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 DEWANDA STEELE’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 Dewanda Steele’s Limited
Deposition Testimony taken on November 10, 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
STEELE, DEWANDA 11/10/21 VOL 1
1 007:09 - 007:19 007:09 Q. Okay. Mrs. Steele, how did you find
10 Good2Go?
11 A. I didn't actually, there was a gentleman
12 that -- his name was Royal Scott that was in our
13 neighborhood when we went after the hurricane to
14 check on our house, he stopped by. So first he got
15 somebody to do our roof, and then from there he found
16 these people and introduced them to us to do our
17 house.
18 Q. And by "these people" you mean Good2Go?
19 A. Good2Go, yes, ma'am.
2 009:01 - 009:10 009:01 Q. And where were you when you signed the
02 contract?
03 A. On my front porch.
04 Q. And who else was present?
05 A. Just Royal Scott and I.
06 Q. Anybody else present?
07 A. Huh-huh.
08 Q. And do you remember what was the format
09 of the contract that was presented to you?
10 A. The format, there was one page.
3 010:04 - 010:14 010:04 Q. Okay. Did you read any of the portions
05 where you were asked to initial before signing those
06 places?
07 A. Okay. I initialed all three spots. When
08 I initialed this, he said, "Go ahead and put your
09 initials there." Because I asked about this and I
10 said, "What are the terms of service, or the terms of
11 the agreement? There's supposed to more with this."
12 And he said, "I will get that to you."
13 Q. And who is "he"?
14 A. Royal Scott.
4 010:17 - 010:25 010:17 Q. So you read the portion about your
18 signature, which states the terms and conditions and
19 you asked about it?
20 A. Yes.
Created with TranscriptPad for iPad Page 1 of 2
1/10/22
21 Q. And he told you he will?
22 A. Get that to me.
23 Q. So there was nothing --
24 A. There was nothing except for this first
25 page, that was it.
5 011:18 - 011:24 011:18 Q. Okay, and by "those papers", you mean the
19 terms and conditions?
20 A. The terms and conditions, yes.
21 Q. And you read the rest of the contract,
22 which is in the first page?
23 A. What is right there, yes, that first
24 page.
6 012:10 - 012:22 012:10 Q. How do you know that he had printed the
11 contract earlier that day?
12 A. Because he told me he had. He said that
13 he had -- that that was all he could get to print
14 out, he was having trouble with his printer and that
15 he would get the other copies -- the copies of the
16 terms, the rest of the contract to me.
17 Q. Okay. And did you ask him at any point
18 after that for the terms and conditions?
19 A. Repeatedly, repeatedly, every time I saw
20 him for weeks and weeks afterwards, that I still
21 needed the rest of the paperwork that went with the
22 contract.
7 013:25 - 014:04 013:25 A. As I repeat, I will repeat, Royal Scott
014:01 was my point of contact, he was their representative,
02 he had promised me the paperwork. I'm not going to
03 chase down other people within the company to get
04 something that I had already been promised.
8 014:15 - 014:24 014:15 A. I mean, it's -- it says the same thing
16 that the one that I signed does, but it did not have
17 a carbon on the back. It was just a printed out
18 page.
19 BY MS. ENNAJI:
20 Q. So how is it different, can you just
21 explain more how is it different?
22 A. There was no carbon, it did not have
23 anything on the back, it was just a printed sheet of
24 paper.
Created with TranscriptPad for iPad Page 2 of 2
1/10/22
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 DEWANDA STEELE’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 Dewanda Steele’s Limited Deposition Testimony taken on November 10, 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 STEELE, DEWANDA 11/10/21 VOL 1 1 007:09 - 007:19 007:09 Q. Okay. Mrs. Steele, how did you find 10 Good2Go? 11 A. I didn't actually, there was a gentleman 12 that -- his name was Royal Scott that was in our 13 neighborhood when we went after the hurricane to 14 check on our house, he stopped by. So first he got 15 somebody to do our roof, and then from there he found 16 these people and introduced them to us to do our 17 house. 18 Q. And by "these people" you mean Good2Go? 19 A. Good2Go, yes, ma'am. 2 009:01 - 009:10 009:01 Q. And where were you when you signed the 02 contract? 03 A. On my front porch. 04 Q. And who else was present? 05 A. Just Royal Scott and I. 06 Q. Anybody else present? 07 A. Huh-huh. 08 Q. And do you remember what was the format 09 of the contract that was presented to you? 10 A. The format, there was one page. 3 010:04 - 010:14 010:04 Q. Okay. Did you read any of the portions 05 where you were asked to initial before signing those 06 places? 07 A. Okay. I initialed all three spots. When 08 I initialed this, he said, "Go ahead and put your 09 initials there." Because I asked about this and I 10 said, "What are the terms of service, or the terms of 11 the agreement? There's supposed to more with this." 12 And he said, "I will get that to you." 13 Q. And who is "he"? 14 A. Royal Scott. 4 010:17 - 010:25 010:17 Q. So you read the portion about your 18 signature, which states the terms and conditions and 19 you asked about it? 20 A. Yes. Created with TranscriptPad for iPad Page 1 of 2 1/10/22 21 Q. And he told you he will? 22 A. Get that to me. 23 Q. So there was nothing -- 24 A. There was nothing except for this first 25 page, that was it. 5 011:18 - 011:24 011:18 Q. Okay, and by "those papers", you mean the 19 terms and conditions? 20 A. The terms and conditions, yes. 21 Q. And you read the rest of the contract, 22 which is in the first page? 23 A. What is right there, yes, that first 24 page. 6 012:10 - 012:22 012:10 Q. How do you know that he had printed the 11 contract earlier that day? 12 A. Because he told me he had. He said that 13 he had -- that that was all he could get to print 14 out, he was having trouble with his printer and that 15 he would get the other copies -- the copies of the 16 terms, the rest of the contract to me. 17 Q. Okay. And did you ask him at any point 18 after that for the terms and conditions? 19 A. Repeatedly, repeatedly, every time I saw 20 him for weeks and weeks afterwards, that I still 21 needed the rest of the paperwork that went with the 22 contract. 7 013:25 - 014:04 013:25 A. As I repeat, I will repeat, Royal Scott 014:01 was my point of contact, he was their representative, 02 he had promised me the paperwork. I'm not going to 03 chase down other people within the company to get 04 something that I had already been promised. 8 014:15 - 014:24 014:15 A. I mean, it's -- it says the same thing 16 that the one that I signed does, but it did not have 17 a carbon on the back. It was just a printed out 18 page. 19 BY MS. ENNAJI: 20 Q. So how is it different, can you just 21 explain more how is it different? 22 A. There was no carbon, it did not have 23 anything on the back, it was just a printed sheet of 24 paper. Created with TranscriptPad for iPad Page 2 of 2 1/10/22