Special interogatories in California litigationLegalDocsPro
Special interrogatories in Caifornia litigation are the topic of this isssue of the weekly legal newsletter from LegalDocsPro. This is is issue number 2.
Sample motion to vacate default under Rule 55(c) in United States District CourtLegalDocsPro
This sample motion to vacate a default under Rule 55(c) in United States District Court is used when a default has been entered but no judgment. The sample motion is used by a defendant to request that the Court vacate an entry of default against them for good cause. The sample on which this preview is based is 10 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service. The author is an entrepreneur and freelance paralegal that worked in California and Federal litigation from January 1995 through September 2017 and has created over 300 sample legal documents for sale. Note that the author is NOT an attorney and no guarantee or warranty is provided.
Sample responses to form interrogatories for California divorceLegalDocsPro
These sample responses to form interrogatories for a California divorce can also be used in a legal separation or nullity case as well. They are designed to be used in responding to Judicial Council Form FL-145 Form Interrogatories-Family Law. The sample on which this preview is based is 10 pages and contains brief instructions, a verification and proof of service by mail.
Sample motion to vacate California divorce judgment for fraud and perjuryLegalDocsPro
This sample motion to vacate a dissolution (divorce) judgment in California on the grounds of fraud and perjury is filed pursuant to the provisions of California Family Code sections 2122(a) and (b). This sample can also be used to vacate a legal separation or nullity judgment in California as well. The sample on which this preview is based is 10 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority and a sample declaration.
Sample California motion to strike for unlawful detainer (eviction) complaintLegalDocsPro
This sample California motion to strike an unlawful detainer (eviction) complaint is used when the plaintiff has not verified the complaint, or is requesting rent or damages they are not entitled to. The sample on which this preview is based is 11 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority and a proof of service by mail. The sample document is sold on scribd.com by LegalDocsPro.
Special interogatories in California litigationLegalDocsPro
Special interrogatories in Caifornia litigation are the topic of this isssue of the weekly legal newsletter from LegalDocsPro. This is is issue number 2.
Sample motion to vacate default under Rule 55(c) in United States District CourtLegalDocsPro
This sample motion to vacate a default under Rule 55(c) in United States District Court is used when a default has been entered but no judgment. The sample motion is used by a defendant to request that the Court vacate an entry of default against them for good cause. The sample on which this preview is based is 10 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service. The author is an entrepreneur and freelance paralegal that worked in California and Federal litigation from January 1995 through September 2017 and has created over 300 sample legal documents for sale. Note that the author is NOT an attorney and no guarantee or warranty is provided.
Sample responses to form interrogatories for California divorceLegalDocsPro
These sample responses to form interrogatories for a California divorce can also be used in a legal separation or nullity case as well. They are designed to be used in responding to Judicial Council Form FL-145 Form Interrogatories-Family Law. The sample on which this preview is based is 10 pages and contains brief instructions, a verification and proof of service by mail.
Sample motion to vacate California divorce judgment for fraud and perjuryLegalDocsPro
This sample motion to vacate a dissolution (divorce) judgment in California on the grounds of fraud and perjury is filed pursuant to the provisions of California Family Code sections 2122(a) and (b). This sample can also be used to vacate a legal separation or nullity judgment in California as well. The sample on which this preview is based is 10 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority and a sample declaration.
Sample California motion to strike for unlawful detainer (eviction) complaintLegalDocsPro
This sample California motion to strike an unlawful detainer (eviction) complaint is used when the plaintiff has not verified the complaint, or is requesting rent or damages they are not entitled to. The sample on which this preview is based is 11 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority and a proof of service by mail. The sample document is sold on scribd.com by LegalDocsPro.
Sample motion to vacate judgment under rule 60(b)(2) in United States Distric...LegalDocsPro
This sample motion to vacate a judgment under Rule 60(b)(2) on the grounds of newly discovered evidence in United States District Court is used when a party has newly discovered evidence that, with reasonable diligence, could not have been discovered in time to move for a new trial under Rule 59(b). The sample on which this preview based is 10 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, a sample declaration and proof of service by mail.
