Preview
Filing # 123324430 E-Filed 03/18/2021 11:41:20 AM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR BROWARD
COUNTY, FLORIDA
Case No. CACE-19-021361
RICARDO CAYOBIT AND ROLAND
CAYUBIT,
Plaintiffs,
vs.
UNITED PROPERTY AND CASUALTY
INSURANCE,
Defendant.
MOTION TO COMPEL PLAINTIFF’S DEPOSITION
COMES NOW, the Defendant, UNITED PROPERTY AND CASUALTY COMPANY
(UNITED), and hereby requests the Court for an order compelling the Plaintiff RICARDO
CAYOBIT (PLAINTIFF), to provide dates for the taking of his deposition, and as grounds
would show:
1. On January 16, 2020, Plaintiff filed a Notice of Taking the Video Deposition of
PLAINTIFF which was scheduled for March 19, 2020. See Ex. 1.
2. On March 19, 2020, the deposition was re-noticed for May 21, 2020. See Ex.
3. The case was again re-noticed for June 3, 2020. See Ex. 3.
4. As a courtesy to Plaintiffs Counsel, and at its request, the re-noticed
deposition was cancelled on June 2, 2020. See Ex. 4.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/18/2021 11:41:19 AM.****5. Since this last cancellation, Plaintiff has not offered Defendant with new
deposition dates.
6. Additionally, on February 24, 2021 and again on February 26, 2021,
Defendant provided proposed deposition dates for PLAINTIFF’S deposition in an effort to
coordinate. See Ex. 5.
7. To date, both e-mails have gone responded by Plaintiff.
8. Defendant has made every effort to accommodate and to coordinate with
Plaintiff, yet Defendant has still not been able to depose Plaintiff. We now seek the Court’s
intervention in this matter.
9. Considering that our first request for this deposition occurred on or about
January 2020, we are requesting that Plaintiffs deposition be taken within thirty days of this
order unless specifically agreed to otherwise by Defendant.
WHEREFORE, the Defendant, UNITED PROPERTY INSURANCE & CASUALTY
COMPANY, respectfully requests that this Honorable Court grant the instant motion and
order the Plaintiff to provide dates for the deposition of the Plaintiff which shall occur within
thirty days.
CERTIFICATE OF SERVICE ON FOLLOWING PAGECERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished
by e-mail to Robin A. Richison, robin@lawlp.com; maritza@lawip.com; LEVY &
PARTNERS, LLC, The Yankee Clipper Law Center, , 3230 Stirling Road, Suite 1,
Hollywood, FL 33021, 954-727-8570, this 18" day of March, 2021.
By_/s/ Ailene S. Rogers
AILENE S. ROGERS.
Florida Bar # 964379
PETERSON BERNARD
Attorneys for United Property And Casualty
Insurance Company
707 S.E. 3 Avenue, Suite 500
Fort Lauderdale, Florida 33316
(954) 763-3200
(954) 728-9019 facsimile
ailene.rogers@petersonbernard.com
sandy.dodamead@petersonbernard.com
ASR/cc
123.23855Filing # 101778990 E-Filed 01/16/2020 02:13:07 PM EXHIBIT 1
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR BROWARD
COUNTY, FLORIDA
Case No. CACE-19-021361
RICARDO CAYOBIT AND ROLAND
CAYUBIT,
Plaintiffs,
VS.
UNITED PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
/
NOTICE OF TAKING VIDEO DEPOSITION
(PLEASE ADVISE IF AN INTERPRETER IS NEEDED)
(Coordinated with Maritza Gutman of OC’s office)
YOU, as attorneys for the respective parties, are hereby notified that the undersigned will take
the deposition by oral examination for purposes of discovery and for use as evidence in said cause, or
both, of the following:
NAME AND ADDRESS: | RICARDO CAYOBIT
DATE AND TIME: March 19, 2020
11:00 a.m.
LOCATION: U.S. Legal Support
100 Northeast 3" Avenue
Suite 1050
Ft. Lauderdale FL 33301
(954) 463-2933
Said deposition(s) and video recording will be taken before U.S. Legal Support, a Notary
Public or any other officer authorized to administer oaths by the laws of the State of Florida, and a
person who is neither a relative, nor employee, nor attomey, nor counsel of any of the parties, and
who is neither a relative nor employee of such attorney or counsel, and who is not financially
interested in the action. The video deposition(s) Operator will be U.S. Legal Support, 100
Northeast 3™ Avenue, Suite 1050, Ft. Lauderdale, FL 33301.
