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Filing # 119120404 E-Filed 01/06/2021 08:37:48 AM
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY, FLORIDA
CASE NO.: 2020CA010576XXXXMB
DIVISION: AH
BERNARD SUSSMAN and
FRANCINE SUSSMAN,
Plaintiff(s),
vs.
BCMB ENTERPRISES, INC d/b/a
A BETTER WAY HOME CARE,
Defendant.
/
PLAINTIFF’S AMENDED NOTICE OF TAKING VIDEO DEPOSITION DUCES TECUM
(Amended as to the name of the Deponent)
PLEASE TAKE NOTICE that the Plaintiffs will take the deposition of the below
named person on the date and at the hour indicated:
NAME DATE/TIME LOCATION
Shatarra Smith January 27, 2021, Wwww.zoom.us
at 1:00 p.m. Meeting ID: 871 9662 5804
Password: 149586
https://usO2web.zoom.us/j/87196625804
Upon oral examination, before Florida Court Reporting, an authorized Court
Reporter, Notary Public in and for the State of Florida at Large, or some other officer duly
authorized by law to take depositions, and videotaped by Florida Court Reporting, 2161
Palm Beach Lakes Blvd., Suite 302, West Palm Beach, Florida 33409. The deposition
will continue from day to day until complete. The deposition is being taken for the purpose
of discovery, for use at trial, or both of the foregoing, or for such other purpose as are
permitted under the applicable and governing rules.
Please take further notice that in connection with the taking of this deposition, and
'** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 01/06/2021 08:37:48 AM ***Sussman v. BCMB Enterprises, Inc.
Case No.: 2020CA010576XXXXMB
Notice of Taking Video Deposition - Shay
Page 2 of 3
pursuant to Rules 1.310(b)(5) and 1.350 of the Florida Rules of Civil Procedure, the
deponent shall, upon commencement of the deposition, produce the items described in
the list attached hereto as Exhibit A, which is made a part of this Notice for all purposes.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the foregoing instrument has
been furnished via electronic mail to the parties as printed below on the attached service
list, and we have filed the foregoing with the Clerk of the Palm Beach County Court by
using the Florida Courts E-Filing Portal, dated this 6" day of January 2021.
Respectfully Submitted,
ROY & ASSOCIATES, P.A.
By: /s/: Dave K. Roy, Esq.
DAVE K. ROY, ESQ. (FBN 92551)
1665 Palm Beach Lakes Blvd., Suite 101
West Palm Beach, FL 33401
Telephone: (561) 729-0095
Facsimile: (267) 222-6953
E-Service: info@daveroylaw.com
SERVICE LIST:
Robin N. Khanal, Esq. and Christopher N. Gonsalves, Esq., 255 S. Orange Ave., Suite
900, Orlando, Florida 32801; E-Service: RNK.Pleadings@gqpwblaw.comSussman v. BCMB Enterprises, Inc.
Case No.: 2020CA010576XXXXMB
Notice of Taking Video Deposition - Shay
Page 3 of 3
EXHIBIT A
1. Any and all of your COVID-19 test results.
2. Your work schedule reflecting any and all home visits scheduled following
receipt of your positive COVID-19 test result.
3. Any and all documents reflecting Defendant's procedures related to use of
personal protective equipment during COVID-19 received by you.
4. Any and all documents reflecting the Defendant's availability of personal
protective equipment for your use.
5. Any and all policies, procedures and protocol related to the prevention of
the spread of COVID-19 you received from your employer.
6. Any and all C.D.C. guidelines provided to you on interacting with individuals
at high-risk of COVID-19
7. Any and all C.D.C. guidelines provided to you on interacting with individuals
and the use of PPE
8. All policies, protocols, procedures, or the similar related to COVID-19 for
which you were required to follow.
9. All warnings you gave to the Plaintiffs related to COVID-19.
10. Any and all policies and procedures related to the sanitization of the medical
equipment used by you.
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Filing # 119120404 E-Filed 01/06/2021 08:37:48 AM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 2020CA010576XXXXMB DIVISION: AH BERNARD SUSSMAN and FRANCINE SUSSMAN, Plaintiff(s), vs. BCMB ENTERPRISES, INC d/b/a A BETTER WAY HOME CARE, Defendant. / PLAINTIFF’S AMENDED NOTICE OF TAKING VIDEO DEPOSITION DUCES TECUM (Amended as to the name of the Deponent) PLEASE TAKE NOTICE that the Plaintiffs will take the deposition of the below named person on the date and at the hour indicated: NAME DATE/TIME LOCATION Shatarra Smith January 27, 2021, Wwww.zoom.us at 1:00 p.m. Meeting ID: 871 9662 5804 Password: 149586 https://usO2web.zoom.us/j/87196625804 Upon oral examination, before Florida Court Reporting, an authorized Court Reporter, Notary Public in and for the State of Florida at Large, or some other officer duly authorized by law to take depositions, and videotaped by Florida Court Reporting, 2161 Palm Beach Lakes Blvd., Suite 302, West Palm Beach, Florida 33409. The deposition will continue from day to day until complete. The deposition is being taken for the purpose of discovery, for use at trial, or both of the foregoing, or for such other purpose as are permitted under the applicable and governing rules. Please take further notice that in connection with the taking of this deposition, and '** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 01/06/2021 08:37:48 AM ***Sussman v. BCMB Enterprises, Inc. Case No.: 2020CA010576XXXXMB Notice of Taking Video Deposition - Shay Page 2 of 3 pursuant to Rules 1.310(b)(5) and 1.350 of the Florida Rules of Civil Procedure, the deponent shall, upon commencement of the deposition, produce the items described in the list attached hereto as Exhibit A, which is made a part of this Notice for all purposes. CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the foregoing instrument has been furnished via electronic mail to the parties as printed below on the attached service list, and we have filed the foregoing with the Clerk of the Palm Beach County Court by using the Florida Courts E-Filing Portal, dated this 6" day of January 2021. Respectfully Submitted, ROY & ASSOCIATES, P.A. By: /s/: Dave K. Roy, Esq. DAVE K. ROY, ESQ. (FBN 92551) 1665 Palm Beach Lakes Blvd., Suite 101 West Palm Beach, FL 33401 Telephone: (561) 729-0095 Facsimile: (267) 222-6953 E-Service: info@daveroylaw.com SERVICE LIST: Robin N. Khanal, Esq. and Christopher N. Gonsalves, Esq., 255 S. Orange Ave., Suite 900, Orlando, Florida 32801; E-Service: RNK.Pleadings@gqpwblaw.comSussman v. BCMB Enterprises, Inc. Case No.: 2020CA010576XXXXMB Notice of Taking Video Deposition - Shay Page 3 of 3 EXHIBIT A 1. Any and all of your COVID-19 test results. 2. Your work schedule reflecting any and all home visits scheduled following receipt of your positive COVID-19 test result. 3. Any and all documents reflecting Defendant's procedures related to use of personal protective equipment during COVID-19 received by you. 4. Any and all documents reflecting the Defendant's availability of personal protective equipment for your use. 5. Any and all policies, procedures and protocol related to the prevention of the spread of COVID-19 you received from your employer. 6. Any and all C.D.C. guidelines provided to you on interacting with individuals at high-risk of COVID-19 7. Any and all C.D.C. guidelines provided to you on interacting with individuals and the use of PPE 8. All policies, protocols, procedures, or the similar related to COVID-19 for which you were required to follow. 9. All warnings you gave to the Plaintiffs related to COVID-19. 10. Any and all policies and procedures related to the sanitization of the medical equipment used by you.