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Filing # 117660552 E-Filed 12/04/2020 11:26:12 AM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA.
JESUS VILLEDA and JHANETH VILLEDA,
Plaintiffs,
v. CASE NUMBER: CACE-19-021344
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant. /
DEFENDANT’S MOTION FOR AN ORDER TO SHOW CAUSE FOR PLAINTIFF’S
FAILURE TO PROVIDE DISCOVERY RESPONSES, MOTION FOR SANCTIONS
AND MOTION TO COMPEL DISCOVERY RESPONSES
COMES NOW Defendant Citizens Property Insurance Corporation, hereinafter
“Citizens” or “Defendant”, by and through its undersigned counsel, pursuant to the Florida Rules
of Civil Procedure, and motions this Court for an Order to Show Cause as to why Plaintiffs failed
to comply with the Agreed Order dated October 11, 2020 and, in support thereof, states:
1. This is an action for an alleged breach of an insurance contract was filed by Plaintiffs
on or about October 15, 2019.
2. Defendant served its Request for Production and Interrogatories on Plaintiffs on April
21, 2020.
3. Plaintiff did not file a Motion for Extension of Time to respond to discovery requests
after service of Defendant’s discovery requests.
4. Defendant made several requests to Plaintiff to obtain responses and agreed to
extension(s) before filing its Motion to Compel on or about September 2, 2020.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/04/2020 11:26:10 AM.****10.
ll.
. The matter was set for hearing on October 12, 2020. Prior to the hearing, the parties
agreed to enter into an Agreed Order which was submitted to the Court and executed
October 11, 2020.
The Agreed Order allowed Plaintiffs to respond to Defendant’s discovery requests by
October 14, 2020.
Plaintiffs did not provide their discovery responses pursuant to the Agreed Order dated
October 14, 2020.
. Defendant emailed Plaintiff Counsel to follow-up on the overdue discovery responses
and received a request from Plaintiffs’ Counsel on October 22, 2020 for an additional
twenty (20) days to provide their discovery responses. See Exhibit A — Plaintiffs’
October 22, 2020 email.
After several emails between the parties, Plaintiff agreed to provide their discovery
responses by November 2, 2020. See Exhibit B — Plaintiffs’ email dated October 27,
2020.
. On November 2, 2020, Defendant received an email from Plaintiffs’ Counsel citing
technical issues with their computer systems and asking for another extension until
November 9, 2020. See Exhibit C — Plaintiffs’ email dated November 2, 2020
Defendant did not receive responses to its discovery requests on November 9, 2020.
. Defendant has made every effort to cooperate with Plaintiff's Counsel and show
consideration for the various issues cited by Plaintiffs since April, 2020 when the
discovery requests were served.13. Plaintiff's lack of response to written discovery requests has prejudiced Defendant by
not allowing it to obtain information needed to defend its position while continuing to
schedule depositions of the witnesses to this matter.
WHEREFORE, Defendant, Citizens Property Insurance Corporation, respectfully
requests this Court grant the Defendant’s Motion for an Order to Show Cause why Plaintiffs’ failed
to comply with the Court’s Agreed Order dated October 14, 2020, to Order Plaintiffs to respond
to Defendant’s written discovery requests promptly, for sanctions for violating the Court’s Order
and for the extensive delay in responding to Defendant’s discovery requests, and any and all other
relief the Court deems appropriate.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been provided
via electronic correspondence to: Annette Del Aguila, Esq. at eservice@mellawyers.com and
mellaw7@mellawyers.com, on this 4™ day of December, 2020.
RUBINTON SIMMS, P.A.
3440 Hollywood Blvd, Suite 460
Hollywood, Florida 33021
Telephone: 954-251-5500
Fax: 954-251-5501
By: /s/Vida Gasactio _
JEFFREY A. RUBINTON, ESQ.
Florida Bar: 821756
VIDA E. JASAITIS, ESQ.
Florida Bar: 245800
Primary E-Mail: vjasaitis@rubintonlaw.com
Secondary E-Mail: vprzewoznik@rubintonlaw.comRE: 2207-034 Jesus Villeda v. Citizens Property Ins. Corp (Kitchen Sink SP) 001-00-211715 Case No.