Property Address: 17905 SW 33", Street, Miramar, FL 33029
Date of Loss: 9/10/17Said deposition to be taken pursuant to the Florida Rules of Civil Procedure in such cases
provided. The said oral examination will continue from hour to hour and from day to day until
completed.
W WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by
e-mail to Robin A. Richison, robin@lawlp.com; maritza@lawlp.com; LEVY & PARTNERS, LLC,
The Yankee Clipper Law Center, , 3230 Stirling Road, Suite 1, Hollywood, FL 33021, 954-727-8570,
this 16", day of January, 2020.
By_/s/ Kimberley S. Brown
KIMBERLEY S. BROWN
Florida Bar # 013294
PETERSON BERNARD
Attomeys for United Property & Casualty Insurance
Company
707 S.E. 3" Avenue, Suite 500
Fort Lauderdale, Florida 33316
(954) 763-3200
(954) 728-9019 facsimile
Kimberley.brown@petersonbernard.com;
sandy.singh@petersonbernard.com;
KSB/shs
123.23845
ce: US. Legal Support
100 NE 3" Avenue, Suite 1050
Ft. Lauderdale, FL 33301
(954)-463-2933
BILLING INFORMATION:
Brown, Lisa
UPC Insurance
800 2nd Avenue South
St. Petersburg, FL 33701
Claim No. 2019FL120077EXHIBIT 2
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR BROWARD
COUNTY, FLORIDA
Case No. CACE-19-021361
RICARDO CAYOBIT AND ROLAND
CAYOBIT,
Plaintiffs,
vs.
UNITED PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
/
RE-NOTICE OF TAKING “VIDEO” DEPOSITION
(previous date: 3/19/20 - cancelled due to Coronavirus precaution)
YOU, as attorneys for the respective parties, are hereby notified that the undersigned has re-
scheduled the deposition by oral examination for purposes of discovery and for use as evidence in
said cause, or both, of the following:
NAME: RICARDO CAYOBIT
DATE AND TIME: Friday, May 21, 2020
11:00 a.m.
LOCATION: U.S. Legal Support
100 Northeast 3™ Avenue
Suite 1050
Ft. Lauderdale FL 33301
(954) 463-2933
Said deposition and video recording will be taken before U.S. Legal Support, a Notary Public
or any other officer authorized to administer oaths by the laws of the State of Florida, and a person
who is neither a relative, nor employee, nor attorney, nor counsel of any of the parties, and who is
neither a relative nor employee of such attorney or counsel, and who is not financially interested in
the action. The video deposition Operator will be U.S. Legal Support, 100 Northeast 3" Avenue,
Suite 1050, Ft. Lauderdale, FL 33301.
Property Address: 17905 SW 33", Street, Miramar, FL 33029
Date of Loss: 9/10/17Said deposition to be taken pursuant to the Florida Rules of Civil Procedure in such cases
provided. The said oral examination will continue from hour to hour and from day to day until
completed.
W WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by
e-mail to Robin A. Richison, robin@lawlp.com; maritza@lawlp.com; LEVY & PARTNERS, LLC,
The Yankee Clipper Law Center, , 3230 Stirling Road, Suite 1, Hollywood, FL 33021, 954-727-8570,
this 19" day of March, 2020, along w/E-Service to the Court.
By_/s/ Kimberley S. Brown
KIMBERLEY S. BROWN
Florida Bar # 013294
PETERSON BERNARD
Attomeys for United Property & Casualty Insurance
Company
707 S.E. 3 Avenue, Suite 500
Fort Lauderdale, Florida 33316
(954) 763-3200
(954) 728-9019 facsimile
Kimberley.brown@petersonbernard.com;
Paula.noritis@petersonbernard.com
KSB/shs/pIn
123.23855
ce: US. Legal Support
100 NE 3" Avenue, Suite 1050
Ft. Lauderdale, FL 33301
(954)-463-2933
BILLING INFORMATION:
Brown, Lisa
UPC Insurance
800 2nd Avenue South
St. Petersburg, FL 33701
Claim No. 2019FL120077EXHIBIT 3
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR BROWARD
COUNTY, FLORIDA
Case No. CACE-19-021361
RICARDO CAYOBIT AND ROLAND
CAYOBIT,
Plaintiffs,
vs.
