On February 26, 2019 a
(2nd amd zoom) Dr John Baldwin Chief Product and Technology Strategist
was filed
involving a dispute between
Tammy Bradford,
and
Discount Tire Co,
for PRODUCTS LIABILITY
in the District Court of Volusia County.
Preview
Filing # E-Filed 01/14/2021 11:59:00 AM
IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT IN AND FOR
VOLUSIA COUNTY, FLORIDA
TAMMY BRADFORD,
as Personal Representative of the Estate
of MICHAEL BLAZE BRADFORD, deceased; CASE NO.: 2019 10377 CIDL
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.
/
PLAINTIFF'S SECOND AMENDED NOTICE OF TAKING VIDEOTAPED
DEPOSITION OF DISCOUNT TIRE CO.'S CORPORATE REPRESENTATIVE
(Amended as to Date and Time)
TO: Counsel of Record
DEPONENTS: Dr. John Baldwin, Chief Product and Technology Strategist
DATES/TIMES: February 2, 2021 at 11:00 A.M. EST
LOCATION: Remotely via Zoom
COURT REPORTER/
VIDEOGRAPHER
INFORMATION: U.S. Legal Support
1515 East Silver Springs Blvd Suite 207
Ocala, Florida 34470
Please take Notice that the deposition of John Baldwin related to topics identified in
Exhibit A attached hereto, will be taken by the undersigned attorneys for Plaintiff, by agreement
of the parties. Said deposition will be taken on Tuesday, February 2, 2021 at 11:00 A.M. before
a certified Court Reporter/Videographer, or some other office duly authorized by law to take
depositions. This deposition is being taken for purposes of discovery, for use at trial, and for such
1
other purposes as are permitted under applicable law. This deposition will continue day to day
until completed. You are invited to attend and cross-examine.
2
Exhibit A
1. Discount Tire's corporate policies, procedures, and training concerning inspection,
installation, and service of tires 10 years of age or older.
2. When and why Discount Tire implemented policies, procedures and training concerning
inspection, installation and service of tires 10 years of age or older.
3. How such policies, procedures and training concerning inspection, installation and service
of tires 10 years of age or older were implemented and/or communicated to all Discount
Tire employees and all training programs related to said policies.
4. The documents produced by Discount Tire which reference the policies, procedures and
training that concern service of tires 10 years of age or older.
5. The training and employee files of:
a. Clarence Gooden
b. Todd Seiler
c. Maxwell Gitto
d. Ronald Ayers
e. Travis Victor Cross
6. Any and all research and testing done by Discount Tire in relation to its policies regarding
not servicing tires 10 years of age or older.
7. Any and all testing, documents, industry literature materials done by others in relation to
Discount Tire's policies regarding not servicing tires 10 years of age or older.
8. Discount Tire's knowledge about any dangers or risks of harm associated with tires 10
years of age or older, including documents and/or testing to support such dangers or risks
of harm.
9. Industry standards known to Discount Tire relating to inspection, installation, or service of
tires 10 years of age or older.
10. The process by which Discount Tire employees determine the age of a customer's tire.
11. The process by which Discount Tire employees record the age of a customer's tire.
12. The process by which Discount Tire informs and/or warns the customer of tires 10 years
of age or older.
13. Discount Tire corporate policies and procedures concerning customer warnings related to
tires 10 years of age or older.
3
14. Any information, advice, or warnings that Discount Tire trains and/or expects its
employees to give to customers regarding tires 10 years of age or older on the customers'
vehicles at the time of service of Michael Bradford's vehicle.
4
Exhibit B
Any and all documents reviewed in preparation for said deposition.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on 1/14/2021, the foregoing was electronically filed with the Clerk
of Court by using the Florida Courts e-Filing Portal and served on all parties by the e-portal.
