On August 23, 2021 a
Party Discovery
was filed
involving a dispute between
Liberis, Simson,
and
Brown, Curtis,
Geico General Insurance Company,
for Auto Negligence
in the District Court of Broward County.
Preview
Filing # 133248617 E-Filed 08/23/2021 08:58:25 PM
,th
IN THE CIRCUIT COURT OF THE 17L
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.:
SIMSON LIBERIS,
Plaintiff.
VS.
CURTIS BROWN and
GEICO GENERAL INSURANCE COMPANY,
Defendants.
I
NOTICE OF TAKING VIDEO DEPOSITION
PLEASE TAKE NOTICE that the undersigned attorney will take the videotapeddeposition
ofthe following:
PERSON: GEICO GENERAL INSURANCE COMPANY's Corporate Designee
pursuant to Florida Rule of Civil Procedures 1.310(b)(6) regarding:
A. Regarding purchasing of automobile insurance through the internet
including but not limited to the application process and all the necessary
forms that are to be signed and/or filled out by the Prospective Insured in
May, 2017;
B. Regarding the coverage provided by GEICO to an applicant who is
applying for insurance over the internet or on the telephone in 2017 by
default;
C. Regarding the Uninsured Motorist Coverage (UM) Selection/Rejection
Form and who within GEICO was responsible for submitting that form to
the Florida Office of Insurance Regulation for approval;
D. Regarding the submission of the Uninsured Motorist Coverage (UM)
Selection/RejectionForm to the Florida Office of Insurance Regulation
and whether the Office was advised that the subject form was to be
prefilled out by GEICO and was a static form;
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/23/2021 08:58:20 PM.****
E. Regarding the process that Plaintiff undertook when
applying for Florida
automobile insurance in or before May, 2017, whether over the telephone,
through an online interface, or through some combinationof the two;
F. Regarding the online DocuSign "signing ceremony" relating to the
Uninsured Motorist Coverage (UM) Selection/Rejection Form in May,
2017;
G. Regarding the selling of uninsured motorist insurance through the means
Plaintiffusedto apply for or purchase the GEICO policy(whether over the
telephone,through an online interface, or through some combinationof the
two) in May, 2017;
H. Regarding the decision to use a static motorist
rejection form in May, 2017;
I. Regarding the removal of the hyperlink to view the Uninsured Motorist
Coverage (UM) Selection/RejectionForm in or before May, 2017;
J. Regarding the language and/or words utilized by GEICO in the application
and quote process in May, 2017;
K. Regarding the language and instructions utilized for the DocuSign "signing
"
ceremony' process in May, 2017;
L. Regarding the quotes provided to Plaintiff in May, 2017;
M. Regarding language, directions and
the content of the information
to applicants for automobile
presented insurance coverage on the
GEICO.com website in May, 2017; and
N. Regarding the metadata for the subject M9FL form.
DATE: TBD
TIME: TBD
PLACE: TBD
upon oral examination before a Notary Public, or any officer authorized by law to take depositions
in the State of Florida. This oral examinationwill continue from day to day until completed. This
2
depositionis being taken for the purpose of discovery, for use at trial or for such other purposes as
are permitted under the applicable and governing rules of Court.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing Notice of Taking
Video Deposition was served with the Complaint and Summons.
/s/ Luke T. Moreau, Esq.
Luke T. Moreau, Esq.
Florida Bar No.: 108241
LAW OFFICES OF LUKE T. MOREAU, ESQ.
Counsel for the Plaintiff
1761 N. Young Circle, Suite 3-343
Hollywood, FL 33020
Phone: (954) 406-6757
Fax: (954) 212-9703
SILVERSTEIN, SILVERSTEIN
& SILVERSTEIN, P.A.
504 Aventura Corporate Center
20801 Biscayne Boulevard
Aventura, Florida 33180
MIAMI DADE -
(305) 935-2500
BROWARD -
(954) 463-1333
FACSIMILE -
(305) 935-3214
By: s/ GREGGA. SILVERSTEIN
Florida Bar #821853
Attorney for Plaintiff
/s/ Ivan A. Schertzer, Esq.
Ivan A. Schertzer, Esq.