UNITED PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
/
2° RE-NOTICE OF TAKING “VIDEO” DEPOSITION
YOU, as attorneys for the respective parties, are hereby notified that the undersigned has re-
scheduled the deposition by oral examination for purposes of discovery and for use as evidence in
said cause, or both, of the following:
NAME: RICARDO CAYOBIT
DATE AND TIME: Wednesday, June 3, 2020
11:00 a.m.
LOCATION: U.S. Legal Support
100 Northeast 3™ Avenue
Suite 1050
Ft. Lauderdale FL 33301
(954) 463-2933
Said deposition and video recording will be taken before U.S. Legal Support, a Notary Public or any
other officer authorized to administer oaths by the laws of the State of Florida, and a person who is
neither a relative, nor employee, nor attorney, nor counsel of any of the parties, and who is neither a
relative nor employee of such attomey or counsel, and who is not financially interested in the action.
The video deposition Operator will be U.S. Legal Support, 100 Northeast 3™ Avenue, Suite 1050,
Ft. Lauderdale, FL 33301.
Property Address: 17905 SW 33", Street, Miramar, FL 33029
Date of Loss: 9/10/17Said deposition to be taken pursuant to the Florida Rules of Civil Procedure in such cases
provided. The said oral examination will continue from hour to hour and from day to day until
completed.
W WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by
e-mail to Robin A. Richison, robin@lawlp.com; maritza@lawlp.com; LEVY & PARTNERS, LLC,
The Yankee Clipper Law Center, , 3230 Stirling Road, Suite 1, Hollywood, FL 33021, 954-727-8570,
this 19" day of March, 2020, along w/E-Service to the Court.
By_/s/ Kimberley S. Brown
KIMBERLEY S. BROWN
Florida Bar # 013294
PETERSON BERNARD
Attomeys for United Property & Casualty Insurance
Company
707 S.E. 3 Avenue, Suite 500
Fort Lauderdale, Florida 33316
(954) 763-3200
(954) 728-9019 facsimile
Kimberley.brown@petersonbernard.com;
Paula.noritis@petersonbernard.com
KSB/shs/pIn
123.23855
ce: US. Legal Support
100 NE 3" Avenue, Suite 1050
Ft. Lauderdale, FL 33301
(954)-463-2933
BILLING INFORMATION:
Brown, Lisa
UPC Insurance
800 2nd Avenue South
St. Petersburg, FL 33701
Claim No. 2019FL120077EXHIBIT 4
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR BROWARD
COUNTY, FLORIDA
Case No. CACE-19-021361
RICARDO CAYOBIT AND ROLAND
CAYOBIT,
Plaintiffs,
vs.
UNITED PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
/
NOTICE OF CANCELLATION OF DEPOSITION
YOU, as attorneys for the respective parties, are hereby notified that the
following deposition is CANCELLED.
NAME: RICARDO CAYOBIT
DATE AND TIME: Wednesday, June 3, 2020
11:00 a.m.
LOCATION: U.S. Legal Support
100 Northeast 3 Avenue
Suite 1050
Ft. Lauderdale FL 33301
(954) 463-2933
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was fumished
by e-mail to Robin A. Richison, robin@lawlp.com; maritza@lawip.com; LEVY &
PARTNERS, LLC, The Yankee Clipper Law Center, , 3230 Stirling Road, Suite 1,
Hollywood, FL 33021, 954-727-8570, this ana day of June, 2020, along w/E-Service to the
Court.By_/s/ Ailene S. Rogers
AILENE S. ROGERS
Florida Bar # 964379
PETERSON BERNARD
Attorneys for United Property And Casualty
Insurance Company
707 S.E. 3% Avenue, Suite 500
Fort Lauderdale, Florida 33316
(954) 763-3200
(954) 728-9019 facsimile
ailene.rogers@petersonbernard.com
sandy.dodamead@petersonbemard.com
ASRijve
123.23855EXHIBIT 5
From: ‘Sandi J. Blouin
To: Maritza Gutman; robin@lawip.com
Ce: Carlton Campbell
Subject: RE: Cayobit v. United Property & Casualty - Claim No. 2019FL20077 File No, 23845 and Claim No. 2019F120079
File No. 23855
Date: Friday, February 26, 2021 9:45:05 AM
Good morning,
Iam following up on the email below regarding scheduling the Plaintiffs depositions. Please
provide their availability on March 15, 16, 17, 18 and 23, beginning at 10:00 a.m. or 1:00 p.m.
