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Filing # 138789943 E-Filed 11/18/2021 11:26:58 AM
IN THE CIRCUIT COURT, OF THE
15" JUDICIAL CIRCUIT, IN AND FOR
PALM BEACH COUNTY, FLORIDA
CASE NO: 50-2121-CA-001896-XXXX-MB
DIVISION: AK
MARC HARRIS and NADIA JOSEPH-HARRIS,
Plaintiff,
vs.
ALAN DENSEN
Defendant,
PLAINTIFFS’ MOTION TO COMPEL DEPOSITION
PLAINTIFFS, MARC HARRIS and NADIA JOSEPH-HARRIS, by and through the
undersigned counsel, hereby file this motion to compel depositions and as grounds states as follows:
1. Plaintiffs are seeking, and Defendant is refusing to provide dates for, the depositions of
Mr. Alan Densen.
2. Defendant’s Deposition was initially scheduled for June 21, 2021, via Zoom Link
meeting.
3. On or about June 17, 2021, Defendant’s counsel reached out to our office advising that
Mr. Densen “does not know how to do a video conference and there is no one home to assist him
with this” and requested the deposition to take place via phone. See Exhibit “A”.
4. Our office did not agree with Defendant’s request to appear via telephone at his
deposition and decided to cancel the deposition to avoid late cancelation fee. See Exhibit “B”
5. Plaintiffs requested dates for the depositions via separate emails sent on June 21, 2021,
September 16, 2021, September 20, 2021, September 22, 2021, October 26, 2021. To date, Defendant
has not provided any dates. See Composite Exhibit “C”
'** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 11/18/2021 11:26:58 AM ***6. Plaintiffs are prejudiced by Defendant’s failure to provide dates for the deposition as
it prevents Plaintiffs from conducting discovery and efficiently preparing the case for trial.
WHEREFORE, Plaintiffs respectfully request that this Court enter an order compelling the
deposition of Defendant, Alan Densen, and any other relief this Court deems just and proper.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the was filed electronically
and was sent by E-Mail from the Florida’s Court’s E-Filing Portal system, unless other noted below,
on all counsel or parties of record listed below, this 18" day of November 2021. The foregoing
document has also been sent from the undersigned counsel by E-Mail to all counsel or parties of
record listed below.
LAW OFFICES OF ROBERT J. SMITI
Attn: Tamar K. Solarin, Esq.
4443 Lyons Road, Suite 206
Coconut Creek, FL 33073
Telephone: (954) 334-3050
Toll Free: (877) 250-9958
Attorney Direct: (954) 767-1384
Fax: (877) 838-0840
FTLAUDERDALELEGAL@ALLSTATE.COM
Respectfully submitted,
SCHULER, HALVORSON, WEISSER,
ZOELLER & OVERBECK, P.A.
1615 Forum Place, Suite 4D
West Palm Beach, FL 33401
Telephone: (561) 689-8180
Facsimile: (888) 969-0199
Attomeys for Plaintiff
hjoss@shw-law.com; darriaga@shw-law.com:
wzoeller@shw-law.com; tcoffey@shw-law.com
By:_/s/Harrison A. Joss, Esquire
William D. Zoeller, Esq.
Florida Bar No: 155233
Harrison A. Joss, Esq.
Florida Bar No.: 118289Exhibit A
From: Romero, Kelly J.
Sent: Wednesday, June 16, 2021 11:14 AM
To: Amanda Coates ; Eric C. Hayden
Subject: Harris et al vs. Densen-0569004542.1 - WE NEED THE ZOOM DETAILS FOR DEPO SET WITH OUR CLIENT ON
MONDAY JUNE 21ST AT 2PM PLEASE
Importance: High
Good Morning,
Zoom Depo of Alan Densen is set June 21* at 2pm we will need the zoom details before the end of day tomorrow so |
can relate that to our client, we are off on Friday in honor of Juneteenth, thank you.
Kelly J. Romero
Legal Admin/Scheduler for Angelina Capece & Chuck Obianagu
Law Offices of Robert J. Smith, P.A.
Staff Counsel for Allstate
110 S.E. 6th. Street, Suite 1800
Fort Lauderdale, Florida 33301
PRINCIPAL E-MAIL ADDRESS FOR SERVICE OF PLEADINGS: FtLauderdaleLegal@Allstate.com
Personal e-mail address: Kelly.Romero@Allstate.com
Telephone: 954-767-1396
Fax: 877-838-0840
ATTENTION: Due to concerns regarding the COVID-19 virus, please be
advised that Allstate Staff Counsel — Fort Lauderdale is operating with limited
on-site staffing. During this time, please serve all pleadings and other
documentation via e-mail to to FtLauderdaleLegal@allstate.com Thank you for
attention and patience.
