On October 15, 2019 a
Notice of Taking Deposition
was filed
involving a dispute between
Villeda , Jesus,
Villeda , Jhaneth,
and
Citizens Property Insurance Corporation,
for Contract and Indebtedness
in the District Court of Broward County.
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Filing # 109830900 E-Filed 07/06/2020 04:07:33 PM
JESUS VILLEDA AND JHANETH IN THE CIRCUIT COURT OF THE 17"
VILLEDA, JUDICIAL CIRCUIT IN AND FOR
a BROWARD COUNTY, FLORIDA
Plaintiffs,
v. CASE NO.: CACE-19-021344
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
NOTICE OF TAKING DEPOSITION DUCES TECUM
PLEASE TAKE NOTICE that the undersigned attomeys will take the following
deposition at the place, date and time indicated below:
NAME DATE TIME PLACE
Corporate U.S Legal Support
Representative with 225 Water Street, Suite 1200
knowledge pursuant October 29, 2020 11:00 AM Jacksonville, FL 32202
to Fla. R. Civ. P. 904.359.0583
1.310(b)(6) or via Zoom
In accordance with the Americans with Disabilities Act of 1990, persons needing a special
accommodation to participate in this proceeding should contact the offices of the
undersigned at 305-444-5969
Pursuant to Rule 1.310(b)(6) of the Florida Rules of Civil Procedure, you are hereby requested to
designate one or more officers, directors, managing agents or other persons who consent to testify
on behalf of the parties being deposed as the persons having the most knowledge concerning the
area of the subject matter described on Schedule A attached hereto.
Upon oral examination before a commissioner appointed by the Court, a Notary Public, or any
other officer authorized to administer oaths by the laws of the State of Florida, who is neither a
relative nor employee of such attomey or counsel and who is not financially interested in this
action. The deposition will continue from day to day until completed. The deposition is being taken
for purposes of discovery and for use as evidence in this case, for use at trial, or for such other
purposes as are permitted under the Florida Rules of Civil Procedure.
The deponent is to bring at the above time and place the following documents listed on the
attached Schedule B.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/06/2020 04:07:32 PM.****CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served via Florida
E-Portal and E-Mail to: Vida Jasaitis, Esq VJasaitis@rubintonlaw.com on this 6" day of July 2020.
Marin, Eljaiek, Lopez & Martinez P.L.
Counsel for the Insured
2601 South Bayshore Drive, 18" Floor
Coconut Grove, Florida 33133
Telephone No. (305) 444-5969
Facsimile No. (305) 444-1939
Email: Mellaw7@mellawyers.com
By: ___Annette del Aguila
Annette Del Aguila, Esq.
Florida Bar No. 40546
Kristen Schlotzhauer, Esq.
Florida Bar No. 1002829SCHEDULE A
1. The allegations set forth in the Complaint.
2. The Insurance Policy entered into between the Insurer and the Insured as referenced in the
Complaint.
3. All facts related to the Insurer’s involvement in the Insured’s claim as referenced in the
Complaint.
4. All facts related to communications between the Insured and agents of the Insurer as it relates
to the allegations set forth in the Complaint.
5. The adjustment and claim handling of the instant claim alleged in the Complaint. .
6. The dollar value of the Insured’s damages.
7. All facts and information supporting your defenses to the Plaintiff(s) claim for insurance
proceeds as alleged in the Complaint.
8. All facts and information supporting Your Answer and Affirmative Defenses.
9. All facts and information supporting any defense or exclusion of coverage under the Insurance
Policy entered into between Plaintiff and Defendant as referenced in the Complaint.
10. The identity, job title, job description and activitied of all persons (including any non-
employees) who participated in any way in Defendant’s investigation of the Loss as described in
the Complaint.SCHEDULE B
1. Please bring a copy of all documents in your possession for the instant Claim as defined in the
Complaint that are not protected by a claimed privilege. If you are not producing documents
pursuant to this Schedule B request because you are claiming a privilege please provide a
privilege log. If a document is not produced and not referenced on a privilege log we will assume
it does not exist.
