Party Discovery: MYRTHIL, GERALD V EISENBERG, IRA

• 
• 
• 
• 
• 
• 

						
                                
Preview
                                Filing # 116119922 E-Filed 11/04/2020 10:48:12 AM

IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY, FLORIDA

GERARD MYRTHIL and ISMELIE CASE NO.: 2020 CA 010577 MB
MYRTHIL,

Plaintiffs,
v.

MARION EISENBERG and IRA
EISENBERG,

Defendants.
/

NOTICE OF TAKING DEPOSITION
(Two hours cleared)

weneee*7 oom deposition appearances will require a computer (not a phone)
with camera and video capabilities, please be governed accordingly.

PLEASE TAKE NOTICE that the undersigned attorney will take the deposition of

the following person:

 

DEPONENT DATE TIME LOCATION
Dr. Rahat Faderani | February 17,2021 | 11:00 AM | Via Zoom, provided by US
Legal Support

 

 

 

 

 

 

 

Please Take Further Notice that:

1. The deposition will be conducted remotely, using audio-visual conference
technology;

2. The court reporter will report the deposition from a location separate from the
witness;

3. Counsel for the parties and their clients will be participating from various,
separate locations;

4. The court reporter will administer the oath to the witness remotely;

COLE, SCOTT & KISSANE, P.A.

*** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 11/04/2020 10:48:12 AM ***CASE NO.: 2020 CA 010577 MB

5. The witness will be required to produce government-issues identification
satisfactory to the court reporter, and this identification must be legible on
camera;

6. Each participating attorney may be visible to all other participants; and their
statements will be audible to all participants;

7. Allexhibits will be provided simultaneously and electronically to the witness and
all participants;

8. The court reporter will record testimony;

9. The deposition may be recorded electronically; and

10. Counsel for all parties will be required to stipulate on the record:

a. Their consent to this manner of deposition and

b. Their waiver of any objection to this manner of deposition, including any
objection to the admissibility at trial of this testimony based on this manner of deposition.
11. The oral examination will be taken before any Notary Public, authorized court reporter,
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 is being taken
for the purpose of discovery, for use at trial, or for such other purposes as are permitted

under the rules of Court, including the applicable Rules of Civil Procedure.

Page 2
COLE, SCOTT & KISSANE, P.A.

COLE, SCOTT & KISSANE BUILDING -9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O, BOX 569015 - MIAMI, FLORIDA 33256 - (305) 350-5300 - (305) 373-2294 FAXCASE NO.: 2020 CA 010577 MB

CERTIFICATE OF SERVICE
| HEREBY CERTIFY that on this 4th day of November, 2020, a true and correct copy of
the foregoing was filed with the Clerk of Palm Beach County by using the Florida Courts
e-Filing Portal, which will send an automatic e-mail message to the following parties
registered with the e-Filing Portal system: James P. Cooksey, Esq., Cooksey & Cooksey,

P.A., ccpalaw@bellsouth.net.

COLE, SCOTT & KISSANE, P.A.

Counsel for Defendants MARION EISENBERG and IRA
EISENBERG

Cole, Scott & Kissane Building

9150 South Dadeland Boulevard, Suite 1400
P.O. Box 569015

Miami, Florida 33256

Telephone (305) 350-5380

Facsimile (305) 373-2294

Primary e-mail:

kristy.alvarez@csklegal.com

Alternate e-mail: lisa.bernardez@csklegal.com;
alina.gonzalez@csklegal.com

By: _s/ Kristy J. Alvarez
MICHAEL E. BRAND

Florida Bar No.: 37672
KRISTY J. ALVAREZ
Florida Bar No.: 121768

0349.2317-00/21376717

Page 3
COLE, SCOTT & KISSANE, P.A.

COLE, SCOTT & KISSANE BUILDING -9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O, BOX 569015 - MIAMI, FLORIDA 33256 - (305) 350-5300 - (305) 373-2294 FAX