ALSO: During COVID 19 Pandemic, we are working remotely and request that you NOT mail
anything to our office. If you must mail, call us in advance so we can make arrangements,
but kindly email or fax if possible. Thank you.Exhibit B
@ie\o/o/6)
Trial Attorneys with offices in West Palm Beach and Delray Beach. For more
information, please visit our website at http: / /www.shw-law.com,
Disclaimer: This e-mail is intended only for the individual(s) or entity(s) named within the message. This e-mail might contain
legally privileged and confidential information. If you properly received this e-mail as a client or retained expert, please hold
it in confidence to protect the attorney-client or work product privileges. Should the intended recipient forward or disclose
this message to another person or party, that action could constitute a waiver of the attorney-client privilege. If the reader of
this message is not the intended recipient, or the agent responsible to deliver it to the intended recipient, you are hereby
notified that any review, dissemination, distribution or copying of this communication is prohibited by the sender and to do
So might constitute a violation of the Electronic Communications Privacy Act, 18 U.S.C. section 2510-2521. If this
communication was received in error we apologize for the intrusion. Please notify us by reply e-mail and delete the original
message. Nothing in this e-mail message shall, in and of itself, create an attorney-client relationship with the sender. This e-
mail address is unable to receive attached files that pose a cyber security risk along with files in excess of 10MB in size.
Contact the sender for information on file transmission.
From: Eric C. Hayden
Sent: Friday, June 18, 2021 5:26 PM
To: Romero, Kelly J,
Cc: Solarin, Tamar ; Amanda Coates
Subject: RE: Harris et al vs, Densen-0569004542.1 - REGARDING ZOOM DEPO OF ALAN DENSEN
Kelly,
We are cancelling this deposition to avoid incurring a late cancellation charge from the court reporter as we have not
received a response from your office as to how your client was going to appear for Monday's deposition. The Notice of
Cancellation will be filed shortly, and my office will be in touch to re-schedule the deposition.
Sincerely,
Eric C. Hayden, Esq.
Civil Trial Lawyer
Schuler, Halvorson, Weisser, Zoeller, Overbeck, & Baxter P.A.
1615 Forum Place 4D
West Palm Beach, FL 33401
(561) 689-8180
(561) 684-9683
attorneys at lew
(B3\)
aTrial Attorneys serving the Entire State of Florida. For more information, please visit
our website at http: //www.shw-law.com/
Disclaimer: This e-mail is intended only for the individual(s) or entity(s) named within the message. This e-mail might contain
legally privileged and confidential information. If you properly received this e-mail as a client or retained expert, please hold
it in confidence to protect the attorney-client or work product privileges. Should the intended recipient forward or disclose
this message to another person or party, that action could constitute a waiver of the attorney-client privilege. If the reader of
this message is not the intended recipient, or the agent responsible to deliver it to the intended recipient, you are hereby
notified that any review, dissemination, distribution or copying of this communication is prohibited by the sender and to do
so might constitute a violation of the Electronic Communications Privacy Act, 18 U.S.C. section 2510-2521. If this
communication was received in error we apologize for the intrusion. Please notify us by reply e-mail and delete the original
message. Nothing in this e-mail message shall, in and of itself, create an attorney-client relationship with the sender. This e-
mail address is unable to receive attached files that pose a cyber security risk along with files in excess of 10MB in size.
Contact the sender for information on file transmission.
From: Amanda Coates
Sent: Friday, June 18, 2021 2:51 PM
To: Romero, Kelly J. ; Eric C. Hayden
Ce: Solarin, Tamar
Subject: RE: Harris et al vs. Densen-0569004542.1 - REGARDING ZOOM DEPO OF ALAN DENSEN
Good morning,
Mr. Hayden is not in agreement to allow the Defendant to appear for his deposition by call in, he may appear in person
at our Court Reporter's office or will need to appear by video conferencing through zoom. Please advise as to how this
issue may be resolved.
Does he have the option of appearing in your office and appearing via video conference from there so he may be
assisted on June 21, 2021?
Kind Regards,
Amanda. Coatey
Litigation Paralegal for Eric C. Hayden, Esq.
Schuler, Halvorson, Weisser, Zoeller, Overbeck, & Baxter P.A.
