On December 28, 2018 a
Party Discovery
was filed
involving a dispute between
Ludes, Carolyn,
and
Goodwin, Gregory,
Goodwin, Shari,
for AUTO NEGLIGENCE - CIRCUIT
in the District Court of Pinellas County.
Preview
Filing # 92704486 E-Filed 07/17/2019 01 :45:28 PM
OPG
09981605 83.1
Total Pages: 2
IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT
IN AND FOR PINELLAS COUNTY, FLORIDA
CIVIL DIVISION
CAROLYN LUDES, CASE N0.
19—000169—CI
PLAINTIFF,
VS.
SHARI GOODWIN, GREGORY GOODWIN
AND GARRISON PROPERTY AND CASUALTY
INSURANCE COMPANY,
DEFENDANTS.
DEFENDANT(S) NOTICE OF TAKING DEPOSITION
AND REQUEST FOR PRODUCTION
(If an Interpreter is necessary, please advise the undersigned.)
PLEASE TAKE NOTICE that the undersigned attorney Will take the deposition of:
NAME: CAROLYN G. LUDES
(Pursuant to Florida Rules of Civil Procedure 1.310(b)(5) and 1.350,
Defendant(s) request(s) Plaintiff(s) to produce, at the time and place of this
deposition for inspection and/or copying, your driver's license, any and all
original photographs pertinent to any issues in this lawsuit, and a copy of any
health insurance cards; including but not limited to Medicare, Medicare
Advantage and/or Medicaid.)
DATE: November 19, 2019
TIME: 9:30 A.M.
PLACE: US Legal Support
2935 First Avenue North, lst Floor
St. Petersburg, FL 33713
813-876-4722
upon oral examination, before US Legal Support, a Notary Public in and for the State of Florida
at Large, or some other officer duly authorized by law to take depositions. The deposition(s) Will
continue from day to day until completed. The deposition(s) is/are being taken for the purpose of
discovery (for use at trial) or both of the foregoing, or for such other purposes as are permitted
under the applicable and governing rules, pursuant to Florida Rules of Civil Procedure.
***ELECTRONICALLY FILED 07/17/2019 01:45:28 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
CASE NO. 19-000 1 69-CI
If you are a person With a disability Who needs any accommodation in order to participate
in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance.
Please contact the attorney at the address and phone number listed below Within two (2) working
days of your receipt of this Notice;
pursuant
I HEREBY CERTIFY that on the
to Administrative Order No.
i
if you are hearing or voice impaired,
AOSC13-49,
day of
a copy of the
July
call 711.
foregoing
,
2019,
Notice of Taking
Deposition and Request for Production has been electronically filed and served using the Florida
Courts E-Filing Portal to:
Attorney for Plaintiff
Tomas L. Gacio, Esquire
Abrahamson & Uiterwyk
900 W Platt St
Tampa FL 33606
tgacio@uiterwyklaw.com
8 1 3-222-0500
FBN: 0845612
LAW OFFICES OF ROBERT J. SMITH
101 East Kennedy Boulevard, Suite 2125
Tampa, FL 33602-5 1 89
Telephone: (813) 222-8067
T011 Free: (877) 886-2591 ext 2228067
Attorney Direct: (8 13) 222-8070
Fax: (877) 420-95 12
k ElectronicallySigned
CRYSTAL URQUIZA
FL Bar No. 670383
Attorney for Defendant(s)
SHARI GOODWIN and GREGORY GOODWIN
PRINCIPAL E-MAIL ADDRESS:
TAMPALEGAL@ALLSTATE.COM
Personal E-mail Address
(N_OT for Service of Pleadings and Documents):
crystal.urquiza@allstate.com
Ct: US Legal Support
Document Filed Date
July 17, 2019
Case Filing Date
December 28, 2018
Category
AUTO NEGLIGENCE - CIRCUIT
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Filing # 92704486 E-Filed 07/17/2019 01 :45:28 PM OPG 09981605 83.1 Total Pages: 2 IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CIVIL DIVISION CAROLYN LUDES, CASE N0. 19—000169—CI PLAINTIFF, VS. SHARI GOODWIN, GREGORY GOODWIN AND GARRISON PROPERTY AND CASUALTY INSURANCE COMPANY, DEFENDANTS. DEFENDANT(S) NOTICE OF TAKING DEPOSITION AND REQUEST FOR PRODUCTION (If an Interpreter is necessary, please advise the undersigned.) PLEASE TAKE NOTICE that the undersigned attorney Will take the deposition of: NAME: CAROLYN G. LUDES (Pursuant to Florida Rules of Civil Procedure 1.310(b)(5) and 1.350, Defendant(s) request(s) Plaintiff(s) to produce, at the time and place of this deposition for inspection and/or copying, your driver's license, any and all original photographs pertinent to any issues in this lawsuit, and a copy of any health insurance cards; including but not limited to Medicare, Medicare Advantage and/or Medicaid.) DATE: November 19, 2019 TIME: 9:30 A.M. PLACE: US Legal Support 2935 First Avenue North, lst Floor St. Petersburg, FL 33713 813-876-4722 upon oral examination, before US Legal Support, a Notary Public in and for the State of Florida at Large, or some other officer duly authorized by law to take depositions. The deposition(s) Will continue from day to day until completed. The deposition(s) is/are being taken for the purpose of discovery (for use at trial) or both of the foregoing, or for such other purposes as are permitted under the applicable and governing rules, pursuant to Florida Rules of Civil Procedure. ***ELECTRONICALLY FILED 07/17/2019 01:45:28 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** CASE NO. 19-000 1 69-CI If you are a person With a disability Who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact the attorney at the address and phone number listed below Within two (2) working days of your receipt of this Notice; pursuant I HEREBY CERTIFY that on the to Administrative Order No. i if you are hearing or voice impaired, AOSC13-49, day of a copy of the July call 711. foregoing , 2019, Notice of Taking Deposition and Request for Production has been electronically filed and served using the Florida Courts E-Filing Portal to: Attorney for Plaintiff Tomas L. Gacio, Esquire Abrahamson & Uiterwyk 900 W Platt St Tampa FL 33606 tgacio@uiterwyklaw.com 8 1 3-222-0500 FBN: 0845612 LAW OFFICES OF ROBERT J. SMITH 101 East Kennedy Boulevard, Suite 2125 Tampa, FL 33602-5 1 89 Telephone: (813) 222-8067 T011 Free: (877) 886-2591 ext 2228067 Attorney Direct: (8 13) 222-8070 Fax: (877) 420-95 12 k ElectronicallySigned CRYSTAL URQUIZA FL Bar No. 670383 Attorney for Defendant(s) SHARI GOODWIN and GREGORY GOODWIN PRINCIPAL E-MAIL ADDRESS: TAMPALEGAL@ALLSTATE.COM Personal E-mail Address (N_OT for Service of Pleadings and Documents): crystal.urquiza@allstate.com Ct: US Legal Support