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NAILAH K. BYRD
CUYAHOGA COUNTY CLERK OF COURTS
1200 Ontario Street
Cleveland, Ohio 44113
Court of Common Pleas
NOTICE OF DEPOSITION
September 15,2023 11:11
By: DAVID M. PARIS 0001358
Confirmation Nbr. 2964881
DEBRA NAMONSKE, ADMINISTRATOR CV 22 969633
vs.
Judge: MICHAEL P. SHAUGHNESSY
UNIVAR SOLUTIONS USA, INC., ET AL.
Pages Filed: 5
Electronically Filed 09/15/2023 11:11 / NOTICE / CV 22 969633 / Confirmation Nbr. 2964881 / CLAJB
IN THE COURT OF COMMON PLEAS
CUYAHOGA COUNTY, OHIO
DEBRA NAMOSKE, Administrator of the ) CASE NO. 2022 CV 969633
Estate of SHAWN MOORE, )
) JUDGE MICHAEL P. SHAUGHNESSY
Plaintiff, )
)
v. )
)
UNIVAR SOLUTIONS USA, INC., et al., )
) PLAINTIFF’S NOTICE OF
) DEPOSITION OF EXPERT
Defendants. ) CHARLES E. VEPPERT
)
Please take notice that the Plaintiff will take the deposition of Vincent J. Cronin
commencing at 2:00 p.m. (EDT) on Wednesday, October 4, 2023, pursuant to Ohio Rules of
Civil Procedure 45 and 30. The deposition will be taken before a Notary Public and will continue
from day to day until completed.
Please Take Further Notice that:
1. The deposition will be conducted remotely, using audio-visual conference
technology;
2. The court reporter will report the deposition from a location separate from the
witness;
3. Counsel for the parties and their clients will be participating from various, separate
locations;
4. The court reporter will administer the oath to the witness remotely;
5. The witness will be required to provide government-issued identification
satisfactory to the court reporter, and this identification must be legible on camera;
6. Each participating attorney may be visible to all other participants, and their
statements will be audible to all participants;
Electronically Filed 09/15/2023 11:11 / NOTICE / CV 22 969633 / Confirmation Nbr. 2964881 / CLAJB
7. All exhibits will be provided simultaneously and electronically to the witness and
all participants;
8. The court reporter will record the testimony;
9. The deposition may be recorded electronically; and
10. Counsel for all parties will be required to stipulate on the record:
a. Their consent to this manner of deposition; and
b. Their waiver of any objection to this manner of deposition, including any
objection to the admissibility at trial of this testimony based on this manner
of deposition.
Said deposition to be conducted by Res Ipsa, 501 Congress Ave., Suite 150, Austin, Texas
78701, Phone: (512) 334-6777.
DUCES TECUM
Pursuant to Ohio Rule of Civil Procedure 30(B)(4), the deponent is required to produce at
the time of the deposition the following records, documents and other writings:
1. Your current curriculum vitae.
2. Your entire file concerning the subject lawsuit.
3. All documents and tangible things that have been made or prepared by any expert used
for consultation purposes that forms the basis, either in whole or in part, of your
opinion(s).
4. All documents, notes and/or records kept by you regarding or related in any way to the
subject lawsuit.
5. All statements made by persons not a party to this suit, either written, recorded or
otherwise, that pertain to the subject lawsuit that you have reviewed or relied upon, in
whole or in part, in forming your opinion(s) in this matter.
6. All published treatises, periodicals, pamphlets or articles that you claim to be reliable
authority which you have reviewed or relied upon, in whole or in part, in forming your
opinions in this matter.
ElectrOfttcalffSi led fi91§/2a?a>11i11 / NOTICE6/C 29648 81 / CLAJB
Page 2 of 5
7. A listing of each person, including name, address and telephone number, acting on your
behalf who assisted you in forming your opinions in this matter.
8. A list of all cases in which you have testified as an expert witness, either by deposition or
at trial.
9. Copies of any and all depositions, affidavits or other sworn testimony that you have given
in the past as a plaintiff, defendant, third party and/or expert witness.
10. Any reports prepared by you regarding the subject lawsuit.
11. All photographs, drawings, charts, models, videotapes, motion pictures or other
demonstrative or physical evidence pertaining to the subject lawsuit and/or your opinions
in this case.
