Case 0:20-cv-61297-RKA Document 55-1 Entered on FLSD Docket 12/11/2020 Page 1 of 20
PAGE | 1 of 2

LAW OFFICES OF JIBRAEL S. HINDI, PLLC

110 SE 6th Street, 17th Floor | Ft. Lauderdale, Florida 33301 | Phone (954) 907-1136 | Fax (855) 529-9540 

www.JibraelLaw.com

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 0:20-cv-61297-RKA

PAMELA TITUS, 

JOSEPH AMODIO, 

WILLIAM VILCINA,

JACQUELINE FONTANEZ,

PAUL JONES,

BYRON HALL, 

and DAMIEN DAY,

Plaintiffs,

v.

RESURGENT CAPITAL SERVICES L.P., 

LVNV FUNDING, LLC, MERRICK BANK 

CORPORATION, PINNACLE CREDIT 

SERVICES, LLC, and PYOD, LLC,

Defendants.

_______________________________________/

NOTICE OF DEPOSITION

The above-captioned Plaintiffs will take the deposition by way of oral examination of 

Susan Gaines, of whom signed under penalty of perjury proofs of claim involving Plaintiffs Jones, 

Titus and Day. The date, time, and location of said deposition is as follows: 

DATE: Wednesday, January 27, 2021

TIME: 2:00 PM

LOCATION: VIA ELECTRONIC or OTHER REMOTE MEANS

The Law Offices of Jibrael S. Hindi, PLLC

110 S.E. 6th Street, Suite 1700

Fort Lauderdale, Florida 33301

This deposition will be video recorded as well as by stenographic means before a notary 

public authorized to administer oaths in the State of Florida. The deposition will continue from 

Case 0:20-cv-61297-RKA Document 55-1 Entered on FLSD Docket 12/11/2020 Page 2 of 20
PAGE | 2 of 2

LAW OFFICES OF JIBRAEL S. HINDI, PLLC

110 SE 6th Street, 17th Floor | Ft. Lauderdale, Florida 33301 | Phone (954) 907-1136 | Fax (855) 529-9540 

www.JibraelLaw.com

day to day until completed. The deposition is being taken for the purposes of discovery, for use at 

trial, and such other purposes as are permitted under the Federal Rules of Civil Procedure.

DATED: December 11, 2020

Respectfully Submitted,

 /s/ Thomas Patti .

JIBRAEL S. HINDI, ESQ.

Florida Bar No.: 118259

E-mail: jibrael@jibraellaw.com

THOMAS J. PATTI, ESQ.

Florida Bar No.: 118377

E-mail: tom@jibraellaw.com

The Law Offices of Jibrael S. Hindi

110 SE 6th Street, Suite 1744

Fort Lauderdale, Florida 33301

Phone: 954-907-1136

Fax: 855-529-9540

COUNSEL FOR PLAINTIFF

CERTIFICATE OF SERVICE

The undersigned certifies that, on December 11, 2020, the forgoing was electronically 

served on counsel for Defendants John Michael Marees, Esq. at jmarees@messerstrickler.com.

 /s/ Thomas Patti .

THOMAS J. PATTI, ESQ.

Florida Bar No.: 118377

Case 0:20-cv-61297-RKA Document 55-1 Entered on FLSD Docket 12/11/2020 Page 3 of 20
PAGE | 1 of 2

LAW OFFICES OF JIBRAEL S. HINDI, PLLC

110 SE 6th Street, 17th Floor | Ft. Lauderdale, Florida 33301 | Phone (954) 907-1136 | Fax (855) 529-9540 

www.JibraelLaw.com

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 0:20-cv-61297-RKA

PAMELA TITUS, 

JOSEPH AMODIO, 

WILLIAM VILCINA,

JACQUELINE FONTANEZ,

PAUL JONES,

BYRON HALL, 

and DAMIEN DAY,

Plaintiffs,

v.

RESURGENT CAPITAL SERVICES L.P., 

LVNV FUNDING, LLC, MERRICK BANK 

CORPORATION, PINNACLE CREDIT 

SERVICES, LLC, and PYOD, LLC,

Defendants.