1615 Forum Place 4D
West Palm Beach, FL 33401
(561) 689-8180
(561) 684-9683
SCHULER
HALVORSON
WEISSERComposite Exhibit 'C
Diana Ar aga
From: Diana Arriaga
Sent: Tuesday, October 26, 2021 4:21 PM
To: Romero, Kelly J.
Subject: RE: Harris et al vs. Densen-0569004542.1
Good afternoon,
Can you please advise as to the status of your client's deposition dates?
Diana M. Arriaga, FRP
to Michael D. Dickenson, Esq. & Harrison A. Jos
SCHULER
_ .. HALVORSON
. WEISSER
‘. ZOELLER
_- 4 OVERBECK
BAXTER
1615 Forum Place, Suite 4D
West Palm Beach, FL 33401
(561)689-8180 — Telephone
(561)684-9683 — Fax
(800)689-8180 — Toll Free
Esq.
Best Lenvvers
BEST
LAW FIRMS,
This electronic message transmission contains information from the law offices of SCHULER, HALVORSON, WEISSER, ZOELLER OVERBECK,
BAXTER, P.A. which may be confidential or privileged. The information is intended for the use of the individual or entity named above. If you are not
the intended recipient, be aware that any disclosure, copying, distribution or use of the contents of this information is prohibited.
laimer: This e-mail is intended only for the individual(s) or entity(s) named within the message. This e-mail might contain legally privileged and
confidential information. If you properly received this e-mail as a client or retained expert, please hold it in confidence to protect the attorney-client
or work product privileges. Should the intended recipient forward or disclose this message to another person or party, that action could constitute
a waiver of the attorney-client privilege. If the reader of this message is not the intended recipient, or the agent responsible to deliver it to the
intended recipient, you are hereby notified that any review, dissemination, distribution or copying of this communication is prohibited by the sender
and to do so might constitute a violation of the Electronic Communications Privacy Act, 18 U.S.C. section 2510-2521. if this communication was
received in error we apologize for the intrusion. Please notify us by reply e-mail and delete the original message. Nothing in this e-mail message
shall, in and of itself, create an attorney-client relationship with the sender.
From: Romero, Kelly J.
Sent: Wednesday, October 6, 2021 7:35 AM
To: Diana Arriaga Subject: Harris et al vs. Densen-0569004542.1
Importance: High
Good Morning,
| have not been able to confirm dates to set the deposition of Alan Densen, October 12" will not work for Tamar. | will
gather date/times with our client and let you know before the end of the week, thank you.
Kelly J. Romero
Legal Admin/Scheduler for Angelina Capece & Chuck Obianagu
Litigation Services
The Law Offices of Robert J. Smith
Staff Counsel
All Staff Members are Employees of
Allstate Insurance Company
This Office is not a Partnership or a Corporation
4443 Lyons Road, Suite 206
Coconut Creek, FL 33073
PRINCIPAL E-MAIL ADDRESS FOR SERVICE OF PLEADINGS: FtLauderdaleLegal@Allstate.com
Personal E-Mail Address, not for service of pleadings: Kelly.Romero@Allstate.com
Telephone: 954.767.1396
Toll Free: 877-250-9958
Fax: 877-838-0840
Connect by Skype or Teams
Telephone: 954-767-1396
Fax: 877-838-0840Diana Ar ga
From: Diana Arriaga
Sent: Wednesday, September 22, 2021 9:42 AM
To: "KELLY.ROMERO@Allstate.com’; 'Solarin, Tamar’
Ce: Harrison A. Joss
Subject: RE: Initial Request or reset Defendant's deposition - RE: Harris et al vs.
Densen-0569004542.1 - REGARDING ZOOM DEPO OF ALAN DENSEN 2nd Request
Good morning,
Following up on this. Please advise. If we don’t hear from by Friday, September 24, 2021, we will schedule the
deposition for October 5".
Thank you,
Diana M. Arriaga, FRP
to Michael D. Dickenson, Esq.
SCHULER
HALVORSON
», WEISSER
* * ZORLLER
©: (OVERBECK
BAXTER
1615 Forum Place, Suite 4D
West Palm Beach, FL 33401
(561)689-8180 - Telephone
(561)684-9683 — Fax
(800)689-8180 — Toll Free
Emails: Mdickenson@shw-law.com; Darriaga@shw-law.com
This electronic message transmission contains information from the law offices of SCHULER, HALVORSON, WEISSER, ZOELLER OVERBECK,
BAXTER, P.A. which may be confidential or privileged. The information is intended for the use of the individual or entity named above. If you are not
the intended recipient, be aware that any disclosure, copying, distribution or use of the contents of this information is prohibited.
