Preview
Filing # 117693470 E-Filed 12/04/2020 03:48:07 PM.
IN. THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT, IN AND
FOR PALM BEACH COUNTY, FLORIDA
MEGHAN MURRAY,
Plaintiff,
Vv.
MARIE VILME and LM GENERAL
INSURANCE COMPANY,
Defendants, Case No.: 502020CA008384XXXXMB
f 7
PLAINTIFF'S MOTION TO COMPEL DEPOSITION OF DEFENDANT, MARIE VILME
COMES NOW the Plaintiff, MEGHAN MURRAY, by and through her undersigned
counsel and hereby files this Motion to Compel Deposition, and as grounds therefore
would state as follows:
1. This is an action for personal injuries resulting from a November 28, 2019 motor
vehicle accident.
2. On October 23, 2020, Plaintiff requested the deposition of Defendant, MARIE
VILME. Please see email attached hereto as Exhibit “A”.
3. On November 5, 2020, because of Defendant's failure to respond, Plaintiff senta
follow-up email requesting dates of availability to schedule the deposition. Please
see emails attached hereto as Exhibit “B”.
4. On November 17, 2020, counsel for Plaintiff confirmed availability for the
deposition of Plaintiff, which has been scheduled for January 27, 2021, aa again
requested dates for deposition of Defendant, MARIE VILME. Please see emails
attached hereto as Exhibit “C”.
*** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 12/04/2020 03:48:07 PM ***5. On December 3, 2020, Plaintiff sent their fourth request for dates of availability
for the deposition of Defendant, MARIE VILME. Please see emails attached
hereto as Exhibit “D”. i
6. As of the date of this motion, Plaintiff has not received dates for the deposition.
1
7. The requested deposition is critical to the Plaintiff's case and should not be
delayed.
8. Plaintiff states that this motion is being made in good faith and not for the
purpose of delay.
WHEREFORE, Plaintiff, MEGHAN MURRAY, requests that the Court enter an order
compelling Defendant to furnish dates for the deposition of persons requested to:occur
within 45-60 days and any other relief the court deems proper.
| HEREBY CERTIFY that a true and correct copy of the foregoing has been e-
filed with the Clerk of the Court via the Florida Court's E-Filing Portal on December 4,
2020 with electronic copies issued to the attorneys listed on the service reflected on the
Court's E-Filing Portal.
GORDON & PARTNERS, P.A.
Attomeys for Plaintiff
4114 Northlake Boulevard
Palm Beach Gardens, FL 33410
Tel.: (561) 799-5070
Fax: (561) 634-2188
REG. pleadings@fortheinjured.com
By: 4/ROBERT E. GORDON
ROBERT E. GORDON, ESQ.
Florida Bar No.: 260479Cherish Hankinson
From:
Sent:
To:
Subject:
Importance:
Good afternoon.
We would like to schedule the deposition of Marie Vilme. Please provide dates of availability.
Thank you.
Cherish Hankinson
Friday, October 23, 2020 3:29 PM
john.camacho@farmersinsurance.com
‘1st Deposition Request - Murray, Meghan v. Marie Vilme:
High
EXHIBITCherish Hankinson
Cherish Hankinson
Thursday, November 05, 2020 9:58 AM
John Camacho; Wendy Carrasco
Hennes, Christine; Julio Diaz
Subject: 2nd Deposition Request - Murray, Meghan v. Marie Vilme:
Good morning.
| am following up on the below request. Please provide dates of availability for the deposition of Marie Vilme.
Thank you.
From: John Camacho
Sent: Friday, October 23, 2020 4:40 PM
To: Cherish Hankinson
Subject: RE: 20-0551 Murray, Meghan v. Marie Vilme: 1st Deposition Request - Murray, Meghan v. Marie Vilme:
Hi Cherish, | forwarded your request to the legal assistant that schedules on the case (Wendy), as well as to the
attorney. As soon as they can I’m sure they will respond to your request below.
Sincerely,
John Camacho, Paralegal
Law Offices of Sanabria and Marsh
Employees of Farmers Insurance Exchange
a Member of the Farmers Insurance Group of Companies
2290 Lucien Way, Suite 280
Maitland, FL 32751
(Direct) 407-551-6705 :
(Fax) 407-875-0205 i
(Email) john.camacho@farmersinsurance.com :
COVID-19 NOTICE — In light of the national health emergency, | am currently working from home and can be reached by
telephone and e-mail. We are sending and accepting only e-mail service from all attorneys and we are not accepting
deliveries from FedEx, UPS or any other courier. E-mail communications are preferred to avoid any potential delays
caused by mailing. If you are unable to email, or if you have a delivery by FedEx, UPS or other courier, please mail
instead to P.O. Box 258829, Oklahoma City, OK 73125-8829.
From: Cherish Hankinson
Sent: Friday, October 23, 2020 3:29 PM
To: John Camacho
Subject: [EXTERNAL] 1st Deposition Request - Murray, Meghan v. Marie Vilme:
Importance: High
Good afternoon. EXH | B It
B
We would like to schedule the deposition of Marie Vilme. Please provide dates of availability.Thank you.
Sincerely,
Cherish Hankinson
Paralegal to Robert Gordon, Esq.
4114 Northlake Bivd, Palm Beach Gardens, FL 33410
office: (561) 799-5070 fax: (661) 799-4050
www.fortheinjured.com
ro
Personal Injury | Medical Malpractice | Wrongful Death | Defective Products | Employment Law ¢ | G 8 y
Veteran's Benefits | Workers’ Compensation | Class Actions | Nursing Home Abuse | Mass Torts
Privileged and Confidential E-mail is not a secure mode of communication and may be accessed by unauthorized persons. This communication originates from the law firm of Gordon
P.A.. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. $2510-2521. The information contained in this e-mail message is intended for the use of the individ.
to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. If the reader of this message is not
intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reproduction, disclosure or dissemination «
‘communication may be subject to legal restriction or sanction. Personal messages express views solely of the sender and shall not be attributed to the law firm. If you received this
‘communication in error, please notify the sender immediately by e-mail or by telephone at (800) 659-1159. |
4 Please consider the environment before printing this e-mail :
***4+ PLEASE NOTE ***** This E-Mail/telefax message and any documents accompanying this transmission
may contain privileged and/or confidential information and is intended solely for the addressee(s) named above.
If you are not the intended addressee/recipient, you are hereby notified that any use of, disclosure, copying,
distribution, or reliance on the contents of this E-Mail/telefax information is strictly prohibited and may result in
legal action against you. Please reply to the sender advising of the error in transmission and immediately
delete/destroy the message and any accompanying documents. Thank you.*****Cherish Hankinson
From: Cherish Hankinson
Sent: Tuesday, November 17, 2020 9:46 AM
To: ‘Mendez, Cierra’; Wendy Carrasco
Subject: 3rd Deposition Dates - Murray, Meghan v. Marie Vilme:
Importance: High !
Good morning.
1am following up on the below emails as our office has not received confirmation to set the deposition of Defendant on
the date given, January 27, 2021. Please confirm.
Thank you.
From: Mendez, Cierra
Sent: Thursday, November 12, 2020 6:52 PM
To: Wendy Carrasco ; Cherish Hankinson
Subject: RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: Deposition Dates - Murray, Meghan v.
Marie Vilme:
Good Evening,
Any update on this?
Curva Vendy
Legal Secretary
Law Office of Glenn G. Gomer
Direct Dial: 813-302-4215
Office: 813-286-0068
4 PLEASE CONSIDER THE ENVIRONMENT BEFORE PRINTING THIS E-MAIL
This e-mail and any attachments thereto, is intended only for the use of the addressee(s) named herein and may contain legally privileged and/or confidential
information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or copying of this e-mail, and any
attachments thereto, is strictly prohibited. If you have received this e-mail in error, please notify me via return e-mail and via telephone at 813-286-0068 and
permanently delete the original and any copy of any e-mail and any printout thereof.
‘From Wendy Carrasco
Sent: Tuesday, November 10, 2020 2:01 PM
To: Cherish Hankinson ; Mendez, Cierra
Subject: {EXTERNAL} RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: Deposition Dates -
Murray, Meghan v. Marie Vilme:
Good afternoon, EXHIBIT
| haven’t been able to confirm the date with Ms. Vilme. CeWill keep you posted. :
Thanks,
Wendy Carrasco Legal Assistant to
Margalie Fenelus Reyes, Esq. & Julio L. Diaz, Esq.
Law Offices of Sanabria & Marsh
Employees of Farmers Insurance Exchange,
a Member of the Farmers Insurance Group of Companies
1000 NW 57th Court, Suite 850
Miami, FL 33126
Direct line: 305 459-5208
COVID-19 NOTICE — In light of the national health emergency, | am currently working from home and can be
reached by telephone and e-mail. We are sending and accepting only e-mail service from all attorneys and we
are not accepting deliveries from FedEx, UPS, or any other courier. E-mail communications are preferred to
avoid any potential delays caused by mailing. If you are unable to e-mail, or if you have a delivery by FedEx, UPS,
or other courier, please mail instead to P.O. Box 258829, Oklahoma City, OK 73125-8829.
From: Cherish Hankinson
Sent: Tuesday, November 10, 2020 11:12 AM
To: Wendy Carrasco ; Mendez, Cierra
Subject: [EXTERNAL] RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: Deposition Dates -
Murray, Meghan v. Marie Vilme:
Good morning.
Following up on the below. Are we set for the 27"?
Sincerely,
Cherish Hankinson
Paralegal to Robert Gordon, Esq.
4114 Northlake Blvd, Palm Beach Gardens, FL 33410 |
office: (561) 799-5070 fax: (561) 799-4050 ;
www. fortheinjured.com
ere
Personal Injury | Medical Malpractice | Wrongful Death | Defective Products | Employment Law a g t
Veteran's Benefits | Workers’ Compensation | Class Actions | Nursing Home Abuse | Mass Torts
Privileged and Confidential E-mail is not a secure mode of communication and may be accessed by unauthorized persons, This communication originates from the law firrr
P.A.. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. $2510-2521. The information contained in this e-mail message is intended for the use of
to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. Ifthe reader of this mes
2 !intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reproduction, disclosure or dis
communication may be subject to legal restriction or sanction. Personal messages express views solely of the sender and shall not be attributed to the law firm. If you rece
communication in error, please notify the sender immediately by e-mail or by telephone at (800) 659-1159,
4 Please consider the environment before printing this e-mail
From: Wendy Carrasco :
Sent: Friday, November 06, 2020 3:02 PM i
To: Cherish Hankinson ; Mendez, Cierra
Subject: RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: Deposition Dates - Murray,
Meghan v. Marie Vilme:
Good afternoon Ladies,
My attorney is available on January 27; however, | am waiting to confirm our client availability on that date.
| will keep you posted.
