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Filing # 66569447 E-Filed 01/16/2018 11:52:14 AM
IN THE CIRCUIT COURT OF THE 17th
JUDICIAL CIRCUIT IN AND FOR BROWARD
COUNTY, FLORIDA
OCEAN HARBOR CASUALTY
INSURANCE COMPANY, GENERAL JURISDICTION DIVISION
Plaintiff, CASE NO.: CACE18000877 03
v.
CHRISTOPHER M. LEDOUX, AND
SERGIO B. GARCIA,
Defendants.
/
NOTICE OF TAKING TELEPHONE DEPOSITION DUCES TECUM
OF DEFENDANT, CHRISTOPHER M. LEDOUX (Florida)
(Served with Plaintiff’s Complaint for Declaratory Judgment; Deposing Counsel will be Attending Telephonically)
YOU ARE HEREBY NOTIFIED THAT THE UNDERSIGNED INTENDS TO TAKE THE
DEPOSITION OF CHRISTOPHER M. LEDOUX PURSUANT TO FLA.R.CIV.P. 1.310 AND, AS A
PARTY, CHRISTOPHER M. LEDOUX IS COMMANDED TO APPEAR AT THE TIME AND
PLACE LISTED:
NAME: CHRISTOPHER M. LEDOUX
DATE: FEBRUARY 13, 2018
TIME: 4:00 P.M. Eastern Standard Time
PLACE: EXECUTIVE REPORTING SERVICE
ULMERTON BUSINESS CENTER, SUITE 100
13555 AUTOMOBILE BOULEVARD
CLEARWATER, FLORIDA 33762
TELEPHONE: 800-337-7740 / 727-823-4155
REPORTER: EXECUTIVE REPORTING SERVICE
upon oral examination before a Notary Public, or officer authorized by law to take Depositions in the
State of Florida. The oral examination will continue from day to day until completed. The Deposition
will continue from day to day until completed. The Deposition is being taken for the purpose of
discovery, for use at trial, or both of the foregoing, or for such other purposes as are permitted under
the applicable and governing rules.
At the time of the Deposition, the deponent shall bring for inspection and copying those items
listed upon the Duces Tecum Schedule as follows:
*4* FILED: BROWARD COUNTY. FL BRENDA D. FORMAN, CLERK 1/16/2018 11:52:14 AM.****lL.
12.
16.
DUCES TECUM SCHEDULE OF PRODUCTION
Your current Driver's license.
Every document that was issued to you by the state of Florida, including occupational
licenses, driver's licenses, unemployment compensation correspondence and payments,
medical benefits, voter registration and identification cards.
Every document that was issued to you by the state of Oklahoma, including
occupational licenses, driver's licenses, unemployment compensation correspondence
and payments, medical benefits, voter registration and identification cards
Copies of all correspondence that you received from Pearl Holding Group or Ocean
Harbor Casualty Insurance Company.
Copies of all correspondence that you mailed to Pearl Holding Group or Ocean Harbor
Casualty Insurance Company.
A copy of the most recent monthly bank statements for all checking and savings
accounts in the name of or under the controlled by CHROSTOPHER M. LEDOUX.
A copy of your most recent monthly credit card statements.
All monthly bank and credit card statements in the name of CHROSTOPHER M.
LEDOUX for the period January 1, 2016 to the present.
Your first page of your 2015 and 2016 tax returns filed with the United States
government and any state in which you were a resident for the same period.
The first page of any tax return filed with the state of Florida and with the state of
Oklahoma.
All monthly bills in your possession regarding telephones, cable, gas and electric
utilities, pertaining to any property at which you reside or any telephone that you used
for the period January 1, 2016 to the present.
All monthly bills in your possession regarding every cellular telephone that you use,
whether in your name or not during the period January 1, 2016 to the present.
A copy of your last or most recent pay check, pay voucher.
Every document in your possession which identifies your present employer.
A copy of the automobile insurance policy that you purchase prior to September 3,
2016.
A copy of the automobile insurance policy that you purchase and were in effect between
217.
18.
19.
20.
January 1, 2016 and the present date.
Every lease for any apartment or property on which you were a tenant, co-tenant, or
roommate from January 1, 2016 to the present.
Proof of any rent payments made by you from January 1, 2016 to the present.
All W-2 forms and 1099 forms issued in the name of CHROSTOPHER M. LEDOUX
from January 1, 2016 to the present.
Your current health insurance card which identifies your health insurer.
If you fail to appear, you may be in contempt of court.
You are REQUIRED to appear by the following attorney and unless excused by these
attorneys or the court, you shall respond to this Notice of Taking Deposition, as directed.
NOTE: IF YOU ATTEND THIS FLORIDA DEPOSITION, THEN YOU WILL BE EXCUSED
FROM ATTENDING THE OKLAHOMA DEPOSITION.
Dated January 11, 2018.
ce:
ROBERT E. O’CONNELL. P.A.
Attorneys for Plaintiff
1701 West Hillsboro Blvd., Suite 304
Deerfield Beach, Florida 33442
Telephone: 954-482-0424
Facsimile: 954-977-7676
Email:
om (primary)
office@reo-law.com (secondary)
e:/s/ Robert E. O'Connell
By:
ROBERT E. O’CONNELL, ESQ.
