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Filing # 106838734 E-Filed 04/29/2020 11:55:17 AM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR,
BROWARD COUNTY, FLORIDA
JESUS VILLEDA and
JHANETH VILLEDA, CASE NO.: CACE-19-021344
Plaintiffs,
Vv.
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
NOTICE OF CANCALLATION OF TAKING DEPOSITION DUCES TECUM
(Coordinated with Julie Larsen from OC)
PLEASE TAKE NOTICE that the undersigned attomeys will take the following
deposition at the place, date and time indicated below:
NAME DATE TIME PLACE
US Legal Support
Harold Bryant April 30, 2020 11:00 A.M. 1080 Woodcock Road, Suite 100
Field Adjuster Orlando, FL
(407) 649-9193
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 Exhibit 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 attorney 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.
[3370016/1]
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/29/2020 11:55:16 AM.****CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served via the
Florida E-Filing Portal to Vida Jasaitis, Esq., Rubinton & Associates, P.A., at
VJasaitis@rubintonlaw.com; JLarsen@rubintonlaw.com, on this 29th day of April 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
Secondary Email: Eservice@mellawyers.com
By: /s/_ Annette Del Aguila
Annette Del Aguila, Esq.
Florida Bar No. 40546
[3370016/1]10.
ll.
12.
[3370016/1]
EXHIBIT A
DOCUMENTS TO BE PRODUCED
A current curriculum vitae or other compilation of biographical or qualifications
information.
Your COMPLETE non-privileged file regarding Claim Number iS
Date of Loss 05/27/2019 for Citizens Property Insurance Corporation.
Policy No. 02178693; including but not limited to any and all photographs, videotapes
of the area where the subject incident occurred, reports, correspondence, calculations,
notes, memoranda, guidelines, publications, estimates, invoices, statements,
inventories, and all documents you have review.
Any and all photographs or videos taken by you during your investigation and/or
adjustment of the claim.
Any documents generated by you during your investigation, adjustment and valuation
of the Plaintiff's Claim.
Any sketches or diagrams prepared by you during your investigation of the Plaintiff's
Claim.
Any estimate of damages prepared by your during your investigation of the Plaintiff’ s
Claim.
Any documents reviewed by you during your investigation and/or adjustment of the
claim.
Any internet websites you reviewed relative to the property or claim during your
investigation and/or adjustment of the claim.
Any underwriting documents you reviewed relative to the property during your
investigation and/or adjustment of the claim.
Any and all documents evidencing or tending to evidence the dates and amounts of
time expended by you in connection with this matter.
Any bills, invoices or other documents evidencing the amount of money you have
billed or have been paid in connection with your work on the claim.
Any and all documents or charts on this matter required or consulted by you in
connection with the expression of your opinion or recommendation in this matter
related to a coverage determination.
Any and all records and/or reports, evaluations, summaries, written opinions or
recommendations prepared by you during your investigation and/or adjustment of the
claim.
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Filing # 106838734 E-Filed 04/29/2020 11:55:17 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR, BROWARD COUNTY, FLORIDA JESUS VILLEDA and JHANETH VILLEDA, CASE NO.: CACE-19-021344 Plaintiffs, Vv. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. NOTICE OF CANCALLATION OF TAKING DEPOSITION DUCES TECUM (Coordinated with Julie Larsen from OC) PLEASE TAKE NOTICE that the undersigned attomeys will take the following deposition at the place, date and time indicated below: NAME DATE TIME PLACE US Legal Support Harold Bryant April 30, 2020 11:00 A.M. 1080 Woodcock Road, Suite 100 Field Adjuster Orlando, FL (407) 649-9193 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 Exhibit 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 attorney 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. [3370016/1] *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/29/2020 11:55:16 AM.****CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served via the Florida E-Filing Portal to Vida Jasaitis, Esq., Rubinton & Associates, P.A., at VJasaitis@rubintonlaw.com; JLarsen@rubintonlaw.com, on this 29th day of April 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 Secondary Email: Eservice@mellawyers.com By: /s/_ Annette Del Aguila Annette Del Aguila, Esq. Florida Bar No. 40546 [3370016/1]10. ll. 12. [3370016/1] EXHIBIT A DOCUMENTS TO BE PRODUCED A current curriculum vitae or other compilation of biographical or qualifications information. Your COMPLETE non-privileged file regarding Claim Number iS Date of Loss 05/27/2019 for Citizens Property Insurance Corporation. Policy No. 02178693; including but not limited to any and all photographs, videotapes of the area where the subject incident occurred, reports, correspondence, calculations, notes, memoranda, guidelines, publications, estimates, invoices, statements, inventories, and all documents you have review. Any and all photographs or videos taken by you during your investigation and/or adjustment of the claim. Any documents generated by you during your investigation, adjustment and valuation of the Plaintiff's Claim. Any sketches or diagrams prepared by you during your investigation of the Plaintiff's Claim. Any estimate of damages prepared by your during your investigation of the Plaintiff’ s Claim. Any documents reviewed by you during your investigation and/or adjustment of the claim. Any internet websites you reviewed relative to the property or claim during your investigation and/or adjustment of the claim. Any underwriting documents you reviewed relative to the property during your investigation and/or adjustment of the claim. Any and all documents evidencing or tending to evidence the dates and amounts of time expended by you in connection with this matter. Any bills, invoices or other documents evidencing the amount of money you have billed or have been paid in connection with your work on the claim. Any and all documents or charts on this matter required or consulted by you in connection with the expression of your opinion or recommendation in this matter related to a coverage determination. Any and all records and/or reports, evaluations, summaries, written opinions or recommendations prepared by you during your investigation and/or adjustment of the claim.