_______________________________________/

NOTICE OF DEPOSITION

The above-captioned Plaintiffs will take the deposition by way of oral examination of

Leoann Shannon, of whom signed under penalty of perjury a proof of claim involving Plaintiff 

Vilcina. The date, time, and location of said deposition is as follows:

DATE: Wednesday, January 27, 2021

TIME: 3:00 PM

LOCATION: VIA ELECTRONIC or OTHER REMOTE MEANS

The Law Offices of Jibrael S. Hindi, PLLC

110 S.E. 6th Street, Suite 1700

Fort Lauderdale, Florida 33301

This deposition will be video recorded as well as by stenographic means before a notary 

public authorized to administer oaths in the State of Florida. The deposition will continue from 

Case 0:20-cv-61297-RKA Document 55-1 Entered on FLSD Docket 12/11/2020 Page 4 of 20
PAGE | 2 of 2

LAW OFFICES OF JIBRAEL S. HINDI, PLLC

110 SE 6th Street, 17th Floor | Ft. Lauderdale, Florida 33301 | Phone (954) 907-1136 | Fax (855) 529-9540 

www.JibraelLaw.com

day to day until completed. The deposition is being taken for the purposes of discovery, for use at 

trial, and such other purposes as are permitted under the Federal Rules of Civil Procedure.

DATED: December 11, 2020

Respectfully Submitted,

 /s/ Thomas Patti .

JIBRAEL S. HINDI, ESQ.

Florida Bar No.: 118259

E-mail: jibrael@jibraellaw.com

THOMAS J. PATTI, ESQ.

Florida Bar No.: 118377

E-mail: tom@jibraellaw.com

The Law Offices of Jibrael S. Hindi

110 SE 6th Street, Suite 1744

Fort Lauderdale, Florida 33301

Phone: 954-907-1136

Fax: 855-529-9540

COUNSEL FOR PLAINTIFF

CERTIFICATE OF SERVICE

The undersigned certifies that, on December 11, 2020, the forgoing was electronically 

served on counsel for Defendants John Michael Marees, Esq. at jmarees@messerstrickler.com.

 /s/ Thomas Patti .

THOMAS J. PATTI, ESQ.

Florida Bar No.: 118377

Case 0:20-cv-61297-RKA Document 55-1 Entered on FLSD Docket 12/11/2020 Page 5 of 20
PAGE | 1 of 2

LAW OFFICES OF JIBRAEL S. HINDI, PLLC

110 SE 6th Street, 17th Floor | Ft. Lauderdale, Florida 33301 | Phone (954) 907-1136 | Fax (855) 529-9540 

www.JibraelLaw.com

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 0:20-cv-61297-RKA

PAMELA TITUS, 

JOSEPH AMODIO, 

WILLIAM VILCINA,

JACQUELINE FONTANEZ,

PAUL JONES,

BYRON HALL, 

and DAMIEN DAY,

Plaintiffs,

v.

RESURGENT CAPITAL SERVICES L.P., 

LVNV FUNDING, LLC, MERRICK BANK 

CORPORATION, PINNACLE CREDIT 

SERVICES, LLC, and PYOD, LLC,

Defendants.

_______________________________________/

NOTICE OF DEPOSITION

The above-captioned Plaintiffs will take the deposition by way of oral examination of

David Lamb, of whom signed under penalty of perjury proofs of claim involving Plaintiffs Titus, 

Hall, Amodio and Fontanez. The date, time, and location of said deposition is as follows: 

DATE: Wednesday, January 27, 2021

TIME: 11:00 AM

LOCATION: VIA ELECTRONIC or OTHER REMOTE MEANS

The Law Offices of Jibrael S. Hindi, PLLC

110 S.E. 6th Street, Suite 1700

Fort Lauderdale, Florida 33301

This deposition will be video recorded as well as by stenographic means before a notary 

public authorized to administer oaths in the State of Florida. The deposition will continue from 

Case 0:20-cv-61297-RKA Document 55-1 Entered on FLSD Docket 12/11/2020 Page 6 of 20
PAGE | 2 of 2

LAW OFFICES OF JIBRAEL S. HINDI, PLLC

110 SE 6th Street, 17th Floor | Ft. Lauderdale, Florida 33301 | Phone (954) 907-1136 | Fax (855) 529-9540 

www.JibraelLaw.com

day to day until completed. The deposition is being taken for the purposes of discovery, for use at 

trial, and such other purposes as are permitted under the Federal Rules of Civil Procedure.

