On February 26, 2019 a
(amd) of Travis Cross
was filed
involving a dispute between
Tammy Bradford,
and
Discount Tire Co,
for PRODUCTS LIABILITY
in the District Court of Volusia County.
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Filing # E-Filed 09/28/2020 12:01:38 PM
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 AMENDED NOTICE OF TAKING VIDEOTAPED DEPOSITION OF TRAVIS
CROSS
(Amended to include Court Reporter / Videographer Information)
TO: Counsel of Record
DEPONENTS: Travis Cross
DATES/TIMES: October 27, 2020 at 1:00 P.M.
LOCATION: DoubleTree Saint Augustine Historic District
Anastasia Ballroom
116 San Marco Ave
Saint Augustine, FL 32084
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 Travis Cross will be taken by the undersigned
attorneys for Plaintiff, by agreement of the parties. Said deposition will be taken on October 27,
2020 at 1:00 P.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 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.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on 09/28/20, 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
Document Filed Date
September 28, 2020
Case Filing Date
February 26, 2019
Category
PRODUCTS LIABILITY
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Filing # E-Filed 09/28/2020 12:01:38 PM 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 AMENDED NOTICE OF TAKING VIDEOTAPED DEPOSITION OF TRAVIS CROSS (Amended to include Court Reporter / Videographer Information) TO: Counsel of Record DEPONENTS: Travis Cross DATES/TIMES: October 27, 2020 at 1:00 P.M. LOCATION: DoubleTree Saint Augustine Historic District Anastasia Ballroom 116 San Marco Ave Saint Augustine, FL 32084 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 Travis Cross will be taken by the undersigned attorneys for Plaintiff, by agreement of the parties. Said deposition will be taken on October 27, 2020 at 1:00 P.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 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. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on 09/28/20, 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