Sample California motion to compel further responses to special interrogatoriesLegalDocsPro
This sample California motion to compel further responses to special interrogatories is made pursuant to Code of Civil Procedure Section 2030.300 and is used when a party has served special interrogatories but the responses received are evasive or incomplete, or the objections are without merit or are too general. The sample could easily be modified to apply to form interrogatories as well. The sample on which this preview is based is 30 pages and includes a memorandum of points and authorities with citations to case law and statutory authority, a separate statement as required by Rule of Court 3.1345, a sample declaration and a proof of service by mail.
Motion to dismiss under rule 12(b)(5) for insufficient service of processLegalDocsPro
Motion to dismiss a complaint for insufficient service of process under Rule 12(b)(5) of the Federal Rules of Civil Procedure is the topic of this document. Rule 12(b)(5) allows a defendant to move for dismissal due to insufficient service of process in civil litigation in United States District Court.
Sample collection of meet and confer letters for discovery in californiaLegalDocsPro
This sample collection of meet and confer letters for discovery in California contains over 10 sample meet and confer letters and responses to meet and confer letters including a (1) meet and confer letter for further discovery responses to interrogatories, requests for admission and requests for production of documents, (2) response to meet and confer letter for motion to compel further responses to interrogatories, (3) response to meet and confer letter for motion to compel further responses to requests for production of documents, (4) meet and confer letter for protective order for interrogatories, (5) meet and confer letter for protective order for requests for admission, (6) meet and confer letter for protective order for requests for production of documents, (7) Response to meet and confer letter for for protective order for interrogatories, (8) response to meet and confer letter for protective order for requests for admission, (9) response to meet and confer letter for protective order for requests for production of documents, (10) meet and confer letter for protective order for deposition, (11) meet and confer letter for motion to quash subpoena duces tecum, (12) meet and confer letter for motion to compel attendance at deposition, and (13) meet and confer letter for motion to compel testimony at deposition. The sample on which this preview is based is 42 pages and includes the meet and confer letters mentioned above. The author is a freelance paralegal that has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents for sale.
Sample California complaint for assault and batteryLegalDocsPro
This sample California complaint for assault and battery also includes a cause of action for intentional infliction of emotional distress. The sample could be modified to add other causes of action as well. This is a preview of the sample complaint sold by LegalDocsPro.
Sample motion for judgment on the pleadings under Rule 12(c) of the Federal R...LegalDocsPro
This sample motion for judgment on the pleadings under Rule 12(c) of the Federal Rules of Civil Procedure is made on the same grounds as a motion to dismiss but may be filed even after an answer to a complaint has been filed. This is a preview of the sample motion sold by LegalDocsPro on scribd.com
Sample notice of lawsuit and request for waiver of service of summons in Unit...LegalDocsPro
This sample notice of lawsuit and request for waiver of service of a summons in United States District Court under Rule 4(d) is used pursuant to subdivision (d) of Federal Rule of Civil Procedure 4. This subdivision imposes a duty on any defendant who is an individual that is not a minor or incompetent, or is a corporation or association to avoid the unnecessary expenses of serving the summons. The sample is 5 pages and contains brief instructions as well as a sample waiver of the service of a summons containing all required statutory language. The author is a freelance paralegal that has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents.
Sample California motion for reconsideration under Code of Civi Procedure sec...LegalDocsPro
This sample motion for reconsideration for California is made pursuant to Code of Civil Procedure section 1008(a) on the grounds that the motion for reconsideration should be granted due to new or different facts, circumstances or law discovered since the date of the order for which reconsideration is being requested. The sample on which this preview is based is 9 pages and includes brief instructions, a memorandum of points and authorities, a sample declaration and proof of service by mail. The author is a freelance paralegal who has worked in California and Federal litigation since 1995 and has created over 235 sample legal documents.
