PLAINTIFF’S RE-NOTICE OF TAKING DEPOSITION DUCES TECUM*
IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA
CASE NO: XXXX
JOHN SMITH,
Plaintiff,
vs.
VACATION CRUISES,
Defendant.
__________________________________/
PLAINTIFF’S RE-NOTICE OF TAKING DEPOSITION DUCES TECUM*
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: The corporate officer(s), director(s), employee(s) or agent(s) of the Defendant, VACATION CRUISES., with the most knowledge concerning the following subject areas: (please bring person with the most knowledge as to each)
(1) Concerning the operation of tender(s) in calm and rough seas and the existence of marine/sea conditions two hours prior the date of the subject incident; and
(2) Protocol and procedure for stabilizing the tender on rough or calm seas.
*AND TO BRING WITH YOU the following:
All written criteria, procedure, guidelines, and instructions, utilized by XX over the past five years in controlling tender(s) in rough or calm seas. Documents evidencing marine/wind conditions existing for the six-hour period prior to the subject incident up to the time of the incident in the port/location where the alleged incident occurred.
DATE: XXXX
TIME: XXXX
LOCATION: XXXX
Said deposition will be taken before 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 XXXX, 20__, a true and correct copy of the foregoing was mailed to: XXXX.
LAW OFFICE OF ALAN D. SACKRIN
Attorney for Defendant, XXXX
2100 East Hallandale Beach Blvd.
Suite 200
Hallandale Beach, FL 33009
By______________________________
ALAN D. SACKRIN
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