If none of these dates are good, please provide their availability.
Thank you.
Sandi J. Blouin, Legal Assistant to
Amy B. Talisman, Esq.
PETERSON BERNARD
707 S.E. Third Avenue, Suite 500
Fort Lauderdale, Florida 33316
(954) 763-3200 Phone Ext. 1126
(954) 728-9019 Fax
Email: sandi-blouin@petersonbernard.com
Peterson@Bernard
CONFIDENTIALITY NOTICE: This e-mail message including attachments, if any, is intended for the
person or entity to which it is addressed and may contain confidential and/or privileged material.
Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended
recipient, please contact the sender by reply e-mail and destroy all copies of the original message.
Thank you.
From: Sandi J. Blouin
Sent: Wednesday, February 24, 2021 11:11 AM
To: 'Maritza Gutman’ ; 'robin@lawlp.com'
Subject: Cayobit v. United Property & Casualty - Claim No. 2019FL20077 File No. 23845 and Claim
No. 2019FL20079 File No. 23855
Good afternoon,
We would like to reschedule the Plaintiffs depositions in the above matters. Please provide
their availability on March 15, 16, 17, 18 and 23, beginning at 10:00 a.m. or 1:00 p.m.
Thank you. Have a good day!
Sincerely,Sandi J. Blouin, Legal Assistant to
Amy B. Talisman, Esq.
PETERSON BERNARD
707 S.E. Third Avenue, Suite 500
Fort Lauderdale, Florida 33316
(954) 763-3200 Phone Ext. 1126
(954) 728-9019 Fax
Email: sandi,.blouin@ rsonbernar
Peterson@ Bernard
CONFIDENTIALITY NOTICE: This e-mail message including attachments, if any, is intended for the
person or entity to which it is addressed and may contain confidential and/or privileged material.
Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended
recipient, please contact the sender by reply e-mail and destroy all copies of the original message.
Thank you.
Preview
Filing # 123324430 E-Filed 03/18/2021 11:41:20 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA Case No. CACE-19-021361 RICARDO CAYOBIT AND ROLAND CAYUBIT, Plaintiffs, vs. UNITED PROPERTY AND CASUALTY INSURANCE, Defendant. MOTION TO COMPEL PLAINTIFF’S DEPOSITION COMES NOW, the Defendant, UNITED PROPERTY AND CASUALTY COMPANY (UNITED), and hereby requests the Court for an order compelling the Plaintiff RICARDO CAYOBIT (PLAINTIFF), to provide dates for the taking of his deposition, and as grounds would show: 1. On January 16, 2020, Plaintiff filed a Notice of Taking the Video Deposition of PLAINTIFF which was scheduled for March 19, 2020. See Ex. 1. 2. On March 19, 2020, the deposition was re-noticed for May 21, 2020. See Ex. 3. The case was again re-noticed for June 3, 2020. See Ex. 3. 4. As a courtesy to Plaintiffs Counsel, and at its request, the re-noticed deposition was cancelled on June 2, 2020. See Ex. 4. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/18/2021 11:41:19 AM.****5. Since this last cancellation, Plaintiff has not offered Defendant with new deposition dates. 6. Additionally, on February 24, 2021 and again on February 26, 2021, Defendant provided proposed deposition dates for PLAINTIFF’S deposition in an effort to coordinate. See Ex. 5. 7. To date, both e-mails have gone responded by Plaintiff. 8. Defendant has made every effort to accommodate and to coordinate with Plaintiff, yet Defendant has still not been able to depose Plaintiff. We now seek the Court’s intervention in this matter. 