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Filing # 134104575 E-Filed 09/07/2021 01:11:48 PM
IN THE CIRCUIT COURT OF THE 17,TH
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO: CACE 20-017837
KEITH FORBES,
Plaintiff(s),
VS.
HERITAGE PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
i
DEFENDANT'S NOTICE OF TAKING DEPOSITIONDUCES TECUM OF PLAINTIFF
(Pleaseadvise ifan Interpreteris needed)
PLEASE TAKE NOTICE that the undersigned attorney will take the depositions duces
tecum of.
NAME:
KEITH FORBES
DATE:
September 16, 2021
TIME:
1:30 P.M.
LOCATION:
COGENT LEGAL SERVICES/ZOOM LINK TO BE
PROVIDED
Upon oral examination before Cogent Legal Services, Notary Public or any other notary public or
officer authorized by law to take depositions in the State of Florida. The oral examination will
continue from day to day until completed. This deposition is being taken for the purpose of
discovery, for use at trial, or for such other purposes as are permitted under the rules of Court.
Deponent shall bring with him/her all pertaining documents as per Schedule "A" attached
hereto.
Staff Counsel, HeritageProperty& Casualty InsuranceCompany
1571 Sawgrass Corporate Parkway, Suite 400, Sunrise,Florida 33323
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/07/2021 01:11:48 PM.****
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy ofthe foregoing was servedvia E-portal
to Aaron D. Silvers, Esq., Schilling & Silvers, PLLC, 1314 E. Las Olas Boulevard, Unit 2191, Fort
Lauderdale, FL 33301
at
and
on this 71
'th day of September 2021, pursuantto Rule 2.516.
COUNSEL FOR HERITAGE PROPERTY &
CASUALTY INSURANCE COMPANY
1571 Sawgrass Corporate Parkway, Suite 400
Sunrise, Florida 33323
Office: (954) 315-1450
Facsimile: (954) 533-3202
By-. /s/ Precious M. Lawrence
PRECIOUS M. LAWRENCE, ESQ.
Florida Bar No.. 126841
For service ofprocess,please also include:
Staff Counsel, HeritageProperty& Casualty InsuranceCompany
1571 Sawgrass Corporate Parkway, Suite 400, Sunrise,Florida 33323
SCHEDULE "A"
1.
All documents, including but not limited to receipts, cancelled checks or any other
documents which evidence any repairs, renovations, or constructionto the insured
property at any time after the loss which gave rise to claim number HP209556.
This request contemplates inclusion of, but not limited to, all documents and
records evidencing the actual amount spent to repair or replace damage to the
Subject Propertylocatedat 11999 Eagle Trace Blvd., Coral Springs,Florida 33071,
subsequent to the October 10, 2018 loss.
2.
All documents,including but not limited to receipts, cancelled checks or any other
documents which evidence any repairs, renovations, or constructionto the insured
property at any time before the loss which gave rise to claim number HP209556.
This request contemplates inclusion of, but not limited to, all documents and
records evidencing the actual amount spent to repair or replace damage to the
Subject Propertylocatedat 11999 Eagle Trace Blvd., Coral Springs,Florida 33071,
prior to the October 10,2018 loss.
3.
Any and all photographs,pictures, or videos taken by you of the Subject Property
located at 18911 NW 10111, Hollywood, Florida 33029, depicting the alleged
October 10, 2018 loss and damages at issue and being claimed in Plaintiff' s
Complaint.
4.
A complete list of all items of personal property claimed to have been lost or
damaged as a result of the loss which occurred on or around October 10, 2018,
including the dates each item was purchased, where purchased, documentationof
purchase price and payment of same, identityofthe purchaser, and whereabouts of
each item at the time of the loss(es). In addition, please provide documentationof
any and all costs incurred to replace items of personal property claimed to have
been lost or damaged as a result of the subject loss(es), where purchased,
documentation of purchase price and payment of same, and identity of the
purchaser.
5.
Any and all documents that refer, relate, and/or concern the claimed October 10,
2018 loss in the Subject Property located at 11999 Eagle Trace Blvd., Coral
Springs, Florida 33071, including, but not limited to, a completecopy ofall reports,
repair estimate, proposals, permits, agreements, contracts, invoices, receipts,
inspection, drawings, graphs, charts, photographs,telephonemessages, and/or any
and all other data in your possession, custody, or control.
6.
