Empathy List Archives

CP

Cary P. Sabol, Esq.

Tue, Feb 18, 2020 9:19 PM

Does anyone have any authority regarding whether there is a right to engage in discovery in a standard residential eviction case? Is there a right to take depos, Request to Produce, etc. when it's statutory required to be an expedited procedure?

Cary

Cary P. Sabol, Esq. J.D. (2001), LLM (2009)

Law Offices of Cary P. Sabol

P.O. Box 15981 | West Palm Beach | Florida | 33416

Office: (561) 413-4449

Cell: (561) 281-2744

Fax: (888) 316-2881

BEWARE OF CYBER-CRIME: IF YOU RECEIVE AN E-MAIL OR ANY OTHER COMMUNICATION THAT APPEARS TO BE GENERATED FROM OUR OFFICE THAT CONTAINS NEW, REVISED, OR ALTERED BANK WIRE INSTRUCTIONS, CONSIDER IT SUSPECT AND CALL OUR OFFICE AT A NUMBER YOU TRUST. OUR BANK WIRE INSTRUCTIONS SELDOM CHANGE.

** PLEASE NOTE: On Closings with a Loan, we require "CLOSING INSTRUCTIONS and LOAN PACKAGES" by NOON the day BEFORE Closing"

CASH TO CLOSE for real estate transactions must be WIRED to our account prior to closing. (SAME DAY WIRE - NO ACH TRANSFERS) Wire instructions will be provided upon request. ACH transfers are NOT SAME DAY wires and cannot be accepted.

THIS COMMUNICATION MAY BE AN ATTEMPT TO COLLECT A DEBT AS DEFINED BY FLORIDA AND FEDERAL LAW AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS IS A COMMUNICATION FROM A DEBT COLLECTOR.

_________________________________________________________________________________________________________________

IRS Circular 230 Notice: Pursuant to recently enacted U.S. Treasury Department Regulations, we are now required to advise you that, unless otherwise expressly indicated, any federal tax advice expressed above was neither written nor intended by the sender or this firm to be used and cannot be used by any taxpayer for the purpose of avoiding penalties that may be imposed under U.S. tax law. If any person uses or refers to any such tax advice in promoting, marketing or recommending a partnership or other entity, investment plan or arrangement to any taxpayer, then the advice should be considered to have been written to support the promotion or marketing by a person other than the sender or this firm of that transaction or matter, and such taxpayer should seek advice based on the taxpayer's particular circumstances from an independent tax advisor.

Confidentiality Notice: This electronic mail transmission is intended for the use of the individual or entity to which it is addressed and may contain confidential information belonging to the sender which is protected by the attorney-client privilege. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, or the taking of any action in reliance on the contents of this information is strictly prohibited. If you have received this transmission in error, please notify the sender immediately by e-mail and delete the original message. Thank you for your cooperation.

JM

Jordan M Brill

Tue, Feb 18, 2020 9:22 PM

Summary procedure 51.011(2)

(2) DISCOVERY.—Depositions on oral examination may be taken by any party at any time. Other discovery and admissions may be had only on order of court setting the time for compliance. No discovery postpones the time for trial except for good cause shown or by stipulation of the parties.

Jordan Marcus Brill, Esq.
Glachman & Brill, P.A.
6421 Congress Ave., Suite 120
Boca Raton, FL 33487
(561)859-0679
jordan@glachmanbrill.com mailto:jordan@glachmanbrill.com
www.glachmanbrill.com http://www.glachmanbrill.com/

The information contained in this email message is intended for review and use of the senders intended recipient and no other. Any recipient or reader of this email that is not an intended recipient or reader is hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited; any wrongful dissemination or receipt shall not constitute a waiver of any privilege held by the sender or any intended recipient or client of the sender. If you have received this communication in error, please immediately notify us via email directed to jordan@glachmanbrill.com mailto:jordan@glachmanbrill.com and by telephone to 561-859-0679, and destroy the original message and all copies thereof and related communications thereto. Thank you.

From: landten-bounces@lists.flabarrpptl.org On Behalf Of Cary P. Sabol, Esq.
Sent: Tuesday, February 18, 2020 4:20 PM
To: Landlord - Tenant Listserve landten@lists.flabarrpptl.org
Subject: [RPPTL LandTen] Residential Eviction & Discovery

Does anyone have any authority regarding whether there is a right to engage in discovery in a standard residential eviction case? Is there a right to take depos, Request to Produce, etc. when it's statutory required to be an expedited procedure?

