Party Discovery: Jaime Murcia Plaintiff vs. Rayfield Family Literacy Inc Defendant

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                                Filing # 79157734 E-Filed 10/10/2018 03:54:29 PM



                                                                        IN THE CIRCUIT COURT OF THE                      17TH
                                                                        JUDICIAL   CIRCUIT, IN AND                        FOR
                                                                        BROWARD COUNTY, FLORIDA


          JAIME    MURCIA,      Individually and                   as   CIVIL DIVISION
          Personal Representative of the Estate                    of
          DIANA MURCIA,                                                 CASE NO: CACE         18 000492

                    Plaintiff,
          Vv.


          RAYFIELD    FAMILY  LITERACY,   INC.
          d/b/a RAYFIELD LITERACY CENTER,

                    Defendants.
                                                               /

                             SECOND SUBPOENA DUCES TECUM FOR DEPOSITION
                                             (Via Videotape)

         TO         Luther Sneed
                    4301 NW 18" Street
                    Apt. 0312
                    Lauderhill, FL 33312


                 YOU ARE HEREBY COMMANDED to appear before a person authorized by law to take
         depositions at U.S. Legal Support, 100 NE 3“ Avenue, Suite 1050, Fort Lauderdale, FL 33301 on
         Wednesday, December 12, 2018 at_10:00 AM, for taking of your deposition in the above styled
         cause and to have with you at said time the following:

         Deponent must bring the following documents:


                1   All rules, regulations, bylaws, policies, procedures, protocols and guidelines provided to
                    you by Rayfield Family Literacy and/or available to staff, counselors, employees and other
                    contractors at Rayfield Family Literacy in effect at any time in 2016 and 2017.

                    Any agreements between you and Rayfield Literacy Center in effect in 2016.

                    Any and all documents related to services provided to you by Rayfield Family Literacy
                    including but not limited to schooling and teaching, meal services, and emergency
                    treatment protocols in 2016 and 2017.



         Ratzan Law Group, P.A.    1450 Brickell Avenue Suite 2600 Miami, Florida 33131   T: 305.374.6366   F: 305.374.6755




                *** FILED: BROWARD COUNTY. FL BRENDA D. FORMAN,                    CLERK 10/10/2018 3:54:28 PM.****
Any and all documents pertaining to benefits and/or services provided to you by Rayfield
        Family Literacy, including but not limited to equipment and other resources, uniforms,
        name badges, identification materials, billing assistance, and/or use of premises in 2016
        and 2017.

        The training materials utilized by you at Rayfield Family Literacy in 2016 and 2017.

        Any and all correspondence, emails, reports to/from Rayfield Family Literacy pertaining
        to Diana Murcia in 2016.

        Any and all emails, correspondence or other documents regarding Diana Murcia’s death in
        2016.

        If you fail to appear, you may be in contempt of Court.

        Unless you are excused by the attorney whose name appears on the bottom of this
subpoena, or the Court, you shall respond to this subpoena as directed.

                Dated this 10" of October, 2018.

                                                               FOR THE COURT


                                                               By: /s/ Evan B. Gilead
                                                               Stuart N. Ratzan
                                                               Florida Bar No.: 911445
                                                               Stuart@ratzanlawgroup.com
                                                               Stuart J. Weissman
                                                               Florida Bar No.: 57909
                                                               StuartW@ratzanlawgroup.com
                                                               Evan B. Gilead
                                                               Florida Bar No. 95971
                                                               Lvan@ratzanlawgroup.com




Attorney For: Plaintiff
RATZAN LAW GROUP, P.A.
Attorneys for Plaintiffs
1450 Brickell Avenue
Suite 2600
Miami, FL 33131
Telephone:   (305) 374-6366
Facsimile:    (305) 374-6755




   Ratzan Law Group, P.A.   1450 Brickell Avenue Suite 2600 Miami, Florida 33131   T: 305.374.6366   F: 305.374.6755