Party Discovery: BRADSHAW, LORRAINE vs. ALLSTATE FIRE AND CAUSALTY INSURANCE COMPANY

• 
• 
• 
• 

						
                                
Preview
                                Filing # 57885629 E-Filed 06/16/2017 03:45:50 PM


                  IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
                  IN AND FOR ORANGE COUNTY, FLORIDA
                  CIVIL DIVISION

                  LORRAINE BRADSHAW,                                                CASE NO.
                                                                                    2017-CA-003987-O
                  PLAINTIFF,

                  VS.

                  ALLSTATE FIRE AND CASUALTY
                  INSURANCE COMPANY,

                  DEFENDANT.

                                         DEFENDANT’S NOTICE OF TAKING DEPOSITION
                                                    AND REQUEST FOR PRODUCTION
                                     (If an Interpreter is necessary, please advise the undersigned.)

                  PLEASE TAKE NOTICE that the undersigned attorney will take the deposition of:
                   NAME:           LORRAINE BRADSHAW
                                   (Pursuant    to Florida   Rules   of Civil   Procedure 1.310(b)(5)      and 1.350,    Defendant
                                   requests    Plaintiff  to  produce,     at  the  time   and   place   of   this  deposition    for
                                   inspection    and/or    copying,    your    driver's   license   and    any   and   all  original
                                   photographs pertinent to any issues in this lawsuit.)
                   DATE:           October 11, 2017

                   TIME:           10:00 am

                   PLACE:          US LEGAL SUPPORT
                                   20 N. Orange Avenue
                                   Suite 1209
                                   Orlando, FL 32801

                  upon   oral  examination,     before  US   Legal   Support,    Telephone:    4076499193,      a  Notary   Public   in
                  and   for  the  State  of  Florida   at Large,   or  some    other  officer   duly  authorized    by   law  to  take
                  depositions.    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, pursuant    to Florida
                  Rules of Civil Procedure.
                           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.
                  CASE NO.       2017-CA-003987-O




                  Please contact the attorney at the address and phone number listed below within two (2) working
                  days of your receipt of this Notice; if you are hearing or voice impaired, call 711.
                           I HEREBY CERTIFY that on the                16th    day of              June            , 2017,
                  pursuant    to Administrative     Order   No.   AOSC13-49,       a  copy  of  the  foregoing    Notice   of  Taking
                  Deposition and Request for Production has been electronically filed and served using the Florida
                  Courts E-Filing Portal to:
                  Attorney for Plaintiff
                  Lawrence Gonzalez, II, Esquire
                  Morgan & Morgan, P.A.
                  20 N Orange Ave 16th Fl
                  PO Box 4979
                  Orlando FL 32802-4979
                  MCoriano-Lopez@forthepeople.com
                  LGonzalez@forthepeople.com
                  SSerrano@forthepeople.com
                  407-420-1414

                                                                     LAW OFFICES OF ROBERT J. SMITH
                                                                     390 North Orange Avenue, Suite 895
                                                                     Orlando, FL 32801-1635
                                                                     Telephone:                (407) 236-0551
                                                                     Toll Free:                (877) 536-5404 ext 2360551
                                                                     Attorney Direct::         (407) 236-0553
                                                                     Fax:                      (877) 437-1334



                                                                     By:
                                                                            MICHELLE GERJEL
                                                                            FL Bar No. 0838772
                                                                            Attorney for Defendant(s)
                                                                            ALLSTATE FIRE AND CASUALTY
                                                                            INSURANCE COMPANY
                                                                            PRINCIPAL E-MAIL ADDRESS:
                                                                            ORLANDOLEGAL@ALLSTATE.COM


                  Ct:    US Legal Support




                                                                            2