Cary
Cary P. Sabol, Esq. J.D. (2001), LLM (2009)
Law Offices of Cary P. Sabol
P.O. Box 15981 | West Palm Beach | Florida | 33416
Office: (561) 413-4449
Cell: (561) 281-2744
Fax: (888) 316-2881

BEWARE OF CYBER-CRIME: IF YOU RECEIVE AN E-MAIL OR ANY OTHER COMMUNICATION THAT APPEARS TO BE GENERATED FROM OUR OFFICE THAT CONTAINS NEW, REVISED, OR ALTERED BANK WIRE INSTRUCTIONS, CONSIDER IT SUSPECT AND CALL OUR OFFICE AT A NUMBER YOU TRUST. OUR BANK WIRE INSTRUCTIONS SELDOM CHANGE.

** PLEASE NOTE: On Closings with a Loan, we require "CLOSING INSTRUCTIONS and LOAN PACKAGES" by NOON the day BEFORE Closing"

CASH TO CLOSE for real estate transactions must be WIRED to our account prior to closing. (SAME DAY WIRE - NO ACH TRANSFERS) Wire instructions will be provided upon request. ACH transfers are NOT SAME DAY wires and cannot be accepted.

THIS COMMUNICATION MAY BE AN ATTEMPT TO COLLECT A DEBT AS DEFINED BY FLORIDA AND FEDERAL LAW AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS IS A COMMUNICATION FROM A DEBT COLLECTOR.
[cid:image001.jpg@01D5E677.AEFAB3E0]
[cid:image002.png@01D5E677.AEFAB3E0]

IRS Circular 230 Notice: Pursuant to recently enacted U.S. Treasury Department Regulations, we are now required to advise you that, unless otherwise expressly indicated, any federal tax advice expressed above was neither written nor intended by the sender or this firm to be used and cannot be used by any taxpayer for the purpose of avoiding penalties that may be imposed under U.S. tax law. If any person uses or refers to any such tax advice in promoting, marketing or recommending a partnership or other entity, investment plan or arrangement to any taxpayer, then the advice should be considered to have been written to support the promotion or marketing by a person other than the sender or this firm of that transaction or matter, and such taxpayer should seek advice based on the taxpayer's particular circumstances from an independent tax advisor.

Confidentiality Notice: This electronic mail transmission is intended for the use of the individual or entity to which it is addressed and may contain confidential information belonging to the sender which is protected by the attorney-client privilege. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, or the taking of any action in reliance on the contents of this information is strictly prohibited. If you have received this transmission in error, please notify the sender immediately by e-mail and delete the original message. Thank you for your cooperation.

Summary procedure 51.011(2) (2) DISCOVERY.—Depositions on oral examination may be taken by any party at any time. Other discovery and admissions may be had only on order of court setting the time for compliance. No discovery postpones the time for trial except for good cause shown or by stipulation of the parties. Jordan Marcus Brill, Esq. Glachman & Brill, P.A. 6421 Congress Ave., Suite 120 Boca Raton, FL 33487 (561)859-0679 jordan@glachmanbrill.com<mailto:jordan@glachmanbrill.com> www.glachmanbrill.com<http://www.glachmanbrill.com/> The information contained in this email message is intended for review and use of the senders intended recipient and no other. Any recipient or reader of this email that is not an intended recipient or reader is hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited; any wrongful dissemination or receipt shall not constitute a waiver of any privilege held by the sender or any intended recipient or client of the sender. If you have received this communication in error, please immediately notify us via email directed to jordan@glachmanbrill.com<mailto:jordan@glachmanbrill.com> and by telephone to 561-859-0679, and destroy the original message and all copies thereof and related communications thereto. Thank you. From: landten-bounces@lists.flabarrpptl.org On Behalf Of Cary P. Sabol, Esq. Sent: Tuesday, February 18, 2020 4:20 PM To: Landlord - Tenant Listserve <landten@lists.flabarrpptl.org> Subject: [RPPTL LandTen] Residential Eviction & Discovery Does anyone have any authority regarding whether there is a right to engage in discovery in a standard residential eviction case? Is there a right to take depos, Request to Produce, etc. when it's statutory required to be an expedited procedure? Cary Cary P. Sabol, Esq. J.D. (2001), LLM (2009) Law Offices of Cary P. Sabol P.O. Box 15981 | West Palm Beach | Florida | 33416 Office: (561) 413-4449 Cell: (561) 281-2744 Fax: (888) 316-2881 BEWARE OF CYBER-CRIME: IF YOU RECEIVE AN E-MAIL OR ANY OTHER COMMUNICATION THAT APPEARS TO BE GENERATED FROM OUR OFFICE THAT CONTAINS NEW, REVISED, OR ALTERED BANK WIRE INSTRUCTIONS, CONSIDER IT SUSPECT AND CALL OUR OFFICE AT A NUMBER YOU TRUST. OUR BANK WIRE INSTRUCTIONS SELDOM CHANGE. ** PLEASE NOTE: On Closings with a Loan, we require "CLOSING INSTRUCTIONS and LOAN PACKAGES" by NOON the day BEFORE Closing" CASH TO CLOSE for real estate transactions must be WIRED to our account prior to closing. (SAME DAY WIRE - NO ACH TRANSFERS) Wire instructions will be provided upon request. ACH transfers are NOT SAME DAY wires and cannot be accepted. THIS COMMUNICATION MAY BE AN ATTEMPT TO COLLECT A DEBT AS DEFINED BY FLORIDA AND FEDERAL LAW AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS IS A COMMUNICATION FROM A DEBT COLLECTOR. [cid:image001.jpg@01D5E677.AEFAB3E0] [cid:image002.png@01D5E677.AEFAB3E0] _________________________________________________________________________________________________________________ IRS Circular 230 Notice: Pursuant to recently enacted U.S. Treasury Department Regulations, we are now required to advise you that, unless otherwise expressly indicated, any federal tax advice expressed above was neither written nor intended by the sender or this firm to be used and cannot be used by any taxpayer for the purpose of avoiding penalties that may be imposed under U.S. tax law. If any person uses or refers to any such tax advice in promoting, marketing or recommending a partnership or other entity, investment plan or arrangement to any taxpayer, then the advice should be considered to have been written to support the promotion or marketing by a person other than the sender or this firm of that transaction or matter, and such taxpayer should seek advice based on the taxpayer's particular circumstances from an independent tax advisor. Confidentiality Notice: This electronic mail transmission is intended for the use of the individual or entity to which it is addressed and may contain confidential information belonging to the sender which is protected by the attorney-client privilege. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, or the taking of any action in reliance on the contents of this information is strictly prohibited. If you have received this transmission in error, please notify the sender immediately by e-mail and delete the original message. Thank you for your cooperation.

