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Filing # 164893337 E-Filed 01/17/2023 04:56:40 PM
IN THE CIRCUIT COURT FOR THE NINTH JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY, FLORIDA
ELEVATION DEVELOPMENT II, LLC, CASE NO.: 2021-CA-001956
a Florida limited liability company,
Plaintiff,
v.
BRONSON FAMILY LIMITED,
PARTNERSHIP, a Nevada limited
liability company, et. al.,
Defendants.
NOTICE OF TAKING DEPOSITION
DUCES TECUM OF HARRY W. COLLISON, JR.
PLEASE TAKE NOTICE that the undersigned, on behalf of Plaintiff, Elevation
Development II, LLC, will take the oral deposition duces tecum of the person named below, at the
times specified below, before an Official Court Reporter or before a Notary public, or some other
officer duly authorized by law to take deposition, of the date and times indicated below, and at the
location indicated below pursuant to Rule 1.310 Fla. R. Civ. P(b)(1).
NAME DATE and TIME LOCATION
Harry W. Collison Jr. January 20, 2023 Via Zoom
10:00 a.m. (Zoom link to be provided
under separate cover)
The deposition is being taken for the purposes of discovery, for use at trial, or for such
other purposes as are permitted under the applicable rules of Civil Procedure. The oral
examination will continue from day to day until completed.
The deponent has been requested to produce the documents described on the attached
Notice of Deposition Duces Tecum - Collison.DOCX
37911.0010
1
EXHIBIT “A”
YOU ARE REQUIRED BY LAW TO PRODUCE THE FOREGOING DOCUMENTS AT
THE TIME OF YOUR DEPOSITION. FAILURE TO DO SO MAY RESULT IN
RESETTING THE DEPOSITION AT YOUR EXPENSE AND POSSIBLE FEES AND
COSTS FOR DISRUPTION.
The examination of the deponent may continue from day to day until completed or may be
adjourned to be reconvened at such later date as may be established by those in attendance at such
deposition.
PLEASE GOVERN YOURSELF ACCORDINGLY.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on January 17, 2023, I electronically filed the foregoing
document with the Clerk of Court by using the Florida Court’s E-Filing Portal, which will send a
Notification of Electronic Filing along with a true and correct copy of the foregoing document to
Todd Norman, Esq., Shaina Stahl, Esq., Counsel for Defendant, (todd.nonnan@nclsonniullins.com,
shaina.slalil@nelsonimillins.com, sliawana.watt@nelsonmullins.com, and katlicrine.reynolds@nelsonmullins.com).
Respectfully submitted,
GREENSPOON MARDER LLP
201 East Pine Street, Suite 500
Orlando, FL 32801
Phone: 407-425-6559
Fax: 407-563-9665
E-mail: Edmund.Loos@gmlaw.com
E-mail: Patrick.Hennessey@gmlaw.com
E-mail: Chad.Tamaroff@gmlaw.com
E-mail 2: Tami.Austin@gmlaw.com
E-mail 2: Eric.Cruz@gmlaw.com
E-mail 2: Agatha.Mctier@gmlaw.com
By: /s/ Edmund O. Loos 111_
EDMUND O. LOOS, III, Esq.
Florida Bar No.: 899161
Notice of Deposition Duces Tecum - Collison.DOCX
37911.0010
2
PATRICK J. HENNESSEY JR., Esq.
Florida Bar No.: 0106964
CHAD J. TAMAROFF, ESQ.
Florida Bar No. 163368
Counsel for Plaintiff ELEVATION
DEVELOPMENT II, LLC
Notice of Deposition Duces Tecum - Collison.DOCX
37911.0010
3
EXHIBIT “A”
1. A current copy of your curriculum vitae;
2. A copy of each certification and/or degree listed or referenced in your curriculum vitae;
a. A copy of your application for each certification and/or degree listed or referenced in
your curriculum vitae, including all paperwork involved in the application process
and/or necessary for securing the specific designation;
b. A copy of each diploma listed or referenced in your curriculum vitae;
c. A copy of each educational degree listed or referenced in your curriculum vitae;
