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Filing # 107405570 E-Filed 05/13/2020 10:40:17 AM
20-9562
MRP/im
IN THE CIRCUIT COURT OF THE 17”!
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
JIMMY AMAYA & AMELIS RAMOS, CASE NO. CACE 19-021027 (04)
(Judge Sandra Perlman)
Plaintiff,
v.
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
/
AMENDED NOTICE OF TAKING VIDEO
DEPOSITION DUCES TECUM
(as to location only)
Scheduled unilaterally after attempting to clear with opposing counsel by email on 2.27.20;
3.17.20; 4.21.20; 5.11.20
PLEASE TAKE NOTICE that the undersigned attorney will take the deposition, either
in person, or via teleconference and/or videoconference, by oral examination of the person
named below, at the time, on the date, at the hour, and place indicated:
Deponent: Jimmy Amaya
Date & Time: August 12, 2020 at 10:00 a.m.
Location: CourtScribes - Hollywood
2719 Hollywood Boulevard
Hollywood, Florida 33020
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
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/13/2020 10:40:16 AM.****Jimmy Amaya & Amelis Ramos v. Citizens
CASE NO. CACE 19-021027 (04)
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 001-00-135685. (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 13th day of May, 2020, to Daniel Cruz, 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
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Filing # 107405570 E-Filed 05/13/2020 10:40:17 AM 20-9562 MRP/im IN THE CIRCUIT COURT OF THE 17”! JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA JIMMY AMAYA & AMELIS RAMOS, CASE NO. CACE 19-021027 (04) (Judge Sandra Perlman) Plaintiff, v. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. / AMENDED NOTICE OF TAKING VIDEO DEPOSITION DUCES TECUM (as to location only) Scheduled unilaterally after attempting to clear with opposing counsel by email on 2.27.20; 3.17.20; 4.21.20; 5.11.20 PLEASE TAKE NOTICE that the undersigned attorney will take the deposition, either in person, or via teleconference and/or videoconference, by oral examination of the person named below, at the time, on the date, at the hour, and place indicated: Deponent: Jimmy Amaya Date & Time: August 12, 2020 at 10:00 a.m. Location: CourtScribes - Hollywood 2719 Hollywood Boulevard Hollywood, Florida 33020 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 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/13/2020 10:40:16 AM.****Jimmy Amaya & Amelis Ramos v. Citizens CASE NO. CACE 19-021027 (04) 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 001-00-135685. (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 13th day of May, 2020, to Daniel Cruz, 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