arrow left
arrow right
  • TAMMY BRADFORD, ETC. V. DISCOUNT TIRE CO, ETC. CIRCUIT CIVIL document preview
  • TAMMY BRADFORD, ETC. V. DISCOUNT TIRE CO, ETC. CIRCUIT CIVIL document preview
  • TAMMY BRADFORD, ETC. V. DISCOUNT TIRE CO, ETC. CIRCUIT CIVIL document preview
  • TAMMY BRADFORD, ETC. V. DISCOUNT TIRE CO, ETC. CIRCUIT CIVIL document preview
						
                                

Preview

Filing # E-Filed 12/22/2020 11:17:27 AM IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT, IN AND FOR VOLUSIA COUNTY, FLORIDA TAMMY BRADFORD, individually, and 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. Case No. 2019-10377 CIDL MICHELIN NORTH AMERICA, INC., a foreign corporation and DISCOUNT TIRE CO., a Florida corporation, Defendant. / DESIGNATION OF PORTIONS OF THE TRANSCRIPT AND VIDEO OF THE DEPOSITION OF MAXWELL GITTO AND CERTAIN EXHIBITS AS CONFIDENTIAL DOCUMENTS Defendant, DISCOUNT TIRE CO., by and through its undersigned counsel, and pursuant to this Court's January 21, 2020 Order on Defendant Michelin North America, Inc.'s Motion for Protective Order and the Protective Order attached thereto as Exhibit "A", hereby designates the following portions of the transcript of the December 9, 2020 Video Deposition of Maxwell Gitto, the corresponding video tape, and certain exhibits used during the deposition as confidential documents as follows: 1. Deposition Testimony of Maxwell Gitto (specific pages and lines of the transcript which, based on a good faith determination, contain confidential information): 8:23-10:10; 16:12-17:20; 22:22-23:15; 23:21-24:2. 2. Exhibits used During Deposition of Maxwell Gitto (documents previously designated as "Confidential-Subject to Protective Order"): Plaintiff's Exhibit 1 (Bates No. DT- FL/Bradford ; Plaintiff's Exhibit 3 (Bates No. DT-FL/Bradford 000060- 63). CERTIFICATE OF SERVICE I HEREBY CERTIFY that on December 22, 2020, I electronically filed the foregoing with the Clerk of the Court using the Florida Courts E-filing Portal, and served a copy by E-mail to: Skip Edward Lynch, Esq., and Bruce R. Kaster, Esq., skip @thetirelawyers.com; brk@thetirelawyers.com; josh@thetirelawyers.com; daneen@th etirelawyers.com Attorneys for Plaintiff; L&G LAW GROUP LLP, /s/ Deborah O'Brien Daly DEBORAH O'BRIEN DALY, ESQUIRE Florida Bar Number: 0580651 Email: ddaly@lgcounsel.com 2170 West State Road 434, Suite 370 Longwood, FL 32779 Telephone: (407) 788-8003 Facsimile: (407) 788-8004 Attorneys for Defendant, DISCOUNT TIRE CO. 2