RR#4005r +
• IN THE CIRCUIT COURT OF THE 11tH
JUDICIAL CIRCUIT, IN AND FOR
` MIAMI-DARE COUNTY, FLORIDA
CASE NO.: o8-g~62 FC i9
FAMILY DIVISION
IN RE THE MARRIAGE OF:
LYDIA CARROLL,
Wife,
and
WALTER C. CARROLL, III,
Husband
SUBPOENA DUCES NTE~ ~I~ N OUT DEPOSITION
~~
THE STATE OF FLORIDA: ~~ ~ /~!
( 2
TO: Records Custodian J ~~
City of Miami Beach ~ l
i~oo Convention Center Drive
Miami Beach, Florida 33139
YOU ARE COMMANDED to appear at the offices of Kofsl~f and Associates, 200
Southeast 1St Street, Suite X05, Miami, Florida 33131on Monday, June 23, 2008, at io:oo
a.m. and to have with you at said time and place the following items attached hereto as
Exhibit "A".
These items will be inspected and may be copied at that time. You will not be
required to surrender the original items. You may comply with this Subpoena by providing
legible copies of the items to be produced to the attorney whose name appears on this
subpoena on or before the scheduled date of production. You may condition the
preparation of the copies upon the payment in advance of the reasonable cost of
preparation.
Exhibit "A"
1. Applications by WALTER C. CARROLL, III for employment.
2. Prior employment verification of WALTER C. CARROLL, III.
g. Pre-employment background or health documentation of WALTER C.
CARROLL, III.
4, Applications by WALTER C. CARROLL, III for insurance and/or insurance
forms.
5. Physician or medical reports or records of any kind pertaining to physical
examination required for employment, continued employment or health or disability
insurance for WALTER C. CARROLL, III.
6. Reports or records of job or other injury pertaining to WALTER C. CARROLL,
III.
~. Attendance records of WALTER C. CARROLL, III.
8. Sick time records of WALTER C. CARROLL, III.
g. Vacation records of WALTER C. CARROLL, III.
io. Progress and/or promotion records of WALTER C. CARROLL, III.
11. Letters of complaint, letters of commendation, disciplinary records and
performance evaluations pertaining to WALTER C. CARROLL, III.
12. Work description records pertaining to WALTER C. CARROLL, III, including
pay scale information.
i3. Records reflecting reasons for WALTER C. CARROLL, III's absences from
work, lay-offs, termination, or any and all times, occasions or reasons.
i4. Copy of your annual employee benefit package.
15. All records in regards to monies or benefits paid or payable to WALTER C.
CARROLL, III, including, but not limited to salaries, bonuses, commissions, allowances,
overtime, or other similar payments from date of employment to the present.
16. Salary history of WALTER C. CARROLL, III.
1~, W-2 forms and/or any other income tax records of WALTER C. CARROLL, III.
18. Expense account records of WALTER C. CARROLL, III.
1q. All records in regards to benefits provided to WALTER C. CARROLL, III,
including, but not limited to disability benefits, pensions, retirement and/or annuity plans,
including all records in regards to the contribution to the same by the employer as well as
WALTER C. CARROLL, III.
20. All records in regards to investment options, stock purchase plans and/or any
similar plans available, including all records in regards to the contribution to the same by
the employer as well as WALTER C. CARROLL, III.
21. All medical, hospitalization, doctor, prescription drugs, and dental insurance
and benefits provided to WALTER C. CARROLL, III, and the amount of money contributed
to the same by the employer as well as WALTER C. CARROLL, III.
22. All life insurance benefits provided to WALTER C. CARROLL, III, and the
amount contributed thereto by the employer as well as WALTER C. CARROLL, III.
23. All sick days accrued and possible benefits to WALTER C. CARROLL, III if he
does not actually use said sick days.
24. All vacation time accrued and possible benefits to WALTER C. CARROLL, III
if WALTER C. CARROLL, III does not actually utilize said vacation time.
25. Any other benefits received by WALTER C. CARROLL, III as a result of
employment.
26. Individual employee personnel file of WALTER C. CARROLL, III, from date of
employment to the present.
' ~ YOU MAY MAIL, FAX OR DELIVER THE COPIES to the attorney whose name
appears on the subpoena and thereby ELEMINATE YOUR APPEARANCE at the time and
place specified above. You have the right to object to the production pursuant to this
subpoena at any time before production by written notice to the attorney whose name
appears on this subpoena.
If you fail to:
1. appear as specified; or
2. furnish the records instead of appearing
as provided above; or
3. object to this subpoena,
you may be in contempt of Court. You are subpoenaed by the attorneys whose name
appears in this Subpoena and unless excused from this Subpoena by the attorneys or the
Court, you shall respond to this Subpoena as directed.
DATED this 19~' day of May, 2008.
By:
Martin B. Kofsky squ' •e
Florida Bar No. 95 00
Karen B. Schapira, squire
Florida Bar No.: 450146
20o SE First Street, Suite 705
Miami, Florida 33131
Tel. (305) 728-2270
Fax (305) 728-2279