CS

Carol S. Grondzik

Tue, Feb 18, 2020 9:32 PM

Chapter 51 allows one deposition without the court’s permission. Court must order any other discovery. Section 51.011(2), Fla. Stat.

Carol

Carol S. Grondzik, Esquire
Lutz, Bobo & Telfair, P.A.
2155 Delta Boulevard, Suite 210-B
Tallahassee, Florida 32303
Telephone: (850) 521-0890
Facsimile: (850) 521-0891

This message is intended only for the use of the addressees shown above. This message contains information that may be privileged, confidential and/or exempt from disclosure under applicable law. If you are not the intended recipient of this message, then you are hereby notified that the copying, use, forwarding or other distribution of any information or materials transmitted in or with, or as an attachment to, this message is strictly prohibited. If you received this message by mistake, then please immediately send it back to us and then immediately destroy this message. Your cooperation is appreciated.

Pursuant to the Fair Debt Collection Practices Act, it is required that we state the following to you: This is a communication from a debt collector. This may be an attempt to collect a debt and any information obtained may be used for that purpose.

From: landten-bounces@lists.flabarrpptl.org landten-bounces@lists.flabarrpptl.org On Behalf Of Cary P. Sabol, Esq.
Sent: Tuesday, February 18, 2020 4:20 PM
To: Landlord - Tenant Listserve landten@lists.flabarrpptl.org
Subject: [RPPTL LandTen] Residential Eviction & Discovery

Does anyone have any authority regarding whether there is a right to engage in discovery in a standard residential eviction case? Is there a right to take depos, Request to Produce, etc. when it's statutory required to be an expedited procedure?

Cary
Cary P. Sabol, Esq. J.D. (2001), LLM (2009)
Law Offices of Cary P. Sabol
P.O. Box 15981 | West Palm Beach | Florida | 33416
Office: (561) 413-4449
Cell: (561) 281-2744
Fax: (888) 316-2881

BEWARE OF CYBER-CRIME: IF YOU RECEIVE AN E-MAIL OR ANY OTHER COMMUNICATION THAT APPEARS TO BE GENERATED FROM OUR OFFICE THAT CONTAINS NEW, REVISED, OR ALTERED BANK WIRE INSTRUCTIONS, CONSIDER IT SUSPECT AND CALL OUR OFFICE AT A NUMBER YOU TRUST. OUR BANK WIRE INSTRUCTIONS SELDOM CHANGE.

** PLEASE NOTE: On Closings with a Loan, we require "CLOSING INSTRUCTIONS and LOAN PACKAGES" by NOON the day BEFORE Closing"

CASH TO CLOSE for real estate transactions must be WIRED to our account prior to closing. (SAME DAY WIRE - NO ACH TRANSFERS) Wire instructions will be provided upon request. ACH transfers are NOT SAME DAY wires and cannot be accepted.

