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Filing # 129358596 E-Filed 06/23/2021 03:05:54 PM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL ACTION
VENISSA DRIGGERS, as Personal
Representative of the Estate of DAVID B.
FLICK, Deceased,
Plaintiffs, CASE NO, 21-CA-410
vs.
MARK BARCIA, HOOTERS OF PORT
CHARLOTTE, INC., BWR NORTH PORT, LLC
d/b/a BUFFALO WINGS AND RINGS,
ATLANTA RESTAURANT PARTNERS, LLC
d/b/a TGl FRIDAYS, and JACKMONT
HOSPITALITY, INC. d/b/a TGI FRIDAYS,
Defendants.
/
NOTICE OF PRODUCTION FROM NON-PARTY
TO: Laurie J. Adams, 515 North Flagler Drive, Suite 1800, West Palm Beach, FL 33401; Howard W Holden, Esq,
Luks, Santaniello, Petrillo & Jones, 1422 Hendry St., 3rd Floor, Fort Myers, FL 33901; James F. Sposato, Esq., Ritter
Chusid, LLP, 5850 Coral Ridge Dr., Ste. 201, Coral Springs, FL 33076
YOU ARE HEREBY NOTIFIED that after ten days from the date of service of this notice, if the service is by
delivery, or 15 days from the date of service if service is by mail, if no objection is received from any party, the
undersigned will issue or will apply to the clerk of this court for issuance the attached Subpoenas directed to the
following who are not parties whose names and addresses are listed below, to produce the items listed at the time
and place specified in the Subpoena.
Cellco Partnership d/b/a Verizon Wireless
180 Washington Valley Rd.
Bedminster, NJ 07921
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a copy of the foregoing has been furnished by Electronic Mail on the 234 day of
June, 2021, to Michael K. McCaffrey, Esq., Litchfield Cavo, LLP, 600 Corporate Drive, Ste. 600, Fort Lauderdale, FL33334,
SPIVEY LAW FIRM,
PERSONAL INJURY ATTORNEYS, P.A.
13400 Parker Commons Blvd.
Fort Myers, Florida 33912
Phone: (239) 337-7483
Fax: (239) 337-7484
By:
RANDALL L. SPIVEY
Florida Bar #0064742
randall@spiveylaw.comIN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL ACTION
VENISSA DRIGGERS, as Personal
Representative of the Estate of DAVID B.
FLICK, Deceased,
Plaintiffs, CASE NO, 21-CA-410
vs.
MARK BARCIA, HOOTERS OF PORT
CHARLOTTE, INC., BWR NORTH PORT, LLC
d/b/a BUFFALO WINGS AND RINGS,
ATLANTA RESTAURANT PARTNERS, LLC
d/b/a TGl FRIDAYS, and JACKMONT
HOSPITALITY, INC. d/b/a TGI FRIDAYS,
Defendants.
SUBPOENA
THE STATE OF FLORIDA, TO: _ Cellco Partnership d/b/a Verizon Wireless
180 Washington Valley Rd.
Bedminster, NJ 07921
YOU ARE COMMANDED to appear at the law offices of SPIVEY LAW FIRM, 13400 Parker Commons Blvd.,
Fort Myers, Florida 33912 during normal business hours, on or before ten days after receipt of this Subpoena, and
to have with you at that time and place the following:
1. Any and all cellular records, statements, call logs, text message logs, and any other records showing
the phone numbers and times of all calls or text messages made by or made to -5291 for the entire date
of December 31, 2019. This request includes every single call and every type of text or other message on that date
during that time period.
These items will be inspected and may be copied at that time. You will not be required to surrender the original
items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney
whose name appears on this subpoena on or before the scheduled date of production. You may condition the
preparation of these copies upon the payment in advance of the reasonable cost of preparation. You may mail or
deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearanceat the time and place specified above. You have the right to object to the production pursuant to this subpoena at
any time before production by giving written notice to the attorneys whose names appear on this subpoena.
If you fail to:
(1) appear as specified, or
(2) furnish the records instead of appearing as provided above, or
(3) object to this subpoena,
you may be in contempt of court. You are subpoenaed by the attorneys whose names appear on this subpoena
and unless excused from this subpoena by the attorneys or the court, you shall respond to this subpoena as
directed.
SPIVEY LAW FIRM,
PERSONAL INJURY ATTORNEYS, P.A.
13400 Parker Commons Blvd.
Fort Myers, Florida 33912
Phone: (239) 337-7483
Fax: (239) 337-7484
By:
RANDALL L. SPIVEY
Florida Bar #0064742
randall@spiveylaw.com
Dated on this 5" day of July, 2021.
DUPLICATE SETS OF THE REQUESTED RECORDS ARE TO BE SENT TO THE FOLLOWING ATTORNEYS WITH A
SEPARATE BILL TO EACH ATTORNEY FOR COPYING COSTS. PLEASE CALL THE ATTORNEYS LISTED BELOW FOR
APPROVAL PRIOR TO FURNISHING SAID COPIES.
