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Filing# 142910793 E-Filed 01/29/2022 03:58:10 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL
CIRCUIT
IN
AND
FOR
BROWARD COUNTY, FLORIDA
CASE NO.: 062021 CA016576 (25)
AARON BRUNER,
Plaintiff,
V
BONNIE JUDSON,
Defendant.
DEFENDANT'S NOTICE OF TAKING DEPOSITION OF PLAINTIFF
(Duces Tecum)
PLEASE TAKE NOTICE that the undersigned attorneys will take the deposition
in the above-captioned matter as follows:
Name
Time and Date
Place of Taking
Aaron Bruner
May 12,2022
ZOOM - TO BE PROVIDED
1:00 p.m.
The Plaintiff shall produce all items requested on the attached Exhibit "A".
The deposition will be taken before an associate or deputy court reporter of
Esquire Deposition Solutions, Notary Public, or before some other officer authorized by
law to administer oaths, who is not a relative,employee, attorney or counsel of any of
the parties, or a relative, or employee of such attorney or counsel, or financially
interested in the action, and pursuant to adjournments, if any, by said office until said
testimony shall be comp eted.
This deposition will be taken for the purpose of
discovery, for use at tria, or for such other purposes as are permitted under the
applicable statutes and/or the Florida Rules of Civil Procedure. You are hereby notified
to be present at the time and place stated. This deposition will continue, day to day,
until completed.
Page 1
COLE, SCOTT & KISSANE, P.A.
ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-
9200 - (561) 683-8977 FAX
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/29/2022 03:58:10 PM.****
CASE NO.: 062021 CA016576 (25)
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 29th day of January, 2022, a true and correct
copy of the foregoing was filed with the Clerk of Broward County by using the Florida
Court's E-Filing Portal, which will send an automatic e-mail message to the following
parties registered with the E-Filing Portal system:
Vincent Duffy, Esq., Goldman &
Daszkal, P.A., service.duffy@gdinjurylaw.com; jfontaine@gdinjurylaw.com, 1630 West
Hillsboro Boulevard, Deerfield Beach, FL 33442, (954) 428-9333/(954) 428-9338 (F),
Attorney for Plaintiff.
COLE, SCOTT & KISSANE, P.A.
Counsel for Defendant
Esperante Building
222 Lakeview Avenue, Suite 120
West Palm Beach, Florida 33401
Telephone (561) 383-9262
Facsimile (561) 683-8977
Primary brian.pita@csklegal.corn
Secondary cassandra.pierre@csklegal.corn
Alternate: kristin.miller@csklegal.corn
By:
s/ Brian S. Pita
BRIAN S. PITA
Florida Bar No.- 41903
CASSANDRA PIERRE
Florida Bar No.: 127410
Page 2
COLE, SCOTT & KISSANE, P.A.
ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-
9200 - (561) 683-8977 FAX
CASE NO.: 062021 CA016576 (25)
EXHIBIT A - DOCUMENTS TO PRODUCE
1-
All bills or statements for medical treatment, medications or other related
items, the cost of which is claimed to have been incurred by the Plaintiff as a result of
the injuriesallegedlysustained in this case by the Plaintiff.
2.
Any and all records of hospitals in which the Plaintiff has been a patient or
received treatment allegedly as a result of the accident here involved; or, in the
alternative,written authorization to obtain same.
3.
The retained copies or other suitable copies of the Plaintiffs United States
Income Tax Returns for the five (5) years preceding the alleged accident/incident to
date.
4.
Any and all photographs taken by the Plaintiff,Plaintiffs attorneys,
investigators,agents, servants, or employees, after the accident referred to in the
complaint which are in any manner related to the subject matter of this lawsuit.
5.
Copies of all medical reports received by Plaintiff,Plaintiffs attorneys,
investigators,agents, servants, or employees, from any doctors, physicians, or anyone
else who has rendered treatment to the Plaintiff for injuriesincurred as a result of the
accident which is the subject matter of this lawsuit.
6.
Copies of all medical reports received by Plaintiff,Plaintiffs attorneys,
investigators,agents, servants or employees, from any doctor, physician, or member of
the healing arts who has examined Plaintiffs physical or mental condition subsequent to
the accident which is the subject matter of this lawsuit, and who may be called as a
witness on behalf of the Plaintiff at the trial of this cause.
7.
All
written statements by any witnesses concerning this action or its
subject matter or a stenographic,
mechanical,
electrical, or
other
recording
or
transcriptionof a statement that is a substantial verbatim recital of an oral statement.
8.
All
written statements by the Defendant concerning this action or its
subject matter or a stenographic,
mechanical,
electrical, or
other
recording or
transcriptionof a statement that is a substantial verbatim recital of an oral statement.
