Party Discovery: BARONE, FRANCES et al.vs.ASHFORD TRS WQ LLC et al.

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                                Filing #91712089 E-Filed 06/26/2019 01:27:00 PM


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

          FRANCES BARONE & GABRIEL BARONE,

                          Plaintiffs,

          VS.                                               CASE NO. 2017 CA 003882-0


          ASHFORD TRS WQ LLC, a foreign limited
          liability company d/b/a WORLD QUEST
          RESORT a/k/a WORLDQUEST ORLANDO
          RESORT, ASHFORD WQ LICENSEE, LLC,
          a foreign limited liability company and
          ASHFORD TRS CORPORATION, a foreign
          profit corporation,

                          Defendants.
                                                            i,

                                        NOTICE OF TAKING DEPOSITION

          To:      Kelly Charles-Collins, Esq.
                   William G. Smoak, Esq.
                   Smoak, Chistolini & Barnett, PLLC
                   320 West Kennedy Blvd., 4"" Floor
                   Tampa, FL   33606

                 YOU ARE HEREBY NOTIFIED that Plaintiffs, FRANCES BARONE & GABRIEL
          BARONE, by and through their undersigned counsel, will take the following deposition before
          Orange Court Reporting, who is not of counsel to any party, or interested in the event or the
          cause:


          WITNESS:                 TIMOTHY GROSS

          DATE:                    JULY 25, 2019

          TIME:                    11:00 A.M.

          LOCATION                 WEST SAND LAKE CONFERENCE CENTER —- BOARDROOM
                                   7208 SAND LAKE ROAD - SUITE 305
                                   ORLANDO, FLORIDA 32819




          00998304-1
By oral examination, for the purposes of discovery or evidence, or both, pursuant to
Florida Rules of Civil Procedure.

        If said deposition is not fully taken and completed on the date mentioned above, said
deposition will be continued from day-to-day until completed. Said deposition is taken for the
purpose of discovery or for use at trial and all other purposes and uses that depositions may be
used under the laws of the State of Florida and the Florida Rules of Civil Procedure.

                                    CERTIFICATE        OF SERVICE


         | HEREBY   CERTIFY that a true and correct copy of the foregoing was filed with the
Clerk via the Florida Courts e-Filing Portal and provided via eservice to: Kelly Charles-Collins,
Esq. & William G. Smoak, Esq., Smoak, Chistolini & Barnett, PLLC, 320 West Kennedy Blvd.,
4" Floor, Tampa, F                 orneys for Defendants, courtdocuments@flatrialcounsel.com,
this   2G      dayo                 , 2019,
                                             ICARD, MERRILL, CULLIS, TIMM,
                                             FUREN & GINSBURG, P.A.
                                             2033     ain Street, Suite 600
                                             Postal    rawer 4195
                                             Sar ota, Florida 34237
                                             (947) 366-8100 - Phone
                                                A    66-1   34 Fax




                                              Te                              Il, ESQ

                                              ttorneys for Plaintiffs




00998304-1