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Filing # 112537408 E-Filed 08/28/2020 10:33:28 AM
IN THE CIRCUIT COURT OF THE EIGHT JUDICIAL CIRCUIT
IN AND FOR ALACHUA COUNTY FLORIDA
GALE ARLEDGE and
TERRANCE ARLEDGE,
her husband, CASE NO: = 2018-CA-004032
DIVISION: _ Circuit Civil
Plaintiffs,
Vv.
13TH STREET HOMES SALES, LLC,
Defendant.
NOTICE OF TAKING VIRTUAL DEPOSITION OF DR. SHAHNASARIAN
PLEASE TAKE NOTICE that on October 29, 2020, beginning at 4:00 p.m., the
undersigned will take the virtual deposition of Michael Shahnasarian, Ph.D., before Phipps
Reporting, located at 100 Ashley Dr. S #475, Tampa, FL 33602, or other Notary Public
authorized by law to take a virtual deposition. Said deposition is to be taken for discovery
purposes, for use as evidence, for use at trial, or for such other purpose as authorized by law and
the Florida Rules of Civil Procedure, and shall be continued from day to day until completed.
The Deponent is further commanded to bring with you at the time and place the requested
materials noted in Schedule “A” attached.
If you are a person with a disability who needs any accommodation in order to
participate in this proceeding, you are entitled, at no cost to you, to the provision of certain
assistance. Please contact the Office of the Court Administrator, (863) 534-4690, within two
(2) working days of your receipt of this (describe notice); if you are hearing or voice
impaired, call TDD (863) 534-7777 or Florida Relay Service 711.
"2018 CA 004032" 112537408 Filed at Alachua County Clerk 08/28/2020 10:33:32 AM EDTCERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 28" day of August, 2020, this document was filed
using the Florida Courts E-Filing Portal pursuant to and in compliance with Fla. R. Jud. Admin.
2.516. The mailing address for opposing counsel is: Carla Sabbagh and Michael S. Rywant,
Rywant, Alvarez, Jones, Russo & Guyton, P.A., 2440 S.W. 76th Street, Suite 130, Gainesville,
FL 32608.
lo] Games P. Brunet
JAMES P. BRUNET (FL Bar No. 016416)
REBECCA H. COZART (FL Bar No. 0487570)
RONALD E. SHOLES, P.A.
8761 Perimeter Park Blvd., Suite 104
Jacksonville, Florida 32216
Ph: 904-661-3730 Fax: 904-683-9282
Primary Email:
RonSholesPA-Team4-Eservice@ Y ouHurtWeFight.com
Attorney for Plaintiff10.
11.
12.
13.
SCHEDULE “A”
Your entire file provided three days prior to your deposition.
Any and all materials you reviewed in this matter, including, but not limited to correspondence,
reports, books, articles, literature, statements, or other reference materials that you used or are
relying on.
Any and all reports you prepared or furnished in this case.
Any and all reports which were furnished to you by other experts or other individuals (including
attorneys) in this case.
Your curriculum vitae.
Your complete billing file in this case, including, but not limited to, the charges you have
rendered, the statements that you have rendered, the time spent on this case, and other relevant
materials concerning the time and billing on this case.
Any and all notes, writings, memoranda, etc., which you have prepared on this case.
Any and all computer printouts from computers used by you or your agents, servants or
employees.
Any and all notes taken or prepared by you or your agents, servants or employees which were
prepared for this case.
Any and all literature written by you.
A list of all cases in which you have been retained to testify in the past three years, including the
name of the attorney who retained you, the name of the case which you reviewed, the court and
judicial circuit in which the case was filed and the case number.
A copy of any and all correspondence, whether written or electronic (e-mail), either directed to
you from Plaintiffs counsel or written by you to Plaintiff's counsel.
All textbooks, journals or similar literature, or any other documents or materials upon which you
have relied in order to arrive at any opinions which you will render in this case.
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Filing # 112537408 E-Filed 08/28/2020 10:33:28 AM IN THE CIRCUIT COURT OF THE EIGHT JUDICIAL CIRCUIT IN AND FOR ALACHUA COUNTY FLORIDA GALE ARLEDGE and TERRANCE ARLEDGE, her husband, CASE NO: = 2018-CA-004032 DIVISION: _ Circuit Civil Plaintiffs, Vv. 13TH STREET HOMES SALES, LLC, Defendant. NOTICE OF TAKING VIRTUAL DEPOSITION OF DR. SHAHNASARIAN PLEASE TAKE NOTICE that on October 29, 2020, beginning at 4:00 p.m., the undersigned will take the virtual deposition of Michael Shahnasarian, Ph.D., before Phipps Reporting, located at 100 Ashley Dr. S #475, Tampa, FL 33602, or other Notary Public authorized by law to take a virtual deposition. Said deposition is to be taken for discovery purposes, for use as evidence, for use at trial, or for such other purpose as authorized by law and the Florida Rules of Civil Procedure, and shall be continued from day to day until completed. The Deponent is further commanded to bring with you at the time and place the requested materials noted in Schedule “A” attached. If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact the Office of the Court Administrator, (863) 534-4690, within two (2) working days of your receipt of this (describe notice); if you are hearing or voice impaired, call TDD (863) 534-7777 or Florida Relay Service 711. "2018 CA 004032" 112537408 Filed at Alachua County Clerk 08/28/2020 10:33:32 AM EDTCERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 28" day of August, 2020, this document was filed using the Florida Courts E-Filing Portal pursuant to and in compliance with Fla. R. Jud. Admin. 2.516. The mailing address for opposing counsel is: Carla Sabbagh and Michael S. Rywant, Rywant, Alvarez, Jones, Russo & Guyton, P.A., 2440 S.W. 76th Street, Suite 130, Gainesville, FL 32608. lo] Games P. Brunet JAMES P. BRUNET (FL Bar No. 016416) REBECCA H. COZART (FL Bar No. 0487570) RONALD E. SHOLES, P.A. 8761 Perimeter Park Blvd., Suite 104 Jacksonville, Florida 32216 Ph: 904-661-3730 Fax: 904-683-9282 Primary Email: RonSholesPA-Team4-Eservice@ Y ouHurtWeFight.com Attorney for Plaintiff10. 11. 12. 13. SCHEDULE “A” Your entire file provided three days prior to your deposition. Any and all materials you reviewed in this matter, including, but not limited to correspondence, reports, books, articles, literature, statements, or other reference materials that you used or are relying on. Any and all reports you prepared or furnished in this case. Any and all reports which were furnished to you by other experts or other individuals (including attorneys) in this case. Your curriculum vitae. Your complete billing file in this case, including, but not limited to, the charges you have rendered, the statements that you have rendered, the time spent on this case, and other relevant materials concerning the time and billing on this case. Any and all notes, writings, memoranda, etc., which you have prepared on this case. Any and all computer printouts from computers used by you or your agents, servants or employees. Any and all notes taken or prepared by you or your agents, servants or employees which were prepared for this case. Any and all literature written by you. A list of all cases in which you have been retained to testify in the past three years, including the name of the attorney who retained you, the name of the case which you reviewed, the court and judicial circuit in which the case was filed and the case number. A copy of any and all correspondence, whether written or electronic (e-mail), either directed to you from Plaintiffs counsel or written by you to Plaintiff's counsel. All textbooks, journals or similar literature, or any other documents or materials upon which you have relied in order to arrive at any opinions which you will render in this case.