THIS COMMUNICATION MAY BE AN ATTEMPT TO COLLECT A DEBT AS DEFINED BY FLORIDA AND FEDERAL LAW AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS IS A COMMUNICATION FROM A DEBT COLLECTOR.
[cid:image001.jpg@01D5E679.01036A50]
[cid:image002.png@01D5E679.01036A50]

IRS Circular 230 Notice: Pursuant to recently enacted U.S. Treasury Department Regulations, we are now required to advise you that, unless otherwise expressly indicated, any federal tax advice expressed above was neither written nor intended by the sender or this firm to be used and cannot be used by any taxpayer for the purpose of avoiding penalties that may be imposed under U.S. tax law. If any person uses or refers to any such tax advice in promoting, marketing or recommending a partnership or other entity, investment plan or arrangement to any taxpayer, then the advice should be considered to have been written to support the promotion or marketing by a person other than the sender or this firm of that transaction or matter, and such taxpayer should seek advice based on the taxpayer's particular circumstances from an independent tax advisor.

Confidentiality Notice: This electronic mail transmission is intended for the use of the individual or entity to which it is addressed and may contain confidential information belonging to the sender which is protected by the attorney-client privilege. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, or the taking of any action in reliance on the contents of this information is strictly prohibited. If you have received this transmission in error, please notify the sender immediately by e-mail and delete the original message. Thank you for your cooperation.

Chapter 51 allows one deposition without the court’s permission. Court must order any other discovery. Section 51.011(2), Fla. Stat. Carol Carol S. Grondzik, Esquire Lutz, Bobo & Telfair, P.A. 2155 Delta Boulevard, Suite 210-B Tallahassee, Florida 32303 Telephone: (850) 521-0890 Facsimile: (850) 521-0891 This message is intended only for the use of the addressees shown above. This message contains information that may be privileged, confidential and/or exempt from disclosure under applicable law. If you are not the intended recipient of this message, then you are hereby notified that the copying, use, forwarding or other distribution of any information or materials transmitted in or with, or as an attachment to, this message is strictly prohibited. If you received this message by mistake, then please immediately send it back to us and then immediately destroy this message. Your cooperation is appreciated. Pursuant to the Fair Debt Collection Practices Act, it is required that we state the following to you: This is a communication from a debt collector. This may be an attempt to collect a debt and any information obtained may be used for that purpose. From: landten-bounces@lists.flabarrpptl.org <landten-bounces@lists.flabarrpptl.org> On Behalf Of Cary P. Sabol, Esq. Sent: Tuesday, February 18, 2020 4:20 PM To: Landlord - Tenant Listserve <landten@lists.flabarrpptl.org> Subject: [RPPTL LandTen] Residential Eviction & Discovery Does anyone have any authority regarding whether there is a right to engage in discovery in a standard residential eviction case? Is there a right to take depos, Request to Produce, etc. when it's statutory required to be an expedited procedure? Cary Cary P. Sabol, Esq. J.D. (2001), LLM (2009) Law Offices of Cary P. Sabol P.O. Box 15981 | West Palm Beach | Florida | 33416 Office: (561) 413-4449 Cell: (561) 281-2744 Fax: (888) 316-2881 BEWARE OF CYBER-CRIME: IF YOU RECEIVE AN E-MAIL OR ANY OTHER COMMUNICATION THAT APPEARS TO BE GENERATED FROM OUR OFFICE THAT CONTAINS NEW, REVISED, OR ALTERED BANK WIRE INSTRUCTIONS, CONSIDER IT SUSPECT AND CALL OUR OFFICE AT A NUMBER YOU TRUST. OUR BANK WIRE INSTRUCTIONS SELDOM CHANGE. ** PLEASE NOTE: On Closings with a Loan, we require "CLOSING INSTRUCTIONS and LOAN PACKAGES" by NOON the day BEFORE Closing" CASH TO CLOSE for real estate transactions must be WIRED to our account prior to closing. (SAME DAY WIRE - NO ACH TRANSFERS) Wire instructions will be provided upon request. ACH transfers are NOT SAME DAY wires and cannot be accepted. THIS COMMUNICATION MAY BE AN ATTEMPT TO COLLECT A DEBT AS DEFINED BY FLORIDA AND FEDERAL LAW AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS IS A COMMUNICATION FROM A DEBT COLLECTOR. [cid:image001.jpg@01D5E679.01036A50] [cid:image002.png@01D5E679.01036A50] _________________________________________________________________________________________________________________ IRS Circular 230 Notice: Pursuant to recently enacted U.S. Treasury Department Regulations, we are now required to advise you that, unless otherwise expressly indicated, any federal tax advice expressed above was neither written nor intended by the sender or this firm to be used and cannot be used by any taxpayer for the purpose of avoiding penalties that may be imposed under U.S. tax law. If any person uses or refers to any such tax advice in promoting, marketing or recommending a partnership or other entity, investment plan or arrangement to any taxpayer, then the advice should be considered to have been written to support the promotion or marketing by a person other than the sender or this firm of that transaction or matter, and such taxpayer should seek advice based on the taxpayer's particular circumstances from an independent tax advisor. Confidentiality Notice: This electronic mail transmission is intended for the use of the individual or entity to which it is addressed and may contain confidential information belonging to the sender which is protected by the attorney-client privilege. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, or the taking of any action in reliance on the contents of this information is strictly prohibited. If you have received this transmission in error, please notify the sender immediately by e-mail and delete the original message. Thank you for your cooperation.

