On August 19, 2021 a
Party Discovery
was filed
involving a dispute between
Steele, David,
Steele, Dewanda,
and
Good2Go Roofing And Contracting Llc,
for CONTRACTS AND INDEBTEDNESS
in the District Court of Bay County.
Preview
Filing # 141678748 E-Filed 01/10/2022 02:35:49 PM
IN THE CIRCUIT COURT, FOURTEENTH JUDICIAL CIRCUIT,
OF THE STATE OF FLORIDA IN AND FOR BAY COUNTY
DAVID AND DEWANDA STEELE,
Plaintiffs,
vs. Case No.: 21001034CA
GOOD2GO ROOFING & CONSTRUCTION, LLC.,
Defendant.
PLAINTIFFS’ NOTICE OF DESIGNATION OF STEVE PASHOIAN’S
LIMITED DEPOSITION TESTIMONY
COME NOW the Plaintiffs, DAVID AND DEWANDA STEELE, by and through the
undersigned attorney and hereby file this Notice of Designation of Steve Pashoian’s Limited
Deposition Testimony taken on November 15, 2021, and requests that this Honorable Court take
notice of the following testimony attached hereto as Exhibit A.
Dated this 10th day of January 2022.
/s/ C. Brian Davidson
C. Brian Davidson, Esquire
Fla. Bar No: 0114394
Ala. Bar No: 5410D66C
DAVIDSON LAW FIRM, LLC
Florida:
747 Jenks Avenue, Suite H
Panama City, Florida 32401
T/ (850) 640-2030
F/ (850) 220-1843
Pleadings: Brian@Panhandle-Law.com
Alabama:
P.O. Box 626
Montevallo, Alabama 35115
T/ (205) 358-7867
F/ (205) 225-6034
Pleadings: Brian@DavidsonFirmLLC.com
1
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 10th day of January 2022, a true and exact copy of the foregoing
was furnished via the Florida Court’s E-Filing Portal to all counsel of record.
/s/ C. Brian Davidson
C. Brian Davidson
2
EXHIBIT
A
Case Steele
Issue Code DESIGNATION
PASHOIAN, STEPHEN 11/15/21 VOL 1
1 006:01 - 006:07 006:01 Q Where on the property or -- well, that is
02 kind of a leading question. Exactly where,
03 physically, were you when the contract was executed?
04 Were you at the house, were you at an office?
05 A Yeah, we were at their house. We were at
06 their house. Between their temporary lodging and the
07 trailer in the front yard and the front porch.
2 010:16 - 011:12 010:16 Q What happens to the original contracts after
17 they're executed?
18 A Typically, the salesperson maintains the
19 original and the carbon copy goes to the homeowner.
20 Q How does Good2Go get a copy of the original?
21 A It's uploaded into our database, you know,
22 our CRN.
23 Q By that, I take it it's scanned and then
24 saved into a, I don't know, some kind of a cloud
25 system?
011:01 A That's correct.
02 Q Is it scanned by the salesperson?
03 A That's correct.
04 Q Does Good2Go ever receive the actual signed
05 documents?
06 A I would assume we have at some point. I
07 don't know precisely whom or when.
08 Q As a general rule, do the salespeople send
09 or deliver the executed original contracts to Good2Go
10 Roofing?
11 A No. Typically, they're just uploaded onto
12 the system.
3 011:21 - 012:03 011:21 Q Okay. So is it Good2Go's policy that you
22 allow these nonemployees to maintain the original
23 copies of your contracts?
24 A Well, at the -- on a normal circumstance, we
25 didn't have much of a choice, because we weren't --
012:01 we weren't there. We're not -- we're not there
02 signing these contracts. So that -- it was not an
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1/10/22
03 uncommon practice.
4 012:07 - 012:11 012:07 Q Why didn't you keep the original copy of
08 this particular contract if you and Mr. Dudeck were
09 there?
10 A I don't know. I -- I don't have a -- I
11 don't have an answer for that.
