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 # 180429131 E-Filed 08/24/2023 12:15:15 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 SECOND AMENDED NOTICE OF TAKING
VIDEO-RECORDED DEPOSITION DUCES TECUM
PLEASE TAKE NOTICE that the undersigned attorney for Plaintiff, BARBARA
GONZALEZ, will take the VIDEO-RECORDED depositions 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 individuals listed below at the times, date, and location indicated below:
NAME DATE LOCATION
8350 Riverwalk Park Boulevard
George Markovich, M.D. Monday, October 23, 2023
Suite 1
*TO BE PRODUCED TIME: 10:00 a.m. Eastern Fort Myers, FL 33919
This deposition shall be taken before an associate or deputy court reporter and videographer
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.
This deposition shall continue until completed. Any cancellation and /or rescheduling of said
1
deposition must be confirmed in writing.
Said deponent is to have with him at the time and place aforesaid the following documents:
1 A current copy of his Curriculum Vitae.
2. All documents reviewed by you in the formulation of your opinion herein.
A copy of your statement for service rendered herein.
A list of cases in which you have previously testified either by deposition and/or by trial.
A copy of any reports, or similar documents, setting forth your opinion herein.
A copy of all notes, outlines, or similar writing prepared by you in the formulation of you
opinion herein.
A copy of any contract, or similar agreement, between you, those in privity with you, and
Defendant or Defendants’ counsel, herein relating to services being provided by you.
A copy of those portions of all texts, periodicals, or similar matters reviewed by you in
the formulation of your opinion herein.
9. A list of those attorney who have previously retained you as an expert.
10. A list of those attorneys whose clients you have previously testified against.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the forgoing has been furnished this 24" day of
August, 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 STEPHANIE B. GLICKMAN, ESQUIRE at sbg@kubickidraper.com
(Counsel for Michael G. Edwards and HHS Environmental Services, LLC); and to JULIE A.
CAMPBELL, ESQUIRE and BRITANY 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
3
Document Filed Date
August 24, 2023
Case Filing Date
June 03, 135
Category
Other - Matters not within the Other Negligence Subcategories
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Filing # 180429131 E-Filed 08/24/2023 12:15:15 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 SECOND AMENDED NOTICE OF TAKING VIDEO-RECORDED DEPOSITION DUCES TECUM PLEASE TAKE NOTICE that the undersigned attorney for Plaintiff, BARBARA GONZALEZ, will take the VIDEO-RECORDED depositions 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 individuals listed below at the times, date, and location indicated below: NAME DATE LOCATION 8350 Riverwalk Park Boulevard George Markovich, M.D. Monday, October 23, 2023 Suite 1 *TO BE PRODUCED TIME: 10:00 a.m. Eastern Fort Myers, FL 33919 This deposition shall be taken before an associate or deputy court reporter and videographer 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. This deposition shall continue until completed. Any cancellation and /or rescheduling of said 1 deposition must be confirmed in writing. Said deponent is to have with him at the time and place aforesaid the following documents: 1 A current copy of his Curriculum Vitae. 2. All documents reviewed by you in the formulation of your opinion herein. A copy of your statement for service rendered herein. A list of cases in which you have previously testified either by deposition and/or by trial. A copy of any reports, or similar documents, setting forth your opinion herein. A copy of all notes, outlines, or similar writing prepared by you in the formulation of you opinion herein. A copy of any contract, or similar agreement, between you, those in privity with you, and Defendant or Defendants’ counsel, herein relating to services being provided by you. A copy of those portions of all texts, periodicals, or similar matters reviewed by you in the formulation of your opinion herein. 9. A list of those attorney who have previously retained you as an expert. 10. A list of those attorneys whose clients you have previously testified against. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the forgoing has been furnished this 24" day of August, 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 STEPHANIE B. GLICKMAN, ESQUIRE at sbg@kubickidraper.com (Counsel for Michael G. Edwards and HHS Environmental Services, LLC); and to JULIE A. CAMPBELL, ESQUIRE and BRITANY 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 3