Laurie J. Adams, 515 North Flagler Drive, Suite 1800, West Palm Beach, FL 33401
PHONE: 561-640-0303
FAX: 561-640-0524Howard W Holden, Esq, Luks, Santaniello, Petrillo & Jones, 1422 Hendry St., 3rd Floor, Fort Myers, FL 33901
PHONE: 239-561-2828
FAX: 239-561-2841
James F. Sposato, Esq., Ritter Chusid, LLP, 5850 Coral Ridge Dr., Ste. 201, Coral Springs, FL 33076
PHONE: 954-340-2200
FAX: 954-340-2210
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Filing # 129358596 E-Filed 06/23/2021 03:05:54 PM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL ACTION VENISSA DRIGGERS, as Personal Representative of the Estate of DAVID B. FLICK, Deceased, Plaintiffs, CASE NO, 21-CA-410 vs. MARK BARCIA, HOOTERS OF PORT CHARLOTTE, INC., BWR NORTH PORT, LLC d/b/a BUFFALO WINGS AND RINGS, ATLANTA RESTAURANT PARTNERS, LLC d/b/a TGl FRIDAYS, and JACKMONT HOSPITALITY, INC. d/b/a TGI FRIDAYS, Defendants. / NOTICE OF PRODUCTION FROM NON-PARTY TO: Laurie J. Adams, 515 North Flagler Drive, Suite 1800, West Palm Beach, FL 33401; Howard W Holden, Esq, Luks, Santaniello, Petrillo & Jones, 1422 Hendry St., 3rd Floor, Fort Myers, FL 33901; James F. Sposato, Esq., Ritter Chusid, LLP, 5850 Coral Ridge Dr., Ste. 201, Coral Springs, FL 33076 YOU ARE HEREBY NOTIFIED that after ten days from the date of service of this notice, if the service is by delivery, or 15 days from the date of service if service is by mail, if no objection is received from any party, the undersigned will issue or will apply to the clerk of this court for issuance the attached Subpoenas directed to the following who are not parties whose names and addresses are listed below, to produce the items listed at the time and place specified in the Subpoena. Cellco Partnership d/b/a Verizon Wireless 180 Washington Valley Rd. Bedminster, NJ 07921 CERTIFICATE OF SERVICE | HEREBY CERTIFY that a copy of the foregoing has been furnished by Electronic Mail on the 234 day of June, 2021, to Michael K. McCaffrey, Esq., Litchfield Cavo, LLP, 600 Corporate Drive, Ste. 600, Fort Lauderdale, FL33334, SPIVEY LAW FIRM, PERSONAL INJURY ATTORNEYS, P.A. 13400 Parker Commons Blvd. Fort Myers, Florida 33912 Phone: (239) 337-7483 Fax: (239) 337-7484 By: RANDALL L. SPIVEY Florida Bar #0064742 randall@spiveylaw.comIN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL ACTION VENISSA DRIGGERS, as Personal Representative of the Estate of DAVID B. FLICK, Deceased, Plaintiffs, CASE NO, 21-CA-410 vs. MARK BARCIA, HOOTERS OF PORT CHARLOTTE, INC., BWR NORTH PORT, LLC d/b/a BUFFALO WINGS AND RINGS, ATLANTA RESTAURANT PARTNERS, LLC d/b/a TGl FRIDAYS, and JACKMONT HOSPITALITY, INC. d/b/a TGI FRIDAYS, Defendants. SUBPOENA THE STATE OF FLORIDA, TO: _ Cellco Partnership d/b/a Verizon Wireless 180 Washington Valley Rd. Bedminster, NJ 07921 YOU ARE COMMANDED to appear at the law offices of SPIVEY LAW FIRM, 13400 Parker Commons Blvd., Fort Myers, Florida 33912 during normal business hours, on or before ten days after receipt of this Subpoena, and to have with you at that time and place the following: 1. Any and all cellular records, statements, call logs, text message logs, and any other records showing the phone numbers and times of all calls or text messages made by or made to -5291 for the entire date of December 31, 2019. This request includes every single call and every type of text or other message on that date during that time period. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of these copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearanceat the time and place specified above. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorneys whose names appear on this subpoena. If you fail to: (1) appear as specified, or (2) furnish the records instead of appearing as provided above, or (3) object to this subpoena, you may be in contempt of court. You are subpoenaed by the attorneys whose names appear on this subpoena and unless excused from this subpoena by the attorneys or the court, you shall respond to this subpoena as directed. SPIVEY LAW FIRM, PERSONAL INJURY ATTORNEYS, P.A. 13400 Parker Commons Blvd. Fort Myers, Florida 33912 Phone: (239) 337-7483 Fax: (239) 337-7484 By: RANDALL L. SPIVEY Florida Bar #0064742 randall@spiveylaw.com Dated on this 5" day of July, 2021. DUPLICATE SETS OF THE REQUESTED RECORDS ARE TO BE SENT TO THE FOLLOWING ATTORNEYS WITH A SEPARATE BILL TO EACH ATTORNEY FOR COPYING COSTS. PLEASE CALL THE ATTORNEYS LISTED BELOW FOR APPROVAL PRIOR TO FURNISHING SAID COPIES. Laurie J. Adams, 515 North Flagler Drive, Suite 1800, West Palm Beach, FL 33401 PHONE: 561-640-0303 FAX: 561-640-0524Howard W Holden, Esq, Luks, Santaniello, Petrillo & Jones, 1422 Hendry St., 3rd Floor, Fort Myers, FL 33901 PHONE: 239-561-2828 FAX: 239-561-2841 James F. Sposato, Esq., Ritter Chusid, LLP, 5850 Coral Ridge Dr., Ste. 201, Coral Springs, FL 33076 PHONE: 954-340-2200 FAX: 954-340-2210