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Filing # 108139630 E-Filed 05/29/2020 03:15:37 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL
CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA
CASE NO. 2017-CA-004395-O
DIV: 35
BRENTLEY M. HUXTABLE,
PLAINTIFF,
V.
CARLOS E. RESUMIL,
DEFENDANT.
______________________________/
DEFENDANT’S NOTICE OF TAKING DEPOSITION DUCES TECUM
(If you require an interpreter for the deposition, please notify my office promptly)
PLEASE TAKE NOTICE that the undersigned attorney will take the depositions of:
NAME: Joshua Tanner, DC – Pavlik Chiropractic
DATE: August 11, 2020
TIME: 10:00 am
PLACE: Esquire Deposition Solutions
200 East Robinson Street
Suite 725
Orlando, FL 32801
upon oral examination before Esquire Deposition Solutions, 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.
At the time of the deposition, deponent shall have in his possession the documents as specified in
Exhibit “A” attached hereto.
CERTIFICATE OF SERVICE
The document contains no confidential or sensitive information or that any such
confidential or sensitive language has been properly protected by complying with the provisions
of Rule 2.420 and 2.425. I HEREBY CERTIFY that a true and correct copy of the foregoing has
been furnished by electronic filing to John Allan Watson, Esquire/ Travis J. McMillen, Esquire,
jwatson@boginmunns.com, storres@boginmunns.com, bmmservice@boginmunns.com, Bogin,
Munns & Munns, P.A., Gateway Center, 1000 Legion Place, Suite 1000, Orlando, FL 32801 on
this 29th day of May, 2020.
/S/ Brad Higginbotham
BRAD HIGGINBOTHAM, ESQUIRE
Fla. Bar No.: 658642
Law Office of Sonya S. Wesner
200 East Robinson Street, Suite 510
Orlando, FL 32801
Direct Dial: (407) 393-9087
Paralegal: (407) 393-9096
Secretary: (407) 393-9094
Primary E-Mail: ORLMAIL@Nationwide.com
Attorneys for Defendant
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EXHIBIT A
1. A current curriculum vitae for Joshua Tanner, DC.
2. Any and all letters, reports (preliminary, final or otherwise), notes or memoranda
prepared by you in reviewing this case, and any such documents that reflect opinions of
conclusions reached by you.
3. Copies of any bills, medical records, disability determinations and/or disability
applications in your possession.
4. All letters, records, or other memoranda received by you from the Plaintiff(s) or any
attorney, or any other party regarding this case.
5. All time slips or other records showing your time devoted to reviewing this matter, and
the dates of review.
6. All material ever sent to or given to you for review in this case, including but not limited
to site plans, sketches, medical records, x-rays, medical literature, depositions, disability
applications, disability determinations and/or employment records.
7. All literature which you discovered, referred to or read dealing with any subject matter of
this case.
8. All textbooks or literature which you have in your home, office or which you may have
been given by any party or attorney, or which you may have given to any party or
attorney dealing with any of the issues or subject matter of the medical conditions for
which you have observed.
9. A list of all legal matters worked on by you for the prior three years through the date of
this deposition. The list should include: year, style of the case, case number, jurisdiction,
attorney who hired you and area of expertise you were hired to testify about.
10. Any and all reports (preliminary, final or otherwise), rough drafts, work sheets and
materials in any manner connected with the opinions or conclusions reached concerning
the subject matter of your expert opinion. Including any and all reports (preliminary, final
or otherwise), rough drafts, work sheets and materials in any manner connected with the
opinions or conclusions regarding the Plaintiff in this case even if that occurred prior to
the accident date in this case.
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Preview
Filing # 108139630 E-Filed 05/29/2020 03:15:37 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CASE NO. 2017-CA-004395-O DIV: 35 BRENTLEY M. HUXTABLE, PLAINTIFF, V. CARLOS E. RESUMIL, DEFENDANT. ______________________________/ DEFENDANT’S NOTICE OF TAKING DEPOSITION DUCES TECUM (If you require an interpreter for the deposition, please notify my office promptly) PLEASE TAKE NOTICE that the undersigned attorney will take the depositions of: NAME: Joshua Tanner, DC – Pavlik Chiropractic DATE: August 11, 2020 TIME: 10:00 am PLACE: Esquire Deposition Solutions 200 East Robinson Street Suite 725 Orlando, FL 32801 upon oral examination before Esquire Deposition Solutions, 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. At the time of the deposition, deponent shall have in his possession the documents as specified in Exhibit “A” attached hereto. CERTIFICATE OF SERVICE The document contains no confidential or sensitive information or that any such confidential or sensitive language has been properly protected by complying with the provisions of Rule 2.420 and 2.425. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by electronic filing to John Allan Watson, Esquire/ Travis J. McMillen, Esquire, jwatson@boginmunns.com, storres@boginmunns.com, bmmservice@boginmunns.com, Bogin, Munns & Munns, P.A., Gateway Center, 1000 Legion Place, Suite 1000, Orlando, FL 32801 on this 29th day of May, 2020. /S/ Brad Higginbotham BRAD HIGGINBOTHAM, ESQUIRE Fla. Bar No.: 658642 Law Office of Sonya S. Wesner 200 East Robinson Street, Suite 510 Orlando, FL 32801 Direct Dial: (407) 393-9087 Paralegal: (407) 393-9096 Secretary: (407) 393-9094 Primary E-Mail: ORLMAIL@Nationwide.com Attorneys for Defendant 2 EXHIBIT A 1. A current curriculum vitae for Joshua Tanner, DC. 2. Any and all letters, reports (preliminary, final or otherwise), notes or memoranda prepared by you in reviewing this case, and any such documents that reflect opinions of conclusions reached by you. 3. Copies of any bills, medical records, disability determinations and/or disability applications in your possession. 4. All letters, records, or other memoranda received by you from the Plaintiff(s) or any attorney, or any other party regarding this case. 5. All time slips or other records showing your time devoted to reviewing this matter, and the dates of review. 6. All material ever sent to or given to you for review in this case, including but not limited to site plans, sketches, medical records, x-rays, medical literature, depositions, disability applications, disability determinations and/or employment records. 7. All literature which you discovered, referred to or read dealing with any subject matter of this case. 8. All textbooks or literature which you have in your home, office or which you may have been given by any party or attorney, or which you may have given to any party or attorney dealing with any of the issues or subject matter of the medical conditions for which you have observed. 9. A list of all legal matters worked on by you for the prior three years through the date of this deposition. The list should include: year, style of the case, case number, jurisdiction, attorney who hired you and area of expertise you were hired to testify about. 10. Any and all reports (preliminary, final or otherwise), rough drafts, work sheets and materials in any manner connected with the opinions or conclusions reached concerning the subject matter of your expert opinion. Including any and all reports (preliminary, final or otherwise), rough drafts, work sheets and materials in any manner connected with the opinions or conclusions regarding the Plaintiff in this case even if that occurred prior to the accident date in this case. 3