On December 21, 2017 a
Party Discovery
was filed
involving a dispute between
Graziano, Anthony W,
and
Johnston, Kaylin I,
for Auto Negligence
in the District Court of Collier County.
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Filing # 69545348 E-Filed 03/20/2018 03:21:41 PM
0414803320.1 BMC
Total Pages: 1
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR COLLIER COUNTY, FLORIDA
CIVIL DIVISION
ANTHONY W. GRAZIANO, CASE NO.
2017-CA-002200
PLAINTIFF,
VS.
KAYLIN I. JOHNSTON,
DEFENDANT.
DEFENDANTS NOTICE OF TAKING DEPOSITION
AND REQUEST FOR PRODUCTION
(If an Interpreter is necessary, please advise the undersigned.)
PLEASE TAKE NOTICE that the undersigned attorney will take the deposition of:
NAME: ANTHONY GRAZIANO
(Pursuant to Florida Rules of Civil Procedure 1.310(b)(5) and 1.350, Defendant
requests Plaintiff to produce, at the time and place of this deposition for
inspection and/or copying, your driver's license, any and all original photographs
pertinent to any issues in this lawsuit, and a copy of any health insurance cards;
including but not limited to Medicare, Medicare Advantage and/or Medicaid.)
DATE: April 23, 2018
TIME: 12:00 p.m.
PLACE: U.S. LEGAL SUPPORT
5644 Tavilla Circle, Suite 101
Naples, FL 34110
upon oral examination, before U.S. Legal Support, Telephone: 239-561-3526, a Notary Public in
and for the State of Florida at Large, or some other officer duly authorized by law to take
depositions. The deposition will continue from day to day until completed. The deposition is
being taken for the purpose of discovery (for use at trial) or both of the foregoing, or for such
other purposes as are permitted under the applicable and governing rules, pursuant to Florida
Rules of Civil Procedure.
If you are a person with a disability who needs any accommodation in order to participate
in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance.
FILED: COLLIER COUNTY, DWIGHT E. BROCK, CLERK, 03/20/2018 04:15:55 PMCASE NO. 2017-CA-002200
Please contact the attorney at the address and phone number listed below within two (2) working
days of your receipt of this Notice; if you are hearing or voice impaired, call 711.
THEREBY CERTIFY that onthe 20th day of March , 2018,
pursuant to Administrative Order No. AOSC13-49, a copy of the foregoing Notice of Taking
Deposition and Request for Production has been electronically filed and served using the Florida
Courts E-Filing Portal to:
Attorney for Plaintiff
Alexander Billias, Esquire
Morgan & Morgan
3360 Pine Ridge Road, Suite 203
Naples, FL 34109
abservice@forthepeople.com
kcowhig@forthepeople.com
LAW OFFICES OF ROBERT J. SMITH
12751 New Brittany Boulevard, Suite 403
Ft. Myers, FL 33907-3694
Telephone: (239) 334-2351
Toll Free: (877) 431-2896 Ext 3342351
Attorney Direct: (239) 334-2069
Fax: (866) 303-4759
By: fax. Signed
JOSEPH DERNBACH
FL Bar No. 103274
Attorney for Defendant
KAYLIN I. JOHNSTON
PRINCIPAL E-MAIL ADDRESS:
FTMYERSLEGAL@ALLSTATE.COM
Personal E-mail Address
(NOT for Service of Pleadings and Documents):
Joseph.Dernbach@allstate.com
Ct: U.S. Legal Support
Document Filed Date
March 20, 2018
Case Filing Date
December 21, 2017
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Filing # 69545348 E-Filed 03/20/2018 03:21:41 PM 0414803320.1 BMC Total Pages: 1 IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA CIVIL DIVISION ANTHONY W. GRAZIANO, CASE NO. 2017-CA-002200 PLAINTIFF, VS. KAYLIN I. JOHNSTON, DEFENDANT. DEFENDANTS NOTICE OF TAKING DEPOSITION AND REQUEST FOR PRODUCTION (If an Interpreter is necessary, please advise the undersigned.) PLEASE TAKE NOTICE that the undersigned attorney will take the deposition of: NAME: ANTHONY GRAZIANO (Pursuant to Florida Rules of Civil Procedure 1.310(b)(5) and 1.350, Defendant requests Plaintiff to produce, at the time and place of this deposition for inspection and/or copying, your driver's license, any and all original photographs pertinent to any issues in this lawsuit, and a copy of any health insurance cards; including but not limited to Medicare, Medicare Advantage and/or Medicaid.) DATE: April 23, 2018 TIME: 12:00 p.m. PLACE: U.S. LEGAL SUPPORT 5644 Tavilla Circle, Suite 101 Naples, FL 34110 upon oral examination, before U.S. Legal Support, Telephone: 239-561-3526, a Notary Public in and for the State of Florida at Large, or some other officer duly authorized by law to take depositions. The deposition will continue from day to day until completed. The deposition is being taken for the purpose of discovery (for use at trial) or both of the foregoing, or for such other purposes as are permitted under the applicable and governing rules, pursuant to Florida Rules of Civil Procedure. If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. FILED: COLLIER COUNTY, DWIGHT E. BROCK, CLERK, 03/20/2018 04:15:55 PMCASE NO. 2017-CA-002200 Please contact the attorney at the address and phone number listed below within two (2) working days of your receipt of this Notice; if you are hearing or voice impaired, call 711. THEREBY CERTIFY that onthe 20th day of March , 2018, pursuant to Administrative Order No. AOSC13-49, a copy of the foregoing Notice of Taking Deposition and Request for Production has been electronically filed and served using the Florida Courts E-Filing Portal to: Attorney for Plaintiff Alexander Billias, Esquire Morgan & Morgan 3360 Pine Ridge Road, Suite 203 Naples, FL 34109 abservice@forthepeople.com kcowhig@forthepeople.com LAW OFFICES OF ROBERT J. SMITH 12751 New Brittany Boulevard, Suite 403 Ft. Myers, FL 33907-3694 Telephone: (239) 334-2351 Toll Free: (877) 431-2896 Ext 3342351 Attorney Direct: (239) 334-2069 Fax: (866) 303-4759 By: fax. Signed JOSEPH DERNBACH FL Bar No. 103274 Attorney for Defendant KAYLIN I. JOHNSTON PRINCIPAL E-MAIL ADDRESS: FTMYERSLEGAL@ALLSTATE.COM Personal E-mail Address (NOT for Service of Pleadings and Documents): Joseph.Dernbach@allstate.com Ct: U.S. Legal Support