Party Discovery: YUE, XIAO vs. FOERSTER, CYNTHIA

• 
• 
• 
• 
• 
• 
• 
• 

						
                                
Preview
                                Filing # 144812410 E-Filed 03/01/2022 12:38:39 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 TAKING VIDEO DEPOSITION DUCES TECUM 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.               Tuesday, March 1, 2022, at          Via Zoom By U.S.
                                              4:30 p.m.                           Legal Support ZOOM
                                                                                  (details to be provided
                                                                                  at least 24-hours prior
                                                                                  to the deposition)



                 The deponent shall produce all documents set forth in the attached Exhibit “A” at the time
        of the deposition. This deposition will be conducted upon oral examination before U.S. Legal
        Support, Court Reporter, and a Notary Public in and for the State of Florida at Large, or some other
        officer duly authorized by law to take depositions. The deposition is being taken for the purpose
        of discovery, for use at trial, or both of the foregoing, or for such other purposes as are permitted
        under the applicable and governing rules.
                                   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.