Sample California meet and confer letter LegalDocsPro
This sample meet and confer letter for California is used when a party has not received any responses to their discovery requests and wants to meet and confer with the other party before filing any motion to compel. The sample can be modified for use in many situations.
Sample California settlement offer letterLegalDocsPro
This sample California settlement offer letter is made pursuant to Evidence Code Section 1152 and 1154. The sample can be modified for use by either a plaintiff or defendant.
The author is a freelance paralegal who has worked in California and Federal litigation since 1995.
Sample motion to vacate California divorce judgment for fraudLegalDocsPro
This sample motion to vacate a dissolution (divorce) judgment in California on the grounds of duress is used pursuant to California Family Code section 2122(c). This sample can also be used to vacate a legal separation or nullity judgment in California as well. The sample on which this preview is based is 10 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority and a sample declaration.
Sample California reply to opposition to motionLegalDocsPro
This document is a sample California reply to an opposition to a motion. This sample is used to reply to an opposition filed to a motion. Note that the author is NOT an attorney and no guarantee or warranty is provided.
Sample California motion to strike answer LegalDocsPro
This sample motion to strike an answer to a complaint for California is made pursuant to Sections 435-437 of the Code of Civil Procedure. The sample requests that the entire answer be stricken as it is not verified, or in the alternative that all of the affirmative defenses contained in the answer should be stricken as they contain only immaterial allegations. The sample contains brief instructions, a memorandum of points and authorities and a proof of service by mail.
Sample stipulation and order for bifurcation of marital status in CaliforniaLegalDocsPro
This sample stipulation and order for bifurcation of marital status in California is used when both parties agree to terminate their marital status and have the Court reserve judgment over all other issues in their case. The sample on which this preview is bases is 6 pages and includes brief instructions.
Sample notice of removal to United States District CourtLegalDocsPro
This sample notice of removal to United States District Court is used to remove a case filed in a State Court to United States District Court and is filed pursuant to Title 28 U.S. Code section 1446 on the grounds that the complaint involves a federal question as stated in Title 28 U.S. Code section 1441(a) but can be easily modified for use in cases with diversity jurisdiction as well. The sample on which this preview is based is 7 pages and includes brief instructions, citations to the statutory authority, a notice to adverse party of removal to Federal Court as well as a certificate of service of notice to adverse party of removal to Federal Court. The author is a freelance paralegal who has worked in California and Federal litigation since 1995.
Sample motion to vacate judgment under rule 60(b)(2) in United States Distric...LegalDocsPro
This sample motion to vacate a judgment under Rule 60(b)(2) on the grounds of newly discovered evidence in United States District Court is used when a party has newly discovered evidence that, with reasonable diligence, could not have been discovered in time to move for a new trial under Rule 59(b). The sample on which this preview based is 10 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, a sample declaration and proof of service by mail.
Sample California motion to compel further responses to special interrogatoriesLegalDocsPro
This sample California motion to compel further responses to special interrogatories is made pursuant to Code of Civil Procedure Section 2030.300 and is used when a party has served special interrogatories but the responses received are evasive or incomplete, or the objections are without merit or are too general. The sample could easily be modified to apply to form interrogatories as well. The sample on which this preview is based is 30 pages and includes a memorandum of points and authorities with citations to case law and statutory authority, a separate statement as required by Rule of Court 3.1345, a sample declaration and a proof of service by mail.
Motion to dismiss under rule 12(b)(5) for insufficient service of processLegalDocsPro
Motion to dismiss a complaint for insufficient service of process under Rule 12(b)(5) of the Federal Rules of Civil Procedure is the topic of this document. Rule 12(b)(5) allows a defendant to move for dismissal due to insufficient service of process in civil litigation in United States District Court.