3. A copy of each report prepared by you related to this matter.
Include in this request:
a. Any and all drafts and the final reports submitted to counsel;
b. All materials and documentation relied upon or reviewed in preparation of each reports;
c. All communication with Defendants, Defendants’ counsel and/or any other person
relating to the preparation of each report;
4. A copy of any and all retainer agreements and/or contracts between you Nelson Mullins
Riley & Scarborough LLP or its attorneys related to this litigation, including but not limited
to all drafts, final agreements, notes, communication related to same;
5. A copy of any and all communication with Defendants or Defendants’ counsel in this
litigation including but not limited to emails, letters, facsimiles, memoranda, hand-written
notes, text messages, voice messages or any other form of communication;
6. A copy of any document, correspondence or material that contains or references any
opinion you may have related to this ligation or is related to any reports made by you in
connection with this litigation;
7. For each and every case in which you have been retained as an expert by the law firm of
Nelson Mullins Riley & Scarborough LLP, please provide the following:
a. Court case style to include the parties name, case number, court of jurisdiction, years
of your involvement;
b. The subject of your testimony;
c. Any and all reports or opinions issued by you in each case;
d. Your retainer agreement or contract for each matter; and
e. Copy of east style of each case listed in your Interrogatory responses;
8. All source or reference material, in any form whatsoever, including, but not limited to,
books, treatises, publications, films, studies, articles or other reference materials that you
relied upon or reviewed in connection with services rendered related to this litigation and/or
the formulation of your report in this matter;
9. All working papers, including but not limited to draft reports, memoranda, calculations,
hand-written notes or background information related to the subject matter of this
litigation;
10. All documents and communications, including but not limited to correspondence, emails,
facsimiles, file notes, hand-written notes, personnel files, disciplinary actions and any other
communications by and between you and Defendants related to your employment or
business relationship;
11. A copy of all articles, books, treatises or other authorities you authored or contributed to
whether published in print or in digital format including Internet and/or Website
publication; and
12. Any information or documentation not herein above itemized which was compiled or
obtained by you or on your behalf and which relate in any manner whatsoever to your
services rendered in connection with the Subject Property.
5
Preview
Filing # 164893337 E-Filed 01/17/2023 04:56:40 PM IN THE CIRCUIT COURT FOR THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA ELEVATION DEVELOPMENT II, LLC, CASE NO.: 2021-CA-001956 a Florida limited liability company, Plaintiff, v. BRONSON FAMILY LIMITED, PARTNERSHIP, a Nevada limited liability company, et. al., Defendants. NOTICE OF TAKING DEPOSITION DUCES TECUM OF HARRY W. COLLISON, JR. PLEASE TAKE NOTICE that the undersigned, on behalf of Plaintiff, Elevation Development II, LLC, will take the oral deposition duces tecum of the person named below, at the times specified below, before an Official Court Reporter or before a Notary public, or some other officer duly authorized by law to take deposition, of the date and times indicated below, and at the location indicated below pursuant to Rule 1.310 Fla. R. Civ. P(b)(1). NAME DATE and TIME LOCATION Harry W. Collison Jr. January 20, 2023 Via Zoom 10:00 a.m. (Zoom link to be provided under separate cover) The deposition is being taken for the purposes of discovery, for use at trial, or for such other purposes as are permitted under the applicable rules of Civil Procedure. The oral examination will continue from day to day until completed. The deponent has been requested to produce the documents described on the attached Notice of Deposition Duces Tecum - Collison.DOCX 37911.0010 1 EXHIBIT “A” YOU ARE REQUIRED BY LAW TO PRODUCE THE FOREGOING DOCUMENTS AT THE TIME OF YOUR DEPOSITION. FAILURE TO DO SO MAY RESULT IN RESETTING THE DEPOSITION AT YOUR EXPENSE AND POSSIBLE FEES AND COSTS FOR DISRUPTION. The examination of the deponent may continue from day to day until completed or may be adjourned to be reconvened at such later date as may be established by those in attendance at such deposition. PLEASE GOVERN YOURSELF ACCORDINGLY. