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Filing # 170339751 E-Filed 04/04/2023 04:53:45 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT,
IN AND FOR OSCEOLA COUNTY, FLORIDA
XIAO SHENG YUE,
Plaintiff,
CASE NO.: 2020-CA-1106AN
v.
CYNTHIA M. FOERSTER AND
CHAPP, INC.,
Defendants.
______________________________/
DEFENDANTS’ NOTICE OF CANCELLATION OF VIDEO DEPOSITION FOR TRIAL
PLEASE TAKE NOTICE that the Defendants, CYNTHIA M. FOERSTER and CHAPP,
INC., by and through the undersigned counsel, hereby cancel the video deposition set forth
below:
DEPONENT DATE/TIME LOCATION
G. Grady McBride, M.D. Thursday, February 23, 2023, Via Zoom By U.S. Legal
at 4:30 p.m. Support ZOOM (details to be
provided at least 24-hours
prior to the deposition)
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that, on this 23rd day of February, 2023, I electronically filed the
foregoing with the Clerk of the Court via the Florida Courts’ e-Filing Portal, pursuant to and in
compliance with Rule 2.516, Florida Rules of Judicial Administration, which completes service
by furnishing a true and correct copy of the foregoing via electronic mail to all counsel of record.
LAW OFFICES OF SANTEIRO & GARRISON
/s/ Jorge Santeiro, Jr.
Jorge Santeiro, Jr.
FBN 66230
6300 University Parkway
Suite 101
Sarasota, FL 34240
Tel: (800) 226-3224 Ext. 1021
Primary: isanteiro@fcci-group.com
Secondary: ssmith5@fcci-group.com
Secondary: legalservice@fcci-group.com
Attorney for Defendants
EXHIBIT A
(Items to Produce)
1. Your complete up-to-date Curriculum Vitae.
2. Copies of all statements written or recorded, that you have examined in connection
with [Xiao Sheng Yue, DOB XX-XX-XXXX] (“the subject case”).
3. Any and all documents sent to you by plaintiff’s counsel in connection with the
subject case.
4. Any and all materials created or generated by you or by other individuals who have
performed any work on the subject case, including but not limited to any documents,
reports, videos, photographs, animation or other digital simulations and the like.
5. All published or non-published standards from any source, texts, treatises, articles,
manuals and journals which you used or referenced to in formulating your opinions.
6. Copies of all published professional articles or drafts or speeches you have given.
7. Copies of all transcripts of testimony you have given in other cases where you acted
as an expert or were deposed as the Defendant.
8. A list of every case in which you have testified in any capacity on either Plaintiff’s or
Defendant’s behalf within the last ten (10) years. This list should include the style of
the case, date(s) your testimony was given, place(s) your testimony was given and the
name(s) of the attorneys involved in the respective cases.
9. All report(s) you have prepared relating to your expert opinion in connection with the
subject case.
10. All notes, calculation and other data prepared by you in formulating your opinion in
connection with the subject case.
11. All drawings, graphs, charts, illustrations and plans prepared by you in formulating
your opinion in connection with the subject case.
12. All reports, office notes and records, signed reports, tests reports, lab reports and
documentation that have been prepared by you or other sub-specialists’ who have
performed any work on the subject case.
13. Your records indicating time spent on undertaking and hourly charges thereof in
connection with the subject case.
14. Reports, notes, transcription of oral opinions or summaries of opinions of other
experts who have reviewed or rendered opinions in this case.
15. Any published monographs, treatises, manuals, articles, textbooks, or other
documents which you have used as a reference and upon which you have based your
expert opinion, in whole or in part.
16. Any correspondence between your office and Plaintiffs’ counsel.
17. All memoranda you have reviewed, prepared by the attorney who engaged you, an
investigator, a paralegal or adjuster.
18. All other documents or writings of any kind or description that you have viewed in
formulating your conclusions or opinions.
19. A list of all other individuals with whom you have consulted in formulating your
opinions, including their respective addresses, phone numbers, areas of expertise and
a summary of their opinions.
20. All protocols, guides, guidelines, outlines and the like upon which you rely in
formulating your opinions in the subject case.
21. Any and all photographs, films, slides, diagrams, drawings, sketches, video tapes, or
other demonstrative materials reviewed or relied upon in formulating your opinions in
the subject case.
22. Any and all documents, correspondence, memoranda, notes or other materials which
reflect or pertain to your training to act as an expert in the subject case.
