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Filing # 128205427 E-Filed 06/07/2021 11:13:01 AM
IN THE CIRCUIT COURT OF THE 17,TH
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
ADRIANA GONZALEZ AND
PEDRO GONZALEZ,
CASE NO.: CACE-19-020995
Plaintiffs,
V
HERITAGE PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
'
RE-NOTICE OF TAKING DEPOSITIONSDUCES TECUM
(Per Plaintiffs' Counsel's Office, InterpreterNot Necessary)
PLEASE TAKE NOTICE that Defendant will take the deposition duces tecum of:
NAME
DATE
TIME
LOCATION
Adriana Gonzalez
June 29,2021
9:00 a.m.
U.S. Legal Support
Via Remote Video
Conferencing (Zoom)
Pedro Gonzalez
June 29,2021
Immediately following the U.S. Legal Support
deposition
of
Adriana
Via Remote Video
Gonzalez
Conferencing (Zoom)
upon examination, before a court reporter or any other officer duly authorized by law to take
depositions. The depositionswill continue from day to day until completed. The depositions are
being taken for the purpose of discovery, for use at trial, or both ofthe foregoing, or for such other
purposes as are permitted under the applicable and governing rules. THE WITNESSES ARE
REQUESTED TO BRING TO THE DEPOSITION ALL ITEMS IN THE ATTACHED
SCHEDULE "A".
*** FILED: BROWARDCOUNTY, FL BRENDA D. FORMAN, CLERK 06/07/2021 11:13:01 AM.****
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy ofthe foregoing was servedvia E-Portal to Yvacheslav
Borshchukov, Esq., Yvacheslav Borshchukov, P.A., service@vb.legal; slava@vb.legal; on June
7,2021.
Attorneyfor Heritage Propertyand Casualty
Insurance Company
1571 Sawgrass Corporate Parkway
Suite 400
Sunrise, Florida 33323
Telephone: 727-362-7200 Ext: 7122
By: \s\Pedro Ortiz, Esquire
PEDRO ORTIZ, ESQUIRE
Florida Bar No. 12075
SCHEDULE "A"
1.
All documentsexchanged betweenyou or any agent or representative ofyours and
Heritage Property and Casualty Insurance Company, and/or its agents from the reporting of the
alleged loss through the present date.
2.
All documents evidencing agreements for representation between you and any
individualor business entityrepresentingyou in this claim, including but not limited to contracts,
letters ofrepresentation,correspondence,and fee schedules for representationby loss consultants,
public adjusters, or public adjuster firms. This request does not seek agreements for legal
representation.
3.
All documents and correspondence between you and any third-party vendor or
contractor relating to the loss.
4.
All documents evidencing the damages that you are claiming in this lawsuit,
including, but not limited to estimates, contracts,receipts, statements, invoices, and work orders.
5.
All documents evidencing payment to any third-party for services relating to the
loss.
6.
Any proofof loss statements from you relatingto the claim.
7.
All documents evidencing the repair and/or replacement of damaged property as a
result of the loss, including but not limited to contracts,receipts, canceled checks, bills of sale,
statements, ATM receipts, credit card statements, evidence of bank withdrawals,and invoices.
8.
All documentsevidencing any mitigation or repairs to any area ofthe property that
are being claimed as damaged in your loss.
9-
The original jpeg files for any photographstaken which show the alleged damage
at the property on or after the date of loss.
10.
All videos, recordings, film, diagrams, drawings, charts, sketches or any other
depictionsillustratingthe damages sustained in the loss.
11.
Any and all photographs or videos which showthe damaged area, prior to the date
ofthe loss.
12.
All engineer,or expertreports in supportofthe claim that the property has sustained
damage as a result ofthe alleged loss.
13.
Any and all documents prepared by third parties who inspected or evaluated the
property and/or the damages as a result ofthe alleged loss.
14.
All documentsevidencingyour efforts to protect the property from further damage.
15.
All maintenanceand/or repair records for the property from the date ofloss through
the present.
16.
All documentsrelatingto any prior insurance claims at the property,including, but
not limited to: proofs of loss; any repair receipts; estimates; photographs; invoices; evidences of
payments; and/or evidences of settlement.
17.
All documents relating to any other losses at the property occurring prior to or
subsequent to the date of loss, including, but not limited to: proofs of loss; any repair receipts;
estimates; photographs;invoices; evidences ofpayments; and/or evidences of settlement.
18.
Copies ofall telephonerecords (land line and/or cellular) evidencingincoming and
outgoing calls for all adults residing at the Property encompassing the 30 days prior to the alleged
date of loss through 30 days after the alleged date of loss.
19.
All documentsin your possessionrelatingto the loss alleged in the Complaint that
were not previously produced in response to the above requests.
20.
Copies of any liens, sales contracts,disclosurereports, inspectionreports,appraisal
reports and/or other documentsrelative to your purchase or acquisition ofthe Property.
21.
A copy of any and all lease agreements, rental agreements, contracts or other
documents with any tenant or tenant(s) residing at the Property from the two years prior to the
alleged loss through the current date.
22.
Copies ofany and all documentscreated as part ofthe home inspectionreport from
your purchase of the subject property, including, but not limited to all inspection reports, 4-point
inspectionreports, appraisal reports, photographs and videos in their native format.
23.