Disclaimer: This e-mail is intended only for the individual(s) or entity(s) named within the message. This e-mail might contain legally privileged and
confidential information. If you properly received this e-mail as a client or retained expert, please hold it in confidence to Protect the attorney-client
or work product privileges. Should the intended recipient forward or disclose this message to another person or party, that action could constitute
a waiver of the attorney-client privilege. If the reader of this message is not the intended recipient, or the agent responsible to deliver it to the
intended recipient, you are hereby notified that any review, dissemination, distribution or copying of this communication is prohibited by the sender
and to do so might constitute a violation of the Electronic Communications Privacy Act, 18 U.S.C. section 2510-2521. If this communication was
received in error we apologize for the intrusion. Please notify us by reply e-mail and delete the original message. Nothing in this e-mail message
shall, in and of itself, create an attorney-client relationship with the sender.From: Diana Arriaga
Sent: Monday, September 20, 2021 1:12 PM
To: KELLY. ROMERO @AlIstate.com; Solarin, Tamar
Cc: Harrison A. Joss
Subject: RE: Initial Request or reset Defendant's deposition - RE: Harris et al vs. Densen-0569004542.1 - REGARDING
ZOOM DEPO OF ALAN DENSEN 2nd Request
Good afternoon,
| wanted to follow up on this. Please advise if 10/5; 10/6/; 10/7 all at 10am will work for your client.
Thank you,
Diana M. Arriaga, FRP
to Michael D. Dickenson, Esq.
-SCHULER
© HALVORSON
~ WEISSER
» ZOELLER
| OVERBECK
“BAXTER
at law
1615 Forum Place, Suite 4D
West Palm Beach, FL 33401
(561)689-8180 — Telephone
(561)684-9683 — Fax
(800)689-8 180 — Toll Free
Emails: Mdickenson@shw-law.com; Darriaga@shw-law.com
This electronic message transmission contains information from the law offices of SCHULER, HALVORSON, WEISSER, ZOELLER OVERBECK,
BAXTER, P.A. which may be confidential or privileged. The information is intended for the use of the individual or entity named above. If you are not
the intended recipient, be aware that any disclosure, copying, distribution or use of the contents of this information is prohibited.
Disclaimer: This e-mail is intended only for the individual(s) or entity(s) named within the message. This e-mail might contain legally privileged and
confidential information. If you properly received this e-mail as a client or retained expert, please hold it in confidence to protect the attorney-client
or work product privileges. Should the intended recipient forward or disclose this message to another person or party, that action could constitute
a waiver of the attorney-client privilege. If the reader of this message is not the intended recipient, or the agent responsible to deliver it to the
intended recipient, you are hereby notified that any review, dissemination, distribution or copying of this communication is prohibited by the sender
and to do so might constitute a violation of the Electronic Communications Privacy Act, 18 U.S.C. section 2510-2521. If this communication was
received in error we apologize for the intrusion. Please notify us by reply e-mail and delete the original message. Nothing in this e-mail message
shall, in and of itself, create an attorney-client relationship with the sender.
From: Diana Arriaga
Sent: Thursday, September 16, 2021 8:57 AM
To: KELLY.ROMERO@Allstate.com; Solarin, Tamar
Cc: Harrison A. Joss
Subject: RE: Initial Request or reset Defendant's deposition - RE: Harris et al vs. Densen-0569004542.1 - REGARDING
2ZOOM DEPO OF ALAN DENSEN
Importance: High
Good morning,
Mr. Harrison Joss will be the new attorney for the Plaintiffs. Please direct all future correspondence to our attention.
That being said, we would like to re-schedule the Deposition of the Defendant. To avoid any issues, and to make it
easier for the Defendant, we will set this Deposition at a Court Reporter’s office.
Mr. Joss is available on any of the following dates:
10/5; 10/6/; 10/7 at 10am.
Thank you and | look forward to hearing from you.
Diana M. Arriaga, FRP
to Michael D. Dickenson, Esq.