Sample collection of meet and confer letters for discovery in californiaLegalDocsPro
This sample collection of meet and confer letters for discovery in California contains over 10 sample meet and confer letters and responses to meet and confer letters including a (1) meet and confer letter for further discovery responses to interrogatories, requests for admission and requests for production of documents, (2) response to meet and confer letter for motion to compel further responses to interrogatories, (3) response to meet and confer letter for motion to compel further responses to requests for production of documents, (4) meet and confer letter for protective order for interrogatories, (5) meet and confer letter for protective order for requests for admission, (6) meet and confer letter for protective order for requests for production of documents, (7) Response to meet and confer letter for for protective order for interrogatories, (8) response to meet and confer letter for protective order for requests for admission, (9) response to meet and confer letter for protective order for requests for production of documents, (10) meet and confer letter for protective order for deposition, (11) meet and confer letter for motion to quash subpoena duces tecum, (12) meet and confer letter for motion to compel attendance at deposition, and (13) meet and confer letter for motion to compel testimony at deposition. The sample on which this preview is based is 42 pages and includes the meet and confer letters mentioned above. The author is a freelance paralegal that has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents for sale.
Sample California complaint for assault and batteryLegalDocsPro
This sample California complaint for assault and battery also includes a cause of action for intentional infliction of emotional distress. The sample could be modified to add other causes of action as well. This is a preview of the sample complaint sold by LegalDocsPro.
Sample motion for judgment on the pleadings under Rule 12(c) of the Federal R...LegalDocsPro
This sample motion for judgment on the pleadings under Rule 12(c) of the Federal Rules of Civil Procedure is made on the same grounds as a motion to dismiss but may be filed even after an answer to a complaint has been filed. This is a preview of the sample motion sold by LegalDocsPro on scribd.com
Sample notice of lawsuit and request for waiver of service of summons in Unit...LegalDocsPro
This sample notice of lawsuit and request for waiver of service of a summons in United States District Court under Rule 4(d) is used pursuant to subdivision (d) of Federal Rule of Civil Procedure 4. This subdivision imposes a duty on any defendant who is an individual that is not a minor or incompetent, or is a corporation or association to avoid the unnecessary expenses of serving the summons. The sample is 5 pages and contains brief instructions as well as a sample waiver of the service of a summons containing all required statutory language. The author is a freelance paralegal that has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents.
Sample California motion for reconsideration under Code of Civi Procedure sec...LegalDocsPro
This sample motion for reconsideration for California is made pursuant to Code of Civil Procedure section 1008(a) on the grounds that the motion for reconsideration should be granted due to new or different facts, circumstances or law discovered since the date of the order for which reconsideration is being requested. The sample on which this preview is based is 9 pages and includes brief instructions, a memorandum of points and authorities, a sample declaration and proof of service by mail. The author is a freelance paralegal who has worked in California and Federal litigation since 1995 and has created over 235 sample legal documents.
Sample California meet and confer letter LegalDocsPro
This sample meet and confer letter for California is used when a party has not received any responses to their discovery requests and wants to meet and confer with the other party before filing any motion to compel. The sample can be modified for use in many situations.
Sample California settlement offer letterLegalDocsPro
This sample California settlement offer letter is made pursuant to Evidence Code Section 1152 and 1154. The sample can be modified for use by either a plaintiff or defendant.
The author is a freelance paralegal who has worked in California and Federal litigation since 1995.
Sample motion to vacate California divorce judgment for fraudLegalDocsPro
This sample motion to vacate a dissolution (divorce) judgment in California on the grounds of duress is used pursuant to California Family Code section 2122(c). This sample can also be used to vacate a legal separation or nullity judgment in California as well. The sample on which this preview is based is 10 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority and a sample declaration.
Sample California reply to opposition to motionLegalDocsPro
This document is a sample California reply to an opposition to a motion. This sample is used to reply to an opposition filed to a motion. Note that the author is NOT an attorney and no guarantee or warranty is provided.