Copies of any documentationevidencingrepairs and/or renovations at the Property
that occurred during the five (5) years prior to the alleged loss.
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Filing # 128205427 E-Filed 06/07/2021 11:13:01 AM IN THE CIRCUIT COURT OF THE 17,TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA ADRIANA GONZALEZ AND PEDRO GONZALEZ, CASE NO.: CACE-19-020995 Plaintiffs, V HERITAGE PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. ' RE-NOTICE OF TAKING DEPOSITIONSDUCES TECUM (Per Plaintiffs' Counsel's Office, InterpreterNot Necessary) PLEASE TAKE NOTICE that Defendant will take the deposition duces tecum of: NAME DATE TIME LOCATION Adriana Gonzalez June 29,2021 9:00 a.m. U.S. Legal Support Via Remote Video Conferencing (Zoom) Pedro Gonzalez June 29,2021 Immediately following the U.S. Legal Support deposition of Adriana Via Remote Video Gonzalez Conferencing (Zoom) upon examination, before a court reporter or any other officer duly authorized by law to take depositions. The depositionswill continue from day to day until completed. The depositions are being taken for the purpose of discovery, for use at trial, or both ofthe foregoing, or for such other purposes as are permitted under the applicable and governing rules. THE WITNESSES ARE REQUESTED TO BRING TO THE DEPOSITION ALL ITEMS IN THE ATTACHED SCHEDULE "A". *** FILED: BROWARDCOUNTY, FL BRENDA D. FORMAN, CLERK 06/07/2021 11:13:01 AM.**** CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy ofthe foregoing was servedvia E-Portal to Yvacheslav Borshchukov, Esq., Yvacheslav Borshchukov, P.A., service@vb.legal; slava@vb.legal; on June 7,2021. Attorneyfor Heritage Propertyand Casualty Insurance Company 1571 Sawgrass Corporate Parkway Suite 400 Sunrise, Florida 33323 Telephone: 727-362-7200 Ext: 7122 By: \s\Pedro Ortiz, Esquire PEDRO ORTIZ, ESQUIRE Florida Bar No. 12075 SCHEDULE "A" 1. All documentsexchanged betweenyou or any agent or representative ofyours and Heritage Property and Casualty Insurance Company, and/or its agents from the reporting of the alleged loss through the present date. 2. All documents evidencing agreements for representation between you and any individualor business entityrepresentingyou in this claim, including but not limited to contracts, letters ofrepresentation,correspondence,and fee schedules for representationby loss consultants, public adjusters, or public adjuster firms. This request does not seek agreements for legal representation. 3. All documents and correspondence between you and any third-party vendor or contractor relating to the loss. 4. All documents evidencing the damages that you are claiming in this lawsuit, including, but not limited to estimates, contracts,receipts, statements, invoices, and work orders. 5. All documents evidencing payment to any third-party for services relating to the loss. 6. Any proofof loss statements from you relatingto the claim. 7. All documents evidencing the repair and/or replacement of damaged property as a result of the loss, including but not limited to contracts,receipts, canceled checks, bills of sale, statements, ATM receipts, credit card statements, evidence of bank withdrawals,and invoices. 8. All documentsevidencing any mitigation or repairs to any area ofthe property that are being claimed as damaged in your loss. 9- The original jpeg files for any photographstaken which show the alleged damage at the property on or after the date of loss. 10. All videos, recordings, film, diagrams, drawings, charts, sketches or any other depictionsillustratingthe damages sustained in the loss. 11. Any and all photographs or videos which showthe damaged area, prior to the date ofthe loss. 12. All engineer,or expertreports in supportofthe claim that the property has sustained damage as a result ofthe alleged loss. 13. Any and all documents prepared by third parties who inspected or evaluated the property and/or the damages as a result ofthe alleged loss. 14. All documentsevidencingyour efforts to protect the property from further damage. 15. All maintenanceand/or repair records for the property from the date ofloss through the present. 16. All documentsrelatingto any prior insurance claims at the property,including, but not limited to: proofs of loss; any repair receipts; estimates; photographs; invoices; evidences of payments; and/or evidences of settlement. 17. All documents relating to any other losses at the property occurring prior to or subsequent to the date of loss, including, but not limited to: proofs of loss; any repair receipts; estimates; photographs;invoices; evidences ofpayments; and/or evidences of settlement. 18. Copies ofall telephonerecords (land line and/or cellular) evidencingincoming and outgoing calls for all adults residing at the Property encompassing the 30 days prior to the alleged date of loss through 30 days after the alleged date of loss. 19. All documentsin your possessionrelatingto the loss alleged in the Complaint that were not previously produced in response to the above requests. 20. Copies of any liens, sales contracts,disclosurereports, inspectionreports,appraisal reports and/or other documentsrelative to your purchase or acquisition ofthe Property. 21. A copy of any and all lease agreements, rental agreements, contracts or other documents with any tenant or tenant(s) residing at the Property from the two years prior to the alleged loss through the current date. 22. Copies ofany and all documentscreated as part ofthe home inspectionreport from your purchase of the subject property, including, but not limited to all inspection reports, 4-point inspectionreports, appraisal reports, photographs and videos in their native format. 23. Copies of any documentationevidencingrepairs and/or renovations at the Property that occurred during the five (5) years prior to the alleged loss.