CACE-19-021344: SECOND FOLLOW UP. : 2207-034 Jesus Villeda v. Citizens Property Ins. Corp No.
CACE-19-021344:
Emily Matos EXHIBIT "A"
Thu 10/22/2020 2:13 PM
To: Veronica Przewoznik ; Vida
Ce: Tulia Sanchez
Good afternoon,
| apologize for the delay our discovery department is a little backed up, would your office agree to provide an extension of 20
days ?
Best Regards,
Emily Matos
Legal Assistant
Marin, Eljaiek, Lopez, & Martinez P.L.
2601 South Bayshore Drive 18" Floor
Coconut Grove, FL 33183
Direct Line: 805-424-2749
Fax: 805-424-2732
Website: www.MELlawyers.com
E-mail: ematos@mellawyers.com
Ca MARIN | ELJAIEK | LOPEZ | MARTINEZ
no 5 *
**SCHEDULING NOTE**
The dates provided may have been offered to other counsels and will only be secured on a first come-first serve basis.
PLEASE BE ADVISED THE DATES PROPOSED ARE NOT CONFIRMED UNTIL YOU RECEIVE A FINAL RESPONSE FROM OUR
OFFICE CONFIRMING SAME. PLEASE NOTE DATES WILL BE RELEASED IF NOTICE IS NOT RECEIVED WITHIN 5 DAYS. ALL DATES
AND TIMES PROVIDED ARE IN EASTERN STANDARD TIME.
NOTICE: The information in this e-mail, including any attachments, is confidential, is intended only for the named recipient(s) to whom
the email is addressed and may contain information that is attorney-client privileged, attomey work product, proprietary and/or exempt
from disclosure under applicable law. If you are not an intended recipient, you are hereby notified that any use, dissemination, distribution
or reproduction of this email, including any attachments, is strictly prohibited. Anyone who receives this message in error should notify
the sender immediately by telephone or by retum e-mail and delete the entire email, including any attachments, from their computer. Any
opinions or advice contained in this email shall be subject to the terms and conditions set forth in the governing Marin, Eljaiek & Lopez,
PL. client engagement agreement. Thank you.
IRS Circular 230 Disclosure: Please note that the views expressed herein or in any attachments hereto are not intended to constitute a
“reliance opinion” under applicable Treasury Regulations, and accordingly are not intended or written to be used, and may not be used or
relied upon, for the purpose of (i) avoiding tax-related penalties that may be imposed by the Internal Revenue Service, or (ii) promoting,
marketing or recommending to another party any tax-related matters addressed herein.
From: Veronica Przewoznik
Sent: Thursday, October 15, 2020 4:04 PM
To: Emily Matos ; Vida
Cc: Tulia Sanchez Subject: RE: 2207-034 Jesus Villeda v. Citizens Property Ins. Corp (Kitchen Sink SP) 001-00-211715 Case No. CACE-19-021344:
SECOND FOLLOW UP. : 2207-034 Jesus Villeda v. Citizens Property Ins. Corp No. CACE-19-021344:
Good afternoon Emily:
| am following up with your Discovery Responses. According with the order entered on 10.11.20, the deadline is overdue.
Please advise at your earliest convenience.
Regards,
Veronica Przewoznik
Legal Assistant to Jesus R. Goatache and Vida Jasaitis
Rubinton Simms, P.A.
3440 Hollywood Blvd., Suite 460
Hollywood, FL 33021
OFFICE 954-251-5500
FAX 954-251-5501
www.RubintonLaw.com
RUBINTON SIMMS, PA
ATTORNEYS AT LAW
From: Emily Matos
Sent: Friday, October 9, 2020 5:16 PM
To: Veronica Przewoznik ; Vida
Cc: Tulia Sanchez
Subject: RE: 2207-034 Jesus Villeda v. Citizens Property Ins. Corp (Kitchen Sink SP) 001-00-211715 Case No. CACE-19-021344:
SECOND FOLLOW UP. : 2207-034 Jesus Villeda v. Citizens Property Ins. Corp No. CACE-19-021344:
From: Veronica Przewoznik
Sei riday, October 9, 2020 5:14 PM
To: Vida ; Emily Matos
Cc: Tulia Sanchez
Subject: RE: 2207-034 Jesus Villeda v. Citizens Property Ins. Corp (Kitchen Sink SP) 001-00-211715 Case No. CACE-19-
021344: SECOND FOLLOW UP. : 2207-034 Jesus Villeda v. Citizens Property Ins. Corp No. CACE-19-021344:
Please Emily submit it right away, and once done | will go ahead and cancel the hearing.