Sample California motion to strike answer LegalDocsPro
This sample motion to strike an answer to a complaint for California is made pursuant to Sections 435-437 of the Code of Civil Procedure. The sample requests that the entire answer be stricken as it is not verified, or in the alternative that all of the affirmative defenses contained in the answer should be stricken as they contain only immaterial allegations. The sample contains brief instructions, a memorandum of points and authorities and a proof of service by mail.
Sample stipulation and order for bifurcation of marital status in CaliforniaLegalDocsPro
This sample stipulation and order for bifurcation of marital status in California is used when both parties agree to terminate their marital status and have the Court reserve judgment over all other issues in their case. The sample on which this preview is bases is 6 pages and includes brief instructions.
Sample notice of removal to United States District CourtLegalDocsPro
This sample notice of removal to United States District Court is used to remove a case filed in a State Court to United States District Court and is filed pursuant to Title 28 U.S. Code section 1446 on the grounds that the complaint involves a federal question as stated in Title 28 U.S. Code section 1441(a) but can be easily modified for use in cases with diversity jurisdiction as well. The sample on which this preview is based is 7 pages and includes brief instructions, citations to the statutory authority, a notice to adverse party of removal to Federal Court as well as a certificate of service of notice to adverse party of removal to Federal Court. The author is a freelance paralegal who has worked in California and Federal litigation since 1995.
United States District Court,Southern District of Florida,11-cv-20120-AMS,Traian Bujduveanu v. Dismas Charities,Inc.,Ana Gispert,Derek Thomas,lashanda Adams
Traian Bujduveani 1,Corruption inside US Government,Corruption of the US Justice System,Election of Criminals into the US Federal Government Offices,The Most Corrupted Country In the World,Democracy Propaganda
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Personal development courses are widely available today, with each one promising life-changing outcomes. Tim Han’s Life Mastery Achievers (LMA) Course has drawn a lot of interest. In addition to offering my frank assessment of Success Insider’s LMA Course, this piece examines the course’s effects via a variety of Tim Han LMA course reviews and Success Insider comments.
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1. Case 1:11-cv-20120-PAS Document 78-1 Entered on FLSD Docket 12/06/2011 Page 1 of 8
IN THE UNITED STATES DISTRICT COURT FOR
THE SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 11-20120-CIV-SEITZ/SIMONTON
TRAIAN BUJDUVEANU,
Plaintiff,
vs.
DISMAS CHARITIES, INC., ANA GISPERT,
DEREK THOMAS and ADAMS LESHOTA,
Defendants.
NOTICE OF TAIONG DEPOSITION
-TO:—Trajan Bujduveanu
5601 W. Broward Blvd.
Plantation, FL 33317
PLEASE TAKE NOTICE that the undersigned counsel will take the following
deposition:
NAME; TRAIAN BUJDUVEANU
TTME AND DATE; OCTOBER 10,2011 @9:00 A.M.
LOCATION: NETWORK REPORTING
" ' TOWER 101
101 NORTHEAST 3rd AVENUE, SUITE 1500
FORT LAUDERDALE, FLORIDA
305-358-8188
upon oral examination before Network Reporting, Notary Public, or any other Notary Public or
Officer authorized by law to take depositions in the State of Florida. The oral examination will
continue from day to day until completed and is being taken for the purposes of discovery, for
use at trial or for such other purposes as are permitted under the Rules.
2. Case 1:11-cv-20120-PAS Document 78-1 Entered on FLSD Docket 12/06/2011 Page 2 of 8
CASE NO.: 11-20120-CIV-SEITZ/SIMONTON
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via
First Class U.S. Mail to the above named addressee(s), this (N 1 day ofAugust, 2011.
EISINGER, BROWN, LEWIS, FRANKEL
& CHATET, P.A.
