Document for Paul Rodriguez Plaintiff vs. Citizens Property Insurance Corporation Defendant

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                                Filing # 103123690 E-Filed 02/11/2020 02:12:27 PM

IN THE CIRCUIT COURT IN AND FOR BROWARD COUNTY, FLORIDA

PAUL RODRIGUEZ, CASE NO. CACE-19-021427

v.

CITIZENS PROPERTY
INSURANCE CORPORATION,

Plaintiffs,

 

Defendant.

 

NOTICE OF TAKING VIDEOTAPED DEPOSITION DUCES TECUM
OF DEFENDANT'S CORPORATE REPRESENTATIVE(S) DESIGNATE(S)

PLEASE TAKE NOTICE that the undersigned will take the videotaped deposition of:
NAME: DEFENDANT'S CORPORATE DESIGNATEY/S who consent/s to testify

on its behalf and to give complete, knowledgeable and binding answers on behalf of

Defendant regarding the following:

(a)
(b)
(©)

(d)

(e)

()

(g)

(h)
@

Plaintiff/s's notice of loss in September 10™ 2017 (hereafter "the Loss");
Defendant's investigation in adjustment of Plaintiff/s' Loss (hereafter "the Claim");

All documents and other tangible evidence identified or obtained by Defendant
during its investigation in the Loss and Claim;

All correspondence and documents issued by Defendant to Plaintiff/s related to the
Loss and Claim;

All correspondence and documents received from Plaintiff/s by Defendant related
to the Loss and Claim;

Defendant's factual determinations and conclusions regarding the cause of the Loss;

Defendant's determinations regarding the scope of the physical damage caused by the
Loss and/or the cost to repair the property to return it to its pre-Loss condition;

Defendant's coverage decision/claim position regarding the Loss and Claim;
All of the evidence, whether admissible or not, known to Defendant at the time it

reached and stated its pre-suit coverage decision/claim position regarding the Loss
and Claim that either supports or rebuts that determination;

DUBOFF

*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/11/2020 02:12:27 PM.****@)
(k)

Q)
(m)

(n)

(0)

(p)

Each and every averment contained in Defendant's "responsive pleading";

All of the evidence, whether admissible or not, known to Defendant that supports
each and every averment contained in its responsive pleading;

Each and every affirmative defense pled by Defendant;

All of the evidence, whether admissible or not, known to Defendant that supports
each and every affirmative defense contained in its responsive pleading;

All of the evidence, whether admissible or not, that supports any of Defendant's
Answers to Interrogatories;

All of the evidence, whether admissible or not, that supports any of Defendant's
Responses to any Requests for Admissions;

All of the evidence, whether admissible or not, that supports any of the legal
arguments made by Defendant in any of the motions for summary judgment that it
has filed in this matter.

When the representative appears, he/she is required to bring and to have with him/her (but not be

required to produce) the following items:

(a)

(b)

(©)
(d)
()

All documents, exhibits, facts and materials representing or containing facts upon
which the deponent has, will or may rely in giving testimony in this case or which
may be used to represent, illustrate or explain testimony in this case;

Any reports, studies, data compilations, data bases, or other information of a
statistical nature upon which the deponent has, will or may rely in giving testimony
in this case or which may be used to represent, illustrate or explain testimony in this
case;

The entire file related to claim number HEE 3 3;
The entire file related to Case No. CACE-19-021427;

Any and all materials reviewed by the deponent in this matter - including, but not
limited to, depositions, correspondence, photographs, reports, books, articles,
literature, films, tests, experiments, statements, results of inspections, drawings,
blueprints, or other reference material which he/she has, will or may rely in giving
testimony in this case or which may be used to represent, illustrate or explain
testimony in this case;

DUBOFF(f) Any and all reports which were furnished to the dependent by any experts in this case
which he/she has, will or may rely on in giving testimony in this case or which may
be used to represent, illustrate or explain testimony in this case;

(g) Any and all notes, writing, memoranda, etc., which the deponent has prepared in this
case which he/she has, will or may rely on in giving testimony in this case or which
may be used to represent, illustrate or explain testimony in this case;

(h) Any and all notes taken or prepared and analysis performed by the deponent which
were prepared for and regarding the subject claim and subject lawsuit and which
he/she has, will or may rely on in giving testimony in this case or which may be used
to represent, illustrate or explain testimony in this case;

June 17" 2020
01:00PM

Universal Court Reporting, whose address is301 West Bay Street
Suite 1400 Jacksonville, Florida 32202

 

Upon oral examination before Universal Court Reporters, Videographer and/or any other Notary
Public or officer authorized by law to take depositions in the State of Florida. The oral
examination will continue from day to day until completed. The deposition is being taken for the
purpose of discovery, for use at trial or for such other purposes as are permitted under
Fla.R.Civ.1.280., 1.310, 1.350, 1.360, 1.380, 1.390, 1.410; or Fed.R.Civ.P.30.

CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that on this February 11, 2020, a true and correct copy of the
foregoing was served via Florida’s eFiling system to: Lyndsay D. Fichtenbaum, of GOEDE,
ADAMCZYK, DEBOEST & CROSS, PLLC, 4800 N. Federal Highway, Suite 307D, Boca
Raton, Florda, 334131, at lfichtenbaum@gadclaw; bblotz@gadclaw..

DusBorF LAW FIRM

ATTORNEYS FOR PLAINTIFFS

680 NE 127 STREET

NorTH MIAMI, FLORIDA 33161

TELEPHONE (305) 899-0085

Fax No. (305) 899-0091
CoURTDOCUMENT@DUBOFFLAWFIRM.COM

BY:__S/ KENNETH R. DUBOFF

KENNETH R. DUBOFF
Fla. Bar #218261

DUBOFF