DATED: December 11, 2020

Respectfully Submitted,

 /s/ Thomas Patti .

JIBRAEL S. HINDI, ESQ.

Florida Bar No.: 118259

E-mail: jibrael@jibraellaw.com

THOMAS J. PATTI, ESQ.

Florida Bar No.: 118377

E-mail: tom@jibraellaw.com

The Law Offices of Jibrael S. Hindi

110 SE 6th Street, Suite 1744

Fort Lauderdale, Florida 33301

Phone: 954-907-1136

Fax: 855-529-9540

COUNSEL FOR PLAINTIFF

CERTIFICATE OF SERVICE

The undersigned certifies that, on December 11, 2020, the forgoing was electronically 

served on counsel for Defendants John Michael Marees, Esq. at jmarees@messerstrickler.com.

 /s/ Thomas Patti .

THOMAS J. PATTI, ESQ.

Florida Bar No.: 118377

Case 0:20-cv-61297-RKA Document 55-1 Entered on FLSD Docket 12/11/2020 Page 7 of 20
PAGE | 1 of 3

LAW OFFICES OF JIBRAEL S. HINDI, PLLC

110 SE 6th Street, 17th Floor | Ft. Lauderdale, Florida 33301 | Phone (954) 907-1136 | Fax (855) 529-9540

www.JibraelLaw.com

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 0:20-cv-61297-RKA

PAMELA TITUS, 

JOSEPH AMODIO, 

WILLIAM VILCINA,

JACQUELINE FONTANEZ,

PAUL JONES,

BYRON HALL, 

and DAMIEN DAY,

Plaintiffs,

v.

RESURGENT CAPITAL SERVICES L.P., 

LVNV FUNDING, LLC, MERRICK BANK 

CORPORATION, PINNACLE CREDIT 

SERVICES, LLC, and PYOD, LLC,

Defendants.

_______________________________________/

NOTICE OF DEPOSITION

Pursuant to Fed.R.Civ.P. 30(b)(6), the above-captioned Plaintiffs will take the deposition

by way of oral examination of the person and/or persons that Resurgent Capital Services, L.P. 

(“Defendant”) designates as the person and/or persons most knowledgeable and prepared to testify

on behalf of Defendant on the following topics (the “Deposition Topics”): [1] the facts and

circumstances surrounding each allegation in the Third Consolidated Complaint and Defendant’s

record response and/or answer thereto; [2] Defendant’s consumer collection agency license and/or

registration with the Florida Department of State; [3] the documents and information Defendant

maintains in accordance with Rule 69V-180.080, Florida Administrative Code; [4] the proofs of

claim filed in Plaintiffs’ bankruptcy cases; [5] the documents and information reviewed by

Defendant to prepare the proofs of claim filed in Plaintiffs’ bankruptcy cases; [6] Defendant’s

Case 0:20-cv-61297-RKA Document 55-1 Entered on FLSD Docket 12/11/2020 Page 8 of 20
PAGE | 2 of 3

LAW OFFICES OF JIBRAEL S. HINDI, PLLC

110 SE 6th Street, 17th Floor | Ft. Lauderdale, Florida 33301 | Phone (954) 907-1136 | Fax (855) 529-9540

www.JibraelLaw.com

policies and procedures regarding the submission of proofs of claim; [7] Defendant’s policies and

procedures that Defendant maintains to prevent filing proofs of claim that falsely represent the

amount sought therein as not including interest or other charges; and [8] the information and

documentation Defendant relies upon to determine the principal portion of the debts underlying

the proofs of claim filed in Plaintiffs’ bankruptcy cases.

