Filing # 135209657 E-Filed 09/23/2021 04:27:24 PM
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`IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT,
`IN AND FOR BROWARD COUNTY, FLORIDA
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`CASE NO- CACE 19-010436
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`TRICIA M. HOYLE, as Personal
`Representative of the Estate and Survivors of
`the Decedent GENE SPEARS,
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`Plaintiff,
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`V A
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`BB INC.,
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`Defendants.
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`i
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`DEFENDANTS' AMENDED NOTICE OF TAKING THE DEPOSITION
`DUCES TECUM OF DR. EDWIN HOLSTEIN
`(Amended to Add Connection Information)
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`TO:
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`ALL COUNSEL OF RECORD
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`PLEASE TAKE NOTICE that counsel for Defendants, BURNHAM LLC, CARRIER
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`CORPORATION, COPELAND CORPORATION,LLC, and FULTON BOILERWORKS, INC.,
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`is hereby noticing the deposition of.
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`NAME-
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`Dr. Edwin Holstein
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`DATE:
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`Friday, October 1, 2021
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`TIME:
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`11:00 a.m. ET
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`PLACE:
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`Virtual - Connection information below
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`Meeting ID: 86194345644
`Password: Yh8kyhT0IL
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`Dial bv vour location:
`+1 646-518-9805 US (New York)
`+1 301-715-8592 US (Washington DC)
`+1 312-626-6799 US (Chicago)
`+1 213-338-8477 US (Los Angeles)
`+1 602-753-0140 US (Phoenix)
`+1 833-548-0276 US
`+1 833-548-0282 US
`+1 877-853-5257 US
`+1 888-475-4499 US
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`Meeting ID: 86194345644
`Password: 8262115708 (for phone connection only)
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`*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/23/2021 04:27:24 PM.****
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`

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`CASE NO.: 19-010436
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`Upon oral examination before Veritext Court Reporters or any other person authorized by
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`law to take depositions in the State of Florida. This deposition shall continue day to day until
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`completed. The deposition of the witness is being taken for the purpose of discovery, use at trial
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`or for such other purposes as are permitted under the rules of the court. The designated witness is
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`required to bring those documentsand things described in Schedule "A" attached hereto.
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`CERTIFICATE OF SERVICE
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`WE HEREBY CERTIFY that a true and correct copy of the foregoing has been served via
`State of Florida E-Filing Portal and FileandServeXpress on all counsel of record on this 23rd day
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`of September 2021.
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`BICE COLE LAW FIRM, P.L.
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`By. Glmuameawwlg-Tim
`Susan J. Cole, B.C.S., FBN: 270474
`Melanie Chung-Tims,FBN: 27603
`Amanda Cachaldora, FBN : 060907
`999 Ponce De Leon Boulevard, Suite 710
`Coral Gables, FL 33134
`Telephone: (305) 444-1225
`Fax: (305) 446-1598
`cole@bicecolelaw.com
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`com
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`com
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`Counselfor Burnham, LLC, Carrier
`Corporation, Copeland Corporation,LLC, and
`Fulton Boilerworks, Inc.
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`-2-
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`CASE NO.: 19-010436
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`SCHEDULE "A"
`MATERIALS TO BE PRODUCED AT DEPOSITION
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`The deponent's current curriculum vitae and any other documents pertaining to the
`deponent'sbackground or identifying the factors that Plaintiffcontends qualify him as an
`expert in each field in which his testimony is sought in this matter.
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`All publications by the deponent, or a list thereof, if such a list is not included on the
`curriculum vitae.
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`All engagement letters and other documents which reflect the scope of employment in
`this matter and the compensation for such service.
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`All materialsprovided to the deponent, including all writings, documents or information
`of any type concerning any issues, allegations or other matters relating to the Plaintiff's
`claims.
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`All materials considered or relied upon by the deponent in reaching his opinions in this
`case. including but not limited to, depositions, correspondence, photographs, reports,
`books, articles, literature, tests, statements, or other reference materials, all source
`materialsreferenced in the deponent'sreport, and any reports or other materials furnished
`to the deponentby or on behalf of other experts in this case.
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`All drafts and final reports and/or writings which the deponent has prepared or which
`were prepared at the deponent's direction or request, concerning this case.
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`All documentsthat pertain to fees incurred or charged by the deponent to the Plaintiffin
`connection with deponent's services rendered in this case, and all documentspertaining
`to fees incurred or charged by the deponent to other Plaintiffs' counsel in all other
`asbestos-related litigation in which the deponent rendered services, including, but not
`limited to invoices, requests for payment and remittances,
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`A list of cases in which the deponent has testified, either at trial or in deposition, for the
`past three years.
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`A list of all cases in which the deponenthas been retainedby attorneysfor Plaintiffherein
`in which asbestos personal injury has been alleged, and a copy of any deposition or trial
`transcriptwhich contains his testimony in any such case.
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`1.
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`2.
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`3.
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`4.
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`5.
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`6.
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`7.
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`8.
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`9.
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`1 O.
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`All drawings, charts, exhibits, photographs, videotapes, and PowerPoint or other
`presentationsmade by the deponent or on the deponent's behalf, given to the deponent,
`or consideredby the deponentwith regard to this case.
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`11.
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`Copies of any and all correspondence or other communications between the deponent and
`Plaintiff or Plaintiff's counsel.
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`-3-
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`CASE NO.: 19-010436
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`12.
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`13.
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`All documents that establish the portion of deponent's involvement as an expert witness,
`including the number of hours, percentage of hours, or percentage of earned income
`derived from serving as an expert witness.
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`All documents which reflect your general litigation experience, including but not limited
`to, the percentage of work performed for plaintiffs as well as defendants.
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`-4-
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