Presidential Circle - Suite 265 South
4000 Hollywood Boulevard
Hollywood, Floridi/ 33021
Telephone: ](95j
Facsimile:
CHATET, ESQUIRE
Bar No.: 963798
cc: Network Reporting
Via Facsimile: (305)358-8187
3. Case 1:11-cv-20120-PAS Document 78-1 Entered on FLSD Docket 12/06/2011 Page 3 of 8
IN THE UNITED STATES DISTRICT COURT FOR
THE SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 11-20120-CIV-SEITZ/SIMONTON
TRAIAN BUJDUVEANU,
Plaintiff,
vs.
DISMAS CHARITIES, INC., ANA GISPERT,
DEREKTHOMAS and ADAMS LESHOTA,
Defendants.
/
RE-NOTICE OF TAKING DEPOSITION
***This Re-Notice of Taking Deposition Cancels the Deposition Previously Scheduled for
October 10,2011 at 9:00 a.m. andReschedules it for November 11, 2011 at 9:00 a.m.***
TO: Traian Bujduveanu
5601 W.Broward Blvd.
Plantation, FL 33317
PLEASE TAKE NOTICE that the undersigned counsel will take the following
deposition:
NAME: TRAIAN BUJDUVEANU
TIME AND DATE: NOVEMBER 11, 2011 @ 9:00 A.M.
LOCATION: NETWORK REPORTING
TOWER 101
101 NORTHEAST 3rd AVENUE, SUITE 1500
FORT LAUDERDALE, FLORIDA
305-358-8188
upon oral examination before Network Reporting, Notary Public, or any other Notary Public or
Officer authorized by law to take depositions in the State of Florida. The oral examination will
4. Case 1:11-cv-20120-PAS Document 78-1 Entered on FLSD Docket 12/06/2011 Page 4 of 8
CASE NO.: 11-20120-CIV-SEITZ/SIMONTON
continue from day to day until completed and is being taken for the purposes of discovery, for
use at trial or for such other purposes as are permittedunderthe Rules.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via
First Class U.S. Mail to the above named addressee(s), this |vdav ofAugust, 2011.
EISINGER, BROWN, LEWIS, FRANKEL
& CHATET, P.A.
Presidential Circle - Suite 265 South
4000 Hollywood Boulevard
Hollywood, Florida 33021
Telephone: (954^ 894-8000
Facsimile: (954^894-8015
By:
WDiaiATET,
DAVID ESQUIRE
idaB&ANo.: 963798
Florida
cc: Network Reporting
Via Facsimile: (305)358-8187
yvv
5. Case 1:11-cv-20120-PAS Document 78-1 Entered on FLSD Docket 12/06/2011 Page 5 of 8
1 IN THE UNITED STATES DISTRICT COURT
2 FOR THE SOUTHERN DISTRICT OF FLORIDA
3
CASE NO. 11-20120-CIV-SEITZ/SIMONTON
4
5 TRAIAN BUJDUVEANU,
7
6
vs.
Plaintiff,
tofGOHH
8 DISMAS CHARITIES, INC., ANA GISPERT,
DEREK THOMAS and ADAMS LESHOTA,
9
10 Defendants.
11
12
13
CERTIFICATE of NON-APPEARANCE
14
15 I, Rick White, RPR, being a Notary Public in and for
the State of Florida at Large, do hereby certify that pursuant
16 to a Notice of Deposition in the above case, I, as well as
David Chaiet, Esq., appeared at 101 N.E. 3rd Avenue, Ft.
17 Lauderdale, Florida, on Friday, November 11, 2011, at 9:00
a.m. for the purpose of reporting the scheduled deposition of
18 Traian Bujduveanu, and after waiting until 9:30 a.m., the
deponent did not appear.
