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Filing # 114106147 E-Filed 09/29/2020 11:43:37 AM
20-9562
MRP/im
JIMMY AMAYA & AMELIS RAMOS,
Plaintiff,
Vv.
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
iH
IN THE CIRCUIT COURT OF THE 17™
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO. CACE 19-021027 (04)
(Judge Sandra Perlman)
DEFENDANT’S SECOND AMENDED NOTICE OF TAKING VIDEO
DEPOSITION DUCES TECUM
(coordinated with Denise Siegel as Opposing Counsel’s office on 8.18.20)
PLEASE TAKE NOTICE that the undersigned attorney will take the deposition, VIA
ZOOM, by oral examination of the person named below, at the time, on the date, at the hour, and
place indicated:
Deponent: Amelis Ramos
Date & Time: December 3, 2020 at 1:00 p.m. or immediately following Jimmy
Amaya’s deposition
Location: VIA ZOOM
CourtScribes - Hollywood
2719 Hollywood Boulevard
Hollywood, Florida 33020
ZOOM INFORMATION:
Courtscribes 44 is inviting you to a scheduled Zoom meeting. Topic: Depo of Jimmy
Amaya (10am), Amelis Ramos (1pm) Time: Dec 3, 2020 10:00 AM Eastern Time (US
and Canada) Join Zoom Meeting https://courtscribes.zoom.us/j/93054231324 Meeting
ID: 930 5423 1324 One tap mobile +13017158592,,93054231324# US (Germantown)
+13126266799,,93054231324# US (Chicago) Dial by your location +1 301 715 8592 US
(Germantown) +1 312 626 6799 US (Chicago) +1 646 558 8656 US (New York) +1 253
215 8782 US (Tacoma) +1 346 248 7799 US (Houston) +1 669 900 6833 US (San Jose)
877 853 5247 US Toll-free 888 788 0099 US Toll-free Meeting ID: 930 5423 1324 Find
your local number: https://courtscribes.zoom.us/u/ad4TLXBU49
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/29/2020 11:43:36 AM.****Jimmy Amaya & Amelis Ramos v. Citizens
CASE NO. CACE 19-021027 (04)
before an Associate or Deputy Court Reporter, Notary Public, or before any other duly qualified
officer who is not of counsel to either of the parties or interested in the event of the cause. This
deposition is being taken for the purposes of discovery, for use at trial, or for such other purposes as
are permitted under the Florida Rules of Civil Procedure.
The above-named deponent is hereby commanded to bring with her on the above-stated
date, time and place the following items:
Your entire file regarding this claim including, but not limited to, the following, Any
documents, papers, tapes, invoices, videos, diagrams, statements, photographs, or any other
thing received, reviewed or prepared by you relating to the property located at 6635 Hood
Street, Hollywood, FL 33024, claim number MES 5. (Date of Loss: 9.10.2017).
Any proof of work including but not limited to documents, receipts, photographs,
invoices, estimates, reports, and any other document or thing regarding claim number 00]-00-
135685. (Date of Loss: 9.10.2017) and any other prior claims for the property located at 6635
Hood Street, Hollywood, FL 33024,
I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been sent
by email on this the 29th day of September, 2020, to Alan M. Blose, Esq., The Diener Firm, P.A.,
Attorneys for Plaintiff, service@dienerfirm.com, daniel@dienerfirm.com, alissa@dienerfirm.com.
BRONSTEIN & CARMONA, P.A.
Attorneys for Defendant
8000 Peters Road, Suite A-200
Fort Lauderdale, FL 33324
(954) 358-0444 — Phone
(954) 358-0445 — Fax
service@bronstein-carmona.com
By: /s/.
Michael R. Podolsky
Florida Bar No.: 105484
c: CourtScribes
Via email: scheduling@courtscribes.com
PLEASE PROVIDE VIDEOGRAPHER
Preview
Filing # 114106147 E-Filed 09/29/2020 11:43:37 AM 20-9562 MRP/im JIMMY AMAYA & AMELIS RAMOS, Plaintiff, Vv. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. iH IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. CACE 19-021027 (04) (Judge Sandra Perlman) DEFENDANT’S SECOND AMENDED NOTICE OF TAKING VIDEO DEPOSITION DUCES TECUM (coordinated with Denise Siegel as Opposing Counsel’s office on 8.18.20) PLEASE TAKE NOTICE that the undersigned attorney will take the deposition, VIA ZOOM, by oral examination of the person named below, at the time, on the date, at the hour, and place indicated: Deponent: Amelis Ramos Date & Time: December 3, 2020 at 1:00 p.m. or immediately following Jimmy Amaya’s deposition Location: VIA ZOOM CourtScribes - Hollywood 2719 Hollywood Boulevard Hollywood, Florida 33020 ZOOM INFORMATION: Courtscribes 44 is inviting you to a scheduled Zoom meeting. Topic: Depo of Jimmy Amaya (10am), Amelis Ramos (1pm) Time: Dec 3, 2020 10:00 AM Eastern Time (US and Canada) Join Zoom Meeting https://courtscribes.zoom.us/j/93054231324 Meeting ID: 930 5423 1324 One tap mobile +13017158592,,93054231324# US (Germantown) +13126266799,,93054231324# US (Chicago) Dial by your location +1 301 715 8592 US (Germantown) +1 312 626 6799 US (Chicago) +1 646 558 8656 US (New York) +1 253 215 8782 US (Tacoma) +1 346 248 7799 US (Houston) +1 669 900 6833 US (San Jose) 877 853 5247 US Toll-free 888 788 0099 US Toll-free Meeting ID: 930 5423 1324 Find your local number: https://courtscribes.zoom.us/u/ad4TLXBU49 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/29/2020 11:43:36 AM.****Jimmy Amaya & Amelis Ramos v. Citizens CASE NO. CACE 19-021027 (04) before an Associate or Deputy Court Reporter, Notary Public, or before any other duly qualified officer who is not of counsel to either of the parties or interested in the event of the cause. This deposition is being taken for the purposes of discovery, for use at trial, or for such other purposes as are permitted under the Florida Rules of Civil Procedure. The above-named deponent is hereby commanded to bring with her on the above-stated date, time and place the following items: Your entire file regarding this claim including, but not limited to, the following, Any documents, papers, tapes, invoices, videos, diagrams, statements, photographs, or any other thing received, reviewed or prepared by you relating to the property located at 6635 Hood Street, Hollywood, FL 33024, claim number MES 5. (Date of Loss: 9.10.2017). Any proof of work including but not limited to documents, receipts, photographs, invoices, estimates, reports, and any other document or thing regarding claim number 00]-00- 135685. (Date of Loss: 9.10.2017) and any other prior claims for the property located at 6635 Hood Street, Hollywood, FL 33024, I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been sent by email on this the 29th day of September, 2020, to Alan M. Blose, Esq., The Diener Firm, P.A., Attorneys for Plaintiff, service@dienerfirm.com, daniel@dienerfirm.com, alissa@dienerfirm.com. BRONSTEIN & CARMONA, P.A. Attorneys for Defendant 8000 Peters Road, Suite A-200 Fort Lauderdale, FL 33324 (954) 358-0444 — Phone (954) 358-0445 — Fax service@bronstein-carmona.com By: /s/. Michael R. Podolsky Florida Bar No.: 105484 c: CourtScribes Via email: scheduling@courtscribes.com PLEASE PROVIDE VIDEOGRAPHER