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 PYOD, 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 67-3 Entered on FLSD Docket 02/26/2021 Page 1 of 12
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, February 19, 2021

TIME: 1:00 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: January 28, 2021

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 67-3 Entered on FLSD Docket 02/26/2021 Page 2 of 12
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 January 28, 2021, 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 67-3 Entered on FLSD Docket 02/26/2021 Page 3 of 12
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 67-3 Entered on FLSD Docket 02/26/2021 Page 4 of 12
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, February 19, 2021

TIME: 1:00 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: January 28, 2021

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

CERTIFICATE OF SERVICE

Case 0:20-cv-61297-RKA Document 67-3 Entered on FLSD Docket 02/26/2021 Page 5 of 12
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

The undersigned hereby certifies that on January 28, 2021, 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 67-3 Entered on FLSD Docket 02/26/2021 Page 6 of 12
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 67-3 Entered on FLSD Docket 02/26/2021 Page 7 of 12
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, February 19, 2021

TIME: 1:00 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: January 28, 2021

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

CERTIFICATE OF SERVICE

Case 0:20-cv-61297-RKA Document 67-3 Entered on FLSD Docket 02/26/2021 Page 8 of 12
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

The undersigned hereby certifies that on January 28, 2021, 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 67-3 Entered on FLSD Docket 02/26/2021 Page 9 of 12
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 Pinnacle Credit Services, 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

Case 0:20-cv-61297-RKA Document 67-3 Entered on FLSD Docket 02/26/2021 Page 10 of 12
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, February 19, 2021

TIME: 1:00 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: January 28, 2021

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

CERTIFICATE OF SERVICE

Case 0:20-cv-61297-RKA Document 67-3 Entered on FLSD Docket 02/26/2021 Page 11 of 12
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

The undersigned hereby certifies that on January 28, 2021, 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 67-3 Entered on FLSD Docket 02/26/2021 Page 12 of 12