MD

Mike Davis

Tue, Feb 18, 2020 10:52 PM

FYI either party can depose not only the other party but also any proposed witnesses. Learned that when Legal Aid North Florida requested to depose manager and our three witnesses in a 7Termination eviction case.
Mike Davis

Sent from my iPhone

On Feb 18, 2020, at 4:34 PM, Carol S. Grondzik csgrondzik@floridahousinglaw.com wrote:

Chapter 51 allows one deposition without the court’s permission. Court must order any other discovery. Section 51.011(2), Fla. Stat.

Carol

Carol S. Grondzik, Esquire
Lutz, Bobo & Telfair, P.A.
2155 Delta Boulevard, Suite 210-B
Tallahassee, Florida 32303
Telephone: (850) 521-0890
Facsimile: (850) 521-0891

This message is intended only for the use of the addressees shown above. This message contains information that may be privileged, confidential and/or exempt from disclosure under applicable law. If you are not the intended recipient of this message, then you are hereby notified that the copying, use, forwarding or other distribution of any information or materials transmitted in or with, or as an attachment to, this message is strictly prohibited. If you received this message by mistake, then please immediately send it back to us and then immediately destroy this message. Your cooperation is appreciated.

Pursuant to the Fair Debt Collection Practices Act, it is required that we state the following to you: This is a communication from a debt collector. This may be an attempt to collect a debt and any information obtained may be used for that purpose.

From: landten-bounces@lists.flabarrpptl.org landten-bounces@lists.flabarrpptl.org On Behalf Of Cary P. Sabol, Esq.
Sent: Tuesday, February 18, 2020 4:20 PM
To: Landlord - Tenant Listserve landten@lists.flabarrpptl.org
Subject: [RPPTL LandTen] Residential Eviction & Discovery

Does anyone have any authority regarding whether there is a right to engage in discovery in a standard residential eviction case? Is there a right to take depos, Request to Produce, etc. when it's statutory required to be an expedited procedure?

Cary
Cary P. Sabol, Esq. J.D. (2001), LLM (2009)
Law Offices of Cary P. Sabol
P.O. Box 15981 | West Palm Beach | Florida | 33416
Office: (561) 413-4449
Cell: (561) 281-2744
Fax: (888) 316-2881

BEWARE OF CYBER-CRIME: IF YOU RECEIVE AN E-MAIL OR ANY OTHER COMMUNICATION THAT APPEARS TO BE GENERATED FROM OUR OFFICE THAT CONTAINS NEW, REVISED, OR ALTERED BANK WIRE INSTRUCTIONS, CONSIDER IT SUSPECT AND CALL OUR OFFICE AT A NUMBER YOU TRUST. OUR BANK WIRE INSTRUCTIONS SELDOM CHANGE.

** PLEASE NOTE: On Closings with a Loan, we require "CLOSING INSTRUCTIONS and LOAN PACKAGES" by NOON the day BEFORE Closing"

CASH TO CLOSE for real estate transactions must be WIRED to our account prior to closing. (SAME DAY WIRE - NO ACH TRANSFERS) Wire instructions will be provided upon request. ACH transfers are NOT SAME DAY wires and cannot be accepted.

THIS COMMUNICATION MAY BE AN ATTEMPT TO COLLECT A DEBT AS DEFINED BY FLORIDA AND FEDERAL LAW AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS IS A COMMUNICATION FROM A DEBT COLLECTOR.
<image001.jpg>

<image002.png>

IRS Circular 230 Notice: Pursuant to recently enacted U.S. Treasury Department Regulations, we are now required to advise you that, unless otherwise expressly indicated, any federal tax advice expressed above was neither written nor intended by the sender or this firm to be used and cannot be used by any taxpayer for the purpose of avoiding penalties that may be imposed under U.S. tax law. If any person uses or refers to any such tax advice in promoting, marketing or recommending a partnership or other entity, investment plan or arrangement to any taxpayer, then the advice should be considered to have been written to support the promotion or marketing by a person other than the sender or this firm of that transaction or matter, and such taxpayer should seek advice based on the taxpayer's particular circumstances from an independent tax advisor.

