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£-Filed 05/10/2013 03:49 PM Tara S. Green
IN THE CIRCUIT COURT OF THE 4TH
JUDICIAL CIRCUIT, IN AND FOR
CLAY COUNTY, FLORIDA
CASE NO: 2012-CA-001823
CORY KATTERHENRY, Individually, and as
Personal Representative of the Estate of David
Katterhenry,
Plaintiff,
Vv.
CLAY ELECTRIC COOPERATIVE, INC., a Florida
corporation,
Defendant.
/
MOTION TO APPOINT SPECIAL PROCESS SERVER
Plaintiff, CORY KATTERHENRY, requests that the Court appoint John Ruda, One Step
Ahead Investigations, Inc., 1603 Mallory Street, Jacksonville, Florida, to serve the attached
Subpoena Duces Tecum on the Non-Party, Vistakon Pharmaceuticals, LLC, in this action. See
attached Exhibit A.
John Ruda, of One Step Ahead Investigations, Inc., is a licensed and insured process
server [firm] located in Jacksonville, Duval County, Florida. The firm employs process servers
and investigators that are licensed and authorized process servers. The firm is licensed and
insured.
Plaintiffs reason for said motion is that the Sheriff cannot serve parties outside of Clay
County.
Plaintiff further moves this Court to appoint, John Ruda, One Step Ahead Investigations,
Inc., as special process server for the duration of this litigation. In support of said Motion,
Leopold Law, P.A.
2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410
Telephone: (561) 515-1400 Facsimile (561) 515-1401Katterhenry v. Clay Electric Cooperative, Inc.
Case No.: 2012-CA-001823
Plaintiff's Motion to Appoint Special Process Server
Page 2
Plaintiff would state that this case is in the early phase of discovery and the need for service of
Subpoenas outside of Clay County is imminent.
WHEREFORE, Plaintiff requests this Honorable Court to grant this motion and enter an
Order appointing the requested special process server to serve the attached Subpoena and to be
appointed special process server for the duration of the litigation of this cause.
Respectiully submitted,
eM bi
LESLIE M. KROEGER, E!
Florida Bar No.: 989762
Ikroeger@leopold-law.com
LEOPOLD LAW, P.A.
2925 PGA Boulevard, Suite 200
Palm Beach Gardens, FL 33410
(561) 515-1400
Leopold Law, P.A,
2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410
Telephone: (561) 515-1400 Facsimile (561) 515-1401Katterhenry v. Clay Electric Cooperative, Inc.
Case No.: 2012-CA-001823
Plaintiff's Motion to Appoint Special Process Server
CERTIFICATE OF SERVICE
Page 3
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by email,
this git day of May, 2013 to:
Timothy Armstrong, Esq.
tim@timarmstronglaw.com
Law Offices of Timothy Armstrong
332 East Adams Street, Suite 200
Jacksonville, FL 32202
Phone: (904)-356-8618
Fax: (904)-356-8616
Attorneys for Co-Counsel for Plaintiff Cory Katterhenry
Reed W. Grimm, Esq.
rwg11@taylordaylaw.com; LKF@taylordaylaw.com; jdo@taylordaylaw.com;
mlb@taylordaylaw.com
Taylor, Day, Grimm, Boyd & Johnson
50 N. Laurda Street
Suite 3500
Jacksonville, FL 32202
Phone: (904)-356-0700
Fax: (904)-356-3224
Attorneys for Clay Electric Cooperative, Inc.
LEOPOLD LAW, P.A.
2925 PGA Boulevard, Suite 200
Palm Beach Gardens, FL 33410
(561) 515-1400
(561) 5 15. 01 LL /
i vy og
wy MAM
(LESLIE M. KROEGER, ESQ.
Florida Bar No.: Me
Ikroeger@leopold-law.gont
Leopold Law, P.A.
2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410
Telephone: (561) 515-1400 Facsimile (561) 515-1401IN THE CIRCUIT COURT OF THE 4TH
JUDICIAL CIRCUIT, IN AND FOR CLAY
COUNTY, FLORIDA
Case No: 2012-CA-001823
CORY KATTERHENRY, Individually,
and as Personal Representative of the
Estate of David Katterhenry,
Plaintiff,
VS.
