On January 17, 2019 a
NOTICE OF TAKING DEPOSITION
was filed
involving a dispute between
Phillips, Virginia,
and
Djs Root Scooter Inc,
Lambert, Donald,
for Circuit Civil 3-C
in the District Court of Marion County.
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Filing # 143523664 E-Filed 02/08/2022 03:10:22 PM
IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT
IN AND FOR MARION COUNTY, FLORIDA
CIVIL DIVISION
VIRGINIA PHILLIPS,
Plaintiff, CASE NO: 2019-CA-0142
Vv.
DONALD LAMBERT AND,
DJS ROOT SCOOTER, INC.
A Florida Corporation,
Defendants.
/
DEFENDANT’S NOTICE OF TAKING
VIRTUAL VIDEOTAPED DEPOSITION DUCES TECUM
PLEASE TAKE NOTICE that the Defendants, DONALD LAMBERT AND DJ’S ROOT
SCOOTER, INC. A Florida Corporation, by and through undersigned counsel, hereby cross-
notices the deposition by oral examination, pursuant to the Florida Rules of Civil Procedure and
the Florida Statutes, of the person named below, at the time, on the date, at the hour and at the
place indicated:
WITNESS DATE/TIME LOCATION
Owen & Associates
Records Custodian
Via Zoom Videoconference
Thursday, February 17, 2022
Conduent Payment
@ 9:30 a.m. Zoom information to be provided
Integrity Solutions
prior to deposition.
Before Owen & Associates, Court Reporters and Notary Public, or before their duly designated
representative by utilizing digital audiovisual recording equipment or any other alternative
methods of capture, for discovery purposes, for use as evidence at trial, or both, or for such other
purposes as are permitted under the applicable and governing rules. The deposition will continue
Electronically Filed Marion Case # 19CA000142AX 02/08/2022 03:10:22 PM
(00383817-1
from day to day until completed. The deponent is to have with her at her deposition a state or
military issued identification card or valid passport as well as those items listed on Exhibit A
attached hereto.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been e-served
through the Florida Courts E-filing Portal to: Scott J. Liotta, Esquire, Dan Newlin & Partners, 7335
W. Sand Lake Road, Suite 300, Orlando, Fl 32819 at liotta.pleadings@newlinlaw.com this 8th
day of February 2022.
/s/ Michael S. Rywant
Michael S. Rywant, Esq.
Florida Bar No.: 240354
Primary email:msrywant@rywantalvarez.com
Secondary: service@rywantalvarez.com
nginn@rywantalvarez.com
Anthony J. Livingston, Esquire
Florida Bar No.: 0028050
Primary email:alivingston@rywantalvarez.com
Secondary: apilcher@rywantalvarez.com
ebridgewater@rywantalvarez.com
Rywant, Alvarez, Jones, Russo & Guyton, P.A.
2440 SW 76" Street, Suite 130
Gainesville, FL 32608
(Tel) 352-333-3700 / (Fax) 352-333-3706
Attorneys for Defendants
(00383817-1
Document Filed Date
February 08, 2022
Case Filing Date
January 17, 2019
Category
Circuit Civil 3-C
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Filing # 143523664 E-Filed 02/08/2022 03:10:22 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR MARION COUNTY, FLORIDA CIVIL DIVISION VIRGINIA PHILLIPS, Plaintiff, CASE NO: 2019-CA-0142 Vv. DONALD LAMBERT AND, DJS ROOT SCOOTER, INC. A Florida Corporation, Defendants. / DEFENDANT’S NOTICE OF TAKING VIRTUAL VIDEOTAPED DEPOSITION DUCES TECUM PLEASE TAKE NOTICE that the Defendants, DONALD LAMBERT AND DJ’S ROOT SCOOTER, INC. A Florida Corporation, by and through undersigned counsel, hereby cross- notices the deposition by oral examination, pursuant to the Florida Rules of Civil Procedure and the Florida Statutes, of the person named below, at the time, on the date, at the hour and at the place indicated: WITNESS DATE/TIME LOCATION Owen & Associates Records Custodian Via Zoom Videoconference Thursday, February 17, 2022 Conduent Payment @ 9:30 a.m. Zoom information to be provided Integrity Solutions prior to deposition. Before Owen & Associates, Court Reporters and Notary Public, or before their duly designated representative by utilizing digital audiovisual recording equipment or any other alternative methods of capture, for discovery purposes, for use as evidence at trial, or both, or for such other purposes as are permitted under the applicable and governing rules. The deposition will continue Electronically Filed Marion Case # 19CA000142AX 02/08/2022 03:10:22 PM (00383817-1 from day to day until completed. The deponent is to have with her at her deposition a state or military issued identification card or valid passport as well as those items listed on Exhibit A attached hereto. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been e-served through the Florida Courts E-filing Portal to: Scott J. Liotta, Esquire, Dan Newlin & Partners, 7335 W. Sand Lake Road, Suite 300, Orlando, Fl 32819 at liotta.pleadings@newlinlaw.com this 8th day of February 2022. /s/ Michael S. Rywant Michael S. Rywant, Esq. Florida Bar No.: 240354 Primary email:msrywant@rywantalvarez.com Secondary: service@rywantalvarez.com nginn@rywantalvarez.com Anthony J. Livingston, Esquire Florida Bar No.: 0028050 Primary email:alivingston@rywantalvarez.com Secondary: apilcher@rywantalvarez.com ebridgewater@rywantalvarez.com Rywant, Alvarez, Jones, Russo & Guyton, P.A. 2440 SW 76" Street, Suite 130 Gainesville, FL 32608 (Tel) 352-333-3700 / (Fax) 352-333-3706 Attorneys for Defendants (00383817-1