Confidentiality Notice: This electronic mail transmission is intended for the use of the individual or entity to which it is addressed and may contain confidential information belonging to the sender which is protected by the attorney-client privilege. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, or the taking of any action in reliance on the contents of this information is strictly prohibited. If you have received this transmission in error, please notify the sender immediately by e-mail and delete the original message. Thank you for your cooperation.

landten mailing list
landten@lists.flabarrpptl.org
http://mailman.fsr.com/mailman/listinfo/landten

FYI either party can depose not only the other party but also any proposed witnesses. Learned that when Legal Aid North Florida requested to depose manager and our three witnesses in a 7Termination eviction case. Mike Davis Sent from my iPhone On Feb 18, 2020, at 4:34 PM, Carol S. Grondzik <csgrondzik@floridahousinglaw.com> wrote: Chapter 51 allows one deposition without the court’s permission. Court must order any other discovery. Section 51.011(2), Fla. Stat. Carol Carol S. Grondzik, Esquire Lutz, Bobo & Telfair, P.A. 2155 Delta Boulevard, Suite 210-B Tallahassee, Florida 32303 Telephone: (850) 521-0890 Facsimile: (850) 521-0891 This message is intended only for the use of the addressees shown above. This message contains information that may be privileged, confidential and/or exempt from disclosure under applicable law. If you are not the intended recipient of this message, then you are hereby notified that the copying, use, forwarding or other distribution of any information or materials transmitted in or with, or as an attachment to, this message is strictly prohibited. If you received this message by mistake, then please immediately send it back to us and then immediately destroy this message. Your cooperation is appreciated. Pursuant to the Fair Debt Collection Practices Act, it is required that we state the following to you: This is a communication from a debt collector. This may be an attempt to collect a debt and any information obtained may be used for that purpose. From: landten-bounces@lists.flabarrpptl.org <landten-bounces@lists.flabarrpptl.org> On Behalf Of Cary P. Sabol, Esq. Sent: Tuesday, February 18, 2020 4:20 PM To: Landlord - Tenant Listserve <landten@lists.flabarrpptl.org> Subject: [RPPTL LandTen] Residential Eviction & Discovery Does anyone have any authority regarding whether there is a right to engage in discovery in a standard residential eviction case? Is there a right to take depos, Request to Produce, etc. when it's statutory required to be an expedited procedure? Cary Cary P. Sabol, Esq. J.D. (2001), LLM (2009) Law Offices of Cary P. Sabol P.O. Box 15981 | West Palm Beach | Florida | 33416 Office: (561) 413-4449 Cell: (561) 281-2744 Fax: (888) 316-2881 BEWARE OF CYBER-CRIME: IF YOU RECEIVE AN E-MAIL OR ANY OTHER COMMUNICATION THAT APPEARS TO BE GENERATED FROM OUR OFFICE THAT CONTAINS NEW, REVISED, OR ALTERED BANK WIRE INSTRUCTIONS, CONSIDER IT SUSPECT AND CALL OUR OFFICE AT A NUMBER YOU TRUST. OUR BANK WIRE INSTRUCTIONS SELDOM CHANGE. ** PLEASE NOTE: On Closings with a Loan, we require "CLOSING INSTRUCTIONS and LOAN PACKAGES" by NOON the day BEFORE Closing" CASH TO CLOSE for real estate transactions must be WIRED to our account prior to closing. (SAME DAY WIRE - NO ACH TRANSFERS) Wire instructions will be provided upon request. ACH transfers are NOT SAME DAY wires and cannot be accepted. THIS COMMUNICATION MAY BE AN ATTEMPT TO COLLECT A DEBT AS DEFINED BY FLORIDA AND FEDERAL LAW AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS IS A COMMUNICATION FROM A DEBT COLLECTOR. <image001.jpg> <image002.png> _________________________________________________________________________________________________________________ IRS Circular 230 Notice: Pursuant to recently enacted U.S. Treasury Department Regulations, we are now required to advise you that, unless otherwise expressly indicated, any federal tax advice expressed above was neither written nor intended by the sender or this firm to be used and cannot be used by any taxpayer for the purpose of avoiding penalties that may be imposed under U.S. tax law. If any person uses or refers to any such tax advice in promoting, marketing or recommending a partnership or other entity, investment plan or arrangement to any taxpayer, then the advice should be considered to have been written to support the promotion or marketing by a person other than the sender or this firm of that transaction or matter, and such taxpayer should seek advice based on the taxpayer's particular circumstances from an independent tax advisor. Confidentiality Notice: This electronic mail transmission is intended for the use of the individual or entity to which it is addressed and may contain confidential information belonging to the sender which is protected by the attorney-client privilege. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, or the taking of any action in reliance on the contents of this information is strictly prohibited. If you have received this transmission in error, please notify the sender immediately by e-mail and delete the original message. Thank you for your cooperation. _______________________________________________ landten mailing list landten@lists.flabarrpptl.org http://mailman.fsr.com/mailman/listinfo/landten