9. Considering that our first request for this deposition occurred on or about January 2020, we are requesting that Plaintiffs deposition be taken within thirty days of this order unless specifically agreed to otherwise by Defendant. WHEREFORE, the Defendant, UNITED PROPERTY INSURANCE & CASUALTY COMPANY, respectfully requests that this Honorable Court grant the instant motion and order the Plaintiff to provide dates for the deposition of the Plaintiff which shall occur within thirty days. CERTIFICATE OF SERVICE ON FOLLOWING PAGECERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by e-mail to Robin A. Richison, robin@lawlp.com; maritza@lawip.com; LEVY & PARTNERS, LLC, The Yankee Clipper Law Center, , 3230 Stirling Road, Suite 1, Hollywood, FL 33021, 954-727-8570, this 18" day of March, 2021. By_/s/ Ailene S. Rogers AILENE S. ROGERS. Florida Bar # 964379 PETERSON BERNARD Attorneys for United Property And Casualty Insurance Company 707 S.E. 3 Avenue, Suite 500 Fort Lauderdale, Florida 33316 (954) 763-3200 (954) 728-9019 facsimile ailene.rogers@petersonbernard.com sandy.dodamead@petersonbernard.com ASR/cc 123.23855Filing # 101778990 E-Filed 01/16/2020 02:13:07 PM EXHIBIT 1 IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA Case No. CACE-19-021361 RICARDO CAYOBIT AND ROLAND CAYUBIT, Plaintiffs, VS. UNITED PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. / NOTICE OF TAKING VIDEO DEPOSITION (PLEASE ADVISE IF AN INTERPRETER IS NEEDED) (Coordinated with Maritza Gutman of OC’s office) YOU, as attorneys for the respective parties, are hereby notified that the undersigned will take the deposition by oral examination for purposes of discovery and for use as evidence in said cause, or both, of the following: NAME AND ADDRESS: | RICARDO CAYOBIT DATE AND TIME: March 19, 2020 11:00 a.m. LOCATION: U.S. Legal Support 100 Northeast 3" Avenue Suite 1050 Ft. Lauderdale FL 33301 (954) 463-2933 Said deposition(s) and video recording will be taken before U.S. Legal Support, a Notary Public or any other officer authorized to administer oaths by the laws of the State of Florida, and a person who is neither a relative, nor employee, nor attomey, nor counsel of any of the parties, and who is neither a relative nor employee of such attorney or counsel, and who is not financially interested in the action. The video deposition(s) Operator will be U.S. Legal Support, 100 Northeast 3™ Avenue, Suite 1050, Ft. Lauderdale, FL 33301. Property Address: 17905 SW 33", Street, Miramar, FL 33029 Date of Loss: 9/10/17Said deposition to be taken pursuant to the Florida Rules of Civil Procedure in such cases provided. The said oral examination will continue from hour to hour and from day to day until completed. W WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by e-mail to Robin A. Richison, robin@lawlp.com; maritza@lawlp.com; LEVY & PARTNERS, LLC, The Yankee Clipper Law Center, , 3230 Stirling Road, Suite 1, Hollywood, FL 33021, 954-727-8570, this 16", day of January, 2020. By_/s/ Kimberley S. Brown KIMBERLEY S. BROWN Florida Bar # 013294 PETERSON BERNARD Attomeys for United Property & Casualty Insurance Company 707 S.E. 3" Avenue, Suite 500 Fort Lauderdale, Florida 33316 (954) 763-3200 (954) 728-9019 facsimile Kimberley.brown@petersonbernard.com; sandy.singh@petersonbernard.com; KSB/shs 123.23845 ce: US. Legal Support 100 NE 3" Avenue, Suite 1050 Ft. Lauderdale, FL 33301 (954)-463-2933 BILLING INFORMATION: Brown, Lisa UPC Insurance 800 2nd Avenue South St. Petersburg, FL 33701 Claim No. 2019FL120077EXHIBIT 2 IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA Case No. CACE-19-021361 RICARDO CAYOBIT AND ROLAND CAYOBIT, Plaintiffs, vs. UNITED PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. / RE-NOTICE OF TAKING “VIDEO” DEPOSITION (previous date: 3/19/20 - cancelled due to Coronavirus precaution) YOU, as attorneys for the respective parties, are hereby notified that the undersigned has re- scheduled the deposition by oral examination for purposes of discovery and for use as evidence