On February 26, 2019 a
Exhibit,Appendix
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 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
Document Filed Date
December 22, 2020
Case Filing Date
February 26, 2019
Category
PRODUCTS LIABILITY
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