On December 04, 2019 a
Party Discovery
was filed
involving a dispute between
Carr, Jamie,
Carr, Jennifer,
and
Gulfstream Property & Casualty Insurance Company,
for INSURANCE CLAIM
in the District Court of Bay County.
Preview
Filing # 104623726 E-Filed 03/10/2020 12:02:11 PM
IN THE CIRCUIT COURT OF THE 14
JUDICIAL CIRCUIT IN AND FOR
BAY COUNTY, FLORIDA
TH
CASE NO.: 19004412CA
JAMIE AND JENNIFER CARR,
Plaintiffs,
vs.
GULFSTREAM PROPERTY AND
CASUALTY INSURANCE COMPANY,
Defendant.
/
PLAINTIFFS’ NOTICE OF TAKING VIDEO DEPOSITION DUCES TECUM
OF DEFENDANT’S FIELD ADJUSTER
Date and time coordinated with opposing counsel
PLEASE TAKE NOTICE that Plaintiffs, JAMIE AND JENNIFER CARR, through the
undersigned counsel will take the deposition, by oral examination of the following person
pursuant to Fla.R.Civ.P. 1.310 as indicated below or at such other location, time, and date as is
mutually agreed upon by counsel or ordered by the Court, before an associate or deputy court
reporter who is not of counsel to the parties or interested in the events of this cause.
NAME DATE/TIME PLACE
Jeremy Rettig July 10, 2020 at 10:00a.m. | Hudson Court Reporting
90 Woodbridge Center Drive
Suite 240
Woodbridge, NJ 07095
The deponent is directed to produce for inspection and/or copying the documents listed in
Schedule “A”, as set forth in the attached Subpoena Duces Tecum with Deposition, 10 days prior to
the scheduled deposition. This is in an effort to expedite the deposition in order to allow
Plaintiffs to review the documents prior to the deposition. If the documents are not provided
prior to the deposition the Defendant is put on notice that Plaintiffs will reserve the necessary
time prior to the deposition in order to review the documents. Plaintiffs will reimburse deponent
for all reasonable costs associated with producing the requested documents as allowed by the
Florida Rules of Civil Procedure. If any documents are being claimed as privileged, Defendant
must file a privilege log prior to the deposition with enough time for the Court to rule upon said
objections prior to the deposition with enough time for the Court to rule upon said objections
prior to the deposition.
The deposition is being taken for the purpose of discovery, use at trial and/or for such
other purposes as permitted under the Florida Rules of Civil Procedure.The deposition will be videotaped and the name and address of the operator will be
provided after Defendant provides the date and location of the deposition as referenced above.
**Documents responsive to Schedule “A”, as set forth in the attached Subpoena Duces
Tecum with Deposition, over which Defendant has claimed a privilege need not be produced to
Plaintiffs, but must be brought to the deposition should the need arise to refresh the witness’
recollection as to questions regarding non-privileged matters. Plaintiffs stipulate that the
witness’ use of such documents to refresh recollection will not waive any privilege Defendant
has claimed over such documents, nor entitle Plaintiffs to review or receive production of such
documents at the deposition, and Plaintiffs retain the right to challenge any claims of privilege
prior to or after the deposition.**
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served on
this 10th day of March, 2020, via the Florida E-Filing Portal to: Kathy J. Maus, Esq., Butler
Weihmuller Katz Craig LLP, 400 North Ashley Drive, Suite 2300, Tampa, FL 33602,
kmaus@butler.legal.
GED LAWYERS, LLP
Attorneys for the Plaintiffs
7171 North Federal Highway
Boca Raton, FL 33487
Telephone: (561) 995-1966
Facsimile: (561) 241-0812
Primary Email: pdlitlaw@gedlawyers.com
Secondary Email:bluque@gedlawyers.com
BY: /s/Scott M. Rosso
SCOTT M. ROSSO, ESQ.
Florida Bar No.: 505757
DAVID R. SHAHEEN, ESQ.
Florida Bar No.: 0117947
Document Filed Date
March 10, 2020
Case Filing Date
December 04, 2019
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Filing # 104623726 E-Filed 03/10/2020 12:02:11 PM IN THE CIRCUIT COURT OF THE 14 JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA TH CASE NO.: 19004412CA JAMIE AND JENNIFER CARR, Plaintiffs, vs. GULFSTREAM PROPERTY AND CASUALTY INSURANCE COMPANY, Defendant. / PLAINTIFFS’ NOTICE OF TAKING VIDEO DEPOSITION DUCES TECUM OF DEFENDANT’S FIELD ADJUSTER Date and time coordinated with opposing counsel PLEASE TAKE NOTICE that Plaintiffs, JAMIE AND JENNIFER CARR, through the undersigned counsel will take the deposition, by oral examination of the following person pursuant to Fla.R.Civ.P. 1.310 as indicated below or at such other location, time, and date as is mutually agreed upon by counsel or ordered by the Court, before an associate or deputy court reporter who is not of counsel to the parties or interested in the events of this cause. NAME DATE/TIME PLACE Jeremy Rettig July 10, 2020 at 10:00a.m. | Hudson Court Reporting 90 Woodbridge Center Drive Suite 240 Woodbridge, NJ 07095 The deponent is directed to produce for inspection and/or copying the documents listed in Schedule “A”, as set forth in the attached Subpoena Duces Tecum with Deposition, 10 days prior to the scheduled deposition. This is in an effort to expedite the deposition in order to allow Plaintiffs to review the documents prior to the deposition. If the documents are not provided prior to the deposition the Defendant is put on notice that Plaintiffs will reserve the necessary time prior to the deposition in order to review the documents. Plaintiffs will reimburse deponent for all reasonable costs associated with producing the requested documents as allowed by the Florida Rules of Civil Procedure. If any documents are being claimed as privileged, Defendant must file a privilege log prior to the deposition with enough time for the Court to rule upon said objections prior to the deposition with enough time for the Court to rule upon said objections prior to the deposition. The deposition is being taken for the purpose of discovery, use at trial and/or for such other purposes as permitted under the Florida Rules of Civil Procedure.The deposition will be videotaped and the name and address of the operator will be provided after Defendant provides the date and location of the deposition as referenced above. **Documents responsive to Schedule “A”, as set forth in the attached Subpoena Duces Tecum with Deposition, over which Defendant has claimed a privilege need not be produced to Plaintiffs, but must be brought to the deposition should the need arise to refresh the witness’ recollection as to questions regarding non-privileged matters. Plaintiffs stipulate that the witness’ use of such documents to refresh recollection will not waive any privilege Defendant has claimed over such documents, nor entitle Plaintiffs to review or receive production of such documents at the deposition, and Plaintiffs retain the right to challenge any claims of privilege prior to or after the deposition.** CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been served on this 10th day of March, 2020, via the Florida E-Filing Portal to: Kathy J. Maus, Esq., Butler Weihmuller Katz Craig LLP, 400 North Ashley Drive, Suite 2300, Tampa, FL 33602, kmaus@butler.legal. GED LAWYERS, LLP Attorneys for the Plaintiffs 7171 North Federal Highway Boca Raton, FL 33487 Telephone: (561) 995-1966 Facsimile: (561) 241-0812 Primary Email: pdlitlaw@gedlawyers.com Secondary Email:bluque@gedlawyers.com BY: /s/Scott M. Rosso SCOTT M. ROSSO, ESQ. Florida Bar No.: 505757 DAVID R. SHAHEEN, ESQ. Florida Bar No.: 0117947