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Filing # 144829393 E-Filed 03/01/2022 02:36:38 PM
IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT
IN AND FOR ALACHUA COUNTY, FLORIDA
RICHANTAE A. JOHNSON, individually,
Plaintiff,
CASE NO.: 2021-CA-102
Vv.
DIVISION: J
THE CITY OF GAINESVILLE, FLORIDA,
Defendant.
/
DEFENDANT'S NOTICE OF PRODUCTION FROM NON-PARTY
TO: Ryan McNeill, Esquire
Reginal J. Reeves, Esquire
via email (rmeneill@esquirelitgroup.com; jessica@esquirelitgroup.com;
rreeves@esquirelitgroup.com; wreeves@esquirelitgroup.com)
YOU ARE NOTIFIED that after 10 days from the date of service of this notice, if
service is by delivery, or 15 days from the date of service, if service is by mail, and if no
objection is received from any party, the undersigned will issue or will apply to the clerk of this
court for issuance of the attached subpoena directed to:
AT&T Wireless
who is not a party in this action, to produce the items listed at the time and place specified in the
attached subpoena.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
electronic mail to Ryan McNeill, Esquire, (rmcneill@esquirelitgroup.com;
jessica@esquirelitgroup.com; wreeves@esquirelitgroup.com) and Reganel J. Reeves, Esquire,
(rreeves@esquirelitgroup.com) on this 1st day of March, 2022.
/s/ Brian W. Franklin
Brian W. Franklin, Senior Assistant City Attorney
Florida Bar No.: 0116695
Daniel M. Nee, B.C.S., Interim City Attorney
Board Certified in City, County and Local Government Law
Florida Bar No.: 0047521
City of Gainesville - Office of the City Attorney
1
"2021 CA 000102" 144829393 Filed at Alachua County Clerk 03/01/2022 02:36:45 PM ESTP.O. Box 490, Station 46
Gainesville, Florida 32627
needm@cityofgainesville.org
franklinbw@cityofgainesville.org
whitecg@cityofgainesville.org
Phone: (352) 334-5011
Fax: (352) 334-2229IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT
IN AND FOR ALACHUA COUNTY, FLORIDA
RICHANTAE A. JOHNSON, individually,
Plaintiff,
CASE NO.: 2021-CA-102
v.
DIVISION: J
THE CITY OF GAINESVILLE, FLORIDA,
Defendant.
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**TF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: AT&T Wireless
Via Email (gide@att.com) & Fax (888) 938-4715
HIPAA COMPLIANCE
In compliance with HIPAA Guidelines, this patient and/or his attorney has been given
notice to object to our obtaining these records and this exact form has been provided to the
patient and/or the patient’s legal counsel.
YOU ARE COMMANDED to do one of the following at your option:
1. Mail legible copies of the documents listed to 200 East University Avenue, Room
425, Gainesville, FL 32601 by April 1, 2022 or fifteen (15) days from the date this
subpoena is served; or
2. Appear at 200 East University Avenue, Room 425, Gainesville, FL 32601 with
legible copies of the documents listed below on April 1, 2022. PLEASE CONTACT
THE UNDERSIGNED’S OFFICE SHOULD YOU CHOOSE TO APPEAR.
THE RECORDS TO BE PROVIDED ARE:
All billing and usage records for phone number 239-XXX-XXXX, for the date of July 1,
2019 (from 12 A.M. EST to 11:59 P.M. EST), including but not limited to incoming and
outgoing call history, call duration, call details, computer generated messages, and text
message logs and content.These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. You may comply with this subpoena by giving legible copies of
the items to be produced to the attorney whose name appears on this subpoena on or before
the scheduled date of production. You may condition the preparation of the copies upon the
payment in advance of the reasonable cost of preparation.
SHOULD THE COST OF PRODUCTION EXCEED $50.00, PLEASE CONTACT
THE LEGAL ASSISTANT AT (352) 393-8821 FOR APPROVAL.
You may mail or deliver the copies to the attorney whose name appears on this
subpoena and thereby eliminate your appearance at the time and place specified above. IF
YOU DO NOT HAVE ANY RECORDS IN YOUR POSSESSION, PLEASE PROVIDE
OUR OFFICE WITH A LETTER REFLECTING YOU WERE UNABLE TO LOCATE
ANY RECORDS. You have the right to object to the production pursuant to this subpoena at
any time before production by giving written notice to the attorney whose name appears on this
subpoena. THIS WILL NOT BE A DEPOSITION, NO TESTIMONY WILL BE TAKEN.
If you fail to:
(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena,
you may be in contempt of court. You are subpoenaed to appear by the following attorney, and
unless excused from this subpoena by this attorney or the Court, you shall respond to this
subpoena as directed.
DATED on , 2022.