The date, time, and location of the deposition shall be as follows:

DATE: Friday, January 29, 2021

TIME: 10:00 am

LOCATION: via Zoom and/or Other Remote Means

The Law Offices of Jibrael S. Hindi, PLLC

110 S.E. 6

TH Street, 17th Floor

Fort Lauderdale, Florida 33301

This deposition will be video recorded as well as by stenographic means before a notary

public authorized to administer oaths in the State of Florida. The deposition will continue from

day to day until completed. The deposition is being taken for the purposes of discovery, for use at

trial, and such other purposes as are permitted under the Federal Rules of Civil Procedure.

DATED: December 11, 2020

Respectfully Submitted,

 /s/ Thomas Patti .

THOMAS J. PATTI, ESQ.

Florida Bar No.: 118377

E-mail: tom@jibraellaw.com

The Law Offices of Jibrael S. Hindi

110 SE 6th Street, Suite 1744

Fort Lauderdale, Florida 33301

Phone: 954-907-1136

Fax: 855-529-9540

Case 0:20-cv-61297-RKA Document 55-1 Entered on FLSD Docket 12/11/2020 Page 9 of 20
PAGE | 3 of 3

LAW OFFICES OF JIBRAEL S. HINDI, PLLC

110 SE 6th Street, 17th Floor | Ft. Lauderdale, Florida 33301 | Phone (954) 907-1136 | Fax (855) 529-9540

www.JibraelLaw.com

CERTIFICATE OF SERVICE

The undersigned hereby certifies that on December 11, 2020, the foregoing was

electronically served on counsel for Defendant, John Maress, Esq., via e-mail at

jmarees@messerstrickler.com.

 /s/ Thomas Patti .

THOMAS J. PATTI, ESQ.

Florida Bar No.: 118377

Case 0:20-cv-61297-RKA Document 55-1 Entered on FLSD Docket 12/11/2020 Page 10 of 20
PAGE | 1 of 3

LAW OFFICES OF JIBRAEL S. HINDI, PLLC

110 SE 6th Street, 17th Floor | Ft. Lauderdale, Florida 33301 | Phone (954) 907-1136 | Fax (855) 529-9540

www.JibraelLaw.com

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 0:20-cv-61297-RKA

PAMELA TITUS, 

JOSEPH AMODIO, 

WILLIAM VILCINA,

JACQUELINE FONTANEZ,

PAUL JONES,

BYRON HALL, 

and DAMIEN DAY,

Plaintiffs,

v.

RESURGENT CAPITAL SERVICES L.P., 

LVNV FUNDING, LLC, MERRICK BANK 

CORPORATION, PINNACLE CREDIT 

SERVICES, LLC, and PYOD, LLC,

Defendants.

_______________________________________/

NOTICE OF DEPOSITION

Pursuant to Fed.R.Civ.P. 30(b)(6), the above-captioned Plaintiffs will take the deposition

by way of oral examination of the person and/or persons that Merrick Bank Corporation 

(“Defendant”) designates as the person and/or persons most knowledgeable and prepared to testify

on behalf of Defendant on the following topics (the “Deposition Topics”): [1] the facts and

circumstances surrounding each allegation in the Third Consolidated Complaint and Defendant’s

record response and/or answer thereto; [2] the proofs of claim filed in Plaintiffs’ bankruptcy cases;

[3] the documents and information reviewed by Defendant to prepare the proofs of claim filed in

Plaintiffs’ bankruptcy cases; [4] Defendant’s policies and procedures regarding the submission of

proofs of claim; [5] Defendant’s policies and procedures that Defendant maintains to prevent filing

proofs of claim that falsely represent the amount sought therein as not including interest or other

Case 0:20-cv-61297-RKA Document 55-1 Entered on FLSD Docket 12/11/2020 Page 11 of 20
PAGE | 2 of 3

LAW OFFICES OF JIBRAEL S. HINDI, PLLC

110 SE 6th Street, 17th Floor | Ft. Lauderdale, Florida 33301 | Phone (954) 907-1136 | Fax (855) 529-9540

www.JibraelLaw.com

charges; and [6] the information and documentation Defendant relies upon to determine the

principal portion of the debts underlying the proofs of claim filed in Plaintiffs’ bankruptcy cases.

