Preview
Filing # 112729621 E-Filed 09/01/2020 04:04:46 PM
IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT
IN AND FOR BAY COUNTY, FLORIDA
PATSY J. ODOM,
Plaintiff,
v. Case No.: 19-004405 CA
TOWER HILL SIGNATURE INSURANCE
COMPANY, a Florida insurance corporation,
Defendant.
/
DEFENDANT’S NOTICE OF TAKING REMOTE DEPOSITION DUCES TECUM
TO: Clark Hamilton, Jr., Esq.
Tyler & Hamilton, P.A.
courtdocs@floridainsurancelawyers.com
tandhpa@bellsouth.net
Jay Manuel, Esq.
Manuel & Thompson, P.A.
velinda@manuelthompson.com
tim@manuelthompson.com
PLEASE BE ADVISED, pursuant to the Fla. R. Civ. P. 1.310, that on the following date
and time, the undersigned attorney will take the following depositions:
DEPONENT: Plaintiff's Expert, David Cianchetti
DATE/TIME: Tuesday, September 22, 2020 at 10:00 a.m. EST
LOCATION: Zoom
upon oral examination under, before a court reporter, or any other notary public or officer
authorized by law to take depositions in the State of Florida. This deposition is being taken for the
purposes of discovery, for use at the trial and for all other purposes as are permitted under the
applicable statutes and Florida Rules of Civil Procedure.
Page 1 of 3[s] Nicole M. Fluct
NICOLE M. FLUET, Fla. Bar No. 91077
nfluet@gallowaylawfirm.com
SARAH K. CULLETON, Fla. Bar No. 1015231
sculleton@gallowaylawfirm.com
Galloway, Johnson, Tompkins, Burr & Smith, PLC
400 N. Ashley Drive, Suite 1000
Tampa, Florida 33602
(813) 977-1200
(813) 977-1288 (facsimile)
tampaservice@gallowaylawfirm.com
Counsel for Defendant, Tower Hill Signature
Insurance Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to
the following via the Florida Courts E-Filing Portal and/or electronic mail delivery this 1% day of
September, 2020:
Clark Hamilton, Jr., Esq. Jay Manuel, Esq.
Tyler & Hamilton, P.A. Manuel & Thompson, P.A.
4741 Atlantic Boulevard, Suite A 120 Richard Jackson Boulevard, Suite 200
Jacksonville, FL 32207 Panama City, Florida 325407
Telephone: 904-398-9999 Phone: 850-785-5555
Facsimile: 904-398-0806 Fax: 850-785-0133
courtdocs@floridainsurancelawyers.com jay@manuelthompson.com
tandhpa@bellsouth.net velinda@manuelthompson.com
Counsel for Plaintiff tim@manuelthompson.com
Counsel for Plaintiff
[o] Nicole M. Fluet
NICOLE M. FLUET
SARAH K. CULLETON
Ifyou are a person with a disability who needs any accommodation in order to participate in this
deposition, you may request such assistance by contacting Galloway, Johnson, Tompkins, Burr
& Smith, PLC, 400 N. Ashley Drive, Suite 1000, Tampa, Florida 33602, 813-977-1200, within
two (2) working days of your receipt of this subpoena; if you are hearing or voice impaired, call
711.
Page 2 of 3EXHIBIT A (DUCES TECUM RE
Your entire file related to Patsy J. Odom.
Your entire file related to the property located at 7601 Kingswood Road, Southport Bay,
Florida 32409.
Your entire file related to Tower Hill Preferred Insurance Company claim number
1100294952.
A list of all cases in which you have testified in the preceding 36 months by deposition or at
trial.
Checks, invoices, statements or other documents related to payments made by Tyler &
Hamilton, P.A.
Checks, invoices, statements or other documents related to payments made by Manuel &
Thompson, P.A.
Page 3 of 3
Preview
Filing # 112729621 E-Filed 09/01/2020 04:04:46 PM IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA PATSY J. ODOM, Plaintiff, v. Case No.: 19-004405 CA TOWER HILL SIGNATURE INSURANCE COMPANY, a Florida insurance corporation, Defendant. / DEFENDANT’S NOTICE OF TAKING REMOTE DEPOSITION DUCES TECUM TO: Clark Hamilton, Jr., Esq. Tyler & Hamilton, P.A. courtdocs@floridainsurancelawyers.com tandhpa@bellsouth.net Jay Manuel, Esq. Manuel & Thompson, P.A. velinda@manuelthompson.com tim@manuelthompson.com PLEASE BE ADVISED, pursuant to the Fla. R. Civ. P. 1.310, that on the following date and time, the undersigned attorney will take the following depositions: DEPONENT: Plaintiff's Expert, David Cianchetti DATE/TIME: Tuesday, September 22, 2020 at 10:00 a.m. EST LOCATION: Zoom upon oral examination under, before a court reporter, or any other notary public or officer authorized by law to take depositions in the State of Florida. This deposition is being taken for the purposes of discovery, for use at the trial and for all other purposes as are permitted under the applicable statutes and Florida Rules of Civil Procedure. Page 1 of 3[s] Nicole M. Fluct NICOLE M. FLUET, Fla. Bar No. 91077 nfluet@gallowaylawfirm.com SARAH K. CULLETON, Fla. Bar No. 1015231 sculleton@gallowaylawfirm.com Galloway, Johnson, Tompkins, Burr & Smith, PLC 400 N. Ashley Drive, Suite 1000 Tampa, Florida 33602 (813) 977-1200 (813) 977-1288 (facsimile) tampaservice@gallowaylawfirm.com Counsel for Defendant, Tower Hill Signature Insurance Company CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to the following via the Florida Courts E-Filing Portal and/or electronic mail delivery this 1% day of September, 2020: Clark Hamilton, Jr., Esq. Jay Manuel, Esq. Tyler & Hamilton, P.A. Manuel & Thompson, P.A. 4741 Atlantic Boulevard, Suite A 120 Richard Jackson Boulevard, Suite 200 Jacksonville, FL 32207 Panama City, Florida 325407 Telephone: 904-398-9999 Phone: 850-785-5555 Facsimile: 904-398-0806 Fax: 850-785-0133 courtdocs@floridainsurancelawyers.com jay@manuelthompson.com tandhpa@bellsouth.net velinda@manuelthompson.com Counsel for Plaintiff tim@manuelthompson.com Counsel for Plaintiff [o] Nicole M. Fluet NICOLE M. FLUET SARAH K. CULLETON Ifyou are a person with a disability who needs any accommodation in order to participate in this deposition, you may request such assistance by contacting Galloway, Johnson, Tompkins, Burr & Smith, PLC, 400 N. Ashley Drive, Suite 1000, Tampa, Florida 33602, 813-977-1200, within two (2) working days of your receipt of this subpoena; if you are hearing or voice impaired, call 711. Page 2 of 3EXHIBIT A (DUCES TECUM RE Your entire file related to Patsy J. Odom. Your entire file related to the property located at 7601 Kingswood Road, Southport Bay, Florida 32409. Your entire file related to Tower Hill Preferred Insurance Company claim number 1100294952. A list of all cases in which you have testified in the preceding 36 months by deposition or at trial. Checks, invoices, statements or other documents related to payments made by Tyler & Hamilton, P.A. Checks, invoices, statements or other documents related to payments made by Manuel & Thompson, P.A. Page 3 of 3