Thank you!
Regards,
Veronica Przewoznik
Legal Assistant to Jesus R. Goatache and Vida Jasaitis
Rubinton Simms, P.A.
3440 Hollywood Blvd., Suite 460
Hollywood, FL 33021
OFFICE 954-251-5500RE: 2207-034 Jesus Villeda v. Citizens Property Ins. Corp (Kitchen Sink SP) 001-00-211715 Case No.
CACE-19-021344: SECOND FOLLOW UP. : 2207-034 Jesus Villeda v. Citizens Property Ins. Corp No.
CACE-19-021344:
Emily Matos EXHIBIT
Tue 10/27/2020 2:33 PM
To: Vida ; Veronica Przewoznik
Ce: Tulia Sanchez
@ 2 attachments (159 KB)
Notice Of Taking Deposition.pdf; Notice Of Taking Deposition.pdf;
Good afternoon,
We will agree to provide the discovery response by Monday 11/2/2020, thank you for the extension.
The plaintiffs deposition has already been scheduled, please see attached.
Please see dates below our office is available for the PA deposition, your office will need to subpoena them.
3/29/2021
4/5/2021
4/6/2021
Best Regards,
Emily Matos
Legal Assistant
Marin, Eljaick, Lopez, & Martinez P.L.
2601 South Bayshore Drive 18" Floor
Coconut Grove, FL 33183
Direct Line: 305-424-2749
Fax: 805-424-2732
Website: www.MELawyers.com
E-mail: ematos@mellaw
a MARIN | ELJAIEK | LOPEZ | MARTINEZ
n 3
**SCHEDULING NOTE**
The dates provided may have been offered to other counsels and will only be secured on a first come-first serve basis.
PLEASE BE ADVISED THE DATES PROPOSED ARE NOT CONFIRMED UNTIL YOU RECEIVE A FINAL RESPONSE FROM OUR
OFFICE CONFIRMING SAME. PLEASE NOTE DATES WILL BE RELEASED IF NOTICE IS NOT RECEIVED WITHIN 5 DAYS. ALL DATES
AND TIMES PROVIDED ARE IN EASTERN STANDARD TIME.
NOTICE: The information in this e-mail, including any attachments, is confidential, is intended only for the named recipient(s) to whom.
the email is addressed and may contain information that is attorney-client privileged, attorney work product, proprietary and/or exempt
from disclosure under applicable law. If you are not an intended recipient, you are hereby notified that any use, dissemination, distribution
or reproduction of this email, including any attachments, is strictly prohibited. Anyone who receives this message in error should notify
the sender immediately by telephone or by retum e-mail and delete the entire email, inoluding any attachments, from their computer. Any
opinions or advice contained in this email shall be subject to the terms and conditions set forth in the governing Marin, Eljaick & Lopez,
PLL. client engagement agreement. Thank you.
IRS Circular 230 Disclosure: Please note that the views expressed herein or in any attachments hereto are not intended to constitute a
“reliance opinion" under applicable Treasury Regulations, and accordingly are not intended or written to be used, and may not be used or
relied upon, for the purpose of (i) avoiding tax-related penalties that may be imposed by the Internal Revenue Service, or (i) promoting,
marketing or recommending to another party any tax-related matters addressed hereinRE: 2207-034 Jesus Villeda v. Citizens Property Ins. Corp (Kitchen Sink SP) 001-00-211715 Case No.
CACE-19-021344: SECOND FOLLOW UP. : 2207-034 Jesus Villeda v. Citizens Property Ins. Corp No.
CACE-19-021344:
Emily Matos EXHIBIT "C"
Mon 11/2/2020 4:29 PM
To: Veronica Przewoznik ; Vida
Good afternoon,
Please provide new dates your office and the CR are available.