Thanks,
Wendy Carrasco Legal Assistant to
Margalie Fenelus Reyes, Esq. & Julio L. Diaz, Esq.
Law Offices of Sanabria & Marsh
Employees of Farmers Insurance Exchange,
a Member of the Farmers Insurance Group of Companies
1000 NW 57th Court, Suite 850
Miami, FL 33126
Direct line: 305 459-5208
COVID-19 NOTICE — In light of the national health emergency, | am currently working from home and can be
reached by telephone and e-mail. We are sending and accepting only e-mail service from all attorneys and we
are not accepting deliveries from FedEx, UPS, or any other courier. E-mail communications are preferred to
avoid any potential delays caused by mailing. If you are unable to e-mail, or if you have a delivery by FedEx, UPS,
or other courier, please mail instead to P.O. Box 258829, Oklahoma City, OK 73125-8829.
From: Cherish Hankinson
Sent: Thursday, November 5, 2020 11:42 AM
To: Mendez, Cierra ; John Camacho
; Wendy Carrasco
Ce: Julio Diaz
Subject: [EXTERNAL] Deposition Dates - Murray, Meghan v. Marie Vilme: !
Our client is available Wednesdays and Fridays at 10:30am. So let’s plan for January 27" start at 10:30 with
Meghan and send me a time, in the afternoon, for Marie.
Sincerely,
Cherish Hankinson
Paralegal to Robert Gordon, Esq.ere irol na saan sath
4114 Northlake Blvd, Palm Beach Gardens, FL 33410
office: (561) 799-5070 fax: (561) 799-4050
www. fortheinjured.com
Bre
Personal Injury | Medical Malpractice | Wrongful Death | Defective Products | Employment Law rv t
Veteran's Benefits | Workers’ Compensation | Class Actions | Nursing Home Abuse | Mass Torts
Privileged and Confidential E-mail is not a secure mode of communication and may be accessed by unauthorized persons. This communication originates from the taw firrr
P.A.. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. $2510-2521. The information contained in this e-mail message is intended for the use of
to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. If the reader of this mes
intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reproduction, disclosure or dist
‘communication may be subject to legal restriction or sanction. Personal messages express views solely of the sender and shall not be attributed to the law firm. If you rece!
‘communication in error, please notify the sender immediately by e-mail or by telephone at (800) 659-1159,
4 Please consider the environment before printing this e-mail
From: Mendez, Cierra
Sent: Thursday, November 05, 2020 11:38 AM
To: Cherish Hankinson ; John Camacho
; Wendy Carrasco
Ce: Julio Diaz
Subject: RE: 20-0551 Murray, Meghan.v. LM GENERAL INSURANCE COMPANY: 2nd Deposition Request - Murray,
Meghan v. Marie Vilme:
We have no preference as to who goes first, but if we can knock these out the same day that would be great.
Here are some dates to get the ball rolling:
1/25-1/28
2/2-2/5
2/8-2/12
(verve endey
Legal Secretary
Law Office of Glenn G. Gomer
813-302-4215
-286-0068 '
4 PLEASE CONSIDER THE ENVIRONMENT BEFORE PRINTING THIS E-MAIL,
This e-mail and any attachments thereto, is intended only for the use of the addressee(s) named herein and may contain legally privileged and/or confidential
information. If you are not the intended recipient of this e-mail, you are hercby notified that any dissemination, distribution or copying of this e-mail, and
any attachments thereto, is strictly probibited. If you have received this e-mail in error, please notify me via return e-mail and via telephone at 813-286-0068
and permanently delete the original and any copy of any e-mail and any printout thereof.
From: Cherish Hankinson
Sent: Thursday, November 05, 2020 10:30 AM
4To: Mendez, Cierra ; John Camacho :
; Wendy Carrasco
Ce: Julio Diaz
Subject: {EXTERNAL} RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: 2nd
Deposition Request - Murray, Meghan v. Marie Vilme:
| have sent a request to our client for dates and times. | am certain we can coordinate the ‘deposition to
occur within a week of each other. If you would like to provide dates, if you already have them, | will
make certain our client goes first.
Sincerely,
Cherish Hankinson
Paralegal to Robert Gordon, Esq.
9° 4114 Northlake Blvd, Palm Beach Gardens, FL 33410.
& office: (561) 799-5070 fax: (561) 799-4050
S www.fortheinjured.com
Personal Injury | Medical Malpractice | Wrongful Death | Defective Products | Employment Law|
Veteran's Benefits | Workers’ Compensation | Class Actions | Nursing Home Abuse | Mass Torts
Privileged and Confidential E-mail is not a secure mode of communication and may be accessed by unauthorized persons. This communication originates from
P.A. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. $2510-2521. The information contained in this e-mail message is intended fe
to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. If the reader
intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reproduction, disck
communication may be subject to legal restriction or sanction. Personal messages express views solely of the sender and shall not be attributed to the taw firm,
communication in error, please notify the sender immediately by e-mail or by telephone at (800) 659-1159.
4 Please consider the environment before printing this e-mail
From: Mendez, Cierra
Sent: Thursday, November 05, 2020 10:28 AM
To: Cherish Hankinson ; John Camacho
; Wendy Carrasco
Ce: Julio Diaz
Subject: RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: 2nd Deposition Request -
Murray, Meghan v. Marie Vilme:
Good Morning,
| would also like to get the deposition of the plaintiff set, maybe we can set these on the same dates.
My office is presently scheduling into late Jan.
(verva VhendeyLegal Secretary
Law Office of Glenn G. Gomer
Direct Dial: 813-302-4215
Office: 813-286-0068
4 PLEASE CONSIDER THE ENVIRONMENT BEFORE PRINTING THIS E-MAIL
This e-mail and any attachments thereto, is intended only for the use of the addressee(s) named herein and may contain legally privileged and/or
confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or
copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this e-mail in error, please notify me via return e-
mail and via telephone at 813-286-0068 and permanently delete the original and any copy of any e-mail and any printout thereof.
From: Hennes, Christine
Sent: Thursday, November 05, 2020 10:00 AM
To: Cherish Hankinson ; John Camacho
; Wendy Carrasco
Ce: Julio Diaz ; Mendez, Cierra
Subject: RE: 2nd Deposition Request - Murray, Meghan v. Marie Vilme:
Please remove me from this email chain
Please communicate with Cierra re scheduling
Christine R. Hennes
Attorney
Law Office of Glenn G. Gomer
Employee of Liberty Mutual Insurance Company
Direct dial: 813-868-8134
Cell: 813-503-6805
Desktop fax: 603-430-0858
Christine. Hennes@LibertyMutual.com
If you need immediate assistance, please contact Cierra at (813) 302-4215
PLEASE NOTE, that we will be working 100% remotely at this time due to COVID-
19. Also, our physical office will be closed through December 31, 2020. As a result,
mail will not be processed at our office during that time. Therefore, please send a
of all letters, discovery, attachments, pleadings, demands and other tim
sensitive documents directly to my email address:
Christine. Hennes@Libertymutual.com.
This will ensure that I receive your correspondence. Also, my client and I will
receive it more quickly, and we should be able to respond more quickly. :
However, I do not waive formal service of anything requiring proper service unless I
specifically advise you in writing to the contrary.
Please note that | can only accept the service of legal documents that
are served in compliance with the Florida Rules of Judicial
Administration. To ensure compliance, please serve both my
designated primary e-mail address at
PLGmail@LibertyMutual.com, as well as my designated secondary
e-mail address at Christine. Hennes@LibertyMutual.com. Also,
6please note that service of legal documents via e-mail does not
excuse or exempt compliance with applicable law which requires
service by other means. | am not authorized to accept time limit
demands via e-mail.
Please be advised that there is a risk a third party can gain access when sending or receiving
electronic communications using a computer or other device, or e-mail account.
This e-mail, and any attachments thereto, is intended only for the use of the addressee(s) named
herein and may contain legally privileged and/or confidential information. If you are not the
intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or
copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this
e-mail in error, please notify me via return e-mail and via telephone at 813 286-0068 and
permanently delete the original and any copy of any e-mail and any printout thereof.
From: Cherish Hankinson
Sent: Thursday, November 5, 2020 9:58 AM
To: John Camacho ; Wendy Carrasco
Cc: Hennes, Christine ; Julio Diaz
i
Subject: {EXTERNAL} 2nd Deposition Request - Murray, Meghan v. Marie Vilme:
Good morning.
1am following up on the below request. Please provide dates of availability for the deposition of
Marie Vilme.
Thank you.
Sincerely,
Cherish Hankinson
Paralegal to Robert Gordon, Esq.
4114 Northlake Blvd, Palm Beach Gardens, FL 33411
office: (561) 799-5070 fax: (561) 799-4050
www. fortheinjured.com |
ere
Personal Injury | Medical Malpractice | Wrongful Death | Defective Products | Employment Law
Veteran's Benefits | Workers’ Compensation | Class Actions | Nursing Home Abuse | Mass Torts
Privileged and Confidential E-mail is not a secure mode of communication and may be accessed by unauthorized persons. This communication orig
P.A.. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. 82510-2521. The information contained in this e-mail message is
to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. |
intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reprodtcommunication may be subject to legal restriction or sanction. Personal messages express views solely of the sender and shall not be attributed to
communication in error, please notify the sender immediately by e-mail or by telephone at (800) 659-1159.
4 Please consider the environment before printing this e-mail i
From: John Camacho <;| ohn. camacho farmersinsurance.c com> i
Sent: Friday, October 23, 2020 4:40 PM |
To: Cherish Hankinson :
Subject: RE: 20-0551 Murray, Meghan v. Marie Vilme: 1st Deposition Request - Murray, Meghan
v. Marie Vilme:
Hi Cherish, | forwarded your request to the legal assistant that schedules on the case (Wendy),
as well as to the attorney. As soon as they can I’m sure they will respond to your request below.
Sincerely,
John Camacho, Paralegal
Law Offices of Sanabria and Marsh
Employees of Farmers Insurance Exchange
a Member of the Farmers Insurance Group of Companies \
2290 Lucien Way, Suite 280 ;
Maitland, FL 32751
(Direct) 407-551-6705
(Fax) 407-875-0205 i
(Email) john.camacho@farmersinsurance.com
COVID-19 NOTICE ~ in light of the national health emergency, | am currently working from home
and can be reached by telephone and e-mail. We are sending and accepting only e-mail service
from all attorneys and we are not accepting deliveries from FedEx, UPS or any other courier. E-
mail communications are preferred to avoid any potential delays caused by mailing. If you are
unable to email, or if you have a delivery by FedEx, UPS or other courier, please mail instead to
P.O. Box 258829, Oklahoma City, OK 73125-8829.
