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Filing # 36658465 E-Filed 01/16/2016 09:26:22 PM
IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL
CIRCUIT IN AND FOR SARASOTA COUNTY, FLORIDA
WILLIAM H. BEHRENS,
Plaintiff,
V. Case No. 2015-CA-002452-NC
BARBARA A. MORFORD,
Defendant.
/
NOTICE OF TAKING DEPOSITION
DUCES TECUM WITH SUBPOENA
TO: Vincent Gannuscio, Esq
677 N. Washington Blvd.
Sarasota, FL 34236
vg@gannusciolaw.com
PLEASE TAKE NOTICE that Plaintiff, WILLIAM H. BEHRENS, by his attorney,
Randy L. Merritt, Esq., and pursuant to Fla. R. Civ. P. 1.310(b)(6), will take the
Deposition of MATILDA DEROY, before an Official Court Reporter, or a Notary Public in
and for the State of Florida at Large, or some other officer duly authorized to take
depositions, on February 11, 2016, at 4:00 p.m., at the offices of Sclafani Williams Court
Reporters, Inc., 1800 Second Street, Suite 875, Sarasota, FL 34236, and MATILDA
DEROY is to have with her at the time of the Deposition the items listed on the
Subpoena attached.
The Deposition is being taken for the purpose of discovery or for the use of
evidence, or both, and for such other uses and purposes as are permitted under the
Florida Rules of Civil Procedure and other applicable law.
Filed 01/19/2016 09:17 AM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FLCERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of this document was
electronically filed with the Clerk of Court using the Florida E-Portal system, which will
send a notice of electronic filing to all parties of record including Vincent S. Gannuscio,
Esq., at vg@gannusciolaw.com and gannusciopleadings@qmail.com, on this LGW
day of January, 2016.
RANDY L. MERRITT, ESQ., P.A.
5409 Downham Mdws
Sarasota, FL 34235
Telephone: 941.377.9966
Email: rmerrittesq@comcast.net
Counsel for Plaintiff
sit
Randy L. Merritt, Esq.
FL Bar No. 0572055
cc: Sclafani Williams Court ReportersIN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL
CIRCUIT IN AND FOR SARASOTA COUNTY, FLORIDA
WILLIAM H. BEHRENS,
V.
Plaintiff,
Case No. 2015-CA-002452-NC
BARBARA A. MORFORD,
Defendant.
/
SUBPOENA DUCES TECUM FOR DEPOSITION
THE STATE OF FLORIDA:
TO:
MATILDA DEROY
117 ROMA ROAD
VENICE, FL 34285
YOU ARE COMMANDED to appear before a person authorized by law to take
depositions at Sclafani Williams Court Reporters, Inc., 1800 Second Street, Suite 875,
Sarasota, FL 34236, on February 11, 2016, at 4:00 p.m. for the taking of your
Deposition in this action, and to have with you at that time and place the following:
Any all Documents and / or Electronically Stored Information that
identifies, discusses, eludes to, describes or otherwise mentions WILLIAM
H. BEHRENS, (“BEHRENS”); BARBARA A. MORFORD, (“MORFORD’);
Shirley Behrens; the William H. Behrens and Barbara A. Morford
Revocabie Trust, (“Trust”); the relationship between BEHRENS and
MORFORD; and any assets or liabilities of BEHRENS, MORFORD,
Shirley Behrens, and / or the Trust during the period from December of
2011, to the date of your aforementioned Deposition:
For purposes of this Subpoena, “Document” or “documents” means all
materials, including, but not limited to, all writings and recordings,
including the originals and all non-identical copies, whether different from
the original by reason of any notation made on such copies or otherwise
(including without limitation, emails and attachments, text messages,
correspondence, memoranda, notes, diaries, minutes, _ statistics,Statements, tags, labels, invoices, brochures, periodicals, telegrams,
receipts, returns, summaries, pamphlets, books, inter-office and intra-
office communications, offers, notations of any sort of conversations,
working papers, applications, permits, file wrappers, indices, telephone
calls, meetings or printouts, teletypes, telefax, work sheets, and all drafts,
alterations, modifications, changes and amendments of any of the
foregoing), graphic or aural representations of any kind (including without
limitation, photographs, charts, microfiche, microfilm, video tape,
recordings, motion pictures, plans, drawings, and surveys).
For purposes of this Subpoena, “Electronically Stored Information” means
all materials including, but not limited to, all electronic, mechanical,
magnetic, or optical records or representations of any kind (including,
without limitation, computer files and programs, tapes, cassettes, discs,
and recordings), metadata, and information stored on a computer, laptop,
hand-held computer device, telephone, smart phone, disk, CD, DVD, and
any mechanical recording or production of any or all material.
If you fail to appear for your aforementioned Deposition, you may be in contempt
of Court. You are Subpoenaed to appear by the following attorney and unless
otherwise excused from this Subpoena by said attorney or the Court, you shall respond
to this Subpoena as directed.
WITNESS my hand and the seal of said Court on this Met day of January,
2016.
KAREN E. RUSHING
CLERK OF CIRCUIT COURT
By: J lysi™
Randy L: Merritt, Esquire
For the Clerk
RANDY L. MERRITT, ESQ., P.A.