Additionally, Our MSP provider has had an IT Issue which has prevented us from temporarily having access to our files.
At the moment we are restoring our system data and should have access to our files by the end of the week.
With that being said, would your office be in agreement with us filling the response by Monday 11/9/2020 ?
Best Regards,
Emily Matos
Legal Assistant
Marin, Eljaick, Lopez, & Martinez P.L.
2601 South Bayshore Drive 18" Floor
Coconut Grove, FL 33183
Direct Line: 805-424-2749
Fax: 805-424-2732
Website: www.MELlawyers.com
E-mail: ematos@mellawyers.com
We" MARIN | ELJAIEK| LOPEZ | MARTINEZ
At 5 a Ae
*e oe
The dates provided may have been offered to other counsels and will only be secured on a first come-first serve basis.
PLEASE BE ADVISED THE DATES PROPOSED ARE NOT CONFIRMED UNTIL YOU RECEIVE A FINAL RESPONSE FROM OUR
OFFICE CONFIRMING SAME. PLEASE NOTE DATES WILL BE RELEASED IF NOTICE IS NOT RECEIVED WITHIN 5 DAYS. ALL DATES
AND TIMES PROVIDED ARE IN EASTERN STANDARD TIME.
NOTICE: The information in this e-mail, including any attachments, is confidential, is intended only for the named recipient(s) to whom
the email is addressed and may contain information that is attorney-client privileged, attorney work product, proprietary and/or exempt
from disclosure under applicable law. If you are not an intended recipient, you are hereby notified that any use, dissemination, distribution
or reproduction of this email, including any attachments, is strictly prohibited. Anyone who receives this message in error should notify
the sender immediately by telephone or by return e-mail and delete the entire email, including any attachments, from their computer. Any
opinions or advice contained in this email shall be subject to the terms and conditions set forth in the governing Marin, Eljaick & Lopez,
PLL. client engagement agreement. Thank you.
IRS Circular 230 Disclosure: Please note that the views expressed herein or in any attachments hereto are not intended to constitute a
“reliance opinion" under applicable Treasury Regulations, and accordingly are not intended or written to be used, and may not be used or
relied upon, for the purpose of (i) avoiding tax-related penalties that may be imposed by the Internal Revenue Service, or (i) promoting,
marketing or recommending to another party any tax-related matters addressed herein.
Preview
Filing # 117660552 E-Filed 12/04/2020 11:26:12 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA. JESUS VILLEDA and JHANETH VILLEDA, Plaintiffs, v. CASE NUMBER: CACE-19-021344 CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. / DEFENDANT’S MOTION FOR AN ORDER TO SHOW CAUSE FOR PLAINTIFF’S FAILURE TO PROVIDE DISCOVERY RESPONSES, MOTION FOR SANCTIONS AND MOTION TO COMPEL DISCOVERY RESPONSES COMES NOW Defendant Citizens Property Insurance Corporation, hereinafter “Citizens” or “Defendant”, by and through its undersigned counsel, pursuant to the Florida Rules of Civil Procedure, and motions this Court for an Order to Show Cause as to why Plaintiffs failed to comply with the Agreed Order dated October 11, 2020 and, in support thereof, states: 1. This is an action for an alleged breach of an insurance contract was filed by Plaintiffs on or about October 15, 2019. 2. Defendant served its Request for Production and Interrogatories on Plaintiffs on April 21, 2020. 3. Plaintiff did not file a Motion for Extension of Time to respond to discovery requests after service of Defendant’s discovery requests. 4. Defendant made several requests to Plaintiff to obtain responses and agreed to extension(s) before filing its Motion to Compel on or about September 2, 2020. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/04/2020 11:26:10 AM.