Document for TAMMY BRADFORD, ETC. V. DISCOUNT TIRE CO, ETC.

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                                Filing #               E-Filed 02/04/2022 01:02:33 PM



                                                        IN THE CIRCUIT COURT OF THE SEVENTH
                                                        JUDICIAL CIRCUIT IN AND FOR VOLUSIA
                                                        COUNTY, FLORIDA

                                                        CASE NO.: 2019 10377 CIDL

           TAMMY BRADFORD, as Personal
           Representative of the Estate of MICHAEL
           BLAZE BRADFORD, Deceased; and as
           Personal Representative of the Estate of
           WARREN MICHAEL BRADFORD,
           Deceased,

                  Plaintiff,
           vs.


           MICHELIN NORTH AMERICA, INC.,
           a foreign corporation, and DISCOUNT TIRE
           CO., a Florida corporation,

                  Defendants.


                      CROSS-NOTICE OF TAKING VIDEOTAPED DEPOSITION

                  YOU ARE HEREBY NOTIFIED that the Defendant, DISCOUNT TIRE CO., by and

           through its undersigned counsel, in the above-styled cause will take the videotaped deposition by

           oral examination for purposes of discovery and for use as evidence in said cause, or both, of




                    WITNESS                     DATE & TIME                         LOCATION

                  JAMES 1PSER                   February 17, 2022                    Via Prevail
                                                  9:00 AM EST                         (Virtual)



           upon oral examination before Prevail, Notary Public in and for the State of Florida at Large, or

           some other officer duly authorized by law to take depositions. The deposition will continue from

           day to day until completed. The deposition is being taken for the purposes as are permitted

           under the applicable and governing rules, pursuant to Florida Rules of Civil Procedure.
                               CERTIFICATE OF SERVICE

       WE HEREBY CERTIFY that a true and correct copy of the foregoing has been served

via email this 4th day of February, 2022, to Skip Edward Lynch, Esq. and Bruce R. Kaster, Esq.,

Kaster, Lynch Farrar & Ball, LLP, 125 N.E. 1st Avenue, Suite 3, Ocala, FL 34470,

Skip @thetirelawyers.com;       daneen@thetirelawyers.com;         Jessica@thetirelawyers.com;

brk@thetirelawyers.com; josh @thetirelawyers.com.


                                           QUINTAIROS, PRIETO, WOOD & BOYER, P.A
                                           Attorneys for Discount Tire Company
                                           2400 East Commercial Blvd., Ste. 520
                                           Fort Lauderdale, FL 33308
                                           Telephone:     (954) 523-7008
                                           Facsimile:     (954) 523-7009
                                           dtarlow.pleadings@qpwblaw.com


                                           BY:      /s/ David M. Tarlow
                                                   DAVID M. TARLOW
                                                   Florida Bar No. 893684




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