5409 Downham Mdws
Sarasota, FL 34235
Telephone: 941.377.9966
Email: rmerrittesq@comcast.net
cc: Sclafani Williams Court Reporters
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Filing # 36658465 E-Filed 01/16/2016 09:26:22 PM IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR SARASOTA COUNTY, FLORIDA WILLIAM H. BEHRENS, Plaintiff, V. Case No. 2015-CA-002452-NC BARBARA A. MORFORD, Defendant. / NOTICE OF TAKING DEPOSITION DUCES TECUM WITH SUBPOENA TO: Vincent Gannuscio, Esq 677 N. Washington Blvd. Sarasota, FL 34236 vg@gannusciolaw.com PLEASE TAKE NOTICE that Plaintiff, WILLIAM H. BEHRENS, by his attorney, Randy L. Merritt, Esq., and pursuant to Fla. R. Civ. P. 1.310(b)(6), will take the Deposition of MATILDA DEROY, before an Official Court Reporter, or a Notary Public in and for the State of Florida at Large, or some other officer duly authorized to take depositions, on February 11, 2016, at 4:00 p.m., at the offices of Sclafani Williams Court Reporters, Inc., 1800 Second Street, Suite 875, Sarasota, FL 34236, and MATILDA DEROY is to have with her at the time of the Deposition the items listed on the Subpoena attached. The Deposition is being taken for the purpose of discovery or for the use of evidence, or both, and for such other uses and purposes as are permitted under the Florida Rules of Civil Procedure and other applicable law. Filed 01/19/2016 09:17 AM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FLCERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of this document was electronically filed with the Clerk of Court using the Florida E-Portal system, which will send a notice of electronic filing to all parties of record including Vincent S. Gannuscio, Esq., at vg@gannusciolaw.com and gannusciopleadings@qmail.com, on this LGW day of January, 2016. RANDY L. MERRITT, ESQ., P.A. 5409 Downham Mdws Sarasota, FL 34235 Telephone: 941.377.9966 Email: rmerrittesq@comcast.net Counsel for Plaintiff sit Randy L. Merritt, Esq. FL Bar No. 0572055 cc: Sclafani Williams Court ReportersIN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR SARASOTA COUNTY, FLORIDA WILLIAM H. BEHRENS, V. Plaintiff, Case No. 2015-CA-002452-NC BARBARA A. MORFORD, Defendant. / SUBPOENA DUCES TECUM FOR DEPOSITION THE STATE OF FLORIDA: TO: MATILDA DEROY 117 ROMA ROAD VENICE, FL 34285 YOU ARE COMMANDED to appear before a person authorized by law to take depositions at Sclafani Williams Court Reporters, Inc., 1800 Second Street, Suite 875, Sarasota, FL 34236, on February 11, 2016, at 4:00 p.m. for the taking of your Deposition in this action, and to have with you at that time and place the following: Any all Documents and / or Electronically Stored Information that identifies, discusses, eludes to, describes or otherwise mentions WILLIAM H. BEHRENS, (“BEHRENS”); BARBARA A. MORFORD, (“MORFORD’); Shirley Behrens; the William H. Behrens and Barbara A. Morford Revocabie Trust, (“Trust”); the relationship between BEHRENS and MORFORD; and any assets or liabilities of BEHRENS, MORFORD, Shirley Behrens, and / or the Trust during the period from December of 2011, to the date of your aforementioned Deposition: For purposes of this Subpoena, “Document” or “documents” means all materials, including, but not limited to, all writings and recordings, including the originals and all non-identical copies, whether different from the original by reason of any notation made on such copies or otherwise (including without limitation, emails and attachments, text messages, correspondence, memoranda, notes, diaries, minutes, _ statistics,Statements, tags, labels, invoices, brochures, periodicals, telegrams, receipts, returns, summaries, pamphlets, books, inter-office and intra- office communications, offers, notations of any sort of conversations, working papers, applications, permits, file wrappers, indices, telephone calls, meetings or printouts, teletypes, telefax, work sheets, and all drafts, alterations, modifications, changes and amendments of any of the foregoing), graphic or aural representations of any kind (including without limitation, photographs, charts, microfiche, microfilm, video tape, recordings, motion pictures, plans, drawings, and surveys). For purposes of this Subpoena, “Electronically Stored Information” means all materials including, but not limited to, all electronic, mechanical, magnetic, or optical records or representations of any kind (including, without limitation, computer files and programs, tapes, cassettes, discs, and recordings), metadata, and information stored on a computer, laptop, hand-held computer device, telephone, smart phone, disk, CD, DVD, and any mechanical recording or production of any or all material. If you fail to appear for your aforementioned Deposition, you may be in contempt of Court. You are Subpoenaed to appear by the following attorney and unless otherwise excused from this Subpoena by said attorney or the Court, you shall respond to this Subpoena as directed. WITNESS my hand and the seal of said Court on this Met day of January, 2016. KAREN E. RUSHING CLERK OF CIRCUIT COURT By: J lysi™ Randy L: Merritt, Esquire For the Clerk RANDY L. MERRITT, ESQ., P.A. 5409 Downham Mdws Sarasota, FL 34235 Telephone: 941.377.9966 Email: rmerrittesq@comcast.net cc: Sclafani Williams Court Reporters ~4—