other person at the City o f Pompano BuildingDepartment regardingPermit
number 21-0868 and/or the Project.
Page 8 of 8
22. To the extent not set forth in the precedingparagraphs,any other documents or
records contained within the permit files or records for permit numbers 20-1277,20-5067,21-
0868 and 21-3277.
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Filing# 170369334 E-Filed 04/05/2023 09:43:53 AM IN THE CIRCUIT COURT IN THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-21-008854 DIVISION: 21 THERMOSET ROOFING CORP., Plaintiff. V TURN TWO ELECTRIC, INC., a Florida Corporation,and LASHAWN LATTIBEAUDIERE, an individual, Defendants. i PLAINTIFF'S AMENDED NOTICE OF TAKING VIDEOTAPED DEPOSITION PLEASE TAKE NOTICE that the undersignedattorney will appear via video conference to take the videotaped depositionof the person(s)described below at the location and on the date and time indicated by and through the natural person designated,on the topics listed in the attached Exhibit A before an officer duly authorized by law to take depositions. NAME Mickey Bray, the City of Pompano Beach's Chief Electrical Inspector, pursuant to Florida Rule of Civil Procedure 1.310(b)(6)to testifyabout the matters set forth on Exhibit "A". DATE 4/6/23 at 1:00 P.M TIME LOCATION https://magnals.zoom.us/j/98665661408?pwd=V3NlNVduOUZKaS9xNUp5elFab0psUT09 Meeting ID: 986 6566 1408 Password: 029229 One tap mobile +16469313807,,98665661408# US (New York) 8558801246,,98665661408# US Toll-free Dial by your locationl 646 931 3807 US (New York) 855 880 1246 US Toll-free Meeting ID: 986 6566 1408 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/05/2023 09:43:52 AM.**** The depositionwill be taken pursuant to Florida Rule of Civil Procedure 1.310, and the testimony shall be recorded by stenographicmeans, before an officer duly authorized to take depositionsin the State of Florida. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on April 5,2023 a true and correct copy ofthe foregoinghas been furnished by the Florida Courts E-Filing Portal System to all electronic with filingparticipants respect to this proceeding. KELLEY KRONENBERG, PA 10360 West State Road 84 Fort Lauderdale, FL 33324 Telephone No.: (954) 370-9970 Facsimile No.: (954) 382-1988 By-./s/ Gary L. Brown GARY L. BROWN Florida Bar No.: 0054585 gbrown@kelleykronenberg.com ygonzalo@kelleykronenberg.com 2 EXHIBIT A DEFINITIONS 1 The terms "you" or "your or "City of Pompano" shall mean City of the entity, Pompano, includingits divisions,departments,subsidiaries,affiliates, present and predecessors, former officers,directors,owners, employees, representatives, servants, insurers,contractors, subcontractors,sub-subcontractors and/or agents and all other persons actingor purportingto act on its behalf as well as each partnershipin which they are a partner. 2. The term "Thermoset" shall mean the THERMOSET entity, ROOFING CORP., includingits divisions,departments,subsidiaries, affiliates, present and former predecessors, officers,directors,owners, employees, representatives, servants, insurers,contractors, subcontractors,sub-subcontractors and/or agents and all other persons actingor purportingto act on its behalf as well as each partnershipin which they are a partner. 3 The term"Holdings" shall mean the entity500 NW 12 HOLDINGS LLC, including its divisions,departments,subsidiaries, affiliates, present and former officers, predecessors, servants, insurers,contractors, subcontractors,sub- directors,owners, employees,representatives, subcontractors and/or agents and all other persons actingor purportingto act on its behalf as well as each in which they are a partner. partnership 4. The term "Turn Two" shall mean the entity TURN TWO ELECTRIC, INC., its divisions,departments,subsidiaries, affiliates, present and former officers, predecessors, directors, servants, insurers,contractors, subcontractors,sub- owners, employees,representatives, subcontractors and/or agents and all other persons actingor purportingto act on its behalf as well as each partnershipin which they are a partner. 5. The term "Pacman" shall mean the entities PACMAN ENTERPRISES, LLC D/B/A PACMAN ELECTRIC and/or PACMAN DATA VOICE & ELECTRIC, INC., as the 3 CASE NO.: CACE-21-008854 predecessors,present and context permits, its divisions,departments, subsidiaries,affiliates, former officers,directors,owners, employees, representatives, servants, insurers, contractors, subcontractors,sub-subcontractors and/or agents and all other persons actingor purportingto act on its behalf as well as each partnershipin which they are a partner. 6. The term "Atech" shall mean the entity ATECH FIRE & SECURITY, INC., its divisions,departments,subsidiaries, predecessors,present and former officers,directors, affiliates, servants, insurers,contractors, subcontractors,sub- owners, employees,representatives, subcontractors and/or agents and all other persons actingor purportingto act on its behalf as well as each partnershipin which they are a partner. 7. The term "Kilowatt" shall mean the entity KILOWATT ELECTRIC, INC., its divisions,departments,subsidiaries, predecessors,present and former officers,directors, affiliates, servants, insurers,contractors, subcontractors,sub- owners, employees, representatives, subcontractors and/or agents and all other persons actingor purportingto act on its behalf as well as each partnershipin which they are a partner. 