On August 27, 2018 a
Party Discovery
was filed
involving a dispute between
and
Keller, Edgar Junior Jr,
in the District Court of Charlotte County.
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Filing # 96028772 E-Filed 09/20/2019 10:29:29 AM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA CRIMINAL ACTION
STATE OF FLORIDA.
Plaintiff.
v. CASENO. — 18-CF-001881
EDGAR JUNIOR KELLER, JR.,
Defendant,
/
MOTION FOR DEPOSITION FEES FOR EXPERT WITNESS
FOR INDIGENT DEFENDANT
COMES NOW the undersigned, BRITTNEY A. DAVIS, and hereby files this Motion for Deposition
Fees for Expert Witness for Indigent Defendant, and for good cause states the following:
1. The State Attorney lists Dr. Francesca M. Swartz, c/o Orthopedic Specialists, 2531 Cleveland Avenue,
Ste. 1, Fort Myers, Florida 33901 as an expert witness in the above-referenced case. The Defendant is
charged with DUI- Serious Bodily Injury, and the taking of Dr. Swartz’s deposition is necessary to his
case.
2. The Defendant was declared indigent for due process costs, depositions, and private investigator by
court order on August 1, 2019.
WHEREFORE, the Defendant respectfully requests that this Honorable Court grant this Motion for
Deposition Fees for Expert Witness for Indigent Defendant to allow the defense to take the deposition of
expert witness Dr. Francesca M. Swartz at her office.
CERTIFICATE OF SERVICE
THEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to The Office
of the State Attorney at servicesao-ch@sao. .org, and to Justice Administrative Commission at
pleadings@justiceadmin.org this A\G day of September, 2019.
ROBERT HARRIS LAW FIRM
Attormey for Defendant
2052 Virginia Ave.
Fort Myers, FL 33901
(239) 334-4343
(239) 334-4345 Fax
bdavis@robertharrislawfirm.com
Florida Bar No. 1002722
Document Filed Date
September 20, 2019
Case Filing Date
August 27, 2018
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Filing # 96028772 E-Filed 09/20/2019 10:29:29 AM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CRIMINAL ACTION STATE OF FLORIDA. Plaintiff. v. CASENO. — 18-CF-001881 EDGAR JUNIOR KELLER, JR., Defendant, / MOTION FOR DEPOSITION FEES FOR EXPERT WITNESS FOR INDIGENT DEFENDANT COMES NOW the undersigned, BRITTNEY A. DAVIS, and hereby files this Motion for Deposition Fees for Expert Witness for Indigent Defendant, and for good cause states the following: 1. The State Attorney lists Dr. Francesca M. Swartz, c/o Orthopedic Specialists, 2531 Cleveland Avenue, Ste. 1, Fort Myers, Florida 33901 as an expert witness in the above-referenced case. The Defendant is charged with DUI- Serious Bodily Injury, and the taking of Dr. Swartz’s deposition is necessary to his case. 2. The Defendant was declared indigent for due process costs, depositions, and private investigator by court order on August 1, 2019. WHEREFORE, the Defendant respectfully requests that this Honorable Court grant this Motion for Deposition Fees for Expert Witness for Indigent Defendant to allow the defense to take the deposition of expert witness Dr. Francesca M. Swartz at her office. CERTIFICATE OF SERVICE THEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to The Office of the State Attorney at servicesao-ch@sao. .org, and to Justice Administrative Commission at pleadings@justiceadmin.org this A\G day of September, 2019. ROBERT HARRIS LAW FIRM Attormey for Defendant 2052 Virginia Ave. Fort Myers, FL 33901 (239) 334-4343 (239) 334-4345 Fax bdavis@robertharrislawfirm.com Florida Bar No. 1002722