The date, time, and location of the deposition shall be as follows:

DATE: Thursday, January 28, 2021

TIME: 10:00 am

LOCATION: via Zoom and/or Other Remote Means

The Law Offices of Jibrael S. Hindi, PLLC

110 S.E. 6

TH Street, 17th Floor

Fort Lauderdale, Florida 33301

This deposition will be video recorded as well as by stenographic means before a notary

public authorized to administer oaths in the State of Florida. The deposition will continue from

day to day until completed. The deposition is being taken for the purposes of discovery, for use at

trial, and such other purposes as are permitted under the Federal Rules of Civil Procedure.

DATED: December 11, 2020

Respectfully Submitted,

 /s/ Thomas Patti .

THOMAS J. PATTI, ESQ.

Florida Bar No.: 118377

E-mail: tom@jibraellaw.com

The Law Offices of Jibrael S. Hindi

110 SE 6th Street, Suite 1744

Fort Lauderdale, Florida 33301

Phone: 954-907-1136

Fax: 855-529-9540

Case 0:20-cv-61297-RKA Document 55-1 Entered on FLSD Docket 12/11/2020 Page 12 of 20
PAGE | 3 of 3

LAW OFFICES OF JIBRAEL S. HINDI, PLLC

110 SE 6th Street, 17th Floor | Ft. Lauderdale, Florida 33301 | Phone (954) 907-1136 | Fax (855) 529-9540

www.JibraelLaw.com

CERTIFICATE OF SERVICE

The undersigned hereby certifies that on December 11, 2020, the foregoing was

electronically served on counsel for Defendant, John Maress, Esq., via e-mail at

jmarees@messerstrickler.com.

 /s/ Thomas Patti .

THOMAS J. PATTI, ESQ.

Florida Bar No.: 118377

Case 0:20-cv-61297-RKA Document 55-1 Entered on FLSD Docket 12/11/2020 Page 13 of 20
PAGE | 1 of 3

LAW OFFICES OF JIBRAEL S. HINDI, PLLC

110 SE 6th Street, 17th Floor | Ft. Lauderdale, Florida 33301 | Phone (954) 907-1136 | Fax (855) 529-9540

www.JibraelLaw.com

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 0:20-cv-61297-RKA

PAMELA TITUS, 

JOSEPH AMODIO, 

WILLIAM VILCINA,

JACQUELINE FONTANEZ,

PAUL JONES,

BYRON HALL, 

and DAMIEN DAY,

Plaintiffs,

v.

RESURGENT CAPITAL SERVICES L.P., 

LVNV FUNDING, LLC, MERRICK BANK 

CORPORATION, PINNACLE CREDIT 

SERVICES, LLC, and PYOD, LLC,

Defendants.

_______________________________________/

NOTICE OF DEPOSITION

Pursuant to Fed.R.Civ.P. 30(b)(6), the above-captioned Plaintiffs will take the deposition

by way of oral examination of the person and/or persons that LVNV Funding, LLC (“Defendant”)

designates as the person and/or persons most knowledgeable and prepared to testify on behalf of

Defendant on the following topics (the “Deposition Topics”): [1] the facts and circumstances

surrounding each allegation in the Third Consolidated Complaint and Defendant’s record response

and/or answer thereto; [2] Defendant’s consumer collection agency license and/or registration with

the Florida Department of State; [3] the documents and information Defendant maintains in

accordance with Rule 69V-180.080, Florida Administrative Code; [4] the proofs of claim filed in

Plaintiffs’ bankruptcy cases; [5] the documents and information reviewed by Defendant to prepare

the proofs of claim filed in Plaintiffs’ bankruptcy cases; [6] Defendant’s policies and procedures

Case 0:20-cv-61297-RKA Document 55-1 Entered on FLSD Docket 12/11/2020 Page 14 of 20
PAGE | 2 of 3

LAW OFFICES OF JIBRAEL S. HINDI, PLLC

110 SE 6th Street, 17th Floor | Ft. Lauderdale, Florida 33301 | Phone (954) 907-1136 | Fax (855) 529-9540

www.JibraelLaw.com

regarding the submission of proofs of claim; [7] Defendant’s policies and procedures that

Defendant maintains to prevent filing proofs of claim that falsely represent the amount sought

therein as not including interest or other charges; and [8] the information and documentation

Defendant relies upon to determine the principal portion of the debts underlying the proofs of claim

filed in Plaintiffs’ bankruptcy cases.

