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Filing # 170335786 E-Filed 04/04/2023 04:29:55 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.
______________________________/
PLAINTIFF’S NOTICE OF TAKING DEPOSITION DUCES TECUM
OF DEFENDANT’S EXPERT
YOU WILL PLEASE TAKE NOTICE that the Plaintiff, XIAO SHENG YUE , will
take the deposition of the following witness, as hereinafter specified, by oral examination for the
purpose of discovery, or for use at trial, or for such other purpose as is permitted under the
applicable and governing Florida Rules of Civil Procedure:
DATE/TIME: DEPONENT: LOCATION:
April 4, 2023 G. Grady McBride, M. D VIA ZOOM (Information to be provided)
4:30 PM (Produced by Counsel) Milestone Reporting
(These court reporters and or Notary Public in and for the State of Florida at Large, or some other
officer duly authorized by law to take depositions who are not of counsel to either of the parties or
interested in the event of the cause.)
MATERIALS TO BE PRODUCED: SEE SCHEDULE A
PLEASE GOVERN YOURSELF ACCORDINGLY.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 4th day of April, 2023, I electronically filed the
foregoing with the Clerk of Court by using the Florida Courts e-Filing Portal. I further certify
that Pursuant to Rule 2.516(b)(1), a true and correct copy of the foregoing was emailed this same
day via email to: Jorge Santerio Esq. Law Offices of Anteiro & Garrison jsanterio@fcci-
Group.com .
/s/ Manuel Stefan, Esq.
Manuel “Manny” Stefan, Esq.
Florida Bar No.: 0103389
MORGAN & MORGAN, P.A.
4495 South Semoran Blvd.
Orlando, FL 32822
Telephone No.: (407) 452-6982
Facsimile No.: (407) 572-0124
Primary email: MStefan@forthepeople.com
Secondary email: Cvitor@forthepeople.com
Attorney for Plaintiff
SCHEDULE A
1. A copy of your curriculum vitae.
2. Any and all materials which have been supplied to you for your review and use in forming your
opinions regarding this lawsuit.
3. Any and all materials, including but not limited to, testing results which you have created or
developed during the course of forming your opinion(s) regarding this lawsuit.
4. Any and all photographs, films, video, CDs or DVDs which you have received, created or used
during the course of forming your opinions regarding this lawsuit.
5. Any and all reports (preliminary, final or otherwise), rough drafts, work sheets, field notes, logs
and/or materials in any manner connected with the opinions or conclusions reached concerning
the subject matter of your expert opinion.
6. A list of all matters where testimony has been given either in trial or in depositions listing the
name of the case, the party taking the deposition, the parties attending the deposition, the date,
and court location for the past three (3) years.
7. A list of all matters where you have been retained as an expert for consultation purposes
excluding treatment and the name of the entity on whose behalf you were retained, the attorney
representing that entity, and whether you were retained on behalf of the plaintiff or defendant for
the past three (3) years.
8. Any and all rules, regulations, statutes, directives, standards, ordinances or other government
enactments which you relied upon in forming your opinions regarding this lawsuit.
9. All computations, calculations, formulas considered, utilized, produced or in any manner
connected with your opinions or conclusions.
10. All time and billing records and statements for all activities performed relating to this matter.
11. Any documents which tend to show how much income you receive in percentage of total income
or how much time you expend in percentage of total time in relation to litigation consulting for
the past three (3) years.
12. Any and all articles or publications that you believe support any opinions formulated.
13. Any and all advertising for professional services by you or your firm for the past three (3) years.
Preview
Filing # 170335786 E-Filed 04/04/2023 04:29:55 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. ______________________________/ PLAINTIFF’S NOTICE OF TAKING DEPOSITION DUCES TECUM OF DEFENDANT’S EXPERT YOU WILL PLEASE TAKE NOTICE that the Plaintiff, XIAO SHENG YUE , will take the deposition of the following witness, as hereinafter specified, by oral examination for the purpose of discovery, or for use at trial, or for such other purpose as is permitted under the applicable and governing Florida Rules of Civil Procedure: DATE/TIME: DEPONENT: LOCATION: April 4, 2023 G. Grady McBride, M. D VIA ZOOM (Information to be provided) 4:30 PM (Produced by Counsel) Milestone Reporting (These court reporters and or Notary Public in and for the State of Florida at Large, or some other officer duly authorized by law to take depositions who are not of counsel to either of the parties or interested in the event of the cause.) MATERIALS TO BE PRODUCED: SEE SCHEDULE A PLEASE GOVERN YOURSELF ACCORDINGLY. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 4th day of April, 2023, I electronically filed the foregoing with the Clerk of Court by using the Florida Courts e-Filing Portal. I further certify that Pursuant to Rule 2.516(b)(1), a true and correct copy of the foregoing was emailed this same day via email to: Jorge Santerio Esq. Law Offices of Anteiro & Garrison jsanterio@fcci- Group.com . /s/ Manuel Stefan, Esq. Manuel “Manny” Stefan, Esq. Florida Bar No.: 0103389 MORGAN & MORGAN, P.A. 4495 South Semoran Blvd. Orlando, FL 32822 Telephone No.: (407) 452-6982 Facsimile No.: (407) 572-0124 Primary email: MStefan@forthepeople.com Secondary email: Cvitor@forthepeople.com Attorney for Plaintiff SCHEDULE A 1. A copy of your curriculum vitae. 2. Any and all materials which have been supplied to you for your review and use in forming your opinions regarding this lawsuit. 3. Any and all materials, including but not limited to, testing results which you have created or developed during the course of forming your opinion(s) regarding this lawsuit. 4. Any and all photographs, films, video, CDs or DVDs which you have received, created or used during the course of forming your opinions regarding this lawsuit. 5. Any and all reports (preliminary, final or otherwise), rough drafts, work sheets, field notes, logs and/or materials in any manner connected with the opinions or conclusions reached concerning the subject matter of your expert opinion. 6. A list of all matters where testimony has been given either in trial or in depositions listing the name of the case, the party taking the deposition, the parties attending the deposition, the date, and court location for the past three (3) years. 7. A list of all matters where you have been retained as an expert for consultation purposes excluding treatment and the name of the entity on whose behalf you were retained, the attorney representing that entity, and whether you were retained on behalf of the plaintiff or defendant for the past three (3) years. 8. Any and all rules, regulations, statutes, directives, standards, ordinances or other government enactments which you relied upon in forming your opinions regarding this lawsuit. 9. All computations, calculations, formulas considered, utilized, produced or in any manner connected with your opinions or conclusions. 10. All time and billing records and statements for all activities performed relating to this matter. 11. Any documents which tend to show how much income you receive in percentage of total income or how much time you expend in percentage of total time in relation to litigation consulting for the past three (3) years. 12. Any and all articles or publications that you believe support any opinions formulated. 13. Any and all advertising for professional services by you or your firm for the past three (3) years.