LC

Leonard Cabral

Wed, Feb 19, 2020 3:43 AM

FS 51.01 Summary Procedure. Depositions (only) are permitted. No other discovery

Sent by Leonard P Cabral

On Feb 18, 2020, at 5:55 PM, Mike Davis mike@mgfdlaw.com wrote:

FYI either party can depose not only the other party but also any proposed witnesses. Learned that when Legal Aid North Florida requested to depose manager and our three witnesses in a 7Termination eviction case.
Mike Davis

Sent from my iPhone

On Feb 18, 2020, at 4:34 PM, Carol S. Grondzik csgrondzik@floridahousinglaw.com wrote:

Chapter 51 allows one deposition without the court’s permission. Court must order any other discovery. Section 51.011(2), Fla. Stat.

Carol

Carol S. Grondzik, Esquire
Lutz, Bobo & Telfair, P.A.
2155 Delta Boulevard, Suite 210-B
Tallahassee, Florida 32303
Telephone: (850) 521-0890
Facsimile: (850) 521-0891

This message is intended only for the use of the addressees shown above. This message contains information that may be privileged, confidential and/or exempt from disclosure under applicable law. If you are not the intended recipient of this message, then you are hereby notified that the copying, use, forwarding or other distribution of any information or materials transmitted in or with, or as an attachment to, this message is strictly prohibited. If you received this message by mistake, then please immediately send it back to us and then immediately destroy this message. Your cooperation is appreciated.

Pursuant to the Fair Debt Collection Practices Act, it is required that we state the following to you: This is a communication from a debt collector. This may be an attempt to collect a debt and any information obtained may be used for that purpose.

From: landten-bounces@lists.flabarrpptl.org landten-bounces@lists.flabarrpptl.org On Behalf Of Cary P. Sabol, Esq.
Sent: Tuesday, February 18, 2020 4:20 PM
To: Landlord - Tenant Listserve landten@lists.flabarrpptl.org
Subject: [RPPTL LandTen] Residential Eviction & Discovery

Does anyone have any authority regarding whether there is a right to engage in discovery in a standard residential eviction case? Is there a right to take depos, Request to Produce, etc. when it's statutory required to be an expedited procedure?

Cary
Cary P. Sabol, Esq. J.D. (2001), LLM (2009)
Law Offices of Cary P. Sabol
P.O. Box 15981 | West Palm Beach | Florida | 33416
Office: (561) 413-4449
Cell: (561) 281-2744
Fax: (888) 316-2881

BEWARE OF CYBER-CRIME: IF YOU RECEIVE AN E-MAIL OR ANY OTHER COMMUNICATION THAT APPEARS TO BE GENERATED FROM OUR OFFICE THAT CONTAINS NEW, REVISED, OR ALTERED BANK WIRE INSTRUCTIONS, CONSIDER IT SUSPECT AND CALL OUR OFFICE AT A NUMBER YOU TRUST. OUR BANK WIRE INSTRUCTIONS SELDOM CHANGE.

** PLEASE NOTE: On Closings with a Loan, we require "CLOSING INSTRUCTIONS and LOAN PACKAGES" by NOON the day BEFORE Closing"

CASH TO CLOSE for real estate transactions must be WIRED to our account prior to closing. (SAME DAY WIRE - NO ACH TRANSFERS) Wire instructions will be provided upon request. ACH transfers are NOT SAME DAY wires and cannot be accepted.

THIS COMMUNICATION MAY BE AN ATTEMPT TO COLLECT A DEBT AS DEFINED BY FLORIDA AND FEDERAL LAW AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS IS A COMMUNICATION FROM A DEBT COLLECTOR.
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IRS Circular 230 Notice: Pursuant to recently enacted U.S. Treasury Department Regulations, we are now required to advise you that, unless otherwise expressly indicated, any federal tax advice expressed above was neither written nor intended by the sender or this firm to be used and cannot be used by any taxpayer for the purpose of avoiding penalties that may be imposed under U.S. tax law. If any person uses or refers to any such tax advice in promoting, marketing or recommending a partnership or other entity, investment plan or arrangement to any taxpayer, then the advice should be considered to have been written to support the promotion or marketing by a person other than the sender or this firm of that transaction or matter, and such taxpayer should seek advice based on the taxpayer's particular circumstances from an independent tax advisor.

Confidentiality Notice: This electronic mail transmission is intended for the use of the individual or entity to which it is addressed and may contain confidential information belonging to the sender which is protected by the attorney-client privilege. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, or the taking of any action in reliance on the contents of this information is strictly prohibited. If you have received this transmission in error, please notify the sender immediately by e-mail and delete the original message. Thank you for your cooperation.

