On June 03, 135 a
Party Discovery
was filed
involving a dispute between
Gonzalez, Barbara,
and
Edwards, Michael G,
Hhs Environmental Services, Llc,
for Other - Matters not within the Other Negligence Subcategories
in the District Court of Charlotte County.
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Filing # 185075837 E-Filed 10/30/2023 03:58:17 PM
IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIRCUIT CIVIL DIVISION
BARBARA GONZALEZ
Plaintiff,
CASE NO.: 21000968CA.
vs.
MICHAEL G. EDWARDS and
HHS ENVIRONMENTAL SERVICES, LLC,
Defendants.
/
PLAINTIFF’S NOTICE OF CANCELLATION
PLEASE TAKE NOTICE that the undersigned attorney for Plaintiff, BARBARA
GONZALEZ, HEREBY CANCELS the VIDEO-RECORDED deposition by oral examination
for the purpose of discovery or evidence or both, pursuant to the Florida Rules of Civil Procedure
and the Florida Statutes, of the individual listed below at the time, date, and location indicated
below:
NAME DATE LOCATION
DIANE CARBERRY VIA ZOOM
October 31, 2023
(Facilities Manager)
9:00 am Eastern
KAREN MITCHELL October 31, 2023 Via Zoom
(Human Resources Manager)
11:00 a.m. Eastern
(Link to be provided)
To be produced
This deposition shall be taken before an associate or deputy court reporter before their duly
designated representative, who is not of counsel to the parties or interested in the events of the cause.
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 Rule of Civil Procedure.
1
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the forgoing has been furnished this 18" day of
October, 2023, by electronic mail to the following designated services e-mail address(es):
FRANCESCA IPPOLITO-CRAVEN, ESQUIRE at fic@kubickidraper.com; fic-
kd@kubickidraper.com and JESSICA M. DEL SOL, ESQUIRE at jmd@kubickidraper.com
(Counsel for Michael G. Edwards and HHS Environmental Services, LLC); and to JULIE A.
CAMPBELL, ESQUIRE and BRITTANY A PEREZ, ESQUIRE at
NAPertpleadings@wickersmith.com (counsel for Bayfront Health Port Charlotte).
For the Clerk of the Court
/s/ Helen Stratigakos, Esq.
HELEN STRATIGAKOS, ESQ.
Florida Bar No.: 0893633
412 East Madison Street, Suite 814
Tampa, Florida 33606
(P): (813) 226-0067
(F): (813) 259-2505
helen@stratigakoslaw.com
admin@stratigakoslaw.com
ATTORNEY FOR PLAINTIFF
/s/ Michael J. Rossi, Esq.
MICHAEL J. ROSSI, ESQ.
Michael J. Rossi, P.A.
Florida Bar No.: 0868000
115 South Albany Ave
Tampa, FL 33606
(P): (813) 253-3351
Michael@michaelrossilaw.com
Document Filed Date
October 30, 2023
Case Filing Date
June 03, 135
Category
Other - Matters not within the Other Negligence Subcategories
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Filing # 185075837 E-Filed 10/30/2023 03:58:17 PM IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIRCUIT CIVIL DIVISION BARBARA GONZALEZ Plaintiff, CASE NO.: 21000968CA. vs. MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES, LLC, Defendants. / PLAINTIFF’S NOTICE OF CANCELLATION PLEASE TAKE NOTICE that the undersigned attorney for Plaintiff, BARBARA GONZALEZ, HEREBY CANCELS the VIDEO-RECORDED deposition by oral examination for the purpose of discovery or evidence or both, pursuant to the Florida Rules of Civil Procedure and the Florida Statutes, of the individual listed below at the time, date, and location indicated below: NAME DATE LOCATION DIANE CARBERRY VIA ZOOM October 31, 2023 (Facilities Manager) 9:00 am Eastern KAREN MITCHELL October 31, 2023 Via Zoom (Human Resources Manager) 11:00 a.m. Eastern (Link to be provided) To be produced This deposition shall be taken before an associate or deputy court reporter before their duly designated representative, who is not of counsel to the parties or interested in the events of the cause. 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 Rule of Civil Procedure. 1 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the forgoing has been furnished this 18" day of October, 2023, by electronic mail to the following designated services e-mail address(es): FRANCESCA IPPOLITO-CRAVEN, ESQUIRE at fic@kubickidraper.com; fic- kd@kubickidraper.com and JESSICA M. DEL SOL, ESQUIRE at jmd@kubickidraper.com (Counsel for Michael G. Edwards and HHS Environmental Services, LLC); and to JULIE A. CAMPBELL, ESQUIRE and BRITTANY A PEREZ, ESQUIRE at NAPertpleadings@wickersmith.com (counsel for Bayfront Health Port Charlotte). For the Clerk of the Court /s/ Helen Stratigakos, Esq. HELEN STRATIGAKOS, ESQ. Florida Bar No.: 0893633 412 East Madison Street, Suite 814 Tampa, Florida 33606 (P): (813) 226-0067 (F): (813) 259-2505 helen@stratigakoslaw.com admin@stratigakoslaw.com ATTORNEY FOR PLAINTIFF /s/ Michael J. Rossi, Esq. MICHAEL J. ROSSI, ESQ. Michael J. Rossi, P.A. Florida Bar No.: 0868000 115 South Albany Ave Tampa, FL 33606 (P): (813) 253-3351 Michael@michaelrossilaw.com