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Filing # 104310672 E-Filed 03/04/2020 11:11:57 AM
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 VIDEO DEPOSITION DUCES TECUM
PLEASE TAKE NOTICE the Defendant, 13" STREET HOME SALES, LLC, will take
the deposition by oral examination, pursuant to the Florida Rules of Civil Procedure and the Florida
Statutes, of the persons named below, at the times, on the dates, at the hours and at the places
indicated:
WITNESSES DATE/TIME LOCATION
Sea Spine Orthopedic Institute
3107 W. Hallandale Beach Blvd.
Unit 100
Pembroke Park, FL 33009
866-8 16-7846
March 20, 2020
Andrew Joshua Appel, M.D. 10:00 a.m.
before Orange Legal, Court Reporters and Notary Public, and videographer, a
representative designated by Orange Legal, 3440 Hollywood Blvd., Suite 415, Hollywood, FL
33021 or before its duly designated representative, 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 day until completed. The deponent is to have with him
at the deposition a state or military issued identification card or valid passport as well as those
items listed on Exhibit A attached hereto.
"2018 CA 004032" 104310672 Filed at Alachua County Clerk 03/04/2020 11:13:04 AM ESTCERTIFICATE 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@YouHurtWeFight.com, this 4th
day of March 2020.
ce: calendar-orange@veritext.com
jimmy.singh@orangelegal.com
s/Carla M. Sabbagh
Michael S. Rywant, Esquire
Florida Bar No.: 240354
Primary email:msrywant@rywantalvarez.com
Secondary: — service@rywantalvarez.com
nginn@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 your examination and/or
treatment of Plaintiff: Gale Arledge.
2. A current copy of your Curriculum Vitae (CV) or resume.
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Filing # 104310672 E-Filed 03/04/2020 11:11:57 AM 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 VIDEO DEPOSITION DUCES TECUM PLEASE TAKE NOTICE the Defendant, 13" STREET HOME SALES, LLC, will take the deposition by oral examination, pursuant to the Florida Rules of Civil Procedure and the Florida Statutes, of the persons named below, at the times, on the dates, at the hours and at the places indicated: WITNESSES DATE/TIME LOCATION Sea Spine Orthopedic Institute 3107 W. Hallandale Beach Blvd. Unit 100 Pembroke Park, FL 33009 866-8 16-7846 March 20, 2020 Andrew Joshua Appel, M.D. 10:00 a.m. before Orange Legal, Court Reporters and Notary Public, and videographer, a representative designated by Orange Legal, 3440 Hollywood Blvd., Suite 415, Hollywood, FL 33021 or before its duly designated representative, 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 day until completed. The deponent is to have with him at the deposition a state or military issued identification card or valid passport as well as those items listed on Exhibit A attached hereto. "2018 CA 004032" 104310672 Filed at Alachua County Clerk 03/04/2020 11:13:04 AM ESTCERTIFICATE 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@YouHurtWeFight.com, this 4th day of March 2020. ce: calendar-orange@veritext.com jimmy.singh@orangelegal.com s/Carla M. Sabbagh Michael S. Rywant, Esquire Florida Bar No.: 240354 Primary email:msrywant@rywantalvarez.com Secondary: — service@rywantalvarez.com nginn@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 your examination and/or treatment of Plaintiff: Gale Arledge. 2. A current copy of your Curriculum Vitae (CV) or resume.