HomeMy Public PortalAbout2014-CA-003721 Plaintiff's Exhibit A of Robert Ganger Depo (01/31/2018)Filing, # 66507702 E -Filed 01/12/2018 04:27:54 PM X
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IN THE FIFTEENTH JUDICIAL CIRCUIT COURT
PALM BEACH COUNTY, FLORIDA
STOPDIRTYGOVERNMENT, Case No.: 2014 -ca -003721
LLC., Division AH: Judge Small
Plaintiff,
V. PLAINTIFF'S AMENDED!
NOTICE OF TAKING VIDEO
TOWN OF GULF STREAM, DEPOSITION DUCES TECUM
OF WITNESS
Defendant. ROBERT GANGER
TO: All counsel for Defendant Town of Gulf Stream
PLEASE TAKE NOTICE that the undersigned counsel will take the videotaped
deposition of:
WITNESS: Robert W. Ganger
DATE: Wednesday, January 31, 2018
TIME: 9:30 a.m.
PLACE: Gulf Stream Town Hall, 100 Sea Lane, Gulf Stream, Florida
Upon oral examination before a court reporter and videographer of Daughters Reporting, Inc., or
other officer or notary public authorized by law to take depositions in the State of Florida, said
deposition to continue from hour to hour and day to day until it completed. The deposition will
be taken for purposes of discovery, for use at trial, or for such other purposes as are permitted
pursuant to the Florida Rules of Civil Procedure, Florida Rules of Evidence, and applicable
statutes.
THE DEFENDANT IS REQUESTED TO PRODUCE, for inspection, examination and
copying, at the time and place above, the following:
1. Copies of any and all e-mails sent by any municipal employee of the Town of
Gulf Stream to you at the e-mail address rwganger@bellsouth.net between
November 1, 2012 and February 7, 2014.
2. Copies of any and all e-mails sent to any municipal employee of the Town of Gulf
Stream from you via the e-mail address rwganger@bellsouth.net between
November 1, 2012 and February 7, 2014.
' . A copy of the subpoena served on the witness is attached to this notice. All parties have
agreed to this second rescheduling of the deposition, and this notice serves to cancel the
deposition previously set to take place on Tuesday, January 16, 2018.
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3. Copies of any and all communications and documents (including but not limited
to: written correspondence, text message, e-mails, telephone logs, memoranda,
video recordings, audio recordings, videotapes, audiotapes, compact discs, hard
drives, portable thumb drives, diskettes, transcriptions of recordings, agendas,
minutes, drafts, calendars, meeting invitations, etc.) sent by you to any municipal
employee of the Town of Gulf Stream between November 1, 2012 and February
7, 2014.
4. Copies of any and all communications and documents (including but not limited
to: written correspondence, text message, e-mails, telephone logs, memoranda,
video recordings, audio recordings, videotapes, audiotapes, compact discs, hard
drives, portable thumb drives, diskettes, transcriptions of recordings, agendas,
minutes, drafts, calendars, meeting invitations, etc...) received by you from any
municipal employee of the Town of Gulf Stream between November 1, 2012 and
February 7, 2014.
5. Copies of any and all e-mails sent by you to any individual not employed by The
Town of Gulf Stream via the email address rwganger@bellsouth.net between
November 1, 2012 and February 7, 2014 which reflect the transaction of public
business. This includes responses to e-mails from citizens sent to you in your
official capacity as Commissioner.
6. Copies of any and all e-mails received by you from any individual not employed
by The Town of Gulf Stream via the email address rwganger@bellsouth.net
between November 1, 2012 and February 7, 2014 which reflect the transaction of
public business. This includes e-mails from citizens sent to you in your official
capacity as Commissioner.
These items will be inspected and may be copied at that time. You will not be required to surrender
the original items.
The operator recording the deposition will be Daughter's Reporting, Inc., of Atrium Plaza
Executive Suites, 1515 N. Federal Highway, Ste. 300, Boca Raton, FL 33432, and the deposition
will be recorded simultaneously by a stenographer. Copies of the videotape will be made available
upon request.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on January 12, 2017, I uploaded a copy of this amended
notice to the Florida Courts Efiling Portal, which was to serve a copy by email on counsel for the
Defendant, Joanne M. O'Connor of Jones Foster Johnson & Stubbs, P.A., 505 S. Flagler Dr.,
Suite 100, West Palm Beach, FL 33401-5950 Ooconnor@jonesfoster.com); Robert A.
Sweetapple, of Sweetapple, Broeker & Vargas, P.A., 20 S.E. 3d St., Boca Raton, FL 33432
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(rsweetapple@sweetapplelaw.com and pleadings@sweetappple.com); and Edward Nazzaro,
Town of Gulf Stream, 100 Sea Rd., Gulf Stream, FL 33483 (tnazzaro@gulf stream.org). I also
certify that I served a copy by email on the witness's attorneys, Brett J. Schneider and Matthew
T. Ramenda of Weiss Serota Helfman Cole & Bierman, 1200 N. Federal Hwy., Suite 312, Boca
Raton, FL 33432-2846 (bschneider@wsh-law.com and mramenda@wsh-law.com).
Respectfully submitted,
/s/Robert Rivas
Robert Rivas
Florida Bar No. 896969
SACH SAX CAPLAN, P.L.
Counsel for Plaintiff
6111 Broken Sound Parkway NW, Suite 200
Boca Raton, FL 33487
(561)994-4499 ;
rrivas@ssclawfirm.com,
dwilkerson@ssclawfirm.com, and
robertrivas@comcast.net
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