From: Cherish Hankinson fortheini ured, com>
Sent: Friday, October 23, 2020 3:29 PM
To: John Camacho
Subject: [EXTERNAL] 1st Deposition Request - Murray, Meghan v. Marie Vilme:
Importance: High
Good afternoon.
We would like to schedule the deposition of Marie Vilme. Please provide dates of availability.
Thank you.
Sincerely,
Cherish Hankinson
Paralegal to Robert Gordon, Esq.4114 Northlake Blvd, Palm Beach Gardens, FL 33411
office: (561) 799-5070 fax: (561) 799-4050
www. fortheinjured.com
9
&
@
Personal Injury | Medical Malpractice | Wrongful Death | Defective Products | Employment Law
Veteran's Benefits | Workers’ Compensation | Class Actions | Nursing Home Abuse | Mass Torts
Privileged and Confidential E-mail is not a secure mode of communication and may be accessed by unauthorized persons. This communication orig
P.A.. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. S2510-2621. The information contained in this e-mail message is
to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. |
intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reprod.
‘communication may be subject to legal restriction or sanction. Personal messages express views solely of the sender and shall not be attributed to 1
‘communication in error, please notify the sender immediately by e-mail or by telephone at (800) 659-1159.
4 Please consider the environment before printing this e-mail
*4*** PLEASE NOTE ***** This E-Mail/telefax message and any documents
accompanying this transmission may contain privileged and/or confidential information
and is intended solely for the addressee(s) named above. If you are not the intended
addressee/recipient, you are hereby notified that any use of, disclosure, copying,
distribution, or reliance on the contents of this E-Mail/telefax information is strictly
prohibited and may result in legal action against you. Please reply to the sender advising
of the error in transmission and immediately delete/destroy the message and any
accompanying documents. Thank you.*****
#44 PLEASE NOTE ***** This E-Mail/telefax message and any documents accompanying this
transmission may contain privileged and/or confidential information and is intended solely for the
addressee(s) named above. If you are not the intended addressee/recipient, you are hereby notified that
any use of, disclosure, copying, distribution, or reliance on the contents of this E-Mail/telefax
information is strictly prohibited and may result in legal action against you. Please reply to the sender
advising of the error in transmission and immediately delete/destroy the message and any accompanying
documents. Thank you.***** :
***** PLEASE NOTE ***** This E-Mail/telefax message and any documents accompanying this transmission
may contain privileged and/or confidential information and is intended solely for the addressee(s) named above.
If you are not the intended addressee/recipient, you are hereby notified that any use of, disclosure, copying,
distribution, or reliance on the contents of this E-Mail/telefax information is strictly prohibited andi may result in
legal action against you. Please reply to the sender advising of the error in transmission and immediately
delete/destroy the message and any accompanying documents. Thank you.*****Cherish Hankinson
From: Cherish Hankinson
Sent: Thursday, December 03, 2020 9:23 AM
To: ‘Wendy Carrasco’; Mendez, Cierra
Subject: 4th Request Deposition Dates - Murray, Meghan v. Marie Vilme: '
Good morning.
| am still waiting for dates for the deposition of your client. Please provide but noon tomorrow or we will unilaterally set.
Thank you.
Fro 3 Wendy Carrasco wendy. carrasco@farmersinsurance. com>
Sent: Wednesday, November 18, 2020 11:07 AM
To: Cherish Hankinson ; Mendez, Cierra
Subject: RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: 3rd Deposition Dates - Murray, Meghan v.
Marie Vilme:
i
Will do, thank you!
Wendy Carrasco Legal Assistant to
Margalie Fenelus Reyes, Esq. & Julio L. Diaz, Esq.
Law Offices of Sanabria & Marsh
Employees of Farmers Insurance Exchange,
a Member of the Farmers Insurance Group of Companies
1000 NW 57th Court, Suite 850
Miami, FL 33126
Direct line: 305 459-5208
COVID-19 NOTICE — In light of the national health emergency, | am currently working from home and can be reached by
telephone and e-mail. We are sending and accepting only e-mail service from all attorneys and we are not accepting
deliveries from FedEx, UPS, or any other courier. E-mail communications are preferred to avoid any potential delays
caused by mailing. If you are unable to e-mail, or if you have a delivery by FedEx, UPS, or other courier, please mail
instead to P.O. Box 258829, Oklahoma City, OK 73125-8829. 7
From: herish Hankinson
Sent: Tuesday, November 17, 2020 3:29 PM
To: Wendy Carrasco ; Mendez, Cierra
Subject: [EXTERNAL] RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: 3rd Deposition Dates -
Murray, Meghan v. Marie Vilme:
Ladies:
| think we should go ahead and schedule Plaintiff's deposition for 10am on 1/27/21 and keep attempting to reach your
client for additional dates. Two depos in one day may take too long. It was a nice attempt.
EXHIBITWendy, please keep after your client for dates. i
Cierra, | look forward to your Notice. Please note all depositions are to be taken via Zoom.
‘
Thank you.
Sincerely,
Cherish Hankinson
Paralegal to Robert Gordon, Esq.
4114 Northlake Blvd, Palm Beach Gardens, FL 33410
office: (561) 799-5070 fax: (561) 799-4050
www. fortheinjured.com
re
Personal Injury | Medical Malpractice | Wrongful Death | Defective Products | Employment Law 6
Veteran's Benefits | Workers’ Compensation | Class Actions | Nursing Home Abuse | Mass Torts : ue
Privileged and Confidential E-mail is not a secure mode of communication and may be accessed by unauthorized persons. This communication originates from the law firm of Gordon
P.A.. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. $2510-2521. The information contained in this e-mail message is intended for the use of the individ.
to which itis addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. Ifthe reader of this message is not
intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified thal any use, printing, reproduction, disclosure or dissemination «
‘communication may be subject to legal restriction or sanction. Personal messages express views solely of the sender and shall not be attributed to the ta Frm. you received this
communication in error, please notify the sender immediately by e-mail or by telephone at (800) 659-1159.
#4 Please consider the environment before printing this e-mail
From: Wendy Carrasco. wendy. carrasco@farmersinsurance. com>
Sent: Tuesday, November 17, 2020 2:22 PM
To: Cherish Hankinson ; Mendez, Cierra
Subject: RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: 3rd Deposition Dates - Murray, Meghan v.
Marie Vilme:
Good afternoon ladies,
| have been attempting to reach Ms. Vilme without success. | need to clear the date with her to make sure that she
actually shows up.
If you want we can tentatively set Ms. Vilme’s deposition for January 27, 2021 with the understanding that, if she is
unavailable on that date, it will be reset to properly accommodate her schedule. !
Please let me know, thanks.
Wendy Carrasco Legal Assistant to
Margalie Fenelus Reyes, Esq. & Julio L. Diaz, Esq.
Law Offices of Sanabria & Marsh
Employees of Farmers Insurance Exchange,
a Member of the Farmers Insurance Group of Companies
21000 NW 57th Court, Suite 850
Miami, FL 33126
Direct line: 305 459-5208
COVID-19 NOTICE ~ In light of the national health emergency, | am currently working from home and can be reached by
telephone and e-mail. We are sending and accepting only e-mail service from all attorneys and we are not accepting
deliveries from FedEx, UPS, or any other courier. E-mail communications are preferred to avoid any potential delays
caused by mailing. If you are unable to e-mail, or if you have a delivery by FedEx, UPS, or other courier, please mail
instead to P.O. Box 258829, Oklahoma City, OK 73125-8829.
From: Cherish Hankinson «
Sent: Tuesday, November 17, 2020 9:46 AM
To: Mendez, Cierra ; Wendy Carrasco
Subject: [EXTERNAL] 3rd Deposition Dates - Murray, Meghan v. Marie Vilme:
Importance: High
Good morning.
1am following up on the below emails as our office has not received confirmation to set the deposition of Defendant on
the date given, January 27, 2021. Please confirm.
Thank you.
Sincerely,
Cherish Hankinson
Paralegal to Robert Gordon, Esq.
RDONESPARTNERS J}
4114 Northlake Blvd, Palm Beach Gardens, FL 33410
office: (561) 799-5070 fax: (561) 799-4050
www.fortheinjured.com
re
Personal Injury | Medical Malpractice | Wrongful Death | Defective Products | Employment Law Qa 0 ¥Z
“S
Veteran's Benefits | Workers’ Compensation | Class Actions | Nursing Home Abuse | Mass Torts
Privileged and Confidential E-mail is not a secure mode of communication and may be accessed by unauthorized persons. This communication originates from the law firm of Gordon
P.A.. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. $2510-2521. The information contained in this e-mail message is intended for the use of the individ.
to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. If the reader of this message is not
intended recipient, or the employee or agent responsibte for delivery to the intended recipient, you are hereby notified that any use, printing, reproduction, disclosure or dissemination «
communication may be subject to legal restriction or sanction. Personal messages express views solely of the sender and shall not be attributed to the law firm, If you received this
communication in error, please notify the sender immediately by e-mail or by telephone at (800) 659-1159.
4 Please consider the environment before printing this e-mailFrom: Mendez, Cierra
Sent: Thursday, November 12, 2020 6:52 PM
To: Wendy Carrasco ; Cherish Hankinson
Subject: RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: Deposition Dates - Murray, Meghan v.
Marie Vilme:
Good Evening,
Any update on this?
Curva Vendy
Legal Secretary
Law Office of Glenn G. Gomer
Direct Dial: 813-302-4215
Office: 813-286-0068
4 PLEASE CONSIDER THE ENVIRONMENT BEFORE PRINTING THIS E-MAIL
This e-mail and any attachments thereto, is intended only for the use of the addressee(s) named herein and may contain legally privileged and/or confidential
information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or copying of this e-mail, and any
attachments thereto, is strictly prohibited, If you have received this e-mail in error, please notify me via return e-mail and via telephone at 813-286-0068 and
permanently delete the original and any copy of any e-mail and any printout thereof.
From: Wendy Carrasco
Sent: Tuesday, November 10, 2020 2:01 PM
To: Cherish Hankinson ; Mendez, Cierra
Subject: {EXTERNAL} RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: Deposition Dates -
Murray, Meghan v. Marie Vilme:
Good afternoon,
| haven’t been able to confirm the date with Ms. Vilme.
Will keep you posted.
Thanks,
Wendy Carrasco Legal Assistant to
Margalie Fenelus Reyes, Esq. & Julio L. Diaz, Esq.