Created with TranscriptPad for iPad Page 2 of 2
1/10/22
Document Filed Date
January 10, 2022
Case Filing Date
August 19, 2021
Category
CONTRACTS AND INDEBTEDNESS
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Filing # 141678748 E-Filed 01/10/2022 02:35:49 PM IN THE CIRCUIT COURT, FOURTEENTH JUDICIAL CIRCUIT, OF THE STATE OF FLORIDA IN AND FOR BAY COUNTY DAVID AND DEWANDA STEELE, Plaintiffs, vs. Case No.: 21001034CA GOOD2GO ROOFING & CONSTRUCTION, LLC., Defendant. PLAINTIFFS’ NOTICE OF DESIGNATION OF STEVE PASHOIAN’S LIMITED DEPOSITION TESTIMONY COME NOW the Plaintiffs, DAVID AND DEWANDA STEELE, by and through the undersigned attorney and hereby file this Notice of Designation of Steve Pashoian’s Limited Deposition Testimony taken on November 15, 2021, and requests that this Honorable Court take notice of the following testimony attached hereto as Exhibit A. Dated this 10th day of January 2022. /s/ C. Brian Davidson C. Brian Davidson, Esquire Fla. Bar No: 0114394 Ala. Bar No: 5410D66C DAVIDSON LAW FIRM, LLC Florida: 747 Jenks Avenue, Suite H Panama City, Florida 32401 T/ (850) 640-2030 F/ (850) 220-1843 Pleadings: Brian@Panhandle-Law.com Alabama: P.O. Box 626 Montevallo, Alabama 35115 T/ (205) 358-7867 F/ (205) 225-6034 Pleadings: Brian@DavidsonFirmLLC.com 1 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 10th day of January 2022, a true and exact copy of the foregoing was furnished via the Florida Court’s E-Filing Portal to all counsel of record. /s/ C. Brian Davidson C. Brian Davidson 2 EXHIBIT A Case Steele Issue Code DESIGNATION PASHOIAN, STEPHEN 11/15/21 VOL 1 1 006:01 - 006:07 006:01 Q Where on the property or -- well, that is 02 kind of a leading question. Exactly where, 03 physically, were you when the contract was executed? 04 Were you at the house, were you at an office? 05 A Yeah, we were at their house. We were at 06 their house. Between their temporary lodging and the 07 trailer in the front yard and the front porch. 2 010:16 - 011:12 010:16 Q What happens to the original contracts after 17 they're executed? 18 A Typically, the salesperson maintains the 19 original and the carbon copy goes to the homeowner. 20 Q How does Good2Go get a copy of the original? 21 A It's uploaded into our database, you know, 22 our CRN. 23 Q By that, I take it it's scanned and then 24 saved into a, I don't know, some kind of a cloud 25 system? 011:01 A That's correct. 02 Q Is it scanned by the salesperson? 03 A That's correct. 04 Q Does Good2Go ever receive the actual signed 05 documents? 06 A I would assume we have at some point. I 07 don't know precisely whom or when. 08 Q As a general rule, do the salespeople send 09 or deliver the executed original contracts to Good2Go 10 Roofing? 11 A No. Typically, they're just uploaded onto 12 the system. 3 011:21 - 012:03 011:21 Q Okay. So is it Good2Go's policy that you 22 allow these nonemployees to maintain the original 23 copies of your contracts? 24 A Well, at the -- on a normal circumstance, we 25 didn't have much of a choice, because we weren't -- 012:01 we weren't there. We're not -- we're not there 02 signing these contracts. So that -- it was not an Created with TranscriptPad for iPad Page 1 of 2 1/10/22 03 uncommon practice. 4 012:07 - 012:11 012:07 Q Why didn't you keep the original copy of 08 this particular contract if you and Mr. Dudeck were 09 there? 10 A I don't know. I -- I don't have a -- I 11 don't have an answer for that. Created with TranscriptPad for iPad Page 2 of 2 1/10/22