CLAY ELECTRIC COOPERATIVE,
INC., a Florida corporation,
Defendant.
/
PLAINTIFE’S SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
To: Vistakon Pharmaceuticals, LLC
Attn: Law Department
7500 Centurion Blvd.
Jacksonville, FL 32256
YOU ARE COMMANDED to appear at the offices of undersigned counsel, within 10
days of receipt of this Subpoena, and to have with you at that time and place the following:
DUCES TECUM:
You are to produce a true and accurate copy of each and every piece of paper in your
employee/personnel file on David A. Katterhenry, deceased, whose date of birth is August 26,
1958, Social Security Number
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 electronic or
legible copies of the items to be produced to the attorney whose name appears on this subpoena
LEOPOLD LAW, P.A.
2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410
Telephone: (561) 515-1400 Facsimile: (561) 515-1401Katterhenry v. Clay Electric Cooperative, Inc.
Case No.: 2012-CA-001823
Page 2
on or before the scheduled date of production. You may condition the preparation of the copies
upon the payment in advance of the reasonable cost of preparation. If the cost of production
will exceed $50.00, please contact our office for authorization to proceed with production.
You may mail or deliver the copies to the attorney whose name appears on this subpoena and
thereby eliminate your appearance at the time and place specified.
THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN.
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 to appear by the following attorney, and
unless excused from this subpoena by this attorney or the court, you shall respond to this
subpoena as directed.
PRIOR TO SERVICE OF THIS SUBPOENA, IN ACCORDANCE WITH HIPAA, 45
CODE OF FEDERAL REGULATIONS 164.512 (E), PLAINTIFF HAS GIVEN 10 DAYS
FOR OTHER NOTICE TO ALL PARTIES TO OBJECT TO THIS RECORD REQUEST
AND HAS NOT RECEIVED ANY OBJECTIONS. WE HEREBY WARRANT THAT
ALL COPIES WILL BE DESTROYED AT THE END OF THE LITIGATION
PROCEEDINGS.
ite
Dated on |*F'day of April, 2013.
FOR THE COURT
w» Llepae Ae
LEZSLIEM. KROEGER
Florida Bar No.: 989762
Email: Ikroeger@leopold-law.c
LEOPOLD LAW, P.A.
2925 PGA Boulevard, Suite 200
Palm Beach Gardens, FL 33410
Telephone: (561) 515-1400
Facsimile: (561) 515-1401
LEOPOLD LAW, P.A.
2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410
Telephone: (561) 515-1400 Facsimile: (561) 515-1401
Preview
£-Filed 05/10/2013 03:49 PM Tara S. Green IN THE CIRCUIT COURT OF THE 4TH JUDICIAL CIRCUIT, IN AND FOR CLAY COUNTY, FLORIDA CASE NO: 2012-CA-001823 CORY KATTERHENRY, Individually, and as Personal Representative of the Estate of David Katterhenry, Plaintiff, Vv. CLAY ELECTRIC COOPERATIVE, INC., a Florida corporation, Defendant. / MOTION TO APPOINT SPECIAL PROCESS SERVER Plaintiff, CORY KATTERHENRY, requests that the Court appoint John Ruda, One Step Ahead Investigations, Inc., 1603 Mallory Street, Jacksonville, Florida, to serve the attached Subpoena Duces Tecum on the Non-Party, Vistakon Pharmaceuticals, LLC, in this action. See attached Exhibit A. John Ruda, of One Step Ahead Investigations, Inc., is a licensed and insured process server [firm] located in Jacksonville, Duval County, Florida. The firm employs process servers and investigators that are licensed and authorized process servers. The firm is licensed and insured. Plaintiffs reason for said motion is that the Sheriff cannot serve parties outside of Clay County. Plaintiff further moves this Court to appoint, John Ruda, One Step Ahead Investigations, Inc., as special process server for the duration of this litigation. In support of said Motion, Leopold Law, P.A. 2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410 Telephone: (561) 515-1400 Facsimile (561) 515-1401Katterhenry v. Clay Electric Cooperative, Inc. Case No.: 2012-CA-001823 Plaintiff's Motion to Appoint Special Process Server Page 2 Plaintiff would state that this case is in the early phase of discovery and the need for service of Subpoenas outside of Clay County is imminent. WHEREFORE, Plaintiff requests this Honorable Court to grant this motion and enter an Order appointing the requested special process server to serve the attached Subpoena and to be appointed special process server for the duration of the litigation of this cause. Respectiully submitted, eM bi LESLIE M. KROEGER, E! Florida Bar No.: 989762 Ikroeger@leopold-law.com LEOPOLD LAW, P.A. 