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Notice of Records Deposition

Angelo Corceone has filed a notice of records deposition against Kimberly Corceone in Family Court in East Baton Rouge Parish, Louisiana. He will receive the record deposition of Patricia Breeland, CEO of Pensacola Nephrology. A subpoena duces tecum has been issued requiring the production of documents listed in Exhibit A, including Kimberly Corceone's employee file, schedules, time cards, pay records, benefits, disciplinary actions, and licenses from the date of her employment to present. The deposition will take place on July 3rd, 2012 at Angelo Corceone's office.

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2K views

Notice of Records Deposition

Angelo Corceone has filed a notice of records deposition against Kimberly Corceone in Family Court in East Baton Rouge Parish, Louisiana. He will receive the record deposition of Patricia Breeland, CEO of Pensacola Nephrology. A subpoena duces tecum has been issued requiring the production of documents listed in Exhibit A, including Kimberly Corceone's employee file, schedules, time cards, pay records, benefits, disciplinary actions, and licenses from the date of her employment to present. The deposition will take place on July 3rd, 2012 at Angelo Corceone's office.

Uploaded by

ANGELO
Copyright
© Attribution Non-Commercial (BY-NC)
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Download as DOCX, PDF, TXT or read online on Scribd
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ANGELO CORCEONE Petitioner VERSUS

NUMBER 136,741 DIVISION B THE FAMILY COURT PARISH OF EAST BATON ROUGE

KIMBERLY CORCEONE Defendant

STATE OF LOUISIANA

NOTICE OF RECORDS DEPOSITION

PLEASE TAKE NOTICE that Petitioner Angelo A. Corceone, appearing herein in propria persona, will receive the record deposition of Patricia Breeland, CEO, Custodian of Records of Pensacola Nephrology at the office of Angelo A. Corceone at 4161 Southpark, Baton Rouge, Louisiana 70816. Deponent with be issued a subpoena duces tecum requiring the production of documents listed on the attached Exhibit "A". An appearance is not required, if the documents are mailed to the undersigned on or prior to the scheduled date.

RESPECTFULLY SUBMITTED,

________________________ Angelo A. Corceone Pro Se 4161 Southpark Baton Rouge, Louisiana 70816 Telephone: 225-907-5534 Facsimile: 805-669-3235 Email: [email protected]

CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have served a copy of the foregoing pleading on all counsel to this proceeding by facsimile transmission, hand delivery, or by placing same in the United States mail, first class, postage prepaid, this _____day of June, 2012.

____________________________ Angelo A. Corceone-Pro Se

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ANGELO CORCEONE Petitioner VERSUS

NUMBER 136,741 DIVISION B THE FAMILY COURT PARISH OF EAST BATON ROUGE

KIMBERLY CORCEONE Defendant

STATE OF LOUISIANA

EXHIBIT "A"

Please produce in the office of Angelo A. Corceone 4161 Southpark, Baton Rouge, La 70816 on or before July 3RD, 2012, the following: Certified Copies of any and all records (personnel, disciplinary and/or other) pertaining to Kimberly D. Corceone DOB November 00TH, 0000 Social Security Number 000-00-0000 from date of employment began through the present day, including, but not limited to: 1. Employee File 2. Schedules 3. Hours Worked 4. Time Cards 5. Rates of Pay 6. Salary 7. Benefits 8. Any awards 9. Disciplinary Actions 10. Correspondence 11. Licenses and/or certificates of completions

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