Law Offices of Sanabria & Marsh
Employees of Farmers Insurance Exchange,
a Member of the Farmers Insurance Group of Companies
1000 NW 57th Court, Suite 850 i
Miami, FL 33126
Direct line: 305 459-5208
COVID-19 NOTICE — In light of the national health emergency, | am currently working from home and can be
reached by telephone and e-mail. We are sending and accepting only e-mail service from all attorneys and we
are not accepting deliveries from FedEx, UPS, or any other courier. E-mail communications are preferred to
avoid any potential delays caused by mailing. If you are unable to e-mail, or if you have a delivery by FedEx, UPS,
or other courier, please mail instead to P.O. Box 258829, Oklahoma City, OK 73125-8829.
4From: Cherish Hankinson
Sent: Tuesday, November 10, 2020 11:12 AM
To: Wendy Carrasco ; Mendez, Cierra
Subject: [EXTERNAL] RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: Deposition Dates -
Murray, Meghan v. Marie Vilme: 1
Good morning.
Following up on the below. Are we set for the 27"?
Sincerely,
Cherish Hankinson
Paralegal to Robert Gordon, Esq.
9 4114 Northlake Blvd, Palm Beach Gardens, FL 33410
& office: (561) 799-5070 fax: (661) 799-4050
www. fortheinjured.com
Personal Injury | Medical Malpractice | Wrongful Death | Defective Products | Employment Law & t
Veteran's Benefits | Workers’ Compensation | Class Actions | Nursing Home Abuse | Mass Torts
Privileged and Confidential E-mail is not a secure mode of communication and may be accessed by unauthorized persons, This communication originates from the law firrr
P.A.. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. $2510-2521. The information contained in this e-mail message is intended for the use of
to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. If the reader of this mes
intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reproduction, disclosure or dis:
communication may be subject to legal restriction or sanction. Personal messages express views solely of the sender and shall not be attributed to the law firm. If you recei
‘communication in error, please notify the sender immediately by e-mail or by telephone at (800) 659-1159, :
4 Please consider the environment before printing this e-mail
From: Wendy Carrasco
Sent: Friday, November 06, 2020 3:02 PM :
To: Cherish Hankinson ; Mendez, Cierra
Subject: RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: Deposition Dates - Murray,
Meghan v. Marie Vilme:
Good afternoon Ladies,
My attorney is available on January 27; however, | am waiting to confirm our client availability on that date.
| will keep you posted.
Thanks,
Wendy Carrasco Legal Assistant toMargalie Fenelus Reyes, Esq. & Julio L. Diaz, Esq.
Law Offices of Sanabria & Marsh
Employees of Farmers Insurance Exchange, '
a Member of the Farmers Insurance Group of Companies
1000 NW 57th Court, Suite 850
Miami, FL 33126
Direct line: 305 459-5208
COVID-19 NOTICE ~ In light of the national health emergency, | am currently working from home and can be
reached by telephone and e-mail. We are sending and accepting only e-mail service from all attorneys and we
are not accepting deliveries from FedEx, UPS, or any other courier. E-mail communications are preferred to
avoid any potential delays caused by mailing. If you are unable to e-mail, or if you have a delivery by FedEx, UPS,
or other courier, please mail instead to P.O. Box 258829, Oklahoma City, OK 73125-8829.
From: Cherish Hankinson
Sent: Thursday, November 5, 2020 11:42 AM
To: Mendez, Cierra ; John Camacho
; Wendy Carrasco
Ce: Julio Diaz
Subject: [EXTERNAL] Deposition Dates - Murray, Meghan v. Marie Vilme:
Our client is available Wednesdays and Fridays at 10:30am. So let’s plan for January 27" start at 10:30 with
Meghan and send me a time, in the afternoon, for Marie.
Sincerely,
Cherish Hankinson
Paralegal to Robert Gordon, Esq.
9 4114 Northlake Blvd, Palm Beach Gardens, FL 33410
& office: (561) 799-5070 fax: (561) 799-4050
@ www. fortheinjured.com
Personal Injury | Medical Malpractice | Wrongful Death | Defective Products | Employment Law a
Veteran's Benefits | Workers’ Compensation | Class Actions | Nursing Home Abuse | Mass Torts '
Privileged and Confidential E-mail is not a secure mode of communication and may be accessed by unauthorized persons. This communication originates from the law firr
P.A. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. 2510-2521. The information contained in this e-mail message is intended for the use of
to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. If the reader of this mes
intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reproduction, disclosure or dis:
communication may be subject to legal restriction or sanction. Personal messages express views solely of the sender and shall not be attributed to the law firm. If you recei
communication in error, please notify the sender immediately by e-mail or by telephone at (800) 659-1159.
4s Please consider the environment before printing this e-mailFrom: Mendez, Cierra
Sent: Thursday, November 05, 2020 11:38 AM
To: Cherish Hankinson ; John Camacho
; Wendy Carrasco
Ce: Julio Diaz
Subject: RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: 2nd Deposition Request - Murray,
Meghan v. Marie Vilme: i
We have no preference as to who goes first, but if we can knock these out the same day that would be great.
Here are some dates to get the ball rolling:
1/25-1/28
2/2-2/5
2/8-2/12
(ra Vhendey
Legal Secretary
Law Office of Glenn G. Gomer
Direct Dial: 813-302-4215
Office: 813-286-0068
64 PLEASE CONSIDER THE ENVIRONMENT BEFORE PRINTING THIS E-MAIL
This e-mail and any attachments thereto, is intended only for the use of the addressee(s) named herein and may contain legally privileged and/or confidential
information, If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or copying of this e-mail, and
any attachments thereto, is strictly prohibited. If you have received this e-mail in error, please notify me via return e-mail and via telephone at 813-286-0068
and permanently delete the original and any copy of any e-mail and any printout thereof.
From: Cherish Hankinson ‘
Sent: Thursday, November 05, 2020 10:30 AM
To: Mendez, Cierra ; John Camacho
; Wendy Carrasco
Cc: Julio Diaz
Subject: {EXTERNAL} RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: 2nd
Deposition Request - Murray, Meghan v. Marie Vilme:
| have sent a request to our client for dates and times. | am certain we can coordinate the deposition to
occur within a week of each other. If you would like to provide dates, if you already have them, twill
make certain our client goes first. 5
Sincerely, '
Cherish Hankinson
Paralegal to Robert Gordon, Esq.
GORDONGSPARTNERS J}9 4114 Northlake Blvd, Palm Beach Gardens, FL 33410
& office: (561) 799-5070 fax: (561) 799-4050 :
www. fortheinjured.com
Personal Injury | Medical Malpractice | Wrongful Death | Defective Products | Employment Law t
Veteran's Benefits | Workers’ Compensation | Class Actions | Nursing Home Abuse | Mass Torts
Privileged and Confidential E-mail is not a secure mode of communication and may be accessed by unauthorized persons. This communication originates from
P.A., ands protected under the Electronic Communication Privacy Act, 18 U.S.C. 2510-2521. The information contained in this e-mail message is intended fc
to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. If the reade!
intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reproduction, disch
communication may be subject to legal restriction or sanction. Personal messages express views solely of the sender and shall not be attributed fo the law firm
communication in error, please notify the sender immediately by e-mail or by telephone at (800) 659-1159. 1
4 Please consider the environment before printing this e-mail
From: Mendez, Cierra
Sent: Thursday, November 05, 2020 10:28 AM
To: Cherish Hankinson ; John Camacho
; Wendy Carrasco
Ce: Julio Diaz
Subject: RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: 2nd Deposition Request -
Murray, Meghan v. Marie Vilme:
Good Morning,
| would also like to get the deposition of the plaintiff set, maybe we can set these on the same dates.
My office is presently scheduling into late Jan.
(verve. Wendy
Legal Secretary
Law Office of Glenn G. Gomer
Direct Dial: 813-302-4215
Office: 813-286-0068 i
4 PLEASE CONSIDER THE ENVIRONMENT BEFORE PRINTING THIS E-MAIL
This e-mail and any attachments thereto, is intended only for the use of the addressee(s) named herein and may contain legally privileged and/or
confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or
copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this e-mail in error, please notify me via retum e-
mail and via telephone at 813-286-0068 and permanently delete the original and any copy of any e-mail and any printout thereof.
From: Hennes, Christine
Sent: Thursday, November 05, 2020 10:00 AM
To: Cherish Hankinson ; John Camacho '
; Wendy Carrasco
Ce: Julio Diaz ; Mendez, Cierra
Subject: RE: 2nd Deposition Request - Murray, Meghan v. Marie Vilme:Please remove me from this email chain
Please communicate with Cierra re scheduling
Christine R. Hennes
Attorney
Law Office of Glenn G. Gomer
Employee of Liberty Mutual Insurance Company
Direct dial: 813-868-8134
Cell: 813-503-6805
Desktop fax: 603-430-0858
Christine. Hennes@LibertyMutual.com
If you need immediate assistance, please contact Cierra at (813) 302-4215
PLEASE NOTE, that we will be working 100% remotely at this time due to COVID-
19. Also, our physical office will be closed through December 31, 2020. As a result,
mail will not be processed at our office during that time. Therefore, please send a
copy of all letters, discovery, attachments, pleadings, demands and other time
sensitive uments dir to my email address:
Christine. Hennes@Libertymutual.com,
This will ensure that I receive your correspondence. Also, my client and I will
receive it more quickly, and we should be able to respond more quickly.
However, I do not waive formal service of anything requiring proper ice unless I
specifically advise you in writing to the contrary.
Please note that | can only accept the service of legal documents that
are served in compliance with the Florida Rules of Judicial
Administration. To ensure compliance, please serve both my
designated primary e-mail address at
PLGmail@LibertyMutual.com, as well as my designated secondary
e-mail address at Christine. Hennes@LibertyMutual.com. Also,
please note that service of legal documents via e-mail does not
excuse or exempt compliance with applicable law which requires
service by other means. | am not authorized to accept time limit
demands via e-mail.
Please be advised that there is a risk a third party can gain access when sending or receiving
electronic communications using a computer or other device, or e-mail account.
This e-mail, and any attachments thereto, is intended only for the use of the addressee(s) named
herein and may contain legally privileged and/or confidential information. If you are not the
intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or
copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this
e-mail in error, please notify me via return e-mail and via telephone at 813 286-0068 and
permanently delete the original and any copy of any e-mail and any printout thereof.
From: Cherish Hankinson
Sent: Thursday, November 5, 2020 9:58 AM
To: John Camacho ; Wendy Carrasco
9Ce: Hennes, Christine ; Julio Diaz
Subject: {EXTERNAL} 2nd Deposition Request - Murray, Meghan v. Marie Vilme:
Good morning.
| am following up on the below request. Please provide dates of availability for the deposition of
Marie Vilme. :
Thank you.
Sincerely,
Cherish Hankinson
Paralegal to Robert Gordon, Esq.