in said cause, or both, of the following: NAME: RICARDO CAYOBIT DATE AND TIME: Friday, May 21, 2020 11:00 a.m. LOCATION: U.S. Legal Support 100 Northeast 3™ Avenue Suite 1050 Ft. Lauderdale FL 33301 (954) 463-2933 Said deposition and video recording will be taken before U.S. Legal Support, a Notary Public or any other officer authorized to administer oaths by the laws of the State of Florida, and a person who is neither a relative, nor employee, nor attorney, nor counsel of any of the parties, and who is neither a relative nor employee of such attorney or counsel, and who is not financially interested in the action. The video deposition Operator will be U.S. Legal Support, 100 Northeast 3" Avenue, Suite 1050, Ft. Lauderdale, FL 33301. Property Address: 17905 SW 33", Street, Miramar, FL 33029 Date of Loss: 9/10/17Said deposition to be taken pursuant to the Florida Rules of Civil Procedure in such cases provided. The said oral examination will continue from hour to hour and from day to day until completed. W WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by e-mail to Robin A. Richison, robin@lawlp.com; maritza@lawlp.com; LEVY & PARTNERS, LLC, The Yankee Clipper Law Center, , 3230 Stirling Road, Suite 1, Hollywood, FL 33021, 954-727-8570, this 19" day of March, 2020, along w/E-Service to the Court. By_/s/ Kimberley S. Brown KIMBERLEY S. BROWN Florida Bar # 013294 PETERSON BERNARD Attomeys for United Property & Casualty Insurance Company 707 S.E. 3 Avenue, Suite 500 Fort Lauderdale, Florida 33316 (954) 763-3200 (954) 728-9019 facsimile Kimberley.brown@petersonbernard.com; Paula.noritis@petersonbernard.com KSB/shs/pIn 123.23855 ce: US. Legal Support 100 NE 3" Avenue, Suite 1050 Ft. Lauderdale, FL 33301 (954)-463-2933 BILLING INFORMATION: Brown, Lisa UPC Insurance 800 2nd Avenue South St. Petersburg, FL 33701 Claim No. 2019FL120077EXHIBIT 3 IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA Case No. CACE-19-021361 RICARDO CAYOBIT AND ROLAND CAYOBIT, Plaintiffs, vs. UNITED PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. / 2° RE-NOTICE OF TAKING “VIDEO” DEPOSITION YOU, as attorneys for the respective parties, are hereby notified that the undersigned has re- scheduled the deposition by oral examination for purposes of discovery and for use as evidence in said cause, or both, of the following: NAME: RICARDO CAYOBIT DATE AND TIME: Wednesday, June 3, 2020 11:00 a.m. LOCATION: U.S. Legal Support 100 Northeast 3™ Avenue Suite 1050 Ft. Lauderdale FL 33301 (954) 463-2933 Said deposition and video recording will be taken before U.S. Legal Support, a Notary Public or any other officer authorized to administer oaths by the laws of the State of Florida, and a person who is neither a relative, nor employee, nor attorney, nor counsel of any of the parties, and who is neither a relative nor employee of such attomey or counsel, and who is not financially interested in the action. The video deposition Operator will be U.S. Legal Support, 100 Northeast 3™ Avenue, Suite 1050, Ft. Lauderdale, FL 33301. Property Address: 17905 SW 33", Street, Miramar, FL 33029 Date of Loss: 9/10/17Said deposition to be taken pursuant to the Florida Rules of Civil Procedure in such cases provided. The said oral examination will continue from hour to hour and from day to day until completed. W WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by e-mail to Robin A. Richison, robin@lawlp.com; maritza@lawlp.com; LEVY & PARTNERS, LLC, The Yankee Clipper Law Center, , 3230 Stirling Road, Suite 1, Hollywood, FL 33021, 954-727-8570, this 19" day of March, 2020, along w/E-Service to the Court. By_/s/ Kimberley S. Brown KIMBERLEY S. BROWN