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Filing # 108103467 E-Filed 05/29/2020 09:14:36 AM
COSTCO WHOLESALE CORPORATION, IN THE CIRCUIT COURT FOR THE
17TH JUDICIAL CIRCUIT IN AND
Plaintiff, FOR BROWARD COUNTY, FLORIDA
vs. CASE NO.: CACE 19-022183
COMUTEL SOLUTIONS LLC, and USIC, LLC
Defendants.
USIC, LLC’S NOTICE OF DEPOSITION OF CORPORATE REPRESENTATIVE FOR
COSTCO WHOLESALE CORPORATION
TO: Costco Wholesale Corporation
c/o David Cooney, Esquire
dcooney@ctkplaw.com; Reception@ctkplaw.com; tzaccour@ctkplaw.com
COONEY, TRYBUS, KWAVNICK, PEETS
1600 W. Commercial Blvd, Suite 200
Fort Lauderdale, FL 33309
PLEASE TAKE NOTICE that on June 22, 2020, at 2:00 PM at the offices of Cooney, Trybus,
Kwavnick, Peets, 1600 W. Commercial Blvd., Suite 200, Fort Lauderdale, FL 33309, Defendant USIC
Locating Services, LLC (“USIC”) will take the deposition of the Corporate Representative of Plaintiff
Costco Wholesale Corporation (“Costco”), pursuant to Rule 1.310(b)(6), Florida Rules of Civil
Procedure. The aforesaid deposition shall be taken upon oral examination, under oath, before a person
authorized by law to take depositions, and shall continue from time to time and from day to day until
completed. Such deposition is being taken for purposes of discovery, for use at trial and for such other
purposes as are authorized by the Florida Rules of Civil Procedure.
Costco shall designate one or more officers, directors, or managing agents or other persons
who consent to do so, to testify on its behalf with respect to the matters described in the attached
Schedule “A.”
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
undersigned counsel at least 7 days before your scheduled deposition, or immediately upon receiving
this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or
voice impaired, call 711.
010-8985-1502/1/AMERICAS
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/29/2020 09:14:36 AM.****SCHEDULE “A”
1. Costco’s Complaint filed in this lawsuit.
2. Any and all steps taken by Costco to identify the location of and/or protect the underground utility
damaged in connection with this lawsuit prior to the damage referenced in the Complaint.
3. The facts and circumstances regarding how the utility strike giving rise to this lawsuit occurred.
4. Costco’s investigation of the utility strike giving rise to this lawsuit, including any evidence and
materials collected during such an investigation.
5. Costco’s responses to all interrogatories, requests for production, and requests for admission
propounded to Costco in this lawsuit.
6. Costco’s involvement and/or participation in Florida’s One Call system (d/b/a Sunshine 811), in
connection with the utility strike giving rise to this lawsuit.
7. Costco’s factual basis for including USIC as a defendant in this lawsuit.
8. The damages claimed by Costco in this lawsuit.
Dated: May 29, 2020 Respectfully Submitted,
SQUIRE PATTON BOGGS (US) LLP
200 South Biscayne Blvd, Suite 4700
Miami, FL 33131
Telephone: (305) 577-7000
Facsimile: (305) 577-7001
By: 4/P. Jan Kubicz
Jason Daniel Joffe
Florida Bar No. 0013564
Email: jason.joffe@squirepb.com
Copy to: joan.andersondavis@squirepb.com
P. Jan Kubicz
Florida Bar No. 84405
Email: jan.kubicz@squirepb.com
Attorneys for Defendant USIC, LLC d/b/a
USIC Locating Services, LLC
010-8985-1502/1/AMERICASCERTIFICATE OF SERVICE
I HEREBY CERTIFY that on May 29, 2020, a true and correct copy of the foregoing was filed and
served on all counsel of record via the Florida Courts E-Portal.
4s/P. Jan Kubicz
P. Jan Kubicz
010-8985-1502/1/AMERICAS
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Filing # 108103467 E-Filed 05/29/2020 09:14:36 AM COSTCO WHOLESALE CORPORATION, IN THE CIRCUIT COURT FOR THE 17TH JUDICIAL CIRCUIT IN AND Plaintiff, FOR BROWARD COUNTY, FLORIDA vs. CASE NO.: CACE 19-022183 COMUTEL SOLUTIONS LLC, and USIC, LLC Defendants. USIC, LLC’S NOTICE OF DEPOSITION OF CORPORATE REPRESENTATIVE FOR COSTCO WHOLESALE CORPORATION TO: Costco Wholesale Corporation c/o David Cooney, Esquire dcooney@ctkplaw.com; Reception@ctkplaw.com; tzaccour@ctkplaw.com COONEY, TRYBUS, KWAVNICK, PEETS 1600 W. Commercial Blvd, Suite 200 Fort Lauderdale, FL 33309 PLEASE TAKE NOTICE that on June 22, 2020, at 2:00 PM at the offices of Cooney, Trybus, Kwavnick, Peets, 1600 W. Commercial Blvd., Suite 200, Fort Lauderdale, FL 33309, Defendant USIC Locating Services, LLC (“USIC”) will take the deposition of the Corporate Representative of Plaintiff Costco Wholesale Corporation (“Costco”), pursuant to Rule 1.310(b)(6), Florida Rules of Civil Procedure. The aforesaid deposition shall be taken upon oral examination, under oath, before a person authorized by law to take depositions, and shall continue from time to time and from day to day until completed. Such deposition is being taken for purposes of discovery, for use at trial and for such other purposes as are authorized by the Florida Rules of Civil Procedure. Costco shall designate one or more officers, directors, or managing agents or other persons who consent to do so, to testify on its behalf with respect to the matters described in the attached Schedule “A.” 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 undersigned counsel at least 7 days before your scheduled deposition, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711. 010-8985-1502/1/AMERICAS *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/29/2020 09:14:36 AM.****SCHEDULE “A” 1. Costco’s Complaint filed in this lawsuit. 2. Any and all steps taken by Costco to identify the location of and/or protect the underground utility damaged in connection with this lawsuit prior to the damage referenced in the Complaint. 3. The facts and circumstances regarding how the utility strike giving rise to this lawsuit occurred. 4. Costco’s investigation of the utility strike giving rise to this lawsuit, including any evidence and materials collected during such an investigation. 5. Costco’s responses to all interrogatories, requests for production, and requests for admission propounded to Costco in this lawsuit. 6. Costco’s involvement and/or participation in Florida’s One Call system (d/b/a Sunshine 811), in connection with the utility strike giving rise to this lawsuit. 7. Costco’s factual basis for including USIC as a defendant in this lawsuit. 8. The damages claimed by Costco in this lawsuit. Dated: May 29, 2020 Respectfully Submitted, SQUIRE PATTON BOGGS (US) LLP 200 South Biscayne Blvd, Suite 4700 Miami, FL 33131 Telephone: (305) 577-7000 Facsimile: (305) 577-7001 By: 4/P. Jan Kubicz Jason Daniel Joffe Florida Bar No. 0013564 Email: jason.joffe@squirepb.com Copy to: joan.andersondavis@squirepb.com P. Jan Kubicz Florida Bar No. 84405 Email: jan.kubicz@squirepb.com Attorneys for Defendant USIC, LLC d/b/a USIC Locating Services, LLC 010-8985-1502/1/AMERICASCERTIFICATE OF SERVICE I HEREBY CERTIFY that on May 29, 2020, a true and correct copy of the foregoing was filed and served on all counsel of record via the Florida Courts E-Portal. 4s/P. Jan Kubicz P. Jan Kubicz 010-8985-1502/1/AMERICAS