Florida Bar No.: 315842
Executive Reporting Service
Email(s):
Telephone:
ERS@WExecutiveReporting.com
800-337-7740 / 727-823-4155
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Filing # 66569447 E-Filed 01/16/2018 11:52:14 AM IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA OCEAN HARBOR CASUALTY INSURANCE COMPANY, GENERAL JURISDICTION DIVISION Plaintiff, CASE NO.: CACE18000877 03 v. CHRISTOPHER M. LEDOUX, AND SERGIO B. GARCIA, Defendants. / NOTICE OF TAKING TELEPHONE DEPOSITION DUCES TECUM OF DEFENDANT, CHRISTOPHER M. LEDOUX (Florida) (Served with Plaintiff’s Complaint for Declaratory Judgment; Deposing Counsel will be Attending Telephonically) YOU ARE HEREBY NOTIFIED THAT THE UNDERSIGNED INTENDS TO TAKE THE DEPOSITION OF CHRISTOPHER M. LEDOUX PURSUANT TO FLA.R.CIV.P. 1.310 AND, AS A PARTY, CHRISTOPHER M. LEDOUX IS COMMANDED TO APPEAR AT THE TIME AND PLACE LISTED: NAME: CHRISTOPHER M. LEDOUX DATE: FEBRUARY 13, 2018 TIME: 4:00 P.M. Eastern Standard Time PLACE: EXECUTIVE REPORTING SERVICE ULMERTON BUSINESS CENTER, SUITE 100 13555 AUTOMOBILE BOULEVARD CLEARWATER, FLORIDA 33762 TELEPHONE: 800-337-7740 / 727-823-4155 REPORTER: EXECUTIVE REPORTING SERVICE upon oral examination before a Notary Public, or officer authorized by law to take Depositions in the State of Florida. The oral examination will continue from day to day until completed. The Deposition will continue from day to day until completed. The Deposition is being taken for the purpose of discovery, for use at trial, or both of the foregoing, or for such other purposes as are permitted under the applicable and governing rules. At the time of the Deposition, the deponent shall bring for inspection and copying those items listed upon the Duces Tecum Schedule as follows: *4* FILED: BROWARD COUNTY. FL BRENDA D. FORMAN, CLERK 1/16/2018 11:52:14 AM.****lL. 12. 16. DUCES TECUM SCHEDULE OF PRODUCTION Your current Driver's license. Every document that was issued to you by the state of Florida, including occupational licenses, driver's licenses, unemployment compensation correspondence and payments, medical benefits, voter registration and identification cards. Every document that was issued to you by the state of Oklahoma, including occupational licenses, driver's licenses, unemployment compensation correspondence and payments, medical benefits, voter registration and identification cards Copies of all correspondence that you received from Pearl Holding Group or Ocean Harbor Casualty Insurance Company. Copies of all correspondence that you mailed to Pearl Holding Group or Ocean Harbor Casualty Insurance Company. A copy of the most recent monthly bank statements for all checking and savings accounts in the name of or under the controlled by CHROSTOPHER M. LEDOUX. A copy of your most recent monthly credit card statements. All monthly bank and credit card statements in the name of CHROSTOPHER M. LEDOUX for the period January 1, 2016 to the present. Your first page of your 2015 and 2016 tax returns filed with the United States government and any state in which you were a resident for the same period. The first page of any tax return filed with the state of Florida and with the state of Oklahoma. All monthly bills in your possession regarding telephones, cable, gas and electric utilities, pertaining to any property at which you reside or any telephone that you used for the period January 1, 2016 to the present. All monthly bills in your possession regarding every cellular telephone that you use, whether in your name or not during the period January 1, 2016 to the present. A copy of your last or most recent pay check, pay voucher. Every document in your possession which identifies your present employer. A copy of the automobile insurance policy that you purchase prior to September 3, 2016. A copy of the automobile insurance policy that you purchase and were in effect between 217. 18. 19. 20. January 1, 2016 and the present date. Every lease for any apartment or property on which you were a tenant, co-tenant, or roommate from January 1, 2016 to the present. Proof of any rent payments made by you from January 1, 2016 to the present. All W-2 forms and 1099 forms issued in the name of CHROSTOPHER M. LEDOUX from January 1, 2016 to the present. Your current health insurance card which identifies your health insurer. If you fail to appear, you may be in contempt of court. You are REQUIRED to appear by the following attorney and unless excused by these attorneys or the court, you shall respond to this Notice of Taking Deposition, as directed. NOTE: IF YOU ATTEND THIS FLORIDA DEPOSITION, THEN YOU WILL BE EXCUSED FROM ATTENDING THE OKLAHOMA DEPOSITION. Dated January 11, 2018. ce: ROBERT E. O’CONNELL. P.A. Attorneys for Plaintiff 1701 West Hillsboro Blvd., Suite 304 Deerfield Beach, Florida 33442 Telephone: 954-482-0424 Facsimile: 954-977-7676 Email: om (primary) office@reo-law.com (secondary) e:/s/ Robert E. O'Connell By: ROBERT E. O’CONNELL, ESQ. Florida Bar No.: 315842 Executive Reporting Service Email(s): Telephone: ERS@WExecutiveReporting.com 800-337-7740 / 727-823-4155