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FS 51.01 Summary Procedure. Depositions (only) are permitted. No other discovery Sent by Leonard P Cabral On Feb 18, 2020, at 5:55 PM, Mike Davis <mike@mgfdlaw.com> wrote: FYI either party can depose not only the other party but also any proposed witnesses. Learned that when Legal Aid North Florida requested to depose manager and our three witnesses in a 7Termination eviction case. Mike Davis Sent from my iPhone On Feb 18, 2020, at 4:34 PM, Carol S. Grondzik <csgrondzik@floridahousinglaw.com> wrote: Chapter 51 allows one deposition without the court’s permission. Court must order any other discovery. Section 51.011(2), Fla. Stat. Carol Carol S. Grondzik, Esquire Lutz, Bobo & Telfair, P.A. 2155 Delta Boulevard, Suite 210-B Tallahassee, Florida 32303 Telephone: (850) 521-0890 Facsimile: (850) 521-0891 This message is intended only for the use of the addressees shown above. This message contains information that may be privileged, confidential and/or exempt from disclosure under applicable law. If you are not the intended recipient of this message, then you are hereby notified that the copying, use, forwarding or other distribution of any information or materials transmitted in or with, or as an attachment to, this message is strictly prohibited. If you received this message by mistake, then please immediately send it back to us and then immediately destroy this message. Your cooperation is appreciated. Pursuant to the Fair Debt Collection Practices Act, it is required that we state the following to you: This is a communication from a debt collector. This may be an attempt to collect a debt and any information obtained may be used for that purpose. From: landten-bounces@lists.flabarrpptl.org <landten-bounces@lists.flabarrpptl.org> On Behalf Of Cary P. Sabol, Esq. Sent: Tuesday, February 18, 2020 4:20 PM To: Landlord - Tenant Listserve <landten@lists.flabarrpptl.org> Subject: [RPPTL LandTen] Residential Eviction & Discovery Does anyone have any authority regarding whether there is a right to engage in discovery in a standard residential eviction case? Is there a right to take depos, Request to Produce, etc. when it's statutory required to be an expedited procedure? Cary Cary P. Sabol, Esq. J.D. (2001), LLM (2009) Law Offices of Cary P. Sabol P.O. Box 15981 | West Palm Beach | Florida | 33416 Office: (561) 413-4449 Cell: (561) 281-2744 Fax: (888) 316-2881 BEWARE OF CYBER-CRIME: IF YOU RECEIVE AN E-MAIL OR ANY OTHER COMMUNICATION THAT APPEARS TO BE GENERATED FROM OUR OFFICE THAT CONTAINS NEW, REVISED, OR ALTERED BANK WIRE INSTRUCTIONS, CONSIDER IT SUSPECT AND CALL OUR OFFICE AT A NUMBER YOU TRUST. OUR BANK WIRE INSTRUCTIONS SELDOM CHANGE. ** PLEASE NOTE: On Closings with a Loan, we require "CLOSING INSTRUCTIONS and LOAN PACKAGES" by NOON the day BEFORE Closing" CASH TO CLOSE for real estate transactions must be WIRED to our account prior to closing. (SAME DAY WIRE - NO ACH TRANSFERS) Wire instructions will be provided upon request. ACH transfers are NOT SAME DAY wires and cannot be accepted. THIS COMMUNICATION MAY BE AN ATTEMPT TO COLLECT A DEBT AS DEFINED BY FLORIDA AND FEDERAL LAW AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS IS A COMMUNICATION FROM A DEBT COLLECTOR. <image001.jpg> <image002.png> _________________________________________________________________________________________________________________ IRS Circular 230 Notice: Pursuant to recently enacted U.S. Treasury Department Regulations, we are now required to advise you that, unless otherwise expressly indicated, any federal tax advice expressed above was neither written nor intended by the sender or this firm to be used and cannot be used by any taxpayer for the purpose of avoiding penalties that may be imposed under U.S. tax law. If any person uses or refers to any such tax advice in promoting, marketing or recommending a partnership or other entity, investment plan or arrangement to any taxpayer, then the advice should be considered to have been written to support the promotion or marketing by a person other than the sender or this firm of that transaction or matter, and such taxpayer should seek advice based on the taxpayer's particular circumstances from an independent tax advisor. Confidentiality Notice: This electronic mail transmission is intended for the use of the individual or entity to which it is addressed and may contain confidential information belonging to the sender which is protected by the attorney-client privilege. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, or the taking of any action in reliance on the contents of this information is strictly prohibited. If you have received this transmission in error, please notify the sender immediately by e-mail and delete the original message. Thank you for your cooperation. _______________________________________________ landten mailing list landten@lists.flabarrpptl.org http://mailman.fsr.com/mailman/listinfo/landten _______________________________________________ landten mailing list landten@lists.flabarrpptl.org http://mailman.fsr.com/mailman/listinfo/landten