Boyd Johnson
634 NW 44th Terrace
Deerfield Beach, FL 33442
10th June 2022
To:
Ms. Jennifer Monrose Moore, Esq. Florida Bar Number 35602
Ogletree, Deakins, Nash, Smoak & Stewart P.C.
100 North Tampa Street,
Tampa, FL 33602
Telephone: 813.289.1247
Facsimile: 813.289.6530
Dear Madam,
RE: MEET AND CONFER
Rule 26 of the Federal Rules of Civil Procedure requires parties to meet and confer before initiating discovery through motion. In good faith and in order to reduce the cost of litigating any such motion, I request you to meet with me so you can provide me with the following documents and/or materials: names, addresses, phone numbers and emails of all persons whom Defendants intends to rely upon as witnesses; all documents that support the asserted affirmative defenses; all documents and/or materials that could satisfy all or part of a possible judgment; and CCTV footage on 23rd April 2020. Please respond with the appropriate date and time you will be able to meet.
Yours Sincerely,
___________________________________
Boyd Johnson