All pictorial representationsofthe subject building(s) and personal property before
and after the subject loss(es)in any form, including but not limited to photographic,
video, electronic or digital formats.
7.
Copies of any engineering or other professional reports that have been prepared
concerning the damages claimed, including but not limited to structural damage
assessments.
Staff Counsel, HeritageProperty& Casualty InsuranceCompany
1571 Sawgrass Corporate Parkway, Suite 400, Sunrise,Florida 33323
8.
A list of all contractors, companies and/or persons, including contact information,
who have done any work or repairs to the property since you have owned the
property to present, including any and all documentation of work or repairs
completed since you have owned the property to the present, including but not
limited to any and all repair estimates and contracts regarding same.
9.
A list of all contractors, companies and/or persons, including contact information,
who have performed any inspectionsofthe subjectdamaged property,prepared any
estimates or proposals regarding same since you have owned the property through
the present date, including but not limited to any and all repair estimates and
contracts regarding same.
10.
A list of all policies ofinsurance underwhich coverage for your propertythat is the
subject of this claim that was effective at any time you owned the property,
including name of insurer, contact information, and claim number for any claims
that have been filed regarding the subject property.
11.
A list of all prior losses and insurance claims for any properties you own or have
owned, including dates of loss(es), cause of loss(es), property damaged, identity of
any insurers for which claims were submitted or that may have afforded coverage
for such property.
12.
All records evidencingpayment(s) to any contractorswho have performed work at
the subject property and/or costs incurred to replace any personal property items
claimed damaged.
13.
Name and contact informationfor any persons that have leased and/or rented from
you any part of the subject property at any time, including a copy of any and all
agreements regarding same.
14.
All inspection reports prepared at any time since you have ownedthe property.
15.
All documents supporting your claim.
16.
Any and all reports, estimates or repair estimates in your possession, custody or
control describing, depicting, or breaking down the alleged repairs needed in the
Subject Propertylocatedat 11999 Eagle Trace Blvd., Coral Springs,Florida 33071,
as a result of the alleged October 10, 2018 loss and damages at issue and being
claimed in Plaintiff's Complaint.
17.
Any and all correspondence between you, your representatives, or vendors and
Defendant regarding claim number HP209556.
Staff Counsel, HeritageProperty& Casualty InsuranceCompany
1571 Sawgrass Corporate Parkway, Suite 400, Sunrise,Florida 33323
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Filing # 134104575 E-Filed 09/07/2021 01:11:48 PM IN THE CIRCUIT COURT OF THE 17,TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO: CACE 20-017837 KEITH FORBES, Plaintiff(s), VS. HERITAGE PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. i DEFENDANT'S NOTICE OF TAKING DEPOSITIONDUCES TECUM OF PLAINTIFF (Pleaseadvise ifan Interpreteris needed) PLEASE TAKE NOTICE that the undersigned attorney will take the depositions duces tecum of. NAME: KEITH FORBES DATE: September 16, 2021 TIME: 1:30 P.M. LOCATION: COGENT LEGAL SERVICES/ZOOM LINK TO BE PROVIDED Upon oral examination before Cogent Legal Services, Notary Public or any other notary public or officer authorized by law to take depositions in the State of Florida. The oral examination will continue from day to day until completed. This deposition is being taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted under the rules of Court. Deponent shall bring with him/her all pertaining documents as per Schedule "A" attached hereto. Staff Counsel, HeritageProperty& Casualty InsuranceCompany 1571 Sawgrass Corporate Parkway, Suite 400, Sunrise,Florida 33323 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/07/2021 01:11:48 PM.**** CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy ofthe foregoing was servedvia E-portal to Aaron D. Silvers, Esq., Schilling & Silvers, PLLC, 1314 E. Las Olas Boulevard, Unit 2191, Fort Lauderdale, FL 33301 at and on this 71 'th day of September 2021, pursuantto Rule 2.516. COUNSEL FOR HERITAGE PROPERTY & CASUALTY INSURANCE COMPANY 1571 Sawgrass Corporate Parkway, Suite 400 Sunrise, Florida 33323 Office: (954) 315-1450 Facsimile: (954) 533-3202 By-. /s/ Precious M. Lawrence PRECIOUS M. LAWRENCE, ESQ. Florida Bar No.. 126841 For service ofprocess,please also include: Staff Counsel, HeritageProperty& Casualty InsuranceCompany 1571 Sawgrass Corporate Parkway, Suite 400, Sunrise,Florida 33323 SCHEDULE "A" 1. All documents, including but not limited to receipts, cancelled checks or any other documents which evidence any repairs, renovations, or constructionto the insured property at any time after the loss