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, FL 33410 (561) 515-1400 Leopold Law, P.A, 2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410 Telephone: (561) 515-1400 Facsimile (561) 515-1401Katterhenry v. Clay Electric Cooperative, Inc. Case No.: 2012-CA-001823 Plaintiff's Motion to Appoint Special Process Server CERTIFICATE OF SERVICE Page 3 I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by email, this git day of May, 2013 to: Timothy Armstrong, Esq. tim@timarmstronglaw.com Law Offices of Timothy Armstrong 332 East Adams Street, Suite 200 Jacksonville, FL 32202 Phone: (904)-356-8618 Fax: (904)-356-8616 Attorneys for Co-Counsel for Plaintiff Cory Katterhenry Reed W. Grimm, Esq. rwg11@taylordaylaw.com; LKF@taylordaylaw.com; jdo@taylordaylaw.com; mlb@taylordaylaw.com Taylor, Day, Grimm, Boyd & Johnson 50 N. Laurda Street Suite 3500 Jacksonville, FL 32202 Phone: (904)-356-0700 Fax: (904)-356-3224 Attorneys for Clay Electric Cooperative, Inc. LEOPOLD LAW, P.A. 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, FL 33410 (561) 515-1400 (561) 5 15. 01 LL / i vy og wy MAM (LESLIE M. KROEGER, ESQ. Florida Bar No.: Me Ikroeger@leopold-law.gont Leopold Law, P.A. 2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410 Telephone: (561) 515-1400 Facsimile (561) 515-1401IN THE CIRCUIT COURT OF THE 4TH JUDICIAL CIRCUIT, IN AND FOR CLAY COUNTY, FLORIDA Case No: 2012-CA-001823 CORY KATTERHENRY, Individually, and as Personal Representative of the Estate of David Katterhenry, Plaintiff, VS. CLAY ELECTRIC COOPERATIVE, INC., a Florida corporation, Defendant. / PLAINTIFE’S SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: To: Vistakon Pharmaceuticals, LLC Attn: Law Department 7500 Centurion Blvd. Jacksonville, FL 32256 YOU ARE COMMANDED to appear at the offices of undersigned counsel, within 10 days of receipt of this Subpoena, and to have with you at that time and place the following: DUCES TECUM: You are to produce a true and accurate copy of each and every piece of paper in your employee/personnel file on David A. Katterhenry, deceased, whose date of birth is August 26, 1958, Social Security Number 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 electronic or legible copies of the items to be produced to the attorney whose name appears on this subpoena LEOPOLD LAW, P.A. 2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410 Telephone: (561) 515-1400 Facsimile: (561) 515-1401Katterhenry v. Clay Electric Cooperative, Inc. Case No.: 2012-CA-001823 Page 2 on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. If the cost of production will exceed $50.00, please contact our office for authorization to proceed with production. You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. 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 to appear by the following attorney, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. PRIOR TO SERVICE OF THIS SUBPOENA, IN ACCORDANCE WITH HIPAA, 45 CODE OF FEDERAL REGULATIONS 164.512 (E), PLAINTIFF HAS GIVEN 10 DAYS FOR OTHER NOTICE TO ALL PARTIES TO OBJECT TO THIS RECORD REQUEST AND HAS NOT RECEIVED ANY OBJECTIONS. WE HEREBY WARRANT THAT ALL COPIES WILL BE DESTROYED AT THE END OF THE LITIGATION PROCEEDINGS. ite Dated on |*F'day of April, 2013. FOR THE COURT w» Llepae Ae LEZSLIEM. KROEGER Florida Bar No.: 989762 Email: Ikroeger@leopold-law.c LEOPOLD LAW, P.A. 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, FL 33410 Telephone: (561) 515-1400 Facsimile: (561) 515-1401 LEOPOLD LAW, P.A. 2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410 Telephone: (561) 515-1400 Facsimile: (561) 515-1401