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  • DE LOURDES SANTIAGO, MARIAvs.THE BOAT HOUSE ORLANDO LLC 3 document preview
  • DE LOURDES SANTIAGO, MARIAvs.THE BOAT HOUSE ORLANDO LLC 3 document preview
  • DE LOURDES SANTIAGO, MARIAvs.THE BOAT HOUSE ORLANDO LLC 3 document preview
  • DE LOURDES SANTIAGO, MARIAvs.THE BOAT HOUSE ORLANDO LLC 3 document preview
						
                                

Preview

Filing # 91785905 E-Filed 06/27/2019 01:48:52 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, STATE OF FLORIDA CIVIL DIVISION MARIA DE LOURDES SANTIAGO, Plaintiff, Case No.: 2017-CA-7719 v. THE BOAT HOUSE ORLANDO, LLC, Defendant. ____________________________________/ DEFENDANT’S OBJECTION AND MOTION FOR PROTECTIVE ORDER REGARDING JUNE 27, 2019 DEPOSITIONS COMES NOW the Defendant, THE BOAT HOUSE ORLANDO, LLC, by and through undersigned counsel, and hereby objects and moves for Protective Order regarding depositions scheduled for June 27, 2019. In support thereof, Defendant states as follows: 1. Due to unforeseen circumstances, to wit: Defendant’s counsel attending earlier depositions that have taken far longer than expected in Tampa, Florida, Defendant’s counsel is unable to attend the depositions scheduled for June 27, 2019 in this matter. 2. The undersigned notified Plaintiff’s counsel at approximately 1:00 p.m. of this issue and has attempted to reschedule. 3. At the time of the filing of this Motion and Objection, the Defendant has been unable to confirm the rescheduling. As a result, Defendant objects and moves for Protective Order with regard to the aforementioned depositions going forward. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and accurate copy of the above and foregoing has been furnished via e-mail through the Florida E-Filing Portal to Michael B. Sanchez, Esquire (msanchez@pendaslaw.com; xvargas@pendaslaw.com; pleadings@pendaslaw.com), The Pendas Law Firm, 625 E. Colonial Drive, Orlando, FL 32803, Attorney for Plaintiff, on June 12, 2019. /s/ William R. Gower, III William R. Gower, III, Esquire FBN: 105172 Joshua D. Wright, Esquire FBN: 0099230 BANKER LOPEZ GASSLER P.A. 501 E. Kennedy Boulevard, Suite 1700 Tampa, FL 33602 Phone: (813) 221-1500 Fax No: (813) 222-3066 service-wgower@bankerlopez.com service-jwright@bankerlopez.com Attorneys for Defendant 2