****10. ll. . The matter was set for hearing on October 12, 2020. Prior to the hearing, the parties agreed to enter into an Agreed Order which was submitted to the Court and executed October 11, 2020. The Agreed Order allowed Plaintiffs to respond to Defendant’s discovery requests by October 14, 2020. Plaintiffs did not provide their discovery responses pursuant to the Agreed Order dated October 14, 2020. . Defendant emailed Plaintiff Counsel to follow-up on the overdue discovery responses and received a request from Plaintiffs’ Counsel on October 22, 2020 for an additional twenty (20) days to provide their discovery responses. See Exhibit A — Plaintiffs’ October 22, 2020 email. After several emails between the parties, Plaintiff agreed to provide their discovery responses by November 2, 2020. See Exhibit B — Plaintiffs’ email dated October 27, 2020. . On November 2, 2020, Defendant received an email from Plaintiffs’ Counsel citing technical issues with their computer systems and asking for another extension until November 9, 2020. See Exhibit C — Plaintiffs’ email dated November 2, 2020 Defendant did not receive responses to its discovery requests on November 9, 2020. . Defendant has made every effort to cooperate with Plaintiff's Counsel and show consideration for the various issues cited by Plaintiffs since April, 2020 when the discovery requests were served.13. Plaintiff's lack of response to written discovery requests has prejudiced Defendant by not allowing it to obtain information needed to defend its position while continuing to schedule depositions of the witnesses to this matter. WHEREFORE, Defendant, Citizens Property Insurance Corporation, respectfully requests this Court grant the Defendant’s Motion for an Order to Show Cause why Plaintiffs’ failed to comply with the Court’s Agreed Order dated October 14, 2020, to Order Plaintiffs to respond to Defendant’s written discovery requests promptly, for sanctions for violating the Court’s Order and for the extensive delay in responding to Defendant’s discovery requests, and any and all other relief the Court deems appropriate. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been provided via electronic correspondence to: Annette Del Aguila, Esq. at eservice@mellawyers.com and mellaw7@mellawyers.com, on this 4™ day of December, 2020. RUBINTON SIMMS, P.A. 3440 Hollywood Blvd, Suite 460 Hollywood, Florida 33021 Telephone: 954-251-5500 Fax: 954-251-5501 By: /s/Vida Gasactio _ JEFFREY A. RUBINTON, ESQ. Florida Bar: 821756 VIDA E. JASAITIS, ESQ. Florida Bar: 245800 Primary E-Mail: vjasaitis@rubintonlaw.com Secondary E-Mail: vprzewoznik@rubintonlaw.comRE: 2207-034 Jesus Villeda v. Citizens Property Ins. Corp (Kitchen Sink SP) 001-00-211715 Case No. CACE-19-021344: SECOND FOLLOW UP. : 2207-034 Jesus Villeda v. Citizens Property Ins. Corp No. CACE-19-021344: Emily Matos EXHIBIT "A" Thu 10/22/2020 2:13 PM To: Veronica Przewoznik ; Vida Ce: Tulia Sanchez Good afternoon, | apologize for the delay our discovery department is a little backed up, would your office agree to provide an extension of 20 days ? Best Regards, Emily Matos Legal Assistant Marin, Eljaiek, Lopez, & Martinez P.L. 2601 South Bayshore Drive 18" Floor Coconut Grove, FL 33183 Direct Line: 805-424-2749 Fax: 805-424-2732 Website: www.MELlawyers.com E-mail: ematos@mellawyers.com Ca MARIN | ELJAIEK | LOPEZ | MARTINEZ no 5 * **SCHEDULING NOTE** The dates provided may have been offered to other counsels and will only be secured on a first come-first serve basis. PLEASE BE ADVISED THE DATES PROPOSED ARE NOT CONFIRMED UNTIL YOU RECEIVE A FINAL RESPONSE FROM OUR OFFICE CONFIRMING SAME. PLEASE NOTE DATES WILL BE RELEASED IF NOTICE IS NOT RECEIVED WITHIN 5 DAYS. ALL DATES AND TIMES PROVIDED ARE IN EASTERN STANDARD TIME. NOTICE: The information in this e-mail, including any attachments, is confidential, is intended only for the named recipient(s) to whom the email is addressed and may contain information that is attorney-client privileged, attomey work product, proprietary and/or exempt from disclosure under applicable law. If you are not an intended recipient, you are hereby notified that any use, dissemination, distribution or reproduction of this email, including any attachments, is strictly prohibited. Anyone who