On December 16, 2019 a
Notice of Taking Deposition Duces Tecum
was filed
involving a dispute between
Mertil, Francky,
Mertil, Marth,
and
Citizens Property Insurance Corporation,
for Contract and Indebtedness
in the District Court of Broward County.
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Filing # 102743067 E-Filed 02/04/2020 04:16:55 PM
0116031
IN THE COUNTY COURT FOR THE
SEVENTEENTH JUDICIAL CIRCUIT IN
AND FOR BROWARD COUNTY,
FLORIDA
CASE NO.: CACE-19-025657
FRANCKY MERTIL,
Plaintiff,
<
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
NOTICE OF TAKING VIDEOTAPED DEPOSITIONS DUCES TECUM
PLEASE TAKE NOTICE that the undersigned will take the videotaped depositions duces
tecum of the following:
NAME: Francky Mertil Marth Etienne
DATE: Thursday, May 7", 2020 Thursday, May 7", 2020
TIME: 11:00 a.m. 12:00 p.m.
ADDRESS: Veritext Reporting, One East Broward Blvd., Suite 902, Ft. Lauderdale, FL
33301
PLEASE BRING THE FOLLOWING DOCUMENTS TO BE PRODUCED AT
DEPOSITION:
1. Any and all receipts for work performed at the property 9610 Dunhill Drive,
Miramar, FL 33025 after the claims occurring on 1/31/19.
2. Photographs before and after this incident of the interior and exterior of the subject
property located at 9610 Dunhill Drive, Miramar, FL 33025.
3. Any and all documentation establishing any prior and post incident repairs to the
areas at issue.
4. Any and all maintenance and/or service records of the subject property.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/04/2020 04:16:55 PM.****Mertil v. Citizens (CLAI.103956)
Case No.: CACE-19-025657
Page 2
5. Any and all receipts, cancelled checks, invoices, estimates, reports, or any other
documentation for any repairs and/or renovations made to the property located at
9610 Dunhill Drive, Miramar, FL 33025 that were preformed by you.
6. Any and all receipts, cancelled checks, invoices, estimates, reports or any other
documentation for any repairs and/or renovations made to the property located at
9610 Dunhill Drive, Miramar, FL 33025 subsequent to the claims occurring on
1/31/19.
upon oral examination, before Veritext Reporting, a Notary Public, or any other Notary Public or
officer duly 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 both of the foregoing, or for such other purposes as are permitted under
the applicable and governing rules.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via the
Florida Courts Efiling Portal this 4" day of February 2020 to all counsel on the attached service list.
Kubicki Draper
One East Broward Boulevard
Suite 1600
Fort Lauderdale, FL 33301
Direct Line:954-713-2334
FBN: 323004
/s/Earleen Cote
BY:
Earleen Cote
SERVICE LIST
Kaneily A. Valdes, Esq.
Marin, Eljaiek, Lopez & Martinez P.L.
2601 South Bayshore Drive
18th Floor
Coconut Grove, Florida 33133
Eservice@mellawyers.com
Mellaw1@mellawyers.com
Preview
Filing # 102743067 E-Filed 02/04/2020 04:16:55 PM 0116031 IN THE COUNTY COURT FOR THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-19-025657 FRANCKY MERTIL, Plaintiff, < CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. NOTICE OF TAKING VIDEOTAPED DEPOSITIONS DUCES TECUM PLEASE TAKE NOTICE that the undersigned will take the videotaped depositions duces tecum of the following: NAME: Francky Mertil Marth Etienne DATE: Thursday, May 7", 2020 Thursday, May 7", 2020 TIME: 11:00 a.m. 12:00 p.m. ADDRESS: Veritext Reporting, One East Broward Blvd., Suite 902, Ft. Lauderdale, FL 33301 PLEASE BRING THE FOLLOWING DOCUMENTS TO BE PRODUCED AT DEPOSITION: 1. Any and all receipts for work performed at the property 9610 Dunhill Drive, Miramar, FL 33025 after the claims occurring on 1/31/19. 2. Photographs before and after this incident of the interior and exterior of the subject property located at 9610 Dunhill Drive, Miramar, FL 33025. 3. Any and all documentation establishing any prior and post incident repairs to the areas at issue. 4. Any and all maintenance and/or service records of the subject property. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/04/2020 04:16:55 PM.****Mertil v. Citizens (CLAI.103956) Case No.: CACE-19-025657 Page 2 5. Any and all receipts, cancelled checks, invoices, estimates, reports, or any other documentation for any repairs and/or renovations made to the property located at 9610 Dunhill Drive, Miramar, FL 33025 that were preformed by you. 6. Any and all receipts, cancelled checks, invoices, estimates, reports or any other documentation for any repairs and/or renovations made to the property located at 9610 Dunhill Drive, Miramar, FL 33025 subsequent to the claims occurring on 1/31/19. upon oral examination, before Veritext Reporting, a Notary Public, or any other Notary Public or officer duly 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 both of the foregoing, or for such other purposes as are permitted under the applicable and governing rules. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via the Florida Courts Efiling Portal this 4" day of February 2020 to all counsel on the attached service list. Kubicki Draper One East Broward Boulevard Suite 1600 Fort Lauderdale, FL 33301 Direct Line:954-713-2334 FBN: 323004 /s/Earleen Cote BY: Earleen Cote SERVICE LIST Kaneily A. Valdes, Esq. Marin, Eljaiek, Lopez & Martinez P.L. 2601 South Bayshore Drive 18th Floor Coconut Grove, Florida 33133 Eservice@mellawyers.com Mellaw1@mellawyers.com