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Filing # 136302050 E-Filed 10/11/2021 02:34:19 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY, FLORIDA
CASE NO: 2020 CA 001106 AN
HON. MARGARET H. SCHREIBER
XIAO SHENG YUE,
Plaintiff,
vs.
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, 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:
November 12, 2021 Ian Zeller, Ph.D. VIA ZOOM (Information to be provided)
At 10:00 AM (Biomechanical US Legal Support
Engineer) (888) 311-4240
Produced by Counsel
November 23, 2021 G. Grady McBride |VIA ZOOM (Information to be provided)
At 4:30 PM M.D. US Legal Support
(Orthopaedic) (888) 311-4240
Produced by Counsel
December 1, 2021 Eric D. Kramer, M.D. |VIA ZOOM (Information to be provided)
At 2:00 PM (Neurologist) US Legal Support
Produced by Counsel) | (888) 311-4240
December 6, 2021 Geoffrey A. Negin, |VIA ZOOM (Information to be provided)
At 1:00 PM M.D. US Legal Support
(Radiologist) (888) 311-4240
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 11” day of October, 2021, 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;
ssmithS@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: EDiaz@forthepeople.com
Attorneyfor Plaintiff
cc: US Legal Support (sescheduling@uslegalsupport.com)
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 # 136302050 E-Filed 10/11/2021 02:34:19 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO: 2020 CA 001106 AN HON. MARGARET H. SCHREIBER XIAO SHENG YUE, Plaintiff, vs. 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, 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: November 12, 2021 Ian Zeller, Ph.D. VIA ZOOM (Information to be provided) At 10:00 AM (Biomechanical US Legal Support Engineer) (888) 311-4240 Produced by Counsel November 23, 2021 G. Grady McBride |VIA ZOOM (Information to be provided) At 4:30 PM M.D. US Legal Support (Orthopaedic) (888) 311-4240 Produced by Counsel December 1, 2021 Eric D. Kramer, M.D. |VIA ZOOM (Information to be provided) At 2:00 PM (Neurologist) US Legal Support Produced by Counsel) | (888) 311-4240 December 6, 2021 Geoffrey A. Negin, |VIA ZOOM (Information to be provided) At 1:00 PM M.D. US Legal Support (Radiologist) (888) 311-4240 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 11” day of October, 2021, 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; ssmithS@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: EDiaz@forthepeople.com Attorneyfor Plaintiff cc: US Legal Support (sescheduling@uslegalsupport.com) 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.