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Filing # 191987687 E-Filed 02/14/2024 05:22:58 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY, FLORIDA
ASBEL ALEXANDER LLERENA CASE NO.: 2020 CA 002872 AN
-v-
ADRIAN RODRIGUEZ CHAVEZ AND
GRANNY'S GARDEN II, INC.
/
NOTICE OF TAKING DEPOSITION DUCES TECUM
OF EXPERT, Dr. Marc D. Kaye
PLEASE TAKE NOTICE that the oral deposition of Dr. Marc D. Kaye will be taken by
Plaintiff on February 28, 2024 at 10:00 AM to be held via Zoom Video.
The deposition will be taken before US Legal Support, certified court reporters, or their
designee, who is not of counsel to the parties or interested in the events of the cause.
Please take further notice that this Notice shall act as a subpoena compelling the attendance
of Deponent at the deposition. Pursuant to the Florida Rules of Civil Procedure, the witness, Dr. Marc
D. Kaye, shall appear and produce, at the commencement of the taking of the deposition, the items
described in Schedule “A” attached hereto and by reference made a part hereof. This deposition is
being taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted
under the Florida Rules of Civil Procedure.
Please also take further notice that this deposition will continue from day to day until
completed. You are hereby invited to attend and cross-examine the witness.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on February 14, 2024, I electronically filed the foregoing with
the Clerk of the Courts by using the Florida Courts eFiling Portal. I further certify that Pursuant to
Rule 2.516(b)(1) I forwarded the foregoing this same day via email designation to: Gary Lewis,
Esquire, Cole, Scott & Kissane, at scott.shelton@csklegal.com; gary.lewis@csklegal.com;
sandra.mcintosh@csklegal.com.
/s/ Melissa Alzate
Melissa Alzate, Esquire
FBN 1013530
Morgan & Morgan Orlando P.A.
198 Broadway Avenue
Kissimmee, Florida 34741
Telephone: (407) 452-1597
Facsimile: (407) 452-1623
Primary Email: MAlzate@forthepeople.com
Secondary Email: MCoriano-Lopez@forthepeople.com
Tertiary Email: VPagan @forthepeople.com
Attorney for Plaintiff
SCHEDULE “A”
1. A copy of your current curriculum vitae.
2. Any and all reports, charts, notes, memoranda, outlines, chronologies, evaluations,
correspondence, summaries, depositions, medical records, laboratory data, laboratory
results, x-rays, and all tests, articles, treatises, recordings, data, papers or statistics that you
used in the formulation of your opinion.
3. Any and all graphs, displays, tables, etc. that support your opinions or that you will rely
upon trial.
4. Any and all photographs and videotapes viewed by you in connection with this case.
5. Copies of all published articles of others on which you have relied in formulating your
opinions in this case.
6. Copies of any transcripts of expert testimony given by you in other cases.
7. Copies of any reports prepared by you and furnished to the Defendant or their attorneys.
8. Copies of any and all notes (handwritten or otherwise), calculations, tape recording or other
data prepared by you during the course of your review or as a part of your evaluation or
formulation of opinions in connection with this case.
9. Office records indicating the amount of time you have spent and hourly charges incurred
in connection with this case.
10. Reports of other experts which you have read in formulating any opinions in connection
with the case.
11. Any memoranda or correspondence reviewed by you which was prepared by the Defendant's
attorney or staff.
12. Any other document or writing of any kind of description which you have reviewed in
formulating your opinion or opinions in connection with this case.
13. Statement of the percentage of your income earned by serving as an expert in litigation
matters.
14. A list of cases, including the names and address of the Plaintiff's and Defendant's attorneys,
in which you gave either deposition or courtroom testimony from to the present.
15. Copies of material you have provided to attorneys for the Defendant regarding your
opinions in this case.
Preview
Filing # 191987687 E-Filed 02/14/2024 05:22:58 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA ASBEL ALEXANDER LLERENA CASE NO.: 2020 CA 002872 AN -v- ADRIAN RODRIGUEZ CHAVEZ AND GRANNY'S GARDEN II, INC. / NOTICE OF TAKING DEPOSITION DUCES TECUM OF EXPERT, Dr. Marc D. Kaye PLEASE TAKE NOTICE that the oral deposition of Dr. Marc D. Kaye will be taken by Plaintiff on February 28, 2024 at 10:00 AM to be held via Zoom Video. The deposition will be taken before US Legal Support, certified court reporters, or their designee, who is not of counsel to the parties or interested in the events of the cause. Please take further notice that this Notice shall act as a subpoena compelling the attendance of Deponent at the deposition. Pursuant to the Florida Rules of Civil Procedure, the witness, Dr. Marc D. Kaye, shall appear and produce, at the commencement of the taking of the deposition, the items described in Schedule “A” attached hereto and by reference made a part hereof. This deposition is being taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted under the Florida Rules of Civil Procedure. Please also take further notice that this deposition will continue from day to day until completed. You are hereby invited to attend and cross-examine the witness. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on February 14, 2024, I electronically filed the foregoing with the Clerk of the Courts by using the Florida Courts eFiling Portal. I further certify that Pursuant to Rule 2.516(b)(1) I forwarded the foregoing this same day via email designation to: Gary Lewis, Esquire, Cole, Scott & Kissane, at scott.shelton@csklegal.com; gary.lewis@csklegal.com; sandra.mcintosh@csklegal.com. /s/ Melissa Alzate Melissa Alzate, Esquire FBN 1013530 Morgan & Morgan Orlando P.A. 198 Broadway Avenue Kissimmee, Florida 34741 Telephone: (407) 452-1597 Facsimile: (407) 452-1623 Primary Email: MAlzate@forthepeople.com Secondary Email: MCoriano-Lopez@forthepeople.com Tertiary Email: VPagan @forthepeople.com Attorney for Plaintiff SCHEDULE “A” 1. A copy of your current curriculum vitae. 2. Any and all reports, charts, notes, memoranda, outlines, chronologies, evaluations, correspondence, summaries, depositions, medical records, laboratory data, laboratory results, x-rays, and all tests, articles, treatises, recordings, data, papers or statistics that you used in the formulation of your opinion. 3. Any and all graphs, displays, tables, etc. that support your opinions or that you will rely upon trial. 4. Any and all photographs and videotapes viewed by you in connection with this case. 5. Copies of all published articles of others on which you have relied in formulating your opinions in this case. 6. Copies of any transcripts of expert testimony given by you in other cases. 7. Copies of any reports prepared by you and furnished to the Defendant or their attorneys. 8. Copies of any and all notes (handwritten or otherwise), calculations, tape recording or other data prepared by you during the course of your review or as a part of your evaluation or formulation of opinions in connection with this case. 9. Office records indicating the amount of time you have spent and hourly charges incurred in connection with this case. 10. Reports of other experts which you have read in formulating any opinions in connection with the case. 11. Any memoranda or correspondence reviewed by you which was prepared by the Defendant's attorney or staff. 12. Any other document or writing of any kind of description which you have reviewed in formulating your opinion or opinions in connection with this case. 13. Statement of the percentage of your income earned by serving as an expert in litigation matters. 14. A list of cases, including the names and address of the Plaintiff's and Defendant's attorneys, in which you gave either deposition or courtroom testimony from to the present. 15. Copies of material you have provided to attorneys for the Defendant regarding your opinions in this case.