FOR THE COURT:
/s/ Brian W. Franklin
Brian W. Franklin, Senior Assistant City Attorney
Florida Bar No.: 0116695
Daniel M. Nee, B.C.S., Interim City Attorney
Board Certified in City, County and Local Government Law
Florida Bar No.: 0047521
City of Gainesville - Office of the City Attorney
P.O. Box 490, Station 46
Gainesville, Florida 32627
franklinbw@cityofgainesville.org
needm@cityofgainesville.org
whitecg@cityofgainesville.org
Phone: (352) 334-5011
Fax: (352) 334-2229
Preview
Filing # 144829393 E-Filed 03/01/2022 02:36:38 PM IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT IN AND FOR ALACHUA COUNTY, FLORIDA RICHANTAE A. JOHNSON, individually, Plaintiff, CASE NO.: 2021-CA-102 Vv. DIVISION: J THE CITY OF GAINESVILLE, FLORIDA, Defendant. / DEFENDANT'S NOTICE OF PRODUCTION FROM NON-PARTY TO: Ryan McNeill, Esquire Reginal J. Reeves, Esquire via email (rmeneill@esquirelitgroup.com; jessica@esquirelitgroup.com; rreeves@esquirelitgroup.com; wreeves@esquirelitgroup.com) YOU ARE NOTIFIED that after 10 days from the date of service of this notice, if service is by delivery, or 15 days from the date of service, if service is by mail, and if no objection is received from any party, the undersigned will issue or will apply to the clerk of this court for issuance of the attached subpoena directed to: AT&T Wireless who is not a party in this action, to produce the items listed at the time and place specified in the attached subpoena. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by electronic mail to Ryan McNeill, Esquire, (rmcneill@esquirelitgroup.com; jessica@esquirelitgroup.com; wreeves@esquirelitgroup.com) and Reganel J. Reeves, Esquire, (rreeves@esquirelitgroup.com) on this 1st day of March, 2022. /s/ Brian W. Franklin Brian W. Franklin, Senior Assistant City Attorney Florida Bar No.: 0116695 Daniel M. Nee, B.C.S., Interim City Attorney Board Certified in City, County and Local Government Law Florida Bar No.: 0047521 City of Gainesville - Office of the City Attorney 1 "2021 CA 000102" 144829393 Filed at Alachua County Clerk 03/01/2022 02:36:45 PM ESTP.O. Box 490, Station 46 Gainesville, Florida 32627 needm@cityofgainesville.org franklinbw@cityofgainesville.org whitecg@cityofgainesville.org Phone: (352) 334-5011 Fax: (352) 334-2229IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT IN AND FOR ALACHUA COUNTY, FLORIDA RICHANTAE A. JOHNSON, individually, Plaintiff, CASE NO.: 2021-CA-102 v. DIVISION: J THE CITY OF GAINESVILLE, FLORIDA, Defendant. SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **TF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: AT&T Wireless Via Email (gide@att.com) & Fax (888) 938-4715 HIPAA COMPLIANCE In compliance with HIPAA Guidelines, this patient and/or his attorney has been given notice to object to our obtaining these records and this exact form has been provided to the patient and/or the patient’s legal counsel. YOU ARE COMMANDED to do one of the following at your option: 1. Mail legible copies of the documents listed to 200 East University Avenue, Room 425, Gainesville, FL 32601 by April 1, 2022 or fifteen (15) days from the date this subpoena is served; or 2. Appear at 200 East University Avenue, Room 425, Gainesville, FL 32601 with legible copies of the documents listed below on April 1, 2022. PLEASE CONTACT THE UNDERSIGNED’S OFFICE SHOULD YOU CHOOSE TO APPEAR. THE RECORDS TO BE PROVIDED ARE: All billing and usage records for phone number 239-XXX-XXXX, for the date of July 1, 2019 (from 12 A.M. EST to 11:59 P.M. EST), including but not limited to incoming and outgoing call history, call duration, call details, computer generated messages, and text message logs and content.These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by giving legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. SHOULD THE COST OF PRODUCTION EXCEED $50.00, PLEASE CONTACT THE LEGAL ASSISTANT AT (352) 393-8821 FOR APPROVAL. You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above. IF YOU DO NOT HAVE ANY RECORDS IN YOUR POSSESSION, PLEASE PROVIDE OUR OFFICE WITH A LETTER REFLECTING YOU WERE UNABLE TO LOCATE ANY RECORDS. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION, NO TESTIMONY WILL BE TAKEN. If you fail to: (1) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena, you may be in contempt of court. You are subpoenaed to appear by the following attorney, and unless excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as directed. DATED on , 2022. FOR THE COURT: /s/ Brian W. Franklin Brian W. Franklin, Senior Assistant City Attorney Florida Bar No.: 0116695 Daniel M. Nee, B.C.S., Interim City Attorney Board Certified in City, County and Local Government Law Florida Bar No.: 0047521 City of Gainesville - Office of the City Attorney P.O. Box 490, Station 46 Gainesville, Florida 32627 franklinbw@cityofgainesville.org needm@cityofgainesville.org whitecg@cityofgainesville.org Phone: (352) 334-5011 Fax: (352) 334-2229