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Filing # 107628693 E-Filed 05/18/2020 03:32:02 PM
IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT
IN AND FOR ALACHUA COUNTY, FLORIDA
CIVIL DIVISION
GALE ARLEDGE and
TERRANCE ARLEDGE,
her husband,
Plaintiffs, CASE NO: 01-2018-CA-004032
v.
13™ STREET HOME SALES, LLC,
Defendant.
NOTICE OF TAKING VIRTUAL DEPOSITION DUCES TECUM
PLEASE TAKE NOTICE that the Defendant, 13! STREET HOME SALES, LLC, by and
through undersigned counsel, will take the deposition by oral examination, pursuant to the Florida
Rules of Civil Procedure and the Florida Statutes, of the person named below, at the time, on the
date, at the hour and at the place indicated:
WITNESSES DATE/TIME LOCATION
Beaches Open MRI
350 10th Avenue South,
Jacksonville Beach, FL 32250
June 19, 2020
Mark Frisk, M.D. 2:00 p.m.
Before Orange Legal, Court Reporters and Notary Public, or before their duly designated
representative by utilizing digital audio recording equipment or any other alternative methods of
capture, for discovery purposes, for use as evidence at trial, or both, or for such other purposes as
are permitted under the applicable and governing rules. The deposition will continue from day to
"2018 CA 004032" 107628693 Filed at Alachua County Clerk 05/18/2020 03:32:05 PM EDTday until completed. The deponent is to have with him at his deposition a state or military issued
identification card or valid passport as well as those items listed on Exhibit A attached hereto.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been e-served
through the Florida Courts E-filing Portal to: Rebecca H. Cozart, Esq., Ronald E. Sholes, P.A.,
8761 Perimeter Park Blvd., Suite 104, Jacksonville, Florida 32216 at RonSholesPA-Team4-
Eservice@ YouHurtWeFight.com; Team20-Premises-Eservice@Y ouHurtWeFight.com, this 18th
day of May 2020.
s/Carla M. Sabbagh
Michael S. Rywant, Esquire
Florida Bar No.: 240354
Primary email:msrywant@rywantalvarez.com
Secondary: service@rywantalvarez.com
cburke@rywantalvarez.com
Carla M. Sabbagh, Esquire
Florida Bar No.: 72727
Primary email:csabbagh@rywantalvarez.com
Secondary: — creneke@rywantalvarez.com
Rywant, Alvarez, Jones, Russo & Guyton, P.A.
2440 S.W. 76" Street Ste. 130
Gainesville, FL 32608
(Tel) 352-333-3700 / (Fax) 352-333-3706
Attorneys for Defendant, 13" Street Home Sales,
LLCEXHIBIT A
1. All medical records, including but not limited to notes, charts, diagnostic test
reports, pharmacy records, prescription records, billing records, payments received,
accounting ledgers, reports and/or correspondence prepared for attorneys and all
correspondence received by the witness from attorneys, patient forms and
questionnaires and any other information provided by the patient, letters of
protection and liens, diagnostic or radiographic imaging, studies and reports,
medical records and reports provided by hospitals and other medical providers, any
and all referral arrangements from the patient’s attorney, and every written piece of
paper included within the patient’s chart, including a copy of any notations on the
file jacket, etc., pertaining to any conclusions and/or opinions regarding the injuries
sustained by the Plaintiff, GALE ARLEDGE, prior to or following September 20,
2017, and causation for same.
2. Accurrent copy of your curriculum vitae (CV) or resume.
3. A state or military issued identification card or valid passport
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Filing # 107628693 E-Filed 05/18/2020 03:32:02 PM IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT IN AND FOR ALACHUA COUNTY, FLORIDA CIVIL DIVISION GALE ARLEDGE and TERRANCE ARLEDGE, her husband, Plaintiffs, CASE NO: 01-2018-CA-004032 v. 13™ STREET HOME SALES, LLC, Defendant. NOTICE OF TAKING VIRTUAL DEPOSITION DUCES TECUM PLEASE TAKE NOTICE that the Defendant, 13! STREET HOME SALES, LLC, by and through undersigned counsel, will take the deposition by oral examination, pursuant to the Florida Rules of Civil Procedure and the Florida Statutes, of the person named below, at the time, on the date, at the hour and at the place indicated: WITNESSES DATE/TIME LOCATION Beaches Open MRI 350 10th Avenue South, Jacksonville Beach, FL 32250 June 19, 2020 Mark Frisk, M.D. 2:00 p.m. Before Orange Legal, Court Reporters and Notary Public, or before their duly designated representative by utilizing digital audio recording equipment or any other alternative methods of capture, for discovery purposes, for use as evidence at trial, or both, or for such other purposes as are permitted under the applicable and governing rules. The deposition will continue from day to "2018 CA 004032" 107628693 Filed at Alachua County Clerk 05/18/2020 03:32:05 PM EDTday until completed. The deponent is to have with him at his deposition a state or military issued identification card or valid passport as well as those items listed on Exhibit A attached hereto. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been e-served through the Florida Courts E-filing Portal to: Rebecca H. Cozart, Esq., Ronald E. Sholes, P.A., 8761 Perimeter Park Blvd., Suite 104, Jacksonville, Florida 32216 at RonSholesPA-Team4- Eservice@ YouHurtWeFight.com; Team20-Premises-Eservice@Y ouHurtWeFight.com, this 18th day of May 2020. s/Carla M. Sabbagh Michael S. Rywant, Esquire Florida Bar No.: 240354 Primary email:msrywant@rywantalvarez.com Secondary: service@rywantalvarez.com cburke@rywantalvarez.com Carla M. Sabbagh, Esquire Florida Bar No.: 72727 Primary email:csabbagh@rywantalvarez.com Secondary: — creneke@rywantalvarez.com Rywant, Alvarez, Jones, Russo & Guyton, P.A. 2440 S.W. 76" Street Ste. 130 Gainesville, FL 32608 (Tel) 352-333-3700 / (Fax) 352-333-3706 Attorneys for Defendant, 13" Street Home Sales, LLCEXHIBIT A 1. All medical records, including but not limited to notes, charts, diagnostic test reports, pharmacy records, prescription records, billing records, payments received, accounting ledgers, reports and/or correspondence prepared for attorneys and all correspondence received by the witness from attorneys, patient forms and questionnaires and any other information provided by the patient, letters of protection and liens, diagnostic or radiographic imaging, studies and reports, medical records and reports provided by hospitals and other medical providers, any and all referral arrangements from the patient’s attorney, and every written piece of paper included within the patient’s chart, including a copy of any notations on the file jacket, etc., pertaining to any conclusions and/or opinions regarding the injuries sustained by the Plaintiff, GALE ARLEDGE, prior to or following September 20, 2017, and causation for same. 2. Accurrent copy of your curriculum vitae (CV) or resume. 3. A state or military issued identification card or valid passport