4114 Northlake Blvd, Palm Beach Gardens, FL 3341
office: (561) 799-5070 fax: (561) 799-4050
www. fortheinjured.com
Bre
Personal Injury | Medical Malpractice | Wrongful Death | Defective Products | Employment Law
Veteran's Benefits | Workers’ Compensation | Class Actions | Nursing Home Abuse | Mass Torts
Privileged and Confidential E-mail is not a secure mode of communication and may be accessed by unauthorized persons. This communication oric
P.A.. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. $2510-2521. The information contained in this e-mail message is
to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws.
intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reprodt
communication may be subject to legal restriction or sanction. Personal messages express views solely of the sender, and shall not be attributed to
communication in error, please notify the sender immediately by e-mail or by telephone at (800) 659-1159, i
#4 Please consider the environment before printing this e-mail 1
From: John Camacho <, john. camacho@farmersinsurance. com>
Sent: Friday, October 23, 2020 4:40 PM
To: Cherish Hankinson
Subject: RE: 20-0551 Murray, Meghan v. Marie
Preview
Filing # 117693470 E-Filed 12/04/2020 03:48:07 PM. IN. THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA MEGHAN MURRAY, Plaintiff, Vv. MARIE VILME and LM GENERAL INSURANCE COMPANY, Defendants, Case No.: 502020CA008384XXXXMB f 7 PLAINTIFF'S MOTION TO COMPEL DEPOSITION OF DEFENDANT, MARIE VILME COMES NOW the Plaintiff, MEGHAN MURRAY, by and through her undersigned counsel and hereby files this Motion to Compel Deposition, and as grounds therefore would state as follows: 1. This is an action for personal injuries resulting from a November 28, 2019 motor vehicle accident. 2. On October 23, 2020, Plaintiff requested the deposition of Defendant, MARIE VILME. Please see email attached hereto as Exhibit “A”. 3. On November 5, 2020, because of Defendant's failure to respond, Plaintiff senta follow-up email requesting dates of availability to schedule the deposition. Please see emails attached hereto as Exhibit “B”. 4. On November 17, 2020, counsel for Plaintiff confirmed availability for the deposition of Plaintiff, which has been scheduled for January 27, 2021, aa again requested dates for deposition of Defendant, MARIE VILME. Please see emails attached hereto as Exhibit “C”. *** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 12/04/2020 03:48:07 PM ***5. On December 3, 2020, Plaintiff sent their fourth request for dates of availability for the deposition of Defendant, MARIE VILME. Please see emails attached hereto as Exhibit “D”. i 6. As of the date of this motion, Plaintiff has not received dates for the deposition. 1 7. The requested deposition is critical to the Plaintiff's case and should not be delayed. 8. Plaintiff states that this motion is being made in good faith and not for the purpose of delay. WHEREFORE, Plaintiff, MEGHAN MURRAY, requests that the Court enter an order compelling Defendant to furnish dates for the deposition of persons requested to:occur within 45-60 days and any other relief the court deems proper. | HEREBY CERTIFY that a true and correct copy of the foregoing has been e- filed with the Clerk of the Court via the Florida Court's E-Filing Portal on December 4, 2020 with electronic copies issued to the attorneys listed on the service reflected on the Court's E-Filing Portal. GORDON & PARTNERS, P.A. Attomeys for Plaintiff 4114 Northlake Boulevard Palm Beach Gardens, FL 33410 Tel.: (561) 799-5070 Fax: (561) 634-2188 REG. pleadings@fortheinjured.com By: 4/ROBERT E. GORDON ROBERT E. GORDON, ESQ. Florida Bar No.: 260479Cherish Hankinson From: Sent: To: Subject: Importance: Good afternoon. We would like to schedule the deposition of Marie Vilme. Please provide dates of availability. Thank you. Cherish Hankinson Friday, October 23, 2020 3:29 PM john.camacho@farmersinsurance.com ‘1st Deposition Request - Murray, Meghan v. Marie Vilme: High EXHIBITCherish Hankinson Cherish Hankinson Thursday, November 05, 2020 9:58 AM John Camacho; Wendy Carrasco Hennes, Christine; Julio Diaz Subject: 2nd Deposition Request - Murray, Meghan v. Marie Vilme: Good morning. | am following up on the below request. Please provide dates of availability for the deposition of Marie Vilme. Thank you. From: John Camacho Sent: Friday, October 23, 2020 4:40 PM To: Cherish Hankinson Subject: RE: 20-0551 Murray, Meghan v. Marie Vilme: 1st Deposition Request - Murray, Meghan v. Marie Vilme: Hi Cherish, | forwarded your request to the legal assistant that schedules on the case (Wendy), as well as to the attorney. As soon as they can I’m sure they will respond to your request below. Sincerely, John Camacho, Paralegal Law Offices of Sanabria and Marsh Employees of Farmers Insurance Exchange a Member of the Farmers Insurance Group of Companies 2290 Lucien Way, Suite 280 Maitland, FL 32751 (Direct) 407-551-6705 : (Fax) 407-875-0205 i (Email) john.camacho@farmersinsurance.com : COVID-19 NOTICE — In light of the national health emergency, | am currently working from home and can be reached by telephone and e-mail. We are sending and accepting only e-mail service from all attorneys and we are not accepting deliveries from FedEx, UPS or any other courier. E-mail communications are preferred to avoid any potential delays caused by mailing. If you are unable to email, or if you have a delivery by FedEx, UPS or other courier, please mail instead to P.O. Box 258829, Oklahoma City, OK 73125-8829. From: Cherish Hankinson Sent: Friday, October 23, 2020 3:29 PM To: John Camacho Subject: [EXTERNAL] 1st Deposition Request - Murray, Meghan v. Marie Vilme: Importance: High Good afternoon. EXH | B It B We would like to schedule the deposition of Marie Vilme. Please provide dates of availability.Thank you. Sincerely, Cherish Hankinson Paralegal to Robert Gordon, Esq. 4114 Northlake Bivd, Palm Beach Gardens, FL 33410 office: (561) 799-5070 fax: (661) 799-4050 www.fortheinjured.com ro Personal Injury | Medical Malpractice | Wrongful Death | Defective Products | Employment Law ¢ | G 8 y Veteran's Benefits | Workers’ Compensation | Class Actions | Nursing Home Abuse | Mass Torts Privileged and Confidential E-mail is not a secure mode of communication and may be accessed by unauthorized persons. This communication originates from the law firm of Gordon P.A.. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. $2510-2521. The information contained in this e-mail message is intended for the use of the individ. to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. If the reader of this message is not intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reproduction, disclosure or dissemination « ‘communication may be subject to legal restriction or sanction. Personal messages express views solely of the sender and shall not be attributed to the law firm. If you received this ‘communication in error, please notify the sender immediately by e-mail or by telephone at (800) 659-1159. | 4 Please consider the environment before printing this e-mail : ***4+ PLEASE NOTE ***** This E-Mail/telefax message and any documents accompanying this transmission may contain privileged and/or confidential information and is intended solely for the addressee(s) named above. If you are not the intended addressee/recipient, you are hereby notified that any use of, disclosure, copying, distribution, or reliance on the contents of this E-Mail/telefax information is strictly prohibited and may result in legal action against you. Please reply to the sender advising of the error in transmission and immediately delete/destroy the message and any accompanying documents. Thank you.*****Cherish Hankinson From: Cherish Hankinson Sent: Tuesday, November 17, 2020 9:46 AM To: ‘Mendez, Cierra’; Wendy Carrasco Subject: 3rd Deposition Dates - Murray, Meghan v. Marie Vilme: Importance: High ! Good morning. 1am following up on the below emails as our office has not received confirmation to set the deposition of Defendant on the date given, January 27, 2021. Please confirm. Thank you. From: Mendez, Cierra Sent: Thursday, November 12, 2020 6:52 PM To: Wendy Carrasco ; Cherish Hankinson Subject: RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: Deposition Dates - Murray, Meghan v. Marie Vilme: Good Evening, Any update on this? Curva Vendy Legal Secretary Law Office of Glenn G. Gomer Direct Dial: 813-302-4215 Office: 813-286-0068 4 PLEASE CONSIDER THE ENVIRONMENT BEFORE PRINTING THIS E-MAIL This e-mail and any attachments thereto, is intended only for the use of the addressee(s) named herein and may contain legally privileged and/or confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this e-mail in error, please notify me via return e-mail and via telephone at 813-286-0068 and permanently delete the original and any copy of any e-mail and any printout thereof. ‘From Wendy Carrasco Sent: Tuesday, November 10, 2020 2:01 PM To: Cherish Hankinson ; Mendez, Cierra Subject: {EXTERNAL} RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: Deposition Dates - Murray, Meghan v. Marie Vilme: Good afternoon, EXHIBIT | haven’t been able to confirm the date with Ms. Vilme. CeWill keep you posted. : Thanks, Wendy Carrasco Legal Assistant to Margalie Fenelus Reyes, Esq. & Julio L. Diaz, Esq. Law Offices of Sanabria & Marsh Employees of Farmers Insurance Exchange, a Member of the Farmers Insurance Group of Companies 1000 NW 57th Court, Suite 850 Miami, FL 33126 Direct line: 305 459-5208 COVID-19 NOTICE — In light of the national health emergency, | am currently working from home and can be reached by telephone and e-mail. We are sending and accepting only e-mail service from all attorneys and we are not accepting deliveries from FedEx, UPS, or any other courier. E-mail communications are preferred to avoid any potential delays caused by mailing. If you are unable to e-mail, or if you have a delivery by FedEx, UPS, or other courier, please mail instead to P.O. Box 258829, Oklahoma City, OK 73125-8829. From: Cherish Hankinson Sent: Tuesday, November 10, 2020 11:12 AM To: Wendy Carrasco ; Mendez, Cierra Subject: [EXTERNAL] RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: Deposition Dates - Murray, Meghan v. Marie Vilme: Good morning. Following up on the below. Are we set for the 27"? Sincerely, Cherish Hankinson Paralegal to Robert Gordon, Esq. 4114 Northlake Blvd, Palm Beach Gardens, FL 33410 | office: (561) 799-5070 fax: (561) 799-4050 ; www. fortheinjured.com ere Personal Injury | Medical Malpractice | Wrongful Death | Defective Products | Employment Law a g t Veteran's Benefits | Workers’ Compensation | Class Actions | Nursing Home Abuse | Mass Torts Privileged and Confidential E-mail is not a secure mode of communication and may be accessed by unauthorized persons, This communication originates from the law firrr P.A.. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. $2510-2521. The information contained in this e-mail message is intended for the use of to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. Ifthe reader of this mes 2 !intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reproduction, disclosure or dis communication may be subject to legal restriction or sanction. Personal messages express views solely of the sender and shall not be attributed to the law firm. If you rece communication in error, please notify the sender immediately by e-mail or by telephone at (800) 659-1159, 4 Please consider the environment before printing this e-mail From: Wendy Carrasco : Sent: Friday, November 06, 2020 3:02 PM i To: Cherish Hankinson ; Mendez, Cierra Subject: RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: Deposition Dates - Murray, Meghan v. Marie Vilme: Good afternoon Ladies, My attorney is available on January 27; however, | am waiting to confirm our client availability on that date. | will keep you posted. Thanks, Wendy Carrasco Legal Assistant to Margalie Fenelus Reyes, Esq. & Julio L. Diaz, Esq. Law Offices of Sanabria & Marsh Employees of Farmers Insurance Exchange, a Member of the Farmers Insurance Group of Companies 1000 NW 57th Court, Suite 850 Miami, FL 33126 Direct line: 305 459-5208 COVID-19 NOTICE — In light of the national health emergency, | am currently working from home and can be reached by telephone and e-mail. We are sending and accepting only e-mail service from all attorneys and we are not accepting deliveries from FedEx, UPS, or any other courier. E-mail communications are preferred to avoid any potential delays caused by mailing. If you are unable to e-mail, or if you have a delivery by FedEx, UPS, or other courier, please mail instead to P.O. Box 258829, Oklahoma City, OK 73125-8829. From: Cherish Hankinson Sent: Thursday, November 5, 2020 11:42 AM To: Mendez, Cierra ; John Camacho ; Wendy Carrasco Ce: Julio Diaz Subject: [EXTERNAL] Deposition Dates - Murray, Meghan v. Marie Vilme: ! Our client is available Wednesdays and Fridays at 10:30am. So let’s plan for January 27" start at 10:30 with Meghan and send me a time, in the afternoon, for Marie. Sincerely, Cherish Hankinson Paralegal to Robert Gordon, Esq.ere irol na saan sath 4114 Northlake Blvd, Palm Beach Gardens, FL 33410 office: (561) 799-5070 fax: (561) 799-4050 www. fortheinjured.com Bre Personal Injury | Medical Malpractice | Wrongful Death | Defective Products | Employment Law rv t Veteran's Benefits | Workers’ Compensation | Class Actions | Nursing Home Abuse | Mass Torts Privileged and Confidential E-mail is not a secure mode of communication and may be accessed by unauthorized persons. This communication originates from the taw firrr P.A.. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. $2510-2521. The information contained in this e-mail message is intended for the use of to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. If the reader of this mes intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reproduction, disclosure or dist ‘communication may be subject to legal restriction or sanction. Personal messages express views solely of the sender and shall not be attributed to the law firm. If you rece! ‘communication in error, please notify the sender immediately by e-mail or by telephone at (800) 659-1159, 4 Please consider the environment before printing this e-mail From: Mendez, Cierra Sent: Thursday, November 05, 2020 11:38 AM To: Cherish Hankinson ; John Camacho ; Wendy Carrasco Ce: Julio Diaz Subject: RE: 20-0551 Murray, Meghan.v. LM GENERAL INSURANCE COMPANY: 2nd Deposition Request - Murray, Meghan v. Marie Vilme: We have no preference as to who goes first, but if we can knock these out the same day that would be great. Here are some dates to get the ball rolling: 1/25-1/28 2/2-2/5 2/8-2/12 (verve endey Legal Secretary Law Office of Glenn G. Gomer 813-302-4215 -286-0068 ' 4 PLEASE CONSIDER THE ENVIRONMENT BEFORE PRINTING THIS E-MAIL, This e-mail and any attachments thereto, is intended only for the use of the addressee(s) named herein and may contain legally privileged and/or confidential information. If you are not the intended recipient of this e-mail, you are hercby notified that any dissemination, distribution or copying of this e-mail, and any attachments thereto, is strictly probibited. If you have received this e-mail in error, please notify me via return e-mail and via telephone at 813-286-0068 and permanently delete the original and any copy of any e-mail and any printout thereof. From: Cherish Hankinson Sent: Thursday, November 05, 2020 10:30 AM 4To: Mendez, Cierra ; John Camacho : ; Wendy Carrasco Ce: Julio Diaz Subject: {EXTERNAL} RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: 2nd Deposition Request - Murray, Meghan v. Marie Vilme: | have sent a request to our client for dates and times. | am certain we can coordinate the ‘deposition to occur within a week of each other. If you would like to provide dates, if you already have them, | will make certain our client goes first. Sincerely, Cherish Hankinson Paralegal to Robert Gordon, Esq. 9° 4114 Northlake Blvd, Palm Beach Gardens, FL 33410. & office: (561) 799-5070 fax: (561) 799-4050 S www.fortheinjured.com Personal Injury | Medical Malpractice | Wrongful Death | Defective Products | Employment Law| Veteran's Benefits | Workers’ Compensation | Class Actions | Nursing Home Abuse | Mass Torts Privileged and Confidential E-mail is not a secure mode of communication and may be accessed by unauthorized persons. This communication originates from P.A. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. $2510-2521. The information contained in this e-mail message is intended fe to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. If the reader intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reproduction, disck communication may be subject to legal restriction or sanction. Personal messages express views solely of the sender and shall not be attributed to the taw firm, communication in error, please notify the sender immediately by e-mail or by telephone at (800) 659-1159. 4 Please consider the environment before printing this e-mail From: Mendez, Cierra Sent: Thursday, November 05, 2020 10:28 AM To: Cherish Hankinson ; John Camacho ; Wendy Carrasco Ce: Julio Diaz Subject: RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: 2nd Deposition Request - Murray, Meghan v. Marie Vilme: Good Morning, | would also like to get the deposition of the plaintiff set, maybe we can set these on the same dates. My office is presently scheduling into late Jan. (verva VhendeyLegal Secretary Law Office of Glenn G. Gomer Direct Dial: 813-302-4215 Office: 813-286-0068 4 PLEASE CONSIDER THE ENVIRONMENT BEFORE PRINTING THIS E-MAIL This e-mail and any attachments thereto, is intended only for the use of the addressee(s) named herein and may contain legally privileged and/or confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this e-mail in error, please notify me via return e- mail and via telephone at 813-286-0068 and permanently delete the original and any copy of any e-mail and any printout thereof. From: Hennes, Christine Sent: Thursday, November 05, 2020 10:00 AM To: Cherish Hankinson ; John Camacho ; Wendy Carrasco Ce: Julio Diaz ; Mendez, Cierra Subject: RE: 2nd Deposition Request - Murray, Meghan v. Marie Vilme: Please remove me from this email chain Please communicate with Cierra re scheduling Christine R. Hennes Attorney Law Office of Glenn G. Gomer Employee of Liberty Mutual Insurance Company Direct dial: 813-868-8134 Cell: 813-503-6805 Desktop fax: 603-430-0858 Christine. Hennes@LibertyMutual.com If you need immediate assistance, please contact Cierra at (813) 302-4215 PLEASE NOTE, that we will be working 100% remotely at this time due to COVID- 19. Also, our physical office will be closed through December 31, 2020. As a result, mail will not be processed at our office during that time. Therefore, please send a of all letters, discovery, attachments, pleadings, demands and other tim sensitive documents directly to my email address: Christine. Hennes@Libertymutual.com. This will ensure that I receive your correspondence. Also, my client and I will receive it more quickly, and we should be able to respond more quickly. : However, I do not waive formal service of anything requiring proper service unless I specifically advise you in writing to the contrary. Please note that | can only accept the service of legal documents that are served in compliance with the Florida Rules of Judicial Administration. To ensure compliance, please serve both my designated primary e-mail address at PLGmail@LibertyMutual.com, as well as my designated secondary e-mail address at Christine. Hennes@LibertyMutual.com. Also, 6please note that service of legal documents via e-mail does not excuse or exempt compliance with applicable law which requires service by other means. | am not authorized to accept time limit demands via e-mail. Please be advised that there is a risk a third party can gain access when sending or receiving electronic communications using a computer or other device, or e-mail account. This e-mail, and any attachments thereto, is intended only for the use of the addressee(s) named herein and may contain legally privileged and/or confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this e-mail in error, please notify me via return e-mail and via telephone at 813 286-0068 and permanently delete the original and any copy of any e-mail and any printout thereof. From: Cherish Hankinson Sent: Thursday, November 5, 2020 9:58 AM To: John Camacho ; Wendy Carrasco Cc: Hennes, Christine ; Julio Diaz i Subject: {EXTERNAL} 2nd Deposition Request - Murray, Meghan v. Marie Vilme: Good morning. 1am following up on the below request. Please provide dates of availability for the deposition of Marie Vilme. Thank you. Sincerely, Cherish Hankinson Paralegal to Robert Gordon, Esq. 4114 Northlake Blvd, Palm Beach Gardens, FL 33411 office: (561) 799-5070 fax: (561) 799-4050 www. fortheinjured.com | ere Personal Injury | Medical Malpractice | Wrongful Death | Defective Products | Employment Law Veteran's Benefits | Workers’ Compensation | Class Actions | Nursing Home Abuse | Mass Torts Privileged and Confidential E-mail is not a secure mode of communication and may be accessed by unauthorized persons. This communication orig P.A.. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. 82510-2521. The information contained in this e-mail message is to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. | intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reprodtcommunication may be subject to legal restriction or sanction. Personal messages express views solely of the sender and shall not be attributed to communication in error, please notify the sender immediately by e-mail or by telephone at (800) 659-1159. 4 Please consider the environment before printing this e-mail i From: John Camacho <;| ohn. camacho farmersinsurance.c com> i Sent: Friday, October 23, 2020 4:40 PM | To: Cherish Hankinson : Subject: RE: 20-0551 Murray, Meghan v. Marie Vilme: 1st Deposition Request - Murray, Meghan v. Marie Vilme: Hi Cherish, | forwarded your request to the legal assistant that schedules on the case (Wendy), as well as to the attorney. As soon as they can I’m sure they will respond to your request below. Sincerely, John Camacho, Paralegal Law Offices of Sanabria and Marsh Employees of Farmers Insurance Exchange a Member of the Farmers Insurance Group of Companies \ 2290 Lucien Way, Suite 280 ; Maitland, FL 32751 (Direct) 407-551-6705 (Fax) 407-875-0205 i (Email) john.camacho@farmersinsurance.com COVID-19 NOTICE ~ in light of the national health emergency, | am currently working from home and can be reached by telephone and e-mail. We are sending and accepting only e-mail service from all attorneys and we are not accepting deliveries from FedEx, UPS or any other courier. E- mail communications are preferred to avoid any potential delays caused by mailing. If you are unable to email, or if you have a delivery by FedEx, UPS or other courier, please mail instead to P.O. Box 258829, Oklahoma City, OK 73125-8829. From: Cherish Hankinson fortheini ured, com> Sent: Friday, October 23, 2020 3:29 PM To: John Camacho Subject: [EXTERNAL] 1st Deposition Request - Murray, Meghan v. Marie Vilme: Importance: High Good afternoon. We would like to schedule the deposition of Marie Vilme. Please provide dates of availability. Thank you. Sincerely, Cherish Hankinson Paralegal to Robert Gordon, Esq.4114 Northlake Blvd, Palm Beach Gardens, FL 33411 office: (561) 799-5070 fax: (561) 799-4050 www. fortheinjured.com 9 & @ Personal Injury | Medical Malpractice | Wrongful Death | Defective Products | Employment Law Veteran's Benefits | Workers’ Compensation | Class Actions | Nursing Home Abuse | Mass Torts Privileged and Confidential E-mail is not a secure mode of communication and may be accessed by unauthorized persons. This communication orig P.A.. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. S2510-2621. The information contained in this e-mail message is to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. | intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reprod. ‘communication may be subject to legal restriction or sanction. Personal messages express views solely of the sender and shall not be attributed to 1 ‘communication in error, please notify the sender immediately by e-mail or by telephone at (800) 659-1159. 4 Please consider the environment before printing this e-mail *4*** PLEASE NOTE ***** This E-Mail/telefax message and any documents accompanying this transmission may contain privileged and/or confidential information and is intended solely for the addressee(s) named above. If you are not the intended addressee/recipient, you are hereby notified that any use of, disclosure, copying, distribution, or reliance on the contents of this E-Mail/telefax information is strictly prohibited and may result in legal action against you. Please reply to the sender advising of the error in transmission and immediately delete/destroy the message and any accompanying documents. Thank you.***** #44 PLEASE NOTE ***** This E-Mail/telefax message and any documents accompanying this transmission may contain privileged and/or confidential information and is intended solely for the addressee(s) named above. If you are not the intended addressee/recipient, you are hereby notified that any use of, disclosure, copying, distribution, or reliance on the contents of this E-Mail/telefax information is strictly prohibited and may result in legal action against you. Please reply to the sender advising of the error in transmission and immediately delete/destroy the message and any accompanying documents. Thank you.***** : ***** PLEASE NOTE ***** This E-Mail/telefax message and any documents accompanying this transmission may contain privileged and/or confidential information and is intended solely for the addressee(s) named above. If you are not the intended addressee/recipient, you are hereby notified that any use of, disclosure, copying, distribution, or reliance on the contents of this E-Mail/telefax information is strictly prohibited andi may result in legal action against you. Please reply to the sender advising of the error in transmission and immediately delete/destroy the message and any accompanying documents. Thank you.*****Cherish Hankinson From: Cherish Hankinson Sent: Thursday, December 03, 2020 9:23 AM To: ‘Wendy Carrasco’; Mendez, Cierra Subject: 4th Request Deposition Dates - Murray, Meghan v. Marie Vilme: ' Good morning. | am still waiting for dates for the deposition of your client. Please provide but noon tomorrow or we will unilaterally set. Thank you. Fro 3 Wendy Carrasco wendy. carrasco@farmersinsurance. com> Sent: Wednesday, November 18, 2020 11:07 AM To: Cherish Hankinson ; Mendez, Cierra Subject: RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: 3rd Deposition Dates - Murray, Meghan v. Marie Vilme: i Will do, thank you! Wendy Carrasco Legal Assistant to Margalie Fenelus Reyes, Esq. & Julio L. Diaz, Esq. Law Offices of Sanabria & Marsh Employees of Farmers Insurance Exchange, a Member of the Farmers Insurance Group of Companies 1000 NW 57th Court, Suite 850 Miami, FL 33126 Direct line: 305 459-5208 COVID-19 NOTICE — In light of the national health emergency, | am currently working from home and can be reached by telephone and e-mail. We are sending and accepting only e-mail service from all attorneys and we are not accepting deliveries from FedEx, UPS, or any other courier. E-mail communications are preferred to avoid any potential delays caused by mailing. If you are unable to e-mail, or if you have a delivery by FedEx, UPS, or other courier, please mail instead to P.O. Box 258829, Oklahoma City, OK 73125-8829. 7 From: herish Hankinson Sent: Tuesday, November 17, 2020 3:29 PM To: Wendy Carrasco ; Mendez, Cierra Subject: [EXTERNAL] RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: 3rd Deposition Dates - Murray, Meghan v. Marie Vilme: Ladies: | think we should go ahead and schedule Plaintiff's deposition for 10am on 1/27/21 and keep attempting to reach your client for additional dates. Two depos in one day may take too long. It was a nice attempt. EXHIBITWendy, please keep after your client for dates. i Cierra, | look forward to your Notice. Please note all depositions are to be taken via Zoom. ‘ Thank you. Sincerely, Cherish Hankinson Paralegal to Robert Gordon, Esq. 4114 Northlake Blvd, Palm Beach Gardens, FL 33410 office: (561) 799-5070 fax: (561) 799-4050 www. fortheinjured.com re Personal Injury | Medical Malpractice | Wrongful Death | Defective Products | Employment Law 6 Veteran's Benefits | Workers’ Compensation | Class Actions | Nursing Home Abuse | Mass Torts : ue Privileged and Confidential E-mail is not a secure mode of communication and may be accessed by unauthorized persons. This communication originates from the law firm of Gordon P.A.. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. $2510-2521. The information contained in this e-mail message is intended for the use of the individ. to which itis addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. Ifthe reader of this message is not intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified thal any use, printing, reproduction, disclosure or dissemination « ‘communication may be subject to legal restriction or sanction. Personal messages express views solely of the sender and shall not be attributed to the ta Frm. you received this communication in error, please notify the sender immediately by e-mail or by telephone at (800) 659-1159. #4 Please consider the environment before printing this e-mail From: Wendy Carrasco. wendy. carrasco@farmersinsurance. com> Sent: Tuesday, November 17, 2020 2:22 PM To: Cherish Hankinson ; Mendez, Cierra Subject: RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: 3rd Deposition Dates - Murray, Meghan v. Marie Vilme: Good afternoon ladies, | have been attempting to reach Ms. Vilme without success. | need to clear the date with her to make sure that she actually shows up. If you want we can tentatively set Ms. Vilme’s deposition for January 27, 2021 with the understanding that, if she is unavailable on that date, it will be reset to properly accommodate her schedule. ! Please let me know, thanks. Wendy Carrasco Legal Assistant to Margalie Fenelus Reyes, Esq. & Julio L. Diaz, Esq. Law Offices of Sanabria & Marsh Employees of Farmers Insurance Exchange, a Member of the Farmers Insurance Group of Companies 21000 NW 57th Court, Suite 850 Miami, FL 33126 Direct line: 305 459-5208 COVID-19 NOTICE ~ In light of the national health emergency, | am currently working from home and can be reached by telephone and e-mail. We are sending and accepting only e-mail service from all attorneys and we are not accepting deliveries from FedEx, UPS, or any other courier. E-mail communications are preferred to avoid any potential delays caused by mailing. If you are unable to e-mail, or if you have a delivery by FedEx, UPS, or other courier, please mail instead to P.O. Box 258829, Oklahoma City, OK 73125-8829. From: Cherish Hankinson « Sent: Tuesday, November 17, 2020 9:46 AM To: Mendez, Cierra ; Wendy Carrasco Subject: [EXTERNAL] 3rd Deposition Dates - Murray, Meghan v. Marie Vilme: Importance: High Good morning. 1am following up on the below emails as our office has not received confirmation to set the deposition of Defendant on the date given, January 27, 2021. Please confirm. Thank you. Sincerely, Cherish Hankinson Paralegal to Robert Gordon, Esq. RDONESPARTNERS J} 4114 Northlake Blvd, Palm Beach Gardens, FL 33410 office: (561) 799-5070 fax: (561) 799-4050 www.fortheinjured.com re Personal Injury | Medical Malpractice | Wrongful Death | Defective Products | Employment Law Qa 0 ¥Z “S Veteran's Benefits | Workers’ Compensation | Class Actions | Nursing Home Abuse | Mass Torts Privileged and Confidential E-mail is not a secure mode of communication and may be accessed by unauthorized persons. This communication originates from the law firm of Gordon P.A.. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. $2510-2521. The information contained in this e-mail message is intended for the use of the individ. to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. If the reader of this message is not intended recipient, or the employee or agent responsibte for delivery to the intended recipient, you are hereby notified that any use, printing, reproduction, disclosure or dissemination « communication may be subject to legal restriction or sanction. Personal messages express views solely of the sender and shall not be attributed to the law firm, If you received this communication in error, please notify the sender immediately by e-mail or by telephone at (800) 659-1159. 4 Please consider the environment before printing this e-mailFrom: Mendez, Cierra Sent: Thursday, November 12, 2020 6:52 PM To: Wendy Carrasco ; Cherish Hankinson Subject: RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: Deposition Dates - Murray, Meghan v. Marie Vilme: Good Evening, Any update on this? Curva Vendy Legal Secretary Law Office of Glenn G. Gomer Direct Dial: 813-302-4215 Office: 813-286-0068 4 PLEASE CONSIDER THE ENVIRONMENT BEFORE PRINTING THIS E-MAIL This e-mail and any attachments thereto, is intended only for the use of the addressee(s) named herein and may contain legally privileged and/or confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or copying of this e-mail, and any attachments thereto, is strictly prohibited, If you have received this e-mail in error, please notify me via return e-mail and via telephone at 813-286-0068 and permanently delete the original and any copy of any e-mail and any printout thereof. From: Wendy Carrasco Sent: Tuesday, November 10, 2020 2:01 PM To: Cherish Hankinson ; Mendez, Cierra Subject: {EXTERNAL} RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: Deposition Dates - Murray, Meghan v. Marie Vilme: Good afternoon, | haven’t been able to confirm the date with Ms. Vilme. Will keep you posted. Thanks, Wendy Carrasco Legal Assistant to Margalie Fenelus Reyes, Esq. & Julio L. Diaz, Esq. Law Offices of Sanabria & Marsh Employees of Farmers Insurance Exchange, a Member of the Farmers Insurance Group of Companies 1000 NW 57th Court, Suite 850 i Miami, FL 33126 Direct line: 305 459-5208 COVID-19 NOTICE — In light of the national health emergency, | am currently working from home and can be reached by telephone and e-mail. We are sending and accepting only e-mail service from all attorneys and we are not accepting deliveries from FedEx, UPS, or any other courier. E-mail communications are preferred to avoid any potential delays caused by mailing. If you are unable to e-mail, or if you have a delivery by FedEx, UPS, or other courier, please mail instead to P.O. Box 258829, Oklahoma City, OK 73125-8829. 