IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT IN AND FOR LEON COUNTY, FLORIDA. v. Case No.: 2012 CA

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1 IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT IN AND FOR LEON COUNTY, FLORIDA BERNARD LONG and VERONICO L. RON FLORES Plaintiffs, v. Case No.: 2012 CA KENNETH DETZNER in his official capacity as Florida Secretary of State, R. FRED LEWIS, individually, BARBARA J. PARIENTE, individually, and PEGGY A. QUINCE, individually, Defendants. / PLAINTIFFS NOTICE OF TAKING DEPOSITION OF THE HONORABLE KENNETH DETZNER, FLORIDA SECRETARY OF STATE TO: Daniel E. Nordby, General Counsel Florida Department of State R.A. Gray Building 500 South Bronough Street Tallahassee, Florida The Honorable R. Fred Lewis The Honorable Barbara J. Pariente The Honorable Peggy A. Quince

2 PLEASE TAKE NOTICE that the undersigned will take the deposition of The Honorable Kenneth Detzner, Florida Secretary of State, at 12:00 p.m. in the Tallahassee Conference Room on the Second Floor of the Doubletree Hotel, 101 South Adams Street, Tallahassee, Florida, , on Friday, August 10th, 2012, before a notary public or other person authorized by law to take depositions. The deposition will be recorded stenographically and on videotape. The recording will be taken before Barbara Graves at Accurate Court Reporters, Inc., 2894 Remington Green Lane, Tallahassee, Florida This deposition is being taken for purposes of discovery, for use at trial, or any other purpose for which it may be used under applicable laws of the State of Florida. Pursuant to Fla. R. Civ. P , the undersigned hereby requests that you produce at the taking of your deposition any and all documents, correspondence, memoranda, or other writings relating in any way to the matters set forth in Plaintiff's Complaint in this case; all documents, correspondence, memoranda, or other writings relating in any way to your response and defenses to Plaintiff's claims in this case; all documents, correspondence, memoranda, or other writings you intend to introduce as an exhibit at the trial in this matter; and, your entire file related to the 2012 merit retention election qualification or campaign or election of Justices Quince, Lewis and Pariente. DEFINITIONS For purposes of this request, the following words and phrases shall have the following meanings: "Document" or "documentation" means any medium upon which intelligence or information can be recorded or retrieved, and includes, without limitation, the original and each copy, regardless

3 of origin and location, or any book, pamphlet, periodical, letter, memorandum (including any memorandum or report of a meeting or conversation), invoice, bill, order, form, receipt, financial statement, accounting entry, diary, calendar, telex, telegram, cable, report, record, contract, agreement, study, handwritten note, draft, working paper, chart, paper, print, laboratory record, drawing, sketch, graph, index, list, tape, photograph, microfilm, data sheet or data processing card, or any other written, recorded, transcribed, punched tape, filmed, or graphic matter, however produced or reproduced, which is in your possession, custody, control, or otherwise accessible to you, or which was, but is no longer in your possession, custody or control. "You" or "your" refers to the Defendant, its agents, employers, servants or representatives, and unless privileged, its attorneys. INSTRUCTIONS 1. If production is withheld pursuant to a claim of privilege, please provide the following identifying information: (l) date; (2) author; (3) addressee; (4) brief description of the subject matter and form of the document and attachments, including number of pages; (5) statement of the basis upon which the privilege is claimed; and (6) the numbers of each specific request to which the document or thing would be responsive.

4 2. Words in the past tense include the present, and words in the present tense include the past. Use of the singular shall be deemed to include the plural and use of the masculine shall be deemed to include the feminine where appropriate, and vice versa. 3. If any document or other tangible item described by this request is no longer in your possession, custody or control, or is no longer in existence or accessible to you, please indicate: (1) the date and nature of the disposition of such document or other tangible item, including, but not limited to whether the document (a) is missing or lost, (b) has been destroyed or (c) has been transferred to another person; (2) the circumstances surrounding such disposition, including any authorization therefore; and (3) where applicable, the person currently in possession, custody or control of such document or item. PLEASE GOVERN YOURSELF ACCORDINGLY. OF COUNSEL TO: SOUTHEASTERN LEGAL FOUNDATION, INC Sewell Mill Road, Suite 320 Marietta, Georgia Telephone No.: (770) Facsimile No.: (770) Eric S. Haug Florida State Bar. No ERIC S. HAUG LAW & CONSULTING, P.A. Post Office Box Tallahassee, Florida Telephone No.: (850) Facsimile No.: (850) Attorney for Plaintiffs

5 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing was furnished to the addressees herein by hand-delivery this 6th day of July, Eric S. Haug