Page 3
COLE, SCOTT & KISSANE, P.A.
ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-
9200 - (561) 683-8977 FAX
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Filing# 142910793 E-Filed 01/29/2022 03:58:10 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: 062021 CA016576 (25) AARON BRUNER, Plaintiff, V BONNIE JUDSON, Defendant. DEFENDANT'S NOTICE OF TAKING DEPOSITION OF PLAINTIFF (Duces Tecum) PLEASE TAKE NOTICE that the undersigned attorneys will take the deposition in the above-captioned matter as follows: Name Time and Date Place of Taking Aaron Bruner May 12,2022 ZOOM - TO BE PROVIDED 1:00 p.m. The Plaintiff shall produce all items requested on the attached Exhibit "A". The deposition will be taken before an associate or deputy court reporter of Esquire Deposition Solutions, Notary Public, or before some other officer authorized by law to administer oaths, who is not a relative,employee, attorney or counsel of any of the parties, or a relative, or employee of such attorney or counsel, or financially interested in the action, and pursuant to adjournments, if any, by said office until said testimony shall be comp eted. This deposition will be taken for the purpose of discovery, for use at tria, or for such other purposes as are permitted under the applicable statutes and/or the Florida Rules of Civil Procedure. You are hereby notified to be present at the time and place stated. This deposition will continue, day to day, until completed. Page 1 COLE, SCOTT & KISSANE, P.A. ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383- 9200 - (561) 683-8977 FAX *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/29/2022 03:58:10 PM.**** CASE NO.: 062021 CA016576 (25) CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 29th day of January, 2022, a true and correct copy of the foregoing was filed with the Clerk of Broward County by using the Florida Court's E-Filing Portal, which will send an automatic e-mail message to the following parties registered with the E-Filing Portal system: Vincent Duffy, Esq., Goldman & Daszkal, P.A., service.duffy@gdinjurylaw.com; jfontaine@gdinjurylaw.com, 1630 West Hillsboro Boulevard, Deerfield Beach, FL 33442, (954) 428-9333/(954) 428-9338 (F), Attorney for Plaintiff. COLE, SCOTT & KISSANE, P.A. Counsel for Defendant Esperante Building 222 Lakeview Avenue, Suite 120 West Palm Beach, Florida 33401 Telephone (561) 383-9262 Facsimile (561) 683-8977 Primary brian.pita@csklegal.corn Secondary cassandra.pierre@csklegal.corn Alternate: kristin.miller@csklegal.corn By: s/ Brian S. Pita BRIAN S. PITA Florida Bar No.- 41903 CASSANDRA PIERRE Florida Bar No.: 127410 Page 2 COLE, SCOTT & KISSANE, P.A. ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383- 9200 - (561) 683-8977 FAX CASE NO.: 062021 CA016576 (25) EXHIBIT A - DOCUMENTS TO PRODUCE 1- All bills or statements for medical treatment, medications or other related items, the cost of which is claimed to have been incurred by the Plaintiff as a result of the injuriesallegedlysustained in this case by the Plaintiff. 2. Any and all records of hospitals in which the Plaintiff has been a patient or received treatment allegedly as a result of the accident here involved; or, in the alternative,written authorization to obtain same. 3. The retained copies or other suitable copies of the Plaintiffs United States Income Tax Returns for the five (5) years preceding the alleged accident/incident to date. 4. Any and all photographs taken by the Plaintiff,Plaintiffs attorneys, investigators,agents, servants, or employees, after the accident referred to in the complaint which are in any manner related to the subject matter of this lawsuit. 5. Copies of all medical reports received by Plaintiff,Plaintiffs attorneys, investigators,agents, servants, or employees, from any doctors, physicians, or anyone else who has rendered treatment to the Plaintiff for injuriesincurred as a result of the accident which is the subject matter of this lawsuit. 6. Copies of all medical reports received by Plaintiff,Plaintiffs attorneys, investigators,agents, servants or employees, from any doctor, physician, or member of the healing arts who has examined Plaintiffs physical or mental condition subsequent to the accident which is the subject matter of this lawsuit, and who may be called as a witness on behalf of the Plaintiff at the trial of this cause. 7. All written statements by any witnesses concerning this action or its subject matter or a stenographic, mechanical, electrical, or other recording or transcriptionof a statement that is a substantial verbatim recital of an oral statement. 8. All written statements by the Defendant concerning this action or its subject matter or a stenographic, mechanical, electrical, or other recording or transcriptionof a statement that is a substantial verbatim recital of an oral statement. Page 3 COLE, SCOTT & KISSANE, P.A. ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383- 9200 - (561) 683-8977 FAX