which gave rise to claim number HP209556. This request contemplates inclusion of, but not limited to, all documents and records evidencing the actual amount spent to repair or replace damage to the Subject Propertylocatedat 11999 Eagle Trace Blvd., Coral Springs,Florida 33071, subsequent to the October 10, 2018 loss. 2. All documents,including but not limited to receipts, cancelled checks or any other documents which evidence any repairs, renovations, or constructionto the insured property at any time before the loss which gave rise to claim number HP209556. This request contemplates inclusion of, but not limited to, all documents and records evidencing the actual amount spent to repair or replace damage to the Subject Propertylocatedat 11999 Eagle Trace Blvd., Coral Springs,Florida 33071, prior to the October 10,2018 loss. 3. Any and all photographs,pictures, or videos taken by you of the Subject Property located at 18911 NW 10111, Hollywood, Florida 33029, depicting the alleged October 10, 2018 loss and damages at issue and being claimed in Plaintiff' s Complaint. 4. A complete list of all items of personal property claimed to have been lost or damaged as a result of the loss which occurred on or around October 10, 2018, including the dates each item was purchased, where purchased, documentationof purchase price and payment of same, identityofthe purchaser, and whereabouts of each item at the time of the loss(es). In addition, please provide documentationof any and all costs incurred to replace items of personal property claimed to have been lost or damaged as a result of the subject loss(es), where purchased, documentation of purchase price and payment of same, and identity of the purchaser. 5. Any and all documents that refer, relate, and/or concern the claimed October 10, 2018 loss in the Subject Property located at 11999 Eagle Trace Blvd., Coral Springs, Florida 33071, including, but not limited to, a completecopy ofall reports, repair estimate, proposals, permits, agreements, contracts, invoices, receipts, inspection, drawings, graphs, charts, photographs,telephonemessages, and/or any and all other data in your possession, custody, or control. 6. All pictorial representationsofthe subject building(s) and personal property before and after the subject loss(es)in any form, including but not limited to photographic, video, electronic or digital formats. 7. Copies of any engineering or other professional reports that have been prepared concerning the damages claimed, including but not limited to structural damage assessments. Staff Counsel, HeritageProperty& Casualty InsuranceCompany 1571 Sawgrass Corporate Parkway, Suite 400, Sunrise,Florida 33323 8. A list of all contractors, companies and/or persons, including contact information, who have done any work or repairs to the property since you have owned the property to present, including any and all documentation of work or repairs completed since you have owned the property to the present, including but not limited to any and all repair estimates and contracts regarding same. 9. A list of all contractors, companies and/or persons, including contact information, who have performed any inspectionsofthe subjectdamaged property,prepared any estimates or proposals regarding same since you have owned the property through the present date, including but not limited to any and all repair estimates and contracts regarding same. 10. A list of all policies ofinsurance underwhich coverage for your propertythat is the subject of this claim that was effective at any time you owned the property, including name of insurer, contact information, and claim number for any claims that have been filed regarding the subject property. 11. A list of all prior losses and insurance claims for any properties you own or have owned, including dates of loss(es), cause of loss(es), property damaged, identity of any insurers for which claims were submitted or that may have afforded coverage for such property. 12. All records evidencingpayment(s) to any contractorswho have performed work at the subject property and/or costs incurred to replace any personal property items claimed damaged. 13. Name and contact informationfor any persons that have leased and/or rented from you any part of the subject property at any time, including a copy of any and all agreements regarding same. 14. All inspection reports prepared at any time since you have ownedthe property. 15. All documents supporting your claim. 16. Any and all reports, estimates or repair estimates in your possession, custody or control describing, depicting, or breaking down the alleged repairs needed in the Subject Propertylocatedat 11999 Eagle Trace Blvd., Coral Springs,Florida 33071, as a result of the alleged October 10, 2018 loss and damages at issue and being claimed in Plaintiff's Complaint. 17. Any and all correspondence between you, your representatives, or vendors and Defendant regarding claim number HP209556. Staff Counsel, HeritageProperty& Casualty InsuranceCompany 1571 Sawgrass Corporate Parkway, Suite 400, Sunrise,Florida 33323