23. Any and all personal notes, statistics, research, memoranda which pertain to in
formulating your opinions in the subject case.
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Filing # 170339751 E-Filed 04/04/2023 04:53:45 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA XIAO SHENG YUE, Plaintiff, CASE NO.: 2020-CA-1106AN v. CYNTHIA M. FOERSTER AND CHAPP, INC., Defendants. ______________________________/ DEFENDANTS’ NOTICE OF CANCELLATION OF VIDEO DEPOSITION FOR TRIAL PLEASE TAKE NOTICE that the Defendants, CYNTHIA M. FOERSTER and CHAPP, INC., by and through the undersigned counsel, hereby cancel the video deposition set forth below: DEPONENT DATE/TIME LOCATION G. Grady McBride, M.D. Thursday, February 23, 2023, Via Zoom By U.S. Legal at 4:30 p.m. Support ZOOM (details to be provided at least 24-hours prior to the deposition) CERTIFICATE OF SERVICE I HEREBY CERTIFY that, on this 23rd day of February, 2023, I electronically filed the foregoing with the Clerk of the Court via the Florida Courts’ e-Filing Portal, pursuant to and in compliance with Rule 2.516, Florida Rules of Judicial Administration, which completes service by furnishing a true and correct copy of the foregoing via electronic mail to all counsel of record. LAW OFFICES OF SANTEIRO & GARRISON /s/ Jorge Santeiro, Jr. Jorge Santeiro, Jr. FBN 66230 6300 University Parkway Suite 101 Sarasota, FL 34240 Tel: (800) 226-3224 Ext. 1021 Primary: isanteiro@fcci-group.com Secondary: ssmith5@fcci-group.com Secondary: legalservice@fcci-group.com Attorney for Defendants EXHIBIT A (Items to Produce) 1. Your complete up-to-date Curriculum Vitae. 2. Copies of all statements written or recorded, that you have examined in connection with [Xiao Sheng Yue, DOB XX-XX-XXXX] (“the subject case”). 3. Any and all documents sent to you by plaintiff’s counsel in connection with the subject case. 4. Any and all materials created or generated by you or by other individuals who have performed any work on the subject case, including but not limited to any documents, reports, videos, photographs, animation or other digital simulations and the like. 5. All published or non-published standards from any source, texts, treatises, articles, manuals and journals which you used or referenced to in formulating your opinions. 6. Copies of all published professional articles or drafts or speeches you have given. 7. Copies of all transcripts of testimony you have given in other cases where you acted as an expert or were deposed as the Defendant. 8. A list of every case in which you have testified in any capacity on either Plaintiff’s or Defendant’s behalf within the last ten (10) years. This list should include the style of the case, date(s) your testimony was given, place(s) your testimony was given and the name(s) of the attorneys involved in the respective cases. 9. All report(s) you have prepared relating to your expert opinion in connection with the subject case. 10. All notes, calculation and other data prepared by you in formulating your opinion in connection with the subject case. 11. All drawings, graphs, charts, illustrations and plans prepared by you in formulating your opinion in connection with the subject case. 12. All reports, office notes and records, signed reports, tests reports, lab reports and documentation that have been prepared by you or other sub-specialists’ who have performed any work on the subject case. 13. Your records indicating time spent on undertaking and hourly charges thereof in connection with the subject case. 14. Reports, notes, transcription of oral opinions or summaries of opinions of other experts who have reviewed or rendered opinions in this case. 15. Any published monographs, treatises, manuals, articles, textbooks, or other documents which you have used as a reference and upon which you have based your expert opinion, in whole or in part. 16. Any correspondence between your office and Plaintiffs’ counsel. 17. All memoranda you have reviewed, prepared by the attorney who engaged you, an investigator, a paralegal or adjuster. 18. All other documents or writings of any kind or description that you have viewed in formulating your conclusions or opinions. 19. A list of all other individuals with whom you have consulted in formulating your opinions, including their respective addresses, phone numbers, areas of expertise and a summary of their opinions. 20. All protocols, guides, guidelines, outlines and the like upon which you rely in formulating your opinions in the subject case. 21. Any and all photographs, films, slides, diagrams, drawings, sketches, video tapes, or other demonstrative materials reviewed or relied upon in formulating your opinions in the subject case. 22. Any and all documents, correspondence, memoranda, notes or other materials which reflect or pertain to your training to act as an expert in the subject case. 23. Any and all personal notes, statistics, research, memoranda which pertain to in formulating your opinions in the subject case.