On May 01, 2017 a
Party Discovery
was filed
involving a dispute between
Mobooka Llc,
and
Forsa Llc,
John Hancock,
Jpmorgan Chase Bank Na,
in the District Court of Orange County.
Preview
Filing # 79129855 E-Filed 10/10/2018 11:36:51 AM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR ORANGE COUNTY, FLORIDA
MOBOOKA, LLC., a Florida limited liability CASE NO: 2017-CA-004043
company,
Plaintiff,
v.
JOHN HANCOCK, individually, FORSA LLC,
a Wyoming limited liability company, and
JPMORGAN CHASE BANK, N.A., an Ohio
banking corporation,
Defendants.
______________________________________/
THIRD AMENDED NOTICE OF TAKING DEPOSITION
TO: JOHN HANCOCK
499 HAMMOCK DRIVE,
PALM HARBOR, FL 34683
YOU ARE HEREBY NOTIFIED that the undersigned will take the deposition of:
JOHN HANCOCK
PLACE: DLE at Riesdorph Reporting Group Inc
100 2nd Avenue South
St. Petersburg, Florida 33701
TIME: 10:00 a.m.
DATE: October 22, 2018
FORSA, LLC (“Forsa”) shall designate one or more officers, directors, or managing agents, or
other persons who consent to do so, to testify concerning matters known or reasonably available
to the organization, and shall have the most knowledge of:
1. The corporate structure and history of Forsa.
2. John Hancock’s management of and role in Forsa.
3. The business of Forsa.
4. Forsa’s relationship with John Hancock
5. Any and all monies received due to diverted network traffic.
6. Any of Forsa’s responses to discovery requests.
7. Any and all facts arising out of the allegations in Plaintiff’s Complaint, or Defendant’s
affirmative defenses.
Upon Oral examination before a designated Court Reporter or any other officer or Notary Public
authorized by law to take depositions, said examination to continue from day to day until
completed. The deposition will be taken for the purpose of discovery, for use at trial, or for such
other purposes as are permitted pursuant to Florida Rules of Court, Florida Rules of Civil
Procedure and all applicable Florida Statutes and case law.
Dated this 10th day of October 2018.
Respectfully Submitted,
EPGD ATTORNEYS AT LAW, P.A.
Attorneys for Plaintiff
777 SW 37th Ave., Ste. 510
T : (786) 837-6787
F : (305) 718-0687
sam@epgdlaw.com
BY : /s/ Samuel J Gittle
Samuel J. Gittle, Esq.
Florida Bar No.: 099778
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by
email this 10th day of October, 2018 to Defendants John Hancock and Forsa LLC at 499
Hammock Drive, Palm Harbor, FL 34683 and to hancock.j.g@gmail.com.
BY: /S/ Samuel J. Gittle
Samuel J. Gittle, Esq.
Florida Bar No.: 99778
Document Filed Date
October 10, 2018
Case Filing Date
May 01, 2017
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Filing # 79129855 E-Filed 10/10/2018 11:36:51 AM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA MOBOOKA, LLC., a Florida limited liability CASE NO: 2017-CA-004043 company, Plaintiff, v. JOHN HANCOCK, individually, FORSA LLC, a Wyoming limited liability company, and JPMORGAN CHASE BANK, N.A., an Ohio banking corporation, Defendants. ______________________________________/ THIRD AMENDED NOTICE OF TAKING DEPOSITION TO: JOHN HANCOCK 499 HAMMOCK DRIVE, PALM HARBOR, FL 34683 YOU ARE HEREBY NOTIFIED that the undersigned will take the deposition of: JOHN HANCOCK PLACE: DLE at Riesdorph Reporting Group Inc 100 2nd Avenue South St. Petersburg, Florida 33701 TIME: 10:00 a.m. DATE: October 22, 2018 FORSA, LLC (“Forsa”) shall designate one or more officers, directors, or managing agents, or other persons who consent to do so, to testify concerning matters known or reasonably available to the organization, and shall have the most knowledge of: 1. The corporate structure and history of Forsa. 2. John Hancock’s management of and role in Forsa. 3. The business of Forsa. 4. Forsa’s relationship with John Hancock 5. Any and all monies received due to diverted network traffic. 6. Any of Forsa’s responses to discovery requests. 7. Any and all facts arising out of the allegations in Plaintiff’s Complaint, or Defendant’s affirmative defenses. Upon Oral examination before a designated Court Reporter or any other officer or Notary Public authorized by law to take depositions, said examination to continue from day to day until completed. The deposition will be taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted pursuant to Florida Rules of Court, Florida Rules of Civil Procedure and all applicable Florida Statutes and case law. Dated this 10th day of October 2018. Respectfully Submitted, EPGD ATTORNEYS AT LAW, P.A. Attorneys for Plaintiff 777 SW 37th Ave., Ste. 510 T : (786) 837-6787 F : (305) 718-0687 sam@epgdlaw.com BY : /s/ Samuel J Gittle Samuel J. Gittle, Esq. Florida Bar No.: 099778 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by email this 10th day of October, 2018 to Defendants John Hancock and Forsa LLC at 499 Hammock Drive, Palm Harbor, FL 34683 and to hancock.j.g@gmail.com. BY: /S/ Samuel J. Gittle Samuel J. Gittle, Esq. Florida Bar No.: 99778