8 The term "documents" shall mean term "document" or "documents" is used in the broadest sense and includes,without limitation, the followingitems whether printedor recorded, written or typed,reproduced by any mechanical, electronic, or photographicprocess, or written or produced by hand, all information stored or located on computer hardware or software, including all Stored Information "ESI" as defined herein, and shall include Electronically all drafts and copiesof any such document (unlesssuch copy is identical in every respect with the original or copy thereof produced),namely agreements; communications, includingnewspaper or other intra office communication; correspondence;telegrams;memoranda; periodicalreports or articles; records books' summaries or record oftelephoneconversations;telephonelogs;diaries; calendars; Page 4 of 8 CASE NO.: CACE-21-008854 day timers; telephone message pads; forecasts;financial statements; statistical statements; management letters;accountants' or clients' work papers; manuals; graphs; charts; accounts; analyticalrecords; minutes or records of meetings or conferences; reports and/or summaries of interviews; reports and/or summaries of investigations; opinions or reports of consultants; reports or summaries of negotiations; appraisals; brochures; pamphlets; circulars;trade letters; press releases;mag cards; telex files;teletypes; marginal notations; contracts; notes; projections; securities ledgersor other records of original photographs;drawings;specifications; entry; checks, back and front;typed or stenographictranscripts of any testimony given at a legalor investigative and other documents or other writingsof proceeding;drafts of any of the foregoing,if applicable; whatever description, but not limited including, to, any information contained in any computer although not yet printedout, within your possession,custody or control or the possession,custody or control of any agent, employee (includingwithout limitation,attorneys, accountants or or other person actingor purportingto advisors), act on your behalf; for any document related to the matters described herein with is not in your possession,but which you know to exist,you are requestedto identifyany such document and indicate to the best of your ability that document's present or last known location and custodian. 9. The term "Project"or "Property" shall mean the property located at 500 NW 12? ,th Avenue, Pompano Beach, Florida in Broward County, which is the subjectofthe above styled action. AREAS OF INQUIRY Your knowledge and understandingas to: 1 All permits,permit applications, permit approvals,and permit permit inspections, to the Projectunder permitnumber 20-1277. fees,relating Page 6 of 8 CASE NO.: CACE-21-008854 2. All permits,permit applications, permit approvals,and permit permit inspections, fees to the Projectunder permit number 20-5067. relating 3 All correspondenceand communications of any kind exchanged by and/or between You and Thermoset regardingpermit number 20-1277 and/or the Project. 4. All correspondenceand communications of any kind exchanged by and/or between You and Holdings regardingpermit number 20-1277 and/or the Project 5. All correspondence and communications of any kind exchanged by and/or between You and Turn Two, regardingPermit number 20-1277 and/or the Project. 6. All correspondenceand communications of any kind exchanged by and/or between You and Thermoset, regardingPermit number 20-5067 and/or the Project. 7. All correspondenceand communications of any kind exchanged by and/or between You and Holdings, regardingPermit number 20-5067 and/or the Project. 8 All correspondenceand communications of any kind exchanged by and/or between You and Pacman regardingpermit number 20-5067 and/or the Project. 9. All correspondence and communications of any kind exchanged by and/or between You and Atech regardingpermit number 20-5067 and/or the Project. 10. All correspondenceand communications of any kind exchanged by and/or between You and Kilowatt regardingpermit number 20-5067 and/or the Project. 11. All correspondenceand communications of any kind exchanged by and/or between You and Thermoset regardingpermit number 21-0868 and/or the Project. 12. All correspondenceand communications o f any kind exchanged by and/or between You and Holdings,regardingPermit number 21-0868 and/or the Project. Page 7 of 8 CASE NO.: CACE-21-008854 13. All correspondenceand communications of any kind exchanged by and/or between You and Pacman regardingpermit number 21-0868 and/or the Project. 14. All correspondence and communications of any kind exchanged by and/or between You and Turn Two, regardingPermit number 21-0868 and/or the Project. 15. All correspondenceand communications of any kind exchanged by and/or between You and Thermoset regardingpermit number 21-3277 and/or the Project. 16. All correspondenceand communications of any kind exchanged by and/or between You and Holdings regardingpermit number 21-3277 and/or the Project. 17. All correspondenceand communications of any kind exchanged by and/or between You and Pacman regardingpermitnumber 21-3277 and/or the Project. 18. All internal correspondence and communications of any kind exchanged by and/or between You and any other person at the City of Pompano Building Department regardingPermit number 20-1277 and/or the Project. 19. All internal correspondence and communications of any kind exchanged by and/or between You and any other person at the City of Pompano Building Department regardingPermit number 20-5067 and/or the Project. 20. All internal correspondenceand communications of any kind exchanged by and/or between You and any other person at the City o f Pompano BuildingDepartment regardingPermit number 21-3277 and/or the Project. 21. All internal correspondenceand communications of any kind exchanged by and/or between You and any other person at the City o f Pompano BuildingDepartment regardingPermit number 21-0868 and/or the Project. Page 8 of 8 22. To the extent not set forth in the precedingparagraphs,any other documents or records contained within the permit files or records for permit numbers 20-1277,20-5067,21- 0868 and 21-3277.