Florida Bar # 013294 PETERSON BERNARD Attomeys for United Property & Casualty Insurance Company 707 S.E. 3 Avenue, Suite 500 Fort Lauderdale, Florida 33316 (954) 763-3200 (954) 728-9019 facsimile Kimberley.brown@petersonbernard.com; Paula.noritis@petersonbernard.com KSB/shs/pIn 123.23855 ce: US. Legal Support 100 NE 3" Avenue, Suite 1050 Ft. Lauderdale, FL 33301 (954)-463-2933 BILLING INFORMATION: Brown, Lisa UPC Insurance 800 2nd Avenue South St. Petersburg, FL 33701 Claim No. 2019FL120077EXHIBIT 4 IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA Case No. CACE-19-021361 RICARDO CAYOBIT AND ROLAND CAYOBIT, Plaintiffs, vs. UNITED PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. / NOTICE OF CANCELLATION OF DEPOSITION YOU, as attorneys for the respective parties, are hereby notified that the following deposition is CANCELLED. NAME: RICARDO CAYOBIT DATE AND TIME: Wednesday, June 3, 2020 11:00 a.m. LOCATION: U.S. Legal Support 100 Northeast 3 Avenue Suite 1050 Ft. Lauderdale FL 33301 (954) 463-2933 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was fumished by e-mail to Robin A. Richison, robin@lawlp.com; maritza@lawip.com; LEVY & PARTNERS, LLC, The Yankee Clipper Law Center, , 3230 Stirling Road, Suite 1, Hollywood, FL 33021, 954-727-8570, this ana day of June, 2020, along w/E-Service to the Court.By_/s/ Ailene S. Rogers AILENE S. ROGERS Florida Bar # 964379 PETERSON BERNARD Attorneys for United Property And Casualty Insurance Company 707 S.E. 3% Avenue, Suite 500 Fort Lauderdale, Florida 33316 (954) 763-3200 (954) 728-9019 facsimile ailene.rogers@petersonbernard.com sandy.dodamead@petersonbemard.com ASRijve 123.23855EXHIBIT 5 From: ‘Sandi J. Blouin To: Maritza Gutman; robin@lawip.com Ce: Carlton Campbell Subject: RE: Cayobit v. United Property & Casualty - Claim No. 2019FL20077 File No, 23845 and Claim No. 2019F120079 File No. 23855 Date: Friday, February 26, 2021 9:45:05 AM Good morning, Iam following up on the email below regarding scheduling the Plaintiffs depositions. Please provide their availability on March 15, 16, 17, 18 and 23, beginning at 10:00 a.m. or 1:00 p.m. If none of these dates are good, please provide their availability. Thank you. Sandi J. Blouin, Legal Assistant to Amy B. Talisman, Esq. PETERSON BERNARD 707 S.E. Third Avenue, Suite 500 Fort Lauderdale, Florida 33316 (954) 763-3200 Phone Ext. 1126 (954) 728-9019 Fax Email: sandi-blouin@petersonbernard.com Peterson@Bernard CONFIDENTIALITY NOTICE: This e-mail message including attachments, if any, is intended for the person or entity to which it is addressed and may contain confidential and/or privileged material. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. Thank you. From: Sandi J. Blouin Sent: Wednesday, February 24, 2021 11:11 AM To: 'Maritza Gutman’ ; 'robin@lawlp.com' Subject: Cayobit v. United Property & Casualty - Claim No. 2019FL20077 File No. 23845 and Claim No. 2019FL20079 File No. 23855 Good afternoon, We would like to reschedule the Plaintiffs depositions in the above matters. Please provide their availability on March 15, 16, 17, 18 and 23, beginning at 10:00 a.m. or 1:00 p.m. Thank you. Have a good day! Sincerely,Sandi J. Blouin, Legal Assistant to Amy B. Talisman, Esq. PETERSON BERNARD 707 S.E. Third Avenue, Suite 500 Fort Lauderdale, Florida 33316 (954) 763-3200 Phone Ext. 1126 (954) 728-9019 Fax Email: sandi,.blouin@ rsonbernar Peterson@ Bernard CONFIDENTIALITY NOTICE: This e-mail message including attachments, if any, is intended for the person or entity to which it is addressed and may contain confidential and/or privileged material. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. Thank you.