The date, time, and location of the deposition shall be as follows:

DATE: Friday, January 29, 2021

TIME: 2:00 pm

LOCATION: via Zoom and/or Other Remote Means

The Law Offices of Jibrael S. Hindi, PLLC

110 S.E. 6

TH Street, 17th Floor

Fort Lauderdale, Florida 33301

This deposition will be video recorded as well as by stenographic means before a notary

public authorized to administer oaths in the State of Florida. The deposition will continue from

day to day until completed. The deposition is being taken for the purposes of discovery, for use at

trial, and such other purposes as are permitted under the Federal Rules of Civil Procedure.

DATED: December 11, 2020

Respectfully Submitted,

 /s/ Thomas Patti .

THOMAS J. PATTI, ESQ.

Florida Bar No.: 118377

E-mail: tom@jibraellaw.com

The Law Offices of Jibrael S. Hindi

110 SE 6th Street, Suite 1744

Fort Lauderdale, Florida 33301

Phone: 954-907-1136

Fax: 855-529-9540

Case 0:20-cv-61297-RKA Document 55-1 Entered on FLSD Docket 12/11/2020 Page 15 of 20
PAGE | 3 of 3

LAW OFFICES OF JIBRAEL S. HINDI, PLLC

110 SE 6th Street, 17th Floor | Ft. Lauderdale, Florida 33301 | Phone (954) 907-1136 | Fax (855) 529-9540

www.JibraelLaw.com

CERTIFICATE OF SERVICE

The undersigned hereby certifies that on December 11, 2020, the foregoing was

electronically served on counsel for Defendant, John Maress, Esq., via e-mail at

jmarees@messerstrickler.com.

 /s/ Thomas Patti .

THOMAS J. PATTI, ESQ.

Florida Bar No.: 118377

Case 0:20-cv-61297-RKA Document 55-1 Entered on FLSD Docket 12/11/2020 Page 16 of 20
PAGE | 1 of 2

LAW OFFICES OF JIBRAEL S. HINDI, PLLC

110 SE 6th Street, 17th Floor | Ft. Lauderdale, Florida 33301 | Phone (954) 907-1136 | Fax (855) 529-9540 

www.JibraelLaw.com

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 0:20-cv-61297-RKA

PAMELA TITUS, 

JOSEPH AMODIO, 

WILLIAM VILCINA,

JACQUELINE FONTANEZ,

PAUL JONES,

BYRON HALL, 

and DAMIEN DAY,

Plaintiffs,

v.

RESURGENT CAPITAL SERVICES L.P., 

LVNV FUNDING, LLC, MERRICK BANK 

CORPORATION, PINNACLE CREDIT 

SERVICES, LLC, and PYOD, LLC,

Defendants.

_______________________________________/

NOTICE OF DEPOSITION

The above-captioned Plaintiffs will take the deposition by way of oral examination of

William Andrews, of whom signed under penalty of perjury proofs of claim involving Plaintiffs 

Vilcina, Titus, Hall, and Amodio. The date, time, and location of said deposition is as follows: 

DATE: Wednesday, January 27, 2021

TIME: 10:00 AM

LOCATION: VIA ELECTRONIC or OTHER REMOTE MEANS

The Law Offices of Jibrael S. Hindi, PLLC

110 S.E. 6th Street, Suite 1700

Fort Lauderdale, Florida 33301

This deposition will be video recorded as well as by stenographic means before a notary 

public authorized to administer oaths in the State of Florida. The deposition will continue from 

Case 0:20-cv-61297-RKA Document 55-1 Entered on FLSD Docket 12/11/2020 Page 17 of 20
PAGE | 2 of 2

LAW OFFICES OF JIBRAEL S. HINDI, PLLC

110 SE 6th Street, 17th Floor | Ft. Lauderdale, Florida 33301 | Phone (954) 907-1136 | Fax (855) 529-9540 

www.JibraelLaw.com

day to day until completed. The deposition is being taken for the purposes of discovery, for use at 

trial, and such other purposes as are permitted under the Federal Rules of Civil Procedure.

