On October 30, 2019 a
Notice of Video Deposition - Wednesday, April 17, 2019 11:00 am / 15020 Associates Realty
was filed
involving a dispute between
15020 Associates Realty,
and
Citizens Property Insurance Corporation,
for Other - Insurance Claim
in the District Court of Broward County.
Preview
*#4* FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 10/30/2019 9:46:00 AM.**#*
Filing # 85868583 E-Filed 03/05/2019 11:12:32 AM
IN THE CIRCUIT COURT FOR THE 117
JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CASE NO.: 18-038533 CA 01 i 3
19- 022883
ILE
OCT 30 2019
15020 ASSOCIATES REALTY,
Plaintiff,
vs.
CITIZENS PROPERTY INSURANCE
CORPORATION, a Florida Corporation,
Defendant.
RE-NOTICE OF TAKING DIGITAL VIDEO DEPOSITION DUCES TECUM
(Please advise if an Interpreter is required)
PLEASE TAKE NOTICE that on Wednesday, April 17, 2019 the undersigned
counsel will take the following deposition:
NAME: 15020 Associates Realty
TIME: 11:00 a.m.
PLACE: Phipps Reporting
28 West Flagler Street, 11** Floor
Miami, Florida 33130
as specified above, upon oral examination before a Court Reporter, or some other officer
duly authorized by law to take depositions. The deposition will continue from day to day
until completed. The deposition is being taken for the purpose of discovery, for use at trial,
or both of the foregoing, or for such other purposes as are permitted under the applicable
and governing rules.*#4* FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 10/30/2019 9:46:00 AM.**#*
C SCHEDULE A
At the deposition, you are required to bring with you the following documents and
testify regarding the following:
Any and all documents which you contend support or tend to support your claim for
benefits, including but not limited to receipts, invoices, work orders, and/or any
documentation concerning repairs to the property which relate to the claimed damages,
estimates, photographs, third party records, and all correspondence exchanged with
Defendant or otherwise which relates to the subject claim. Furthermore, this request
seeks any and all documentation responsive to Defendant's First Request for Production
which was not previously submitted to this Defendant in response to same. Lastly, you
are required to produce any and all information concerning any subsequent insurance
claims made concerning the subject property identified in the Complaint.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was provided
via e-mail to: Joe Parrish Jr., Esq., Morgan & Morgan, P.A., jparrish@forthepeople.com,
30338 Overseas Highway, Unit 7, Big Pine Key, Florida on March 5, 2019.
\
WADSWORTH, MARGREY & DIXON LLP
Attorneys for Defendant
The Jane Building
261 N.E. 1* Street, 5% Floor
Miami, Florida 33132
(305) 777-1000 Telephone
(305) 777-1001 Facsimile
By: /s/ Dania Battle
Dania Battle, Esq.
Florida Bar No.: 74873
E-mail: db@wadsworth-law.com
Christopher W. Wadsworth, Esq.
Florida Bar No.: 78026
E-mail: cw@wadsworth-law.com
Secondary: pleadings@wadsworth-law.com
Ce: Phipps Reporting
Document Filed Date
October 30, 2019
Case Filing Date
October 30, 2019
Category
Other - Insurance Claim
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*#4* FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 10/30/2019 9:46:00 AM.**#* Filing # 85868583 E-Filed 03/05/2019 11:12:32 AM IN THE CIRCUIT COURT FOR THE 117 JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NO.: 18-038533 CA 01 i 3 19- 022883 ILE OCT 30 2019 15020 ASSOCIATES REALTY, Plaintiff, vs. CITIZENS PROPERTY INSURANCE CORPORATION, a Florida Corporation, Defendant. RE-NOTICE OF TAKING DIGITAL VIDEO DEPOSITION DUCES TECUM (Please advise if an Interpreter is required) PLEASE TAKE NOTICE that on Wednesday, April 17, 2019 the undersigned counsel will take the following deposition: NAME: 15020 Associates Realty TIME: 11:00 a.m. PLACE: Phipps Reporting 28 West Flagler Street, 11** Floor Miami, Florida 33130 as specified above, upon oral examination before a Court Reporter, or some other officer duly authorized by law to take depositions. The deposition will continue from day to day until completed. The deposition is being taken for the purpose of discovery, for use at trial, or both of the foregoing, or for such other purposes as are permitted under the applicable and governing rules.*#4* FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 10/30/2019 9:46:00 AM.**#* C SCHEDULE A At the deposition, you are required to bring with you the following documents and testify regarding the following: Any and all documents which you contend support or tend to support your claim for benefits, including but not limited to receipts, invoices, work orders, and/or any documentation concerning repairs to the property which relate to the claimed damages, estimates, photographs, third party records, and all correspondence exchanged with Defendant or otherwise which relates to the subject claim. Furthermore, this request seeks any and all documentation responsive to Defendant's First Request for Production which was not previously submitted to this Defendant in response to same. Lastly, you are required to produce any and all information concerning any subsequent insurance claims made concerning the subject property identified in the Complaint. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was provided via e-mail to: Joe Parrish Jr., Esq., Morgan & Morgan, P.A., jparrish@forthepeople.com, 30338 Overseas Highway, Unit 7, Big Pine Key, Florida on March 5, 2019. \ WADSWORTH, MARGREY & DIXON LLP Attorneys for Defendant The Jane Building 261 N.E. 1* Street, 5% Floor Miami, Florida 33132 (305) 777-1000 Telephone (305) 777-1001 Facsimile By: /s/ Dania Battle Dania Battle, Esq. Florida Bar No.: 74873 E-mail: db@wadsworth-law.com Christopher W. Wadsworth, Esq. Florida Bar No.: 78026 E-mail: cw@wadsworth-law.com Secondary: pleadings@wadsworth-law.com Ce: Phipps Reporting