NOTICE OF TAKING DEPOSITION

IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA

CASE NO. XX

MARY GARCIA,

Plaintiff,

v.

SMITH INC.,

Defendant.

_________________________________/

NOTICE OF TAKING DEPOSITION

PLEASE TAKE NOTICE that the undersigned attorney will take the deposition by oral examination for the purposes of discovery and for use as evidence in said cause, or both, as follows:

DEPONENT:         *Corporate representative of the Defendant, SMITH INC., with the most knowledge concerning the following subject areas:

(1) The placement of oil, grease or any other foreign? surface on any of the ladders affixed to the Defendant’s (Smith Inc.’s) premises for the six-month period prior to the subject incident to the date of the subject incident; and

(2) The facts and circumstances of the incident sued upon.

* Please bring more than one representative if it is not the same representative concerning the two areas above.

DATE:          XX

*or at a time and place to be agreed upon by counsel.

   LOCATION:          XX

Said deposition will be taken before XX, a certified court reporter, or any other officer authorized to administer oaths by the laws of the State of Florida, and a person who is neither a relative nor employee of such attorney or counsel, and who is not financially interested in the action. Said deposition to be taken pursuant to the Florida Rules of Civil Procedure in such cases provided. The said oral examination(s) will continue from hour to hour and from day to day until completed.

CERTIFICATE OF SERVICE

IT IS HEREBY CERTIFIED that on the ____ day of XX, 20__, a true and correct copy of the foregoing has been ( )Telefaxed (X)Mailed to: XX

Law Office of Alan D. Sackrin

2100 E. Hallandale Beach Blvd.Suite 200

Hallandale Beach, FL 33009

By:_____________________________

ALAN D. SACKRIN

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The pleading above is a sample document related to a specific set of facts and circumstances and should not be used or relied upon for any personal injury matter. This document is being provided for illustrative purposes only. We recommend and urge you to consult with an experienced personal injury lawyer for professional advice as each case is unique.

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