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

Similar documents
Information or instructions: Combined discovery requests, admissions, production of documents and interrogatories

FILED: QUEENS COUNTY CLERK 02/07/ :50 PM INDEX NO /2016 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 02/07/2017

January 24, Via Electronic Transmission

DIVISION OF ST. THOMAS/ ST. JOHN PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT WAHEED HAMED

December 12, Via facsimile transmission: Mitchell A. Leon President DesignWrite Inc. 175 Wall Street Princeton, NJ 08540

DEFINITIONS AND INSTRUCTIONS

Defendants. X THE PEOPLE OF THE STATE OF NEW YORK. WE COMMAND YOU, That all business and excuses being laid aside, you appear at

DISTRICT COURT CLARK COUNTY, NEVADA

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION

Plaintiff, Defendant. PLEASE TAKE NOTICE that Plaintiff Acme Home & Garden, LLC demands answers

FILED: NEW YORK COUNTY CLERK 02/29/ :38 PM INDEX NO /2014 NYSCEF DOC. NO. 580 RECEIVED NYSCEF: 03/01/2016

S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION OF DOCUMENTS,

BEFORE THE INVESTIGATIVE PANEI. OF TIIE FI ORIDA JUDICIAL QUAl IFICATIONS COMMISSION STATE 01 Fl.ORIDA

Sample. Index No: [Insert] RJI No: [Insert] PLAINTIFF S NOTICE TO PRODUCE

FILED: NEW YORK COUNTY CLERK 07/01/ :00 AM INDEX NO /2016 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 07/01/2017

Medicaid Fraud Control Unit Investigative Subpoena Duces Tecum

APPENDIX I SAMPLE INTERROGATORIES

FILED: NEW YORK COUNTY CLERK 12/15/ :09 AM INDEX NO /2017 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 12/15/2017

FILED: KINGS COUNTY CLERK 12/22/ :45 PM INDEX NO /2015 NYSCEF DOC. NO. 132 RECEIVED NYSCEF: 12/22/2017

FILED: NEW YORK COUNTY CLERK 12/18/ :44 PM INDEX NO /2014 NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 12/18/2015

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

In the Superior Court Allen County, Indiana Cause No.. 02D PL-499

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) ) ) )

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA PALM BEACH DIVISION CASE NO CIV-KAM

STATE OF FLORIDA OFFICE OF THE ATTORNEY GENERAL DEPARTMENT OF LEGAL AFFAIRS ECONOMIC CRIMES SUBPOENA DUCES TECUM WITHOUT APPEARANCE POWDERZ, INC.

ATTORNEY GENERAL DEPARTMENT OF LEGAL AFFAIRS ECONOMIC CRIMES SUBPOENA DUCES TECUM C/O:

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

December 12, Via Electronic Transmission

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

Control N rnber: ' Item Number: 397. Addendurn StartPage: 0

Case 3:16-md VC Document Filed 01/09/19 Page 1 of 18 EXHIBIT A

UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION ) ) ) ) ) ) ) ) ) ) ) ) Debtor.

FILED: NEW YORK COUNTY CLERK 04/11/2013 INDEX NO /2012 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 04/11/2013

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

THE STATE OF NEW HAMPSHIRE. Docket No CV Sanjeev Lath

SUPERIOR COURT OF THE DISTRICT OF COLUMBIA CIVIL DIVISION Landlord and Tenant Branch

Have you received a request for discovery?

CAUSE NO. 18-C STREETS TO SHEETS ANIMAL IN THE COUNTY COURT AT LAW RESCUE Plaintiff, v. NO. 1

FILED: KINGS COUNTY CLERK 07/28/ :10 PM INDEX NO /2015 NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 07/28/2017. Exhibit UU

IN THE DISTRICT COURT, COUNTY OF CASS, NORTH DAKOTA

FILED: NEW YORK COUNTY CLERK 06/11/2014 INDEX NO /2013 NYSCEF DOC. NO. 61 RECEIVED NYSCEF: 06/11/2014

IN THE CIRCUIT COURT OF COUNTY, ARKANSAS DIVISION PLAINTIFF DEFENDANT S FIRST INTERROGATORIES TO PLAINTIFF

IN THE UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA Charlotte Division

Pursuant to Rule 34, Federal Rules of Civil Procedure, plaintiff, by his attorneys,

YOU ARE HEREBY COMMANDED to produce to Eric Wm. Hendon, Esq., Assistant Attorney

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK. [insert individual case information] ) ) MDL NO.

Case 3:16-cv Document 1-1 Filed 02/29/16 Page 1 of 68 SUBPOENA UNITED STATES OF AMERICA NATIONAL LABOR RELATIONS BOARD

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CIVIL DIVISION. Plaintiffs, Case No CA (01)

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

SUPERIOR COURT OF THE DISTRICT OF COLUMBIA CIVIL DIVISION Landlord And Tenant Branch

PLEASE TAKE NOTICE that pursuant to CPLR 3101, 3120, et. seq., Defendant

FILED: KINGS COUNTY CLERK 06/08/ :39 PM INDEX NO /2017 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 06/08/2017

Case 1:16-cv CMA Document Entered on FLSD Docket 03/17/2017 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

FILED: ORANGE COUNTY CLERK 03/17/ :37 PM

Case Doc 225 Filed 10/05/18 Entered 10/05/18 14:02:08 Desc Main Document Page 1 of 9

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF FLORIDA TALLAHASSEE DIVISION

FILED: NEW YORK COUNTY CLERK 07/13/ :56 PM INDEX NO /2015 NYSCEF DOC. NO. 50 RECEIVED NYSCEF: 07/13/2018

PLAINTIFF RESPONSE TO DEFENDANT LINDA LAJOIE FIRST REQUEST FOR PRODUCTION

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR MARION COUNTY, FLORIDA. vs. Case No: ORDER ESTABLISHING MOTION PRACTICE PROCEDURE

Case: JGR Doc#:231 Filed:02/23/17 Entered:02/23/17 16:06:19 Page1 of 2 UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF COLORADO

CASE 0:13-cv PJS-LIB Document 59-1 Filed 02/27/14 Page 1 of 10 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA COURT FILE NO.

