Party Discovery: Adriana Hincapie, et al Plaintiff vs. Joseph Bernard Wezkiewicz, Jr., et al Defendant

• 
• 
• 
• 
• 
• 

						
                                
Preview
                                Filing# 137341685 E-Filed 10/27/2021 08:50:04           AM

                                                       IN  THE CIRCUIT COURT OF THE
                                                       SEVENTEENTH JUDICIAL CIRCUIT IN AND
                                                       FOR BROWARD COUNTY, FLORIDA

                                                       CASE NO- CACE 21-016648             (14)

        ADRIANA HINCAPIE AND NICOLAS
        HINCAPIE,

               Plaintiffs,
        VS.



        JOSEPH BERNARD WEZKIEWICZ,

               Defendant.
                                                   i



              DEFENDANTS' NOTICE OF TAKING VIDEO DEPOSITION DUCES TECUM
                            (Date and time coordinated with Plaintiffs
                                                                     Counsel's office)


               PLEASE TAKE NOTICE that the undersignedwill take the depositionby oral examination

        for the purposes of discoveryor evidence, or both, pursuant to the Florida Rules    of Civil Procedure,

        of the below named person(s)at the time, date and location indicated:


         NAME AND ADDRESS                      TIME AND DATE                    PLACE OF TAKING
         NICOLAS HINCAPIE                      January 26,2022                 *Via   ZOOM through Esquire
                                               @ 10:30 am                       Deposition Solutions
                                                                                (Zoom link to be provided
                                                                                closer to the deposition date)



                            PLEASE ADVISE IF AN INTERPRETER IS NEEDED

               before a Court Reporter and Notary Public of the firm of Esquire Deposition Solutions or


        any o fficer authorized to administer oaths by the laws o f the State o f Florida,and a person   who    is



        neither a relative,nor employee, nor attorney, nor counsel of                        and who
                                                                           any of the parties,            is   not


                  interested in the action. The deponent
        financially                                          is   instructed to brin? the documents listed in


        Schedule 't4" attached hereto and incorporated herein. The said        oral   examination will continue


        from hour to hour and from day to day until completed.




          *** FILED:   BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK              10/27/2021 08:50:03   AM.****
           I   HEREBY CERTIFY that on October 27, 2021, the foregoingwas electronically
                                                                                     filed with
the Florida Courts E-Filing Portal and that as a registeredparticipantof the Portal I have
effectuated service through the Portal in compliance with Rule 2.516, Fla. R. Jud. Admin., on
Kevin          Houston,    Es*
                          khouston@rubensteinlaw.com,    emsantana@rubensteinlaw.com,
                          Rubenstein
eservice@rubensteinlaw.com,          Law, P.A., 9130 S. Dadeland Blvd., PH, Miami, FL
33156.
                                                   NICHOLAS J. RYAN & ASSOCIATES
                                                    110                        2100
                                                          S. E. 6th Street,Suite
                                                   Fort Lauderdale, FL 33301

                                                   Telephone: (954) 627-9401
                                                   E-mail for service (FL R. Jud. Admin. 2.516).
                                                   flor.law-shericritelli.2980 19@statefarm.com



                                                    Juul.CiADU
                                                   Sheri L. Critelli,
                                                                    Esq.
                                                   Florida Bar No.. 813508

                                                   Attorney for Defendant




cc:        Esquire Deposition Solutions
CC:        Grazia Ossenih, Claim No.. 59-09K8-30G
cc:        Joseph Bernard Wezkiewicz, III




      IFYOU ARE A PERSON WITH A DISABILITY WHO NEEDS ANY ACCOMMODATION IN ORDER TO PARTICIPATE IN THIS
      PROCEEDING, YOU AREENTITLED, AT NO COST TO YOU, TO THE, PROVISION OFCERTAIN ASSISTANCE. PLEASECONTACT
      [FOR COURT PROCEEDINGS - CONTACT THE COURT ADA COORDINATOR; AND, FOR DEPOSITIONS - CONTACT THE
      UNDERSIGNED ATTORNEYI AT LEAST 7 DAYS BEFORE YOUR SCHEDULED COURT APPEARANCE, OR IMMEDIATELY UPON
      RECEIVING THIS NOTIFICATION IF THE TIME BEFORE THE SCHEDULED APPEARANCE IS LESS THAN 7 DAYS; IF YOU ARE
      HEARING OR VOICE IMPAIRED, CALL 711.
                                    SCHEDULE "A"

1.   Color copies of the photographs of the vehicles involved, subjectaccident scene and/or of
     the partiestaken by the Plaintiff or on the Plaintiff's behalf relatingto the subjectmva.


2.   Bring the ACTUAL PHYSICAL Passport(,) or Fisu(s) of the Plaintiff at the time of the
     subjectaeeident up to the present time (even if the Plaintiff provided copies of same in
     the Plaintiff's Response to Request for Production).