12. All documents you have received and/or reviewed in connection with the subject lawsuit.
13. All documents you have given to the Defendants and/or their attorneys in connection
with the subject lawsuit.
14. All documents which reflect any advertising you have conducted regarding your services
as an expert witness.
15. All standards, rules, regulations, protocols, statutes, policies, procedures and/or laws that
support and/or form the basis of any opinions that you intend to offer in connection with
this case.
16. All reports prepared by you in connection with any lawsuit wherein you served as expert
witness.
Respectfully submitted,
/s/ David M. Paris___________
David M. Paris, Esq. (0001358)
NURENBERG, PARIS, HELLER
& McCarthy co., l.p.a.
600 Superior Ave East, 12th Floor
Cleveland, Ohio 44114
Ph: (216) 621-2300
Fax: (216) 771-2242
Email: dparis@nphm.com
AND
ElectrOfoCallfi led / NOTICEs/fC 2964881 / CLAJB
Page 3 of 5
/s/Louie J. Cook________
Louie J. Cook, Of Counsel,
Appearing Pro Hac Vice
State Bar No. 24101191
PHV-26323-2002
WHITE & CARLSON LAW FIRM
653 Everhart Rd., Suite 105 Corpus
Christi, Texas 78411
Ph: (361) 336-3317
Fax: (361) 400-5293
Email:
lcook@whiteandcarlson.com (cc:
lgarcia@whiteandcarlson.com)
Attorneys for Plaintiff
ElectrSnCafi led OSIl^IlQ^bimill INWCEsI ICW2p/96963BdCbfmaiOnNM. 2964881 I CLAJB
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CERTIFICATE OF SERVICE
A copy of the foregoing has been sent via email only to the following this 14th day of
September, 2023:
David Fagnilli, Esq.
Marshall Dennehey Warner Coleman
& Goggin
127 Public Square, Suite 3510
Cleveland, ohio 44114
Email: djfagnilli@mdwcg.com
Attorney for Defendants
/s/ David M. Paris_______
David M. Paris, Esq. (0001358)
Nurenberg, Paris, Heller
& McCarthy Co., L.P.A.
/s/Louie J. Cook_________
Louie J. Cook, Esq. (24101191)
White & Carlson Law Firm
ElectrOfoCafi led OSH^/TQ^bimill dfOaCSs/C29648 81 I CLAJB
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Preview
NAILAH K. BYRD CUYAHOGA COUNTY CLERK OF COURTS 1200 Ontario Street Cleveland, Ohio 44113 Court of Common Pleas NOTICE OF DEPOSITION September 15,2023 11:11 By: DAVID M. PARIS 0001358 Confirmation Nbr. 2964881 DEBRA NAMONSKE, ADMINISTRATOR CV 22 969633 vs. Judge: MICHAEL P. SHAUGHNESSY UNIVAR SOLUTIONS USA, INC., ET AL. Pages Filed: 5 Electronically Filed 09/15/2023 11:11 / NOTICE / CV 22 969633 / Confirmation Nbr. 2964881 / CLAJB IN THE COURT OF COMMON PLEAS CUYAHOGA COUNTY, OHIO DEBRA NAMOSKE, Administrator of the ) CASE NO. 2022 CV 969633 Estate of SHAWN MOORE, ) ) JUDGE MICHAEL P. SHAUGHNESSY Plaintiff, ) ) v. ) ) UNIVAR SOLUTIONS USA, INC., et al., ) ) PLAINTIFF’S NOTICE OF ) DEPOSITION OF EXPERT Defendants. ) CHARLES E. VEPPERT ) Please take notice that the Plaintiff will take the deposition of Vincent J. Cronin commencing at 2:00 p.m. (EDT) on Wednesday, October 4, 2023, pursuant to Ohio Rules of Civil Procedure 45 and 30. The deposition will be taken before a Notary Public and will continue from day to day until completed. Please Take Further Notice that: 1. The deposition will be conducted remotely, using audio-visual conference technology; 2. The court reporter will report the deposition from a location separate from the witness; 3. Counsel for the parties and their clients will be participating from various, separate locations; 4. The court reporter will administer the oath to the witness remotely; 5. The witness will be required to provide government-issued identification satisfactory to the court reporter, and this identification must be legible on camera; 6. Each participating attorney may be visible to all other participants, and their statements will be audible to all participants; Electronically Filed 09/15/2023 11:11 / NOTICE / CV 22 969633 / Confirmation Nbr. 2964881 / CLAJB 7. All exhibits will be provided simultaneously and electronically to the witness and all participants; 8. The court reporter will record the testimony; 9. The deposition may be recorded electronically; and 10. Counsel for all parties will be required to stipulate on the record: a. Their consent to this manner of deposition; and b. Their waiver of any objection to this manner of deposition, including any objection to the admissibility at trial of this testimony based on this manner of deposition. Said deposition to be conducted by Res Ipsa, 501 Congress Ave., Suite 150, Austin, Texas 78701, Phone: (512) 334-6777. DUCES TECUM Pursuant to Ohio Rule of Civil Procedure 30(B)(4), the deponent is required to produce at the time of the deposition the following records, documents and other writings: 1. Your current curriculum vitae. 