IN THE SUPREME COURT OF FLORIDA ANSWERS AND OBJECTIONS TO RESPONDENT S EXPERT AND WITNESS INTERROGATORIES GENERAL OBJECTIONS

Case 1:16-cv CMA Document Entered on FLSD Docket 03/17/2017 Page 1 of 16 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION TRUSTEE S FIRST DISCOVERY REQUESTS TO SOLAR INTEGRATED TECHNOLOGIES GMHB

Case 4:12-cv RH-CAS Document 38 Filed 07/03/12 Page 1 of 6

Case 0:17-cv CMA Document 58 Entered on FLSD Docket 11/30/2017 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

ASSOCIATION OF AMERICAN ) PHYSICIANS AND SURGEONS, INC. ) etc., et al., ) ) Plaintiffs ) CIVIL ACTION NO

UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Miami Division CASE NO CIV-SIMONTON

ANTITRUST CIVIL INVESTIGATIVE DEMAND

19-CV-0222 CAUSE NO. Plaintiff, v. GALVESTON COUNTY, TEXAS

Plaintiff, DEFENDANT'S INTERROGATORIES, REQUEST. Defendant. City of Bloomington ( Bloomington ) and demands that Plaintiff Tony Webster ( Webster )

Case KJC Doc 4929 Filed 12/14/17 Page 1 of 12 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE. x : : : : : : x.

DIVISION 2 DIVISION OF FINANCE - DEPARTMENT OF FINANCE

Case 3:16-cv DPJ-FKB Document 43 Filed 04/13/17 Page 1 of 2

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

BEFORE THE FLORIDA JUDICIAL QUALIFICATIONS COMMISSION SIXTH AMENDED WITNESS AND EXHIBIT LIST WITNESS LIST. 1. Honorable Charles W.

FILED: NEW YORK COUNTY CLERK 09/04/ :54 PM INDEX NO /2013 NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 09/04/2014

Case 2:13-cv Document Filed in TXSD on 11/18/14 Page 1 of 5

IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT IN AND FOR LEON COUNTY, FLORIDA PLAINTIFF'S EXPEDITED MOTION FOR REHEARING

BEFORE THE JUDICIAL QUALIFICATIONS COMMISSION STATE OF FLORIDA CASE NO: 07-64

SOLID ROCK CHURCH, INC. ofcourt File No. 71-C ELK RIVER, MINNESOTA, a Minnesota Non-Profit Corporation,

IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI AT INDEPENDENCE

COMPLEX CONSTRUCTION CASE MANAGEMENT ORDER. It is, ORDERED AND ADJUDGED that, unless later modified by Order of this Court,

Case 4:11-cv RH-CAS Document 80 Filed 08/10/12 Page 1 of 7

READ THIS BEFORE COMPLETING THE FORMS!!! INSTRUCTIONS FOR MOTION FOR MODIFICATION

ATTORNEY GENERAL DEPARTMENT OF LEGAL AFFAIRS ECONOMIC CRIME DIVISION FIRST INVESTIGATIVE SUBPOENA DUCES TECUM

PART III Discovery CHAPTER 8. Overview of the Discovery Process KEY POINTS THE NATURE OF DISCOVERY THE EXTENT OF ALLOWABLE DISCOVERY

Case 4:14-cv JA Document 251 Filed 06/19/14 Page 1 of 5

MUNICIPAL AUTHORITY OF WESTMORELAND COUNTY RIGHT-TO-KNOW POLICY FOR PUBLIC RECORDS

Case Doc Filed 11/22/17 Entered 11/22/17 17:35:58 Desc Exhibit 2 Page 1 of 6

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA

Copyright and Patent NOVA SOUTHEASTERN UNIVERSITY POLICY ARTICLE I. Definitions. Issue Date: August 1987; revised June 1997, October 2004

What if the other parent is not making child support payments? The court will consider whether a parent is helping to support their child.

Supreme Court of Florida

Return form to: THE FLORIDA BAR Fee Arbitration Program 651 East Jefferson Street Tallahassee, FL

Case 2:13-cv Document Filed in TXSD on 11/18/14 Page 1 of 7

BEFORE THE FLORIDA JUDICIAL QUALIFICATIONS COMMISSION SPECIAL COUNSEL'S WITNESS AND EXHIBIT LISTS CERTIFICATE OF SERVICE

Transcription:

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 001980 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 32399-0250 The Honorable R. Fred Lewis The Honorable Barbara J. Pariente The Honorable Peggy A. Quince

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, 32301-7774, 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 32308. 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. 1.350, 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

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.

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. 2255 Sewell Mill Road, Suite 320 Marietta, Georgia 30062 Telephone No.: (770) 977 2131 Facsimile No.: (770) 977-2134 Eric S. Haug Florida State Bar. No. 850713 ERIC S. HAUG LAW & CONSULTING, P.A. Post Office Box 12031 Tallahassee, Florida 32317-2031 Telephone No.: (850) 583-1480 Facsimile No.: (850) 297-0300 Attorney for Plaintiffs

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, 2012. Eric S. Haug