4From: Cherish Hankinson Sent: Tuesday, November 10, 2020 11:12 AM To: Wendy Carrasco ; Mendez, Cierra Subject: [EXTERNAL] RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: Deposition Dates - Murray, Meghan v. Marie Vilme: 1 Good morning. Following up on the below. Are we set for the 27"? Sincerely, Cherish Hankinson Paralegal to Robert Gordon, Esq. 9 4114 Northlake Blvd, Palm Beach Gardens, FL 33410 & office: (561) 799-5070 fax: (661) 799-4050 www. fortheinjured.com Personal Injury | Medical Malpractice | Wrongful Death | Defective Products | Employment Law & t Veteran's Benefits | Workers’ Compensation | Class Actions | Nursing Home Abuse | Mass Torts Privileged and Confidential E-mail is not a secure mode of communication and may be accessed by unauthorized persons, This communication originates from the law firrr P.A.. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. $2510-2521. The information contained in this e-mail message is intended for the use of to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. If the reader of this mes intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reproduction, disclosure or dis: communication may be subject to legal restriction or sanction. Personal messages express views solely of the sender and shall not be attributed to the law firm. If you recei ‘communication in error, please notify the sender immediately by e-mail or by telephone at (800) 659-1159, : 4 Please consider the environment before printing this e-mail From: Wendy Carrasco Sent: Friday, November 06, 2020 3:02 PM : To: Cherish Hankinson ; Mendez, Cierra Subject: RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: Deposition Dates - Murray, Meghan v. Marie Vilme: Good afternoon Ladies, My attorney is available on January 27; however, | am waiting to confirm our client availability on that date. | will keep you posted. Thanks, Wendy Carrasco Legal Assistant toMargalie Fenelus Reyes, Esq. & Julio L. Diaz, Esq. Law Offices of Sanabria & Marsh Employees of Farmers Insurance Exchange, ' a Member of the Farmers Insurance Group of Companies 1000 NW 57th Court, Suite 850 Miami, FL 33126 Direct line: 305 459-5208 COVID-19 NOTICE ~ In light of the national health emergency, | am currently working from home and can be reached by telephone and e-mail. We are sending and accepting only e-mail service from all attorneys and we are not accepting deliveries from FedEx, UPS, or any other courier. E-mail communications are preferred to avoid any potential delays caused by mailing. If you are unable to e-mail, or if you have a delivery by FedEx, UPS, or other courier, please mail instead to P.O. Box 258829, Oklahoma City, OK 73125-8829. From: Cherish Hankinson Sent: Thursday, November 5, 2020 11:42 AM To: Mendez, Cierra ; John Camacho ; Wendy Carrasco Ce: Julio Diaz Subject: [EXTERNAL] Deposition Dates - Murray, Meghan v. Marie Vilme: Our client is available Wednesdays and Fridays at 10:30am. So let’s plan for January 27" start at 10:30 with Meghan and send me a time, in the afternoon, for Marie. Sincerely, Cherish Hankinson Paralegal to Robert Gordon, Esq. 9 4114 Northlake Blvd, Palm Beach Gardens, FL 33410 & office: (561) 799-5070 fax: (561) 799-4050 @ www. fortheinjured.com Personal Injury | Medical Malpractice | Wrongful Death | Defective Products | Employment Law a Veteran's Benefits | Workers’ Compensation | Class Actions | Nursing Home Abuse | Mass Torts ' Privileged and Confidential E-mail is not a secure mode of communication and may be accessed by unauthorized persons. This communication originates from the law firr P.A. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. 2510-2521. The information contained in this e-mail message is intended for the use of to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. If the reader of this mes intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reproduction, disclosure or dis: communication may be subject to legal restriction or sanction. Personal messages express views solely of the sender and shall not be attributed to the law firm. If you recei communication in error, please notify the sender immediately by e-mail or by telephone at (800) 659-1159. 4s Please consider the environment before printing this e-mailFrom: Mendez, Cierra Sent: Thursday, November 05, 2020 11:38 AM To: Cherish Hankinson ; John Camacho ; Wendy Carrasco Ce: Julio Diaz Subject: RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: 2nd Deposition Request - Murray, Meghan v. Marie Vilme: i We have no preference as to who goes first, but if we can knock these out the same day that would be great. Here are some dates to get the ball rolling: 1/25-1/28 2/2-2/5 2/8-2/12 (ra Vhendey Legal Secretary Law Office of Glenn G. Gomer Direct Dial: 813-302-4215 Office: 813-286-0068 64 PLEASE CONSIDER THE ENVIRONMENT BEFORE PRINTING THIS E-MAIL This e-mail and any attachments thereto, is intended only for the use of the addressee(s) named herein and may contain legally privileged and/or confidential information, If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this e-mail in error, please notify me via return e-mail and via telephone at 813-286-0068 and permanently delete the original and any copy of any e-mail and any printout thereof. From: Cherish Hankinson ‘ Sent: Thursday, November 05, 2020 10:30 AM To: Mendez, Cierra ; John Camacho ; Wendy Carrasco Cc: Julio Diaz Subject: {EXTERNAL} RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: 2nd Deposition Request - Murray, Meghan v. Marie Vilme: | have sent a request to our client for dates and times. | am certain we can coordinate the deposition to occur within a week of each other. If you would like to provide dates, if you already have them, twill make certain our client goes first. 5 Sincerely, ' Cherish Hankinson Paralegal to Robert Gordon, Esq. GORDONGSPARTNERS J}9 4114 Northlake Blvd, Palm Beach Gardens, FL 33410 & office: (561) 799-5070 fax: (561) 799-4050 : www. fortheinjured.com Personal Injury | Medical Malpractice | Wrongful Death | Defective Products | Employment Law t Veteran's Benefits | Workers’ Compensation | Class Actions | Nursing Home Abuse | Mass Torts Privileged and Confidential E-mail is not a secure mode of communication and may be accessed by unauthorized persons. This communication originates from P.A., ands protected under the Electronic Communication Privacy Act, 18 U.S.C. 2510-2521. The information contained in this e-mail message is intended fc to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. If the reade! intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reproduction, disch communication may be subject to legal restriction or sanction. Personal messages express views solely of the sender and shall not be attributed fo the law firm communication in error, please notify the sender immediately by e-mail or by telephone at (800) 659-1159. 1 4 Please consider the environment before printing this e-mail From: Mendez, Cierra Sent: Thursday, November 05, 2020 10:28 AM To: Cherish Hankinson ; John Camacho ; Wendy Carrasco Ce: Julio Diaz Subject: RE: 20-0551 Murray, Meghan v. LM GENERAL INSURANCE COMPANY: 2nd Deposition Request - Murray, Meghan v. Marie Vilme: Good Morning, | would also like to get the deposition of the plaintiff set, maybe we can set these on the same dates. My office is presently scheduling into late Jan. (verve. Wendy Legal Secretary Law Office of Glenn G. Gomer Direct Dial: 813-302-4215 Office: 813-286-0068 i 4 PLEASE CONSIDER THE ENVIRONMENT BEFORE PRINTING THIS E-MAIL This e-mail and any attachments thereto, is intended only for the use of the addressee(s) named herein and may contain legally privileged and/or confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this e-mail in error, please notify me via retum e- mail and via telephone at 813-286-0068 and permanently delete the original and any copy of any e-mail and any printout thereof. From: Hennes, Christine Sent: Thursday, November 05, 2020 10:00 AM To: Cherish Hankinson ; John Camacho ' ; Wendy Carrasco Ce: Julio Diaz ; Mendez, Cierra Subject: RE: 2nd Deposition Request - Murray, Meghan v. Marie Vilme:Please remove me from this email chain Please communicate with Cierra re scheduling Christine R. Hennes Attorney Law Office of Glenn G. Gomer Employee of Liberty Mutual Insurance Company Direct dial: 813-868-8134 Cell: 813-503-6805 Desktop fax: 603-430-0858 Christine. Hennes@LibertyMutual.com If you need immediate assistance, please contact Cierra at (813) 302-4215 PLEASE NOTE, that we will be working 100% remotely at this time due to COVID- 19. Also, our physical office will be closed through December 31, 2020. As a result, mail will not be processed at our office during that time. Therefore, please send a copy of all letters, discovery, attachments, pleadings, demands and other time sensitive uments dir to my email address: Christine. Hennes@Libertymutual.com, This will ensure that I receive your correspondence. Also, my client and I will receive it more quickly, and we should be able to respond more quickly. However, I do not waive formal service of anything requiring proper ice unless I specifically advise you in writing to the contrary. Please note that | can only accept the service of legal documents that are served in compliance with the Florida Rules of Judicial Administration. To ensure compliance, please serve both my designated primary e-mail address at PLGmail@LibertyMutual.com, as well as my designated secondary e-mail address at Christine. Hennes@LibertyMutual.com. Also, please note that service of legal documents via e-mail does not excuse or exempt compliance with applicable law which requires service by other means. | am not authorized to accept time limit demands via e-mail. Please be advised that there is a risk a third party can gain access when sending or receiving electronic communications using a computer or other device, or e-mail account. This e-mail, and any attachments thereto, is intended only for the use of the addressee(s) named herein and may contain legally privileged and/or confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this e-mail in error, please notify me via return e-mail and via telephone at 813 286-0068 and permanently delete the original and any copy of any e-mail and any printout thereof. From: Cherish Hankinson Sent: Thursday, November 5, 2020 9:58 AM To: John Camacho ; Wendy Carrasco 9Ce: Hennes, Christine ; Julio Diaz Subject: {EXTERNAL} 2nd Deposition Request - Murray, Meghan v. Marie Vilme: Good morning. | am following up on the below request. Please provide dates of availability for the deposition of Marie Vilme. : Thank you. Sincerely, Cherish Hankinson Paralegal to Robert Gordon, Esq. 4114 Northlake Blvd, Palm Beach Gardens, FL 3341 office: (561) 799-5070 fax: (561) 799-4050 www. fortheinjured.com Bre Personal Injury | Medical Malpractice | Wrongful Death | Defective Products | Employment Law Veteran's Benefits | Workers’ Compensation | Class Actions | Nursing Home Abuse | Mass Torts Privileged and Confidential E-mail is not a secure mode of communication and may be accessed by unauthorized persons. This communication oric P.A.. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. $2510-2521. The information contained in this e-mail message is to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reprodt communication may be subject to legal restriction or sanction. Personal messages express views solely of the sender, and shall not be attributed to communication in error, please notify the sender immediately by e-mail or by telephone at (800) 659-1159, i #4 Please consider the environment before printing this e-mail 1 From: John Camacho <, john. camacho@farmersinsurance. com> Sent: Friday, October 23, 2020 4:40 PM To: Cherish Hankinson Subject: RE: 20-0551 Murray, Meghan v. Marie