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Filing # 168267147 E-Filed 03/08/2023 09:43:01 AM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY, FLORIDA
CASE NO: 2020 CA 001106 AN
XIAO SHENG YUE,
Plaintiff,
vs.
CYNTHIA M FOERSTER AND
CHAPP, INC.,
Defendants.
/
PLAINTIFF’S NOTICE OF TAKING UPDATED DEPOSITION DUCES TECUM
OF DEFENDANT’S EXPERT
YOU WILL PLEASE TAKE NOTICE that the Plaintiff, XIA 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:
March 8, 2023 Eric D. Kramer, M.D. VIA ZOOM (Information to be provided)
Milestone Reporting
At 2:30 PM (Neurologist)
407-423-9900
(Produced by Counsel)
(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 8th day of March, 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 Santeiro, Jr., Esquire, Law Offices of Santeiro & Garrison, 6300
University Parkway, Ste 101, Sarasota, FL 34240, via email at jsanteiro@fcci-group.com;
ssmith5@fcci-group.com; legalservice@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: Cvictor@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.