135 San Lorenzo Avenue, Suite 770, Coral Gables, FL 33146

TEL 305.230.4884 FAX 305.230.4844

www.fairlawattorney.com

1

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 1:22-CV-20748-LENARD/LOUIS

SERGIO PEREZ,

Plaintiff,

vs.

CITY OF OPA-LOCKA AND 

STEVEN BARREIRA,

Defendants.

______________________________/

PLAINTIFF’S NOTICE OF TAKING IN PERSON DEPOSITION

(DUCES TECUM)

TO: ALL COUNSEL LISTED BELOW

PLEASE TAKE NOTICE that, pursuant to Fed. R. Civ. P. 30, 45, and other applicable 

rules and laws, the undersigned attorney will take the deposition of:

NAME: Michael Steel

DATE AND TIME: February 16, 2023 at 10:00 a.m. 

PLACE: FairLaw Firm

135 San Lorenzo Avenue, Suite 770

Coral Gables, Fl 33146

Upon oral examination before Universal Court Reporting, a Notary Public, or any other 

notary public or officer authorized by law to take depositions in the State of Florida. This 

deposition is being taken for the purpose of discovery, for use at trial, or for such other purposes as 

are permitted under the Rules of Court. The deposition will continue from hour to hour and from 

Case 1:22-cv-23074-BB Document 71-2 Entered on FLSD Docket 02/08/2023 Page 1 of 3
135 San Lorenzo Avenue, Suite 770, Coral Gables, FL 33146

TEL 305.230.4884 FAX 305.230.4844

www.fairlawattorney.com

2

day to day until completed, not to exceed eight (8) hours. You must have with you the items 

identified on Exhibit “A” for inspection and/or copying.

PLEASE GOVERN YOURSELF ACCORDINGLY.

CERTIFICATE OF SERVICE

WE HEREBY CERTIFY that a true and correct copy of the foregoing was served by email 

on this 13th day of January 2023 on Jonathan H. Railey, Esq., railey@jamg, Christopher J. Stearns, 

Esq., stearns@jambg.com, Johnson, Anselmo, Murdoch, Burke, Piper & Hochman, P.A., 2455 

E. Sunrise Blvd., Suite 1000, Fort Lauderdale, FL 33304 as Counsel for Defendant.

s/Brian H. Pollock, Esq.

Brian H. Pollock, Esq. (174742)

brian@fairlawattorney.com

FAIRLAW FIRM

135 San Lorenzo Avenue

Suite 770

Coral Gables, FL 33146

Tel: 305.230.4884

Counsel for Plaintiff

Case 1:22-cv-23074-BB Document 71-2 Entered on FLSD Docket 02/08/2023 Page 2 of 3
135 San Lorenzo Avenue, Suite 770, Coral Gables, FL 33146

TEL 305.230.4884 FAX 305.230.4844

www.fairlawattorney.com

3

EXHIBIT “A”

1. Your cellular phone that contains all pictures/images depicting the area of 

your back which you showed to Steven Barreira in early September 2021.

2. The digital image of your back that you showed to Steven Barreira in early 

September 2021.

3. All digital images of your back that depict the area where you contend you 

were struck by a taser and/or taser training cartridge in early September 

2021.

4. All digital information identifying the date on which each digital images of 

your back that depict(s) the area where you contend you were struck by a 

taser and/or taser training cartridge was taken.

5. All digital information identifying all adjustments and/or modifications to 

the date on which each digital images of your back that depict(s) the area 

where you contend you were struck by a taser and/or taser training cartridge 

was taken.

6. All text messages between you and Steven Barreira between September 1, 

2021 and the date of your deposition.

7. All emails exchanged between you and Steven Barreira between September 

1, 2021 and the date of your deposition.

8. All WhatsApp messages exchanged between you and Steven Barreira between 

September 1, 2021 and the date of your deposition.

Case 1:22-cv-23074-BB Document 71-2 Entered on FLSD Docket 02/08/2023 Page 3 of 3