2. Your entire file concerning the subject lawsuit. 3. All documents and tangible things that have been made or prepared by any expert used for consultation purposes that forms the basis, either in whole or in part, of your opinion(s). 4. All documents, notes and/or records kept by you regarding or related in any way to the subject lawsuit. 5. All statements made by persons not a party to this suit, either written, recorded or otherwise, that pertain to the subject lawsuit that you have reviewed or relied upon, in whole or in part, in forming your opinion(s) in this matter. 6. All published treatises, periodicals, pamphlets or articles that you claim to be reliable authority which you have reviewed or relied upon, in whole or in part, in forming your opinions in this matter. ElectrOfttcalffSi led fi91§/2a?a>11i11 / NOTICE6/C 29648 81 / CLAJB Page 2 of 5 7. A listing of each person, including name, address and telephone number, acting on your behalf who assisted you in forming your opinions in this matter. 8. A list of all cases in which you have testified as an expert witness, either by deposition or at trial. 9. Copies of any and all depositions, affidavits or other sworn testimony that you have given in the past as a plaintiff, defendant, third party and/or expert witness. 10. Any reports prepared by you regarding the subject lawsuit. 11. All photographs, drawings, charts, models, videotapes, motion pictures or other demonstrative or physical evidence pertaining to the subject lawsuit and/or your opinions in this case. 12. All documents you have received and/or reviewed in connection with the subject lawsuit. 13. All documents you have given to the Defendants and/or their attorneys in connection with the subject lawsuit. 14. All documents which reflect any advertising you have conducted regarding your services as an expert witness. 15. All standards, rules, regulations, protocols, statutes, policies, procedures and/or laws that support and/or form the basis of any opinions that you intend to offer in connection with this case. 16. All reports prepared by you in connection with any lawsuit wherein you served as expert witness. Respectfully submitted, /s/ David M. Paris___________ David M. Paris, Esq. (0001358) NURENBERG, PARIS, HELLER & McCarthy co., l.p.a. 600 Superior Ave East, 12th Floor Cleveland, Ohio 44114 Ph: (216) 621-2300 Fax: (216) 771-2242 Email: dparis@nphm.com AND ElectrOfoCallfi led / NOTICEs/fC 2964881 / CLAJB Page 3 of 5 /s/Louie J. Cook________ Louie J. Cook, Of Counsel, Appearing Pro Hac Vice State Bar No. 24101191 PHV-26323-2002 WHITE & CARLSON LAW FIRM 653 Everhart Rd., Suite 105 Corpus Christi, Texas 78411 Ph: (361) 336-3317 Fax: (361) 400-5293 Email: lcook@whiteandcarlson.com (cc: lgarcia@whiteandcarlson.com) Attorneys for Plaintiff ElectrSnCafi led OSIl^IlQ^bimill INWCEsI ICW2p/96963BdCbfmaiOnNM. 2964881 I CLAJB Page 4 of 5 CERTIFICATE OF SERVICE A copy of the foregoing has been sent via email only to the following this 14th day of September, 2023: David Fagnilli, Esq. Marshall Dennehey Warner Coleman & Goggin 127 Public Square, Suite 3510 Cleveland, ohio 44114 Email: djfagnilli@mdwcg.com Attorney for Defendants /s/ David M. Paris_______ David M. Paris, Esq. (0001358) Nurenberg, Paris, Heller & McCarthy Co., L.P.A. /s/Louie J. Cook_________ Louie J. Cook, Esq. (24101191) White & Carlson Law Firm ElectrOfoCafi led OSH^/TQ^bimill dfOaCSs/C29648 81 I CLAJB Page 5 of 5