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on January 17, 2023, I electronically filed the foregoing document with the Clerk of Court by using the Florida Court’s E-Filing Portal, which will send a Notification of Electronic Filing along with a true and correct copy of the foregoing document to Todd Norman, Esq., Shaina Stahl, Esq., Counsel for Defendant, (todd.nonnan@nclsonniullins.com, shaina.slalil@nelsonimillins.com, sliawana.watt@nelsonmullins.com, and katlicrine.reynolds@nelsonmullins.com). Respectfully submitted, GREENSPOON MARDER LLP 201 East Pine Street, Suite 500 Orlando, FL 32801 Phone: 407-425-6559 Fax: 407-563-9665 E-mail: Edmund.Loos@gmlaw.com E-mail: Patrick.Hennessey@gmlaw.com E-mail: Chad.Tamaroff@gmlaw.com E-mail 2: Tami.Austin@gmlaw.com E-mail 2: Eric.Cruz@gmlaw.com E-mail 2: Agatha.Mctier@gmlaw.com By: /s/ Edmund O. Loos 111_ EDMUND O. LOOS, III, Esq. Florida Bar No.: 899161 Notice of Deposition Duces Tecum - Collison.DOCX 37911.0010 2 PATRICK J. HENNESSEY JR., Esq. Florida Bar No.: 0106964 CHAD J. TAMAROFF, ESQ. Florida Bar No. 163368 Counsel for Plaintiff ELEVATION DEVELOPMENT II, LLC Notice of Deposition Duces Tecum - Collison.DOCX 37911.0010 3 EXHIBIT “A” 1. A current copy of your curriculum vitae; 2. A copy of each certification and/or degree listed or referenced in your curriculum vitae; a. A copy of your application for each certification and/or degree listed or referenced in your curriculum vitae, including all paperwork involved in the application process and/or necessary for securing the specific designation; b. A copy of each diploma listed or referenced in your curriculum vitae; c. A copy of each educational degree listed or referenced in your curriculum vitae; 3. A copy of each report prepared by you related to this matter. Include in this request: a. Any and all drafts and the final reports submitted to counsel; b. All materials and documentation relied upon or reviewed in preparation of each reports; c. All communication with Defendants, Defendants’ counsel and/or any other person relating to the preparation of each report; 4. A copy of any and all retainer agreements and/or contracts between you Nelson Mullins Riley & Scarborough LLP or its attorneys related to this litigation, including but not limited to all drafts, final agreements, notes, communication related to same; 5. A copy of any and all communication with Defendants or Defendants’ counsel in this litigation including but not limited to emails, letters, facsimiles, memoranda, hand-written notes, text messages, voice messages or any other form of communication; 6. A copy of any document, correspondence or material that contains or references any opinion you may have related to this ligation or is related to any reports made by you in connection with this litigation; 7. For each and every case in which you have been retained as an expert by the law firm of Nelson Mullins Riley & Scarborough LLP, please provide the following: a. Court case style to include the parties name, case number, court of jurisdiction, years of your involvement; b. The subject of your testimony; c. Any and all reports or opinions issued by you in each case; d. Your retainer agreement or contract for each matter; and e. Copy of east style of each case listed in your Interrogatory responses; 8. All source or reference material, in any form whatsoever, including, but not limited to, books, treatises, publications, films, studies, articles or other reference materials that you relied upon or reviewed in connection with services rendered related to this litigation and/or the formulation of your report in this matter; 9. All working papers, including but not limited to draft reports, memoranda, calculations, hand-written notes or background information related to the subject matter of this litigation; 10. All documents and communications, including but not limited to correspondence, emails, facsimiles, file notes, hand-written notes, personnel files, disciplinary actions and any other communications by and between you and Defendants related to your employment or business relationship; 11. A copy of all articles, books, treatises or other authorities you authored or contributed to whether published in print or in digital format including Internet and/or Website publication; and 12. Any information or documentation not herein above itemized which was compiled or obtained by you or on your behalf and which relate in any manner whatsoever to your services rendered in connection with the Subject Property. 5