Document Filed Date
July 06, 2020
Case Filing Date
October 15, 2019
Category
Contract and Indebtedness
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Filing # 109830900 E-Filed 07/06/2020 04:07:33 PM JESUS VILLEDA AND JHANETH IN THE CIRCUIT COURT OF THE 17" VILLEDA, JUDICIAL CIRCUIT IN AND FOR a BROWARD COUNTY, FLORIDA Plaintiffs, v. CASE NO.: CACE-19-021344 CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. NOTICE OF TAKING DEPOSITION DUCES TECUM PLEASE TAKE NOTICE that the undersigned attomeys will take the following deposition at the place, date and time indicated below: NAME DATE TIME PLACE Corporate U.S Legal Support Representative with 225 Water Street, Suite 1200 knowledge pursuant October 29, 2020 11:00 AM Jacksonville, FL 32202 to Fla. R. Civ. P. 904.359.0583 1.310(b)(6) or via Zoom In accordance with the Americans with Disabilities Act of 1990, persons needing a special accommodation to participate in this proceeding should contact the offices of the undersigned at 305-444-5969 Pursuant to Rule 1.310(b)(6) of the Florida Rules of Civil Procedure, you are hereby requested to designate one or more officers, directors, managing agents or other persons who consent to testify on behalf of the parties being deposed as the persons having the most knowledge concerning the area of the subject matter described on Schedule A attached hereto. Upon oral examination before a commissioner appointed by the Court, a Notary Public, or any other officer authorized to administer oaths by the laws of the State of Florida, who is neither a relative nor employee of such attomey or counsel and who is not financially interested in this action. The deposition will continue from day to day until completed. The deposition is being taken for purposes of discovery and for use as evidence in this case, for use at trial, or for such other purposes as are permitted under the Florida Rules of Civil Procedure. The deponent is to bring at the above time and place the following documents listed on the attached Schedule B. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/06/2020 04:07:32 PM.****CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served via Florida E-Portal and E-Mail to: Vida Jasaitis, Esq VJasaitis@rubintonlaw.com on this 6" day of July 2020. Marin, Eljaiek, Lopez & Martinez P.L. Counsel for the Insured 2601 South Bayshore Drive, 18" Floor Coconut Grove, Florida 33133 Telephone No. (305) 444-5969 Facsimile No. (305) 444-1939 Email: Mellaw7@mellawyers.com By: ___Annette del Aguila Annette Del Aguila, Esq. Florida Bar No. 40546 Kristen Schlotzhauer, Esq. Florida Bar No. 1002829SCHEDULE A 1. The allegations set forth in the Complaint. 2. The Insurance Policy entered into between the Insurer and the Insured as referenced in the Complaint. 3. All facts related to the Insurer’s involvement in the Insured’s claim as referenced in the Complaint. 4. All facts related to communications between the Insured and agents of the Insurer as it relates to the allegations set forth in the Complaint. 5. The adjustment and claim handling of the instant claim alleged in the Complaint. . 6. The dollar value of the Insured’s damages. 7. All facts and information supporting your defenses to the Plaintiff(s) claim for insurance proceeds as alleged in the Complaint. 8. All facts and information supporting Your Answer and Affirmative Defenses. 9. All facts and information supporting any defense or exclusion of coverage under the Insurance Policy entered into between Plaintiff and Defendant as referenced in the Complaint. 10. The identity, job title, job description and activitied of all persons (including any non- employees) who participated in any way in Defendant’s investigation of the Loss as described in the Complaint.SCHEDULE B 1. Please bring a copy of all documents in your possession for the instant Claim as defined in the Complaint that are not protected by a claimed privilege. If you are not producing documents pursuant to this Schedule B request because you are claiming a privilege please provide a privilege log. If a document is not produced and not referenced on a privilege log we will assume it does not exist.