DOJ-OGR-00031544.jpg
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assertion in the Motion For Protective Order that Mr. Leopold and the undersigned agreed
7 that Mr. Leopold would accept service on behalf of Jane Doe No. 1, and that the
undersigned had agreed not to take the disposition on February 6, 2008, the matter has
been rendered moot.
3. Prior to filing of a Motion For Protective Order, Mr. Leopold and the undersigned
conferred and agreed in writing with the consent of the State Attorney’s Office to the taking
of Jane Doe No.1's deposition on February 20, 2008. The parties have also agreed that
Mr. Leopold will accept service for Jane Doe’s No.1's appearance on that date eliminating
the need to use a process server to serve Jane Doe No.1. See Exhibit “A” attached. (Jane
Doe No. 1's real name has been redacted from the exhibit.)
WHEREFORE, given the fact that the parties have agreed to a procedure for the
taking of Jane Doe’s No.1's deposition, it is respectfully requested that this Court deny
Jane Doe No.1's Motion for Protective Order as moot.
| HEREBY CERTIFY that a copy of the foregoing has been furnished by mail to
Lanna Belohlavek, Esquire, The Office of the State Attorney, 401 North Dixie Highway,
West Palm Beach, Florida 33401, Theodore J. Leopold, Esquire, 2925 PGA Boulevard,
Suite 200, Palm Beach Gardens, Florida, 33410 and Jeffrey Herman, Esquire, 18205
Biscayne Boulevard, Suite 2218, Miami, Florida, 33160, on this 7" day of February, 2008.
CK A. GOLDBERGER, ESQ.
07/26/17 Page 23 Public Records Request No.: 17-295
DOJ-OGR-00031544
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Document Details
| Filename | DOJ-OGR-00031544.jpg |
| File Size | 660.6 KB |
| OCR Confidence | 95.4% |
| Has Readable Text | Yes |
| Text Length | 1,514 characters |
| Indexed | 2026-02-03 21:56:31.520284 |