19
20 DATED at Ft. Lauderdale, this 14th day of November, 2011.
21
22
23 Rick White, C.S.R., Notary Public in and for the
24 State of Florida at Large
25 Commission #EE86209 Expires: July 1, 2015.
6. Case 1:11-cv-20120-PAS Document 78-1 Entered on FLSD Docket 12/06/2011 Page 6 of 8
IN THE UNITED STATES DISTRICT COURT FOR
THE SOUTHERN DISTRICT OFFLORIDA
CASE NO.: 11-20120-CIV-SEITZ/SIMONTON
TRAIAN BUJDUVEANU,
Plaintiff,
vs.
DISMAS CHARITIES, INC., ANA GISPERT
DEREK THOMAS and ADAMS LESHOTA,
Defendants.
/
RE-NOTICE OF TAKING DEPOSITION
TO: Traian Bujduveanu
5601 W. Broward Blvd.
Plantation, FL 33317
PLEASE TAKE NOTICE that the undersigned counsel will take the following
deposition:
MME: TRAIAN BUJDUVEANU
TIME AND DATE: DECEMBER 5,2011 @2:00 P.M.
LOCATION: NETWORK REPORTING
TOWER 101
101 NORTHEAST 3rd AVENUE, SUITE 1500
FORT LAUDERDALE, FLORIDA
305-358-8188
upon oral examination before Network Reporting, Notary Public, or any other Notary Public or
Officer authorized by law to take depositions in the State ofFlorida. The oral examination will
continue from day to day until completed and is being taken for the purposes of discovery, for
use attrial orfor such other purposes as are permitted under the Rules.
7. Case 1:11-cv-20120-PAS Document 78-1 Entered on FLSD Docket 12/06/2011 Page 7 of 8
CASE NO.: 11-20120-CTV-SEITZ/SIMONTON
CERTIFICATE OF SF.wvinr.
I HEREBY CERTIFY that a true and correct copy ofthe foregoing was furnished via
First Class U.S. Mail to the above named addressee(s), this jKvVday ofNovember, 2011.
EISTNGER, BROWN, LEWIS, FRANKEL
& CHATET, P.A.
Presidential Circle - Suite 265 South
4000 Hollywood Boulevard
Hollywood, Florida 33021
Telephone: (954) 894^000
Facsimile: (954)
By:
DAVID CHATEt, ESQUIRE
Florida BarNo.: 1963798
cc: Network Reporting
Via Facsimile: (305)358-8187
8. Case 1:11-cv-20120-PAS Document 78-1 Entered on FLSD Docket 12/06/2011 Page 8 of 8
1 IN THE UNITED STATES DISTRICT COURT FOR
THE SOUTHERN DISTRICT OF FLORIDA
2
CASE NO.: 11-20120-CIV-SEITZ/SIMONTON
3
4
TRAIAN BUJDUVEANU,
5
Plaintiff,
6
vs .
7
DISMAS CHARITIES, INC., ANA GISPERT,
8 DEREK THOMAS and ADAMS LESHOTA,
9 Defendants.
10
11
12 CERTIFICATE OF NON-APPEARANCE FOR DEPOSITION
13 I, NATALIE CRYSTAL CARROLL, being a Notary Public in
and for the State of Florida at Large, do hereby certify
14 that I appeared on Monday, December 5th, 2011 from 2:00
p.m. to 2:30 p.m. for the purpose of reporting the
15 deposition of TRAIAN BUJDUVEANU, which was scheduled to
begin at 2:00 p.m. at 101 Northeast 3rd Avenue, Suite
16 1500, Fort Lauderdale, Florida 33301 pursuant to Notice
of Taking Deposition and that the witness, TRAIAN
17 BUJDUVEANU, did not appear nor did anyone appear on the
witness's behalf.
18
19
DATED at Miami-Dade County, Florida, this 5th day of
20 December, 2011.
21
/^kUCfuuu.it
22 Natalie Crystal Carroll
Notary Public - State of Florida
23 My Commission #EE056298
Expires April 20, 2012
24
25
-NETWORK REPORTING CORPORATION 305-358-8188