HomeMy WebLinkAbout10-6179
Trafalgar at Greenacres, Ltd.,
Plaintiff ,
vs.
Zurich American Insurance Company,
Defendant
RULE 206.1 Petition
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
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PETITION FOR ISSUANCE OF LETTERS ROGATORY
TO THE HONORABLE, THE JUDGES OF SAID COURT: Court of Common Pleas of Cumberland
County, PA.
Michael A. Winkleman, counsel for the Plaintiff in the above action, respectfully represents that:
1. The above-captioned action is at issue and is a bad faith insurance claim.
2. The claim of plaintiff in this action is in excess of $15,000.
3. The Plaintiff seeks the deposition of Dave Grandon who resides at 91 Poplar ave. New
Cumberland, PA 17070-2040.
4. The proposed deponent, Dave Grandon, has material information necessary for the prosecution
of this claim.
5. The Defendant in the above action has no objection to the taking of this deposition.
6. For the issuance of a subpoena it is necessary that this Court grant an order for issuance of
Letters Rogatory.
WHEREFORE, your petitioner prays your Honorable Court to issue Letters Rogatory for
the taking of the deposition of Dave Grandon.
Mi an
FLA. BAR. NO. 367
LIP ON, MARGULIEt
SI
NA &
WINKLEMAN, P.A.
One Biscayne Tower, Suite 1776
Two South Biscayne Boulevard
Miami, FL 33131
Counsel for Defendant
Gary J. Guzzi
Akerman Senterfitt
One S.E. Third Avenue, 25th Floor
Miami, Florida 33131
0
4QA.00 PO ATTy
67.100
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SEP 2 d 2010
Trafalgar at Greenacres, Ltd.,
Plaintiff ,
vs.
Zurich American Insurance Company,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
File No. 10- (v179 Oi V I I -,-n?
PROPOSED ORDER GRANTING PLAINTIFF'S PETITION FOR ISSUANCE OF
LETTERS ROGATORY
The petition of Plaintiff in the above action is granted. After consideration of the facts
presented in Plaintiff's Petition for Issuance of Letters Rogatory, it is hereby ordered and decreed
that Letters Rogatory be issued to obtain the testimony of Dave Grandon, residing at 91 Poplar
Ave. New Cumberland, PA 17070-2040.
Dated this .30 ` day of 20/0
BY THE COURT:
Copies furnished to: - Michael A. Wi eman, Esq.
One Biscayne Tower, Suite 1776
2 South Biscayne Blvd.
Miami, FL 33131
J Guzzi, Esq.
One Southeast Third Avenue
25th Floor
Miami, FL 33131
?D'J t E.S I7'L?l?
JUDGE
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