DATED: December 11, 2020

Respectfully Submitted,

 /s/ Thomas Patti .

JIBRAEL S. HINDI, ESQ.

Florida Bar No.: 118259

E-mail: jibrael@jibraellaw.com

THOMAS J. PATTI, ESQ.

Florida Bar No.: 118377

E-mail: tom@jibraellaw.com

The Law Offices of Jibrael S. Hindi

110 SE 6th Street, Suite 1744

Fort Lauderdale, Florida 33301

Phone: 954-907-1136

Fax: 855-529-9540

COUNSEL FOR PLAINTIFF

CERTIFICATE OF SERVICE

The undersigned certifies that, on December 11, 2020, the forgoing was electronically 

served on counsel for Defendants John Michael Marees, Esq. at jmarees@messerstrickler.com.

 /s/ Thomas Patti .

THOMAS J. PATTI, ESQ.

Florida Bar No.: 118377

Case 0:20-cv-61297-RKA Document 55-1 Entered on FLSD Docket 12/11/2020 Page 18 of 20
PAGE | 1 of 2

LAW OFFICES OF JIBRAEL S. HINDI, PLLC

110 SE 6th Street, 17th Floor | Ft. Lauderdale, Florida 33301 | Phone (954) 907-1136 | Fax (855) 529-9540 

www.JibraelLaw.com

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 0:20-cv-61297-RKA

PAMELA TITUS, 

JOSEPH AMODIO, 

WILLIAM VILCINA,

JACQUELINE FONTANEZ,

PAUL JONES,

BYRON HALL, 

and DAMIEN DAY,

Plaintiffs,

v.

RESURGENT CAPITAL SERVICES L.P., 

LVNV FUNDING, LLC, MERRICK BANK 

CORPORATION, PINNACLE CREDIT 

SERVICES, LLC, and PYOD, LLC,

Defendants.

_______________________________________/

NOTICE OF DEPOSITION

The above-captioned Plaintiffs will take the deposition by way of oral examination of

Suzanna Dickson, of whom signed under penalty of perjury a proof of claim involving Plaintiff 

Hall. The date, time, and location of said deposition is as follows:

DATE: Wednesday, January 27, 2021

TIME: 1:00 PM

LOCATION: VIA ELECTRONIC or OTHER REMOTE MEANS

The Law Offices of Jibrael S. Hindi, PLLC

110 S.E. 6th Street, Suite 1700

Fort Lauderdale, Florida 33301

This deposition will be video recorded as well as by stenographic means before a notary 

public authorized to administer oaths in the State of Florida. The deposition will continue from 

Case 0:20-cv-61297-RKA Document 55-1 Entered on FLSD Docket 12/11/2020 Page 19 of 20
PAGE | 2 of 2

LAW OFFICES OF JIBRAEL S. HINDI, PLLC

110 SE 6th Street, 17th Floor | Ft. Lauderdale, Florida 33301 | Phone (954) 907-1136 | Fax (855) 529-9540 

www.JibraelLaw.com

day to day until completed. The deposition is being taken for the purposes of discovery, for use at 

trial, and such other purposes as are permitted under the Federal Rules of Civil Procedure.

DATED: December 11, 2020

Respectfully Submitted,

 /s/ Thomas Patti .

JIBRAEL S. HINDI, ESQ.

Florida Bar No.: 118259

E-mail: jibrael@jibraellaw.com

THOMAS J. PATTI, ESQ.

Florida Bar No.: 118377

E-mail: tom@jibraellaw.com

The Law Offices of Jibrael S. Hindi

110 SE 6th Street, Suite 1744

Fort Lauderdale, Florida 33301

Phone: 954-907-1136

Fax: 855-529-9540

COUNSEL FOR PLAINTIFF

CERTIFICATE OF SERVICE

The undersigned certifies that, on December 11, 2020, the forgoing was electronically 

served on counsel for Defendants John Michael Marees, Esq. at jmarees@messerstrickler.com.

 /s/ Thomas Patti .

THOMAS J. PATTI, ESQ.

Florida Bar No.: 118377

Case 0:20-cv-61297-RKA Document 55-1 Entered on FLSD Docket 12/11/2020 Page 20 of 20