Respectfully submitted,
KASTER, LYNCH, FARRAR & BALL, LLP
BY: /s/Skip Edward Lynch
Skip Edward Lynch
Florida Bar No. 0021085
Skip@thetirelawyers.com
josh@thetirelawyers.com
Jessica@thetirelawyers.com
Bruce R. Kaster
Florida Bar No. 200271
brk@thetirelawyers.com
daneen@thetirelawyers.com
125 N.E. 1st Avenue, Suite 3
Ocala, FL 34470
Phone: 352-622-1600
Fax: 352-622-1611
ATTORNEYS FOR PLAINTIFF
6
Document Filed Date
January 14, 2021
Case Filing Date
February 26, 2019
Category
PRODUCTS LIABILITY
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing # E-Filed 01/14/2021 11:59:00 AM IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT IN AND FOR VOLUSIA COUNTY, FLORIDA TAMMY BRADFORD, as Personal Representative of the Estate of MICHAEL BLAZE BRADFORD, deceased; CASE NO.: 2019 10377 CIDL 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. / PLAINTIFF'S SECOND AMENDED NOTICE OF TAKING VIDEOTAPED DEPOSITION OF DISCOUNT TIRE CO.'S CORPORATE REPRESENTATIVE (Amended as to Date and Time) TO: Counsel of Record DEPONENTS: Dr. John Baldwin, Chief Product and Technology Strategist DATES/TIMES: February 2, 2021 at 11:00 A.M. EST LOCATION: Remotely via Zoom COURT REPORTER/ VIDEOGRAPHER INFORMATION: U.S. Legal Support 1515 East Silver Springs Blvd Suite 207 Ocala, Florida 34470 Please take Notice that the deposition of John Baldwin related to topics identified in Exhibit A attached hereto, will be taken by the undersigned attorneys for Plaintiff, by agreement of the parties. Said deposition will be taken on Tuesday, February 2, 2021 at 11:00 A.M. before a certified Court Reporter/Videographer, or some other office duly authorized by law to take depositions. This deposition is being taken for purposes of discovery, for use at trial, and for such 1 other purposes as are permitted under applicable law. This deposition will continue day to day until completed. You are invited to attend and cross-examine. 2 Exhibit A 1. Discount Tire's corporate policies, procedures, and training concerning inspection, installation, and service of tires 10 years of age or older. 2. When and why Discount Tire implemented policies, procedures and training concerning inspection, installation and service of tires 10 years of age or older. 3. How such policies, procedures and training concerning inspection, installation and service of tires 10 years of age or older were implemented and/or communicated to all Discount Tire employees and all training programs related to said policies. 4. The documents produced by Discount Tire which reference the policies, procedures and training that concern service of tires 10 years of age or older. 5. The training and employee files of: a. Clarence Gooden b. Todd Seiler c. Maxwell Gitto d. Ronald Ayers e. Travis Victor Cross 6. Any and all research and testing done by Discount Tire in relation to its policies regarding not servicing tires 10 years of age or older. 7. Any and all testing, documents, industry literature materials done by others in relation to Discount Tire's policies regarding not servicing tires 10 years of age or older. 8. Discount Tire's knowledge about any dangers or risks of harm associated with tires 10 years of age or older, including documents and/or testing to support such dangers or risks of harm. 9. Industry standards known to Discount Tire relating to inspection, installation, or service of tires 10 years of age or older. 10. The process by which Discount Tire employees determine the age of a customer's tire. 11. The process by which Discount Tire employees record the age of a customer's tire. 12. The process by which Discount Tire informs and/or warns the customer of tires 10 years of age or older. 13. Discount Tire corporate policies and procedures concerning customer warnings related to tires 10 years of age or older. 3 14. Any information, advice, or warnings that Discount Tire trains and/or expects its employees to give to customers regarding tires 10 years of age or older on the customers' vehicles at the time of service of Michael Bradford's vehicle. 4 Exhibit B Any and all documents reviewed in preparation for said deposition. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on 1/14/2021, the foregoing was electronically filed with the Clerk of Court by using the Florida Courts e-Filing Portal and served on all parties by the e-portal. Respectfully submitted, KASTER, LYNCH, FARRAR & BALL, LLP BY: /s/Skip Edward Lynch Skip Edward Lynch Florida Bar No. 0021085 Skip@thetirelawyers.com josh@thetirelawyers.com Jessica@thetirelawyers.com Bruce R. Kaster Florida Bar No. 200271 brk@thetirelawyers.com daneen@thetirelawyers.com 125 N.E. 1st Avenue, Suite 3 Ocala, FL 34470 Phone: 352-622-1600 Fax: 352-622-1611 ATTORNEYS FOR PLAINTIFF 6