receives this message in error should notify the sender immediately by telephone or by retum e-mail and delete the entire email, including any attachments, from their computer. Any opinions or advice contained in this email shall be subject to the terms and conditions set forth in the governing Marin, Eljaiek & Lopez, PL. client engagement agreement. Thank you. IRS Circular 230 Disclosure: Please note that the views expressed herein or in any attachments hereto are not intended to constitute a “reliance opinion” under applicable Treasury Regulations, and accordingly are not intended or written to be used, and may not be used or relied upon, for the purpose of (i) avoiding tax-related penalties that may be imposed by the Internal Revenue Service, or (ii) promoting, marketing or recommending to another party any tax-related matters addressed herein. From: Veronica Przewoznik Sent: Thursday, October 15, 2020 4:04 PM To: Emily Matos ; Vida Cc: Tulia Sanchez Subject: RE: 2207-034 Jesus Villeda v. Citizens Property Ins. Corp (Kitchen Sink SP) 001-00-211715 Case No. CACE-19-021344: SECOND FOLLOW UP. : 2207-034 Jesus Villeda v. Citizens Property Ins. Corp No. CACE-19-021344: Good afternoon Emily: | am following up with your Discovery Responses. According with the order entered on 10.11.20, the deadline is overdue. Please advise at your earliest convenience. Regards, Veronica Przewoznik Legal Assistant to Jesus R. Goatache and Vida Jasaitis Rubinton Simms, P.A. 3440 Hollywood Blvd., Suite 460 Hollywood, FL 33021 OFFICE 954-251-5500 FAX 954-251-5501 www.RubintonLaw.com RUBINTON SIMMS, PA ATTORNEYS AT LAW From: Emily Matos Sent: Friday, October 9, 2020 5:16 PM To: Veronica Przewoznik ; Vida Cc: Tulia Sanchez Subject: RE: 2207-034 Jesus Villeda v. Citizens Property Ins. Corp (Kitchen Sink SP) 001-00-211715 Case No. CACE-19-021344: SECOND FOLLOW UP. : 2207-034 Jesus Villeda v. Citizens Property Ins. Corp No. CACE-19-021344: From: Veronica Przewoznik Sei riday, October 9, 2020 5:14 PM To: Vida ; Emily Matos Cc: Tulia Sanchez Subject: RE: 2207-034 Jesus Villeda v. Citizens Property Ins. Corp (Kitchen Sink SP) 001-00-211715 Case No. CACE-19- 021344: SECOND FOLLOW UP. : 2207-034 Jesus Villeda v. Citizens Property Ins. Corp No. CACE-19-021344: Please Emily submit it right away, and once done | will go ahead and cancel the hearing. Thank you! Regards, Veronica Przewoznik Legal Assistant to Jesus R. Goatache and Vida Jasaitis Rubinton Simms, P.A. 3440 Hollywood Blvd., Suite 460 Hollywood, FL 33021 OFFICE 954-251-5500RE: 2207-034 Jesus Villeda v. Citizens Property Ins. Corp (Kitchen Sink SP) 001-00-211715 Case No. CACE-19-021344: SECOND FOLLOW UP. : 2207-034 Jesus Villeda v. Citizens Property Ins. Corp No. CACE-19-021344: Emily Matos EXHIBIT Tue 10/27/2020 2:33 PM To: Vida ; Veronica Przewoznik Ce: Tulia Sanchez @ 2 attachments (159 KB) Notice Of Taking Deposition.pdf; Notice Of Taking Deposition.pdf; Good afternoon, We will agree to provide the discovery response by Monday 11/2/2020, thank you for the extension. The plaintiffs deposition has already been scheduled, please see attached. Please see dates below our office is available for the PA deposition, your office will need to subpoena them. 3/29/2021 4/5/2021 4/6/2021 Best Regards, Emily Matos Legal Assistant Marin, Eljaick, Lopez, & Martinez P.L. 2601 South Bayshore Drive 18" Floor Coconut Grove, FL 33183 Direct Line: 305-424-2749 Fax: 805-424-2732 Website: www.MELawyers.com E-mail: ematos@mellaw a MARIN | ELJAIEK | LOPEZ | MARTINEZ n 3 **SCHEDULING NOTE** The dates provided may have been offered to other counsels and will only be secured on a first come-first serve basis. PLEASE BE ADVISED THE DATES PROPOSED ARE NOT CONFIRMED UNTIL YOU RECEIVE A FINAL RESPONSE FROM OUR OFFICE CONFIRMING SAME. PLEASE NOTE DATES WILL BE RELEASED IF NOTICE IS NOT RECEIVED WITHIN 5 DAYS. ALL DATES AND TIMES PROVIDED ARE IN EASTERN STANDARD TIME. NOTICE: The information in this e-mail, including any attachments, is confidential, is