Florida Bar No-311121
LAW OFFICES OF IVAN A. SCHERTZER
3
Co-Counsel.forthe Plaintiff
16211 NE 18th Avenue, Suite 100
North Miami Beach, FL 33162-4751
Phone: (305) 940-0007
Fax: (305) 354-8895
4
Document Filed Date
August 23, 2021
Case Filing Date
August 23, 2021
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Filing # 133248617 E-Filed 08/23/2021 08:58:25 PM ,th IN THE CIRCUIT COURT OF THE 17L JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: SIMSON LIBERIS, Plaintiff. VS. CURTIS BROWN and GEICO GENERAL INSURANCE COMPANY, Defendants. I NOTICE OF TAKING VIDEO DEPOSITION PLEASE TAKE NOTICE that the undersigned attorney will take the videotapeddeposition ofthe following: PERSON: GEICO GENERAL INSURANCE COMPANY's Corporate Designee pursuant to Florida Rule of Civil Procedures 1.310(b)(6) regarding: A. Regarding purchasing of automobile insurance through the internet including but not limited to the application process and all the necessary forms that are to be signed and/or filled out by the Prospective Insured in May, 2017; B. Regarding the coverage provided by GEICO to an applicant who is applying for insurance over the internet or on the telephone in 2017 by default; C. Regarding the Uninsured Motorist Coverage (UM) Selection/Rejection Form and who within GEICO was responsible for submitting that form to the Florida Office of Insurance Regulation for approval; D. Regarding the submission of the Uninsured Motorist Coverage (UM) Selection/RejectionForm to the Florida Office of Insurance Regulation and whether the Office was advised that the subject form was to be prefilled out by GEICO and was a static form; *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/23/2021 08:58:20 PM.**** E. Regarding the process that Plaintiff undertook when applying for Florida automobile insurance in or before May, 2017, whether over the telephone, through an online interface, or through some combinationof the two; F. Regarding the online DocuSign "signing ceremony" relating to the Uninsured Motorist Coverage (UM) Selection/Rejection Form in May, 2017; G. Regarding the selling of uninsured motorist insurance through the means Plaintiffusedto apply for or purchase the GEICO policy(whether over the telephone,through an online interface, or through some combinationof the two) in May, 2017; H. Regarding the decision to use a static motorist rejection form in May, 2017; I. Regarding the removal of the hyperlink to view the Uninsured Motorist Coverage (UM) Selection/RejectionForm in or before May, 2017; J. Regarding the language and/or words utilized by GEICO in the application and quote process in May, 2017; K. Regarding the language and instructions utilized for the DocuSign "signing " ceremony' process in May, 2017; L. Regarding the quotes provided to Plaintiff in May, 2017; M. Regarding language, directions and the content of the information to applicants for automobile presented insurance coverage on the GEICO.com website in May, 2017; and N. Regarding the metadata for the subject M9FL form. DATE: TBD TIME: TBD PLACE: TBD upon oral examination before a Notary Public, or any officer authorized by law to take depositions in the State of Florida. This oral examinationwill continue from day to day until completed. This 2 depositionis being taken for the purpose of discovery, for use at trial or for such other purposes as are permitted under the applicable and governing rules of Court. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing Notice of Taking Video Deposition was served with the Complaint and Summons. /s/ Luke T. Moreau, Esq. Luke T. Moreau, Esq. Florida Bar No.: 108241 LAW OFFICES OF LUKE T. MOREAU, ESQ. Counsel for the Plaintiff 1761 N. Young Circle, Suite 3-343 Hollywood, FL 33020 Phone: (954) 406-6757 Fax: (954) 212-9703 SILVERSTEIN, SILVERSTEIN & SILVERSTEIN, P.A. 504 Aventura Corporate Center 20801 Biscayne Boulevard Aventura, Florida 33180 MIAMI DADE - (305) 935-2500 BROWARD - (954) 463-1333 FACSIMILE - (305) 935-3214 By: s/ GREGGA. SILVERSTEIN Florida Bar #821853 Attorney for Plaintiff /s/ Ivan A. Schertzer, Esq. Ivan A. Schertzer, Esq. Florida Bar No-311121 LAW OFFICES OF IVAN A. SCHERTZER 3 Co-Counsel.forthe Plaintiff 16211 NE 18th Avenue, Suite 100 North Miami Beach, FL 33162-4751 Phone: (305) 940-0007 Fax: (305) 354-8895 4