intended only for the named recipient(s) to whom. the email is addressed and may contain information that is attorney-client privileged, attorney work product, proprietary and/or exempt from disclosure under applicable law. If you are not an intended recipient, you are hereby notified that any use, dissemination, distribution or reproduction of this email, including any attachments, is strictly prohibited. Anyone who receives this message in error should notify the sender immediately by telephone or by retum e-mail and delete the entire email, inoluding any attachments, from their computer. Any opinions or advice contained in this email shall be subject to the terms and conditions set forth in the governing Marin, Eljaick & Lopez, PLL. client engagement agreement. Thank you. IRS Circular 230 Disclosure: Please note that the views expressed herein or in any attachments hereto are not intended to constitute a “reliance opinion" under applicable Treasury Regulations, and accordingly are not intended or written to be used, and may not be used or relied upon, for the purpose of (i) avoiding tax-related penalties that may be imposed by the Internal Revenue Service, or (i) promoting, marketing or recommending to another party any tax-related matters addressed hereinRE: 2207-034 Jesus Villeda v. Citizens Property Ins. Corp (Kitchen Sink SP) 001-00-211715 Case No. CACE-19-021344: SECOND FOLLOW UP. : 2207-034 Jesus Villeda v. Citizens Property Ins. Corp No. CACE-19-021344: Emily Matos EXHIBIT "C" Mon 11/2/2020 4:29 PM To: Veronica Przewoznik ; Vida Good afternoon, Please provide new dates your office and the CR are available. Additionally, Our MSP provider has had an IT Issue which has prevented us from temporarily having access to our files. At the moment we are restoring our system data and should have access to our files by the end of the week. With that being said, would your office be in agreement with us filling the response by Monday 11/9/2020 ? Best Regards, Emily Matos Legal Assistant Marin, Eljaick, Lopez, & Martinez P.L. 2601 South Bayshore Drive 18" Floor Coconut Grove, FL 33183 Direct Line: 805-424-2749 Fax: 805-424-2732 Website: www.MELlawyers.com E-mail: ematos@mellawyers.com We" MARIN | ELJAIEK| LOPEZ | MARTINEZ At 5 a Ae *e oe The dates provided may have been offered to other counsels and will only be secured on a first come-first serve basis. PLEASE BE ADVISED THE DATES PROPOSED ARE NOT CONFIRMED UNTIL YOU RECEIVE A FINAL RESPONSE FROM OUR OFFICE CONFIRMING SAME. PLEASE NOTE DATES WILL BE RELEASED IF NOTICE IS NOT RECEIVED WITHIN 5 DAYS. ALL DATES AND TIMES PROVIDED ARE IN EASTERN STANDARD TIME. NOTICE: The information in this e-mail, including any attachments, is confidential, is intended only for the named recipient(s) to whom the email is addressed and may contain information that is attorney-client privileged, attorney work product, proprietary and/or exempt from disclosure under applicable law. If you are not an intended recipient, you are hereby notified that any use, dissemination, distribution or reproduction of this email, including any attachments, is strictly prohibited. Anyone who receives this message in error should notify the sender immediately by telephone or by return e-mail and delete the entire email, including any attachments, from their computer. Any opinions or advice contained in this email shall be subject to the terms and conditions set forth in the governing Marin, Eljaick & Lopez, PLL. client engagement agreement. Thank you. IRS Circular 230 Disclosure: Please note that the views expressed herein or in any attachments hereto are not intended to constitute a “reliance opinion" under applicable Treasury Regulations, and accordingly are not intended or written to be used, and may not be used or relied upon, for the purpose of (i) avoiding tax-related penalties that may be imposed by the Internal Revenue Service, or (i) promoting, marketing or recommending to another party any tax-related matters addressed herein.