SCHULER
HALVORSON
/ \WEISSER
~ ZOELLER
OVERBECK
BAXTER
attri at hae
1615 Forum Place, Suite 4D
West Palm Beach, FL 33401
(561)689-8180 — Telephone
(561 )684-9683 — Fax
(800)689-8180 — Toll Free
Emails: Mdickenson@shw-law.com; Darriaga@shw-law.com
LORIDA
ECISTERED
PARALEGA
pra
This electronic message transmission contains information from the law offices of SCHULER, HALVORSON, WEISSER, ZOELLER OVERBECK,
BAXTER, P.A. which may be confidential or privileged. The information is intended for the use of the individual or entity named above. If you are not
the intended recipient, be aware that any disclosure, copying, distribution or use of the contents of this information is prohibited.
laimer: This e-mail is intended only for the individual(s) or entity(s) named within the message. This e-mail might contain legally privileged and
confidential information. If you properly received this e-mail as a client or retained expert, please hold it in confidence to protect the attorney-client
or work product privileges. Should the intended recipient forward or disclose this message to another person or party, that action could constitute
a waiver of the attorney-client privilege. If the reader of this message is not the intended recipient, or the agent responsible to deliver it to the
intended recipient, you are hereby notified that any review, dissemination, distribution or copying of this communication is prohibited by the sender
and to do so might constitute a violation of the Electronic Communications Privacy Act, 18 U.S.C. section 2510-2521. If this communication was
received in error we apologize for the intrusion. Please notify us by reply e-mail and delete the original message. Nothing in this e-mail message
shall, in and of itself, create an attorney-client relationship with the sender.
From: Amanda Coates
Sent: Monday, June 21, 2021 1:16 PM
To: Romero, Kelly J. Cc: Solarin, Tamar ; Eric C. Hayden
Subject: Initial Request or reset Defendant's deposition - RE: Harris et al vs. Densen-0569004542.1 - REGARDING ZOOM
DEPO OF ALAN DENSEN
Importance: High
Good afternoon,
Please provide your client’s availability for his deposition as soon as possible. We have not heard back from your office
and as you know his deposition was supposed to be occurring today at 2:00 p.m. Since your client is unable to attend by
video conferencing we can conduct his deposition in person. Please advise.
| look forward to hearing from you.
Kind Regards,
Amanda. Coutey
Litigation Paralegal for Eric C. Hayden, Esq.
Schuler, Halvorson, Weisser, Zoeller, Overbeck, & Baxter P.A.
1615 Forum Place 4D
West Palm Beach, FL 33401
(561) 689-8180
(561) 684-9683
Trial Attorneys with offices in West Palm Beach and Delray Beach. For more
information, please visit our website at http://www. shw-law.com/
Disclaimer: This e-mail is intended only for the individual(s) or entity(s) named within the message. This e-mail might contain
legally privileged and confidential information. If you properly received this e-mail as a client or retained expert, please hold
it in confidence to protect the attorney-client or work product privileges. Should the intended recipient forward or disclose
this message to another person or party, that action could constitute a waiver of the attorney-client privilege. If the reader of
this message is not the intended recipient, or the agent responsible to deliver it to the intended recipient, you are hereby
notified that any review, dissemination, distribution or copying of this communication is prohibited by the sender and to do
so might constitute a violation of the Electronic Communications Privacy Act, 18 U.S.C. section 2510-2521. If this
communication was received in error we apologize for the intrusion. Please notify us by reply e-mail and delete the original
message. Nothing in this e-mail message shall, in and of itself, create an attorney-client relationship with the sender. This e-
mail address is unable to receive attached files that pose a cyber security risk along with files in excess of 10MB in size.
Contact the sender for information on file transmission.
Preview
Filing # 138789943 E-Filed 11/18/2021 11:26:58 AM IN THE CIRCUIT COURT, OF THE 15" JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 50-2121-CA-001896-XXXX-MB DIVISION: AK MARC HARRIS and NADIA JOSEPH-HARRIS, Plaintiff, vs. ALAN DENSEN Defendant, PLAINTIFFS’ MOTION TO COMPEL DEPOSITION PLAINTIFFS, MARC HARRIS and NADIA JOSEPH-HARRIS, by and through the undersigned counsel, hereby file this motion to compel depositions and as grounds states as follows: 1. Plaintiffs are seeking, and Defendant is refusing to provide dates for, the depositions of Mr. Alan Densen. 2. Defendant’s Deposition was initially scheduled for June 21, 2021, via Zoom Link meeting. 3. On or about June 17, 2021, Defendant’s counsel reached out to our office advising that Mr. Densen “does not know how to do a video conference and there is no one home to assist him with this” and requested the deposition to take place via phone. See Exhibit “A”. 4. Our office did not agree with Defendant’s request to appear via telephone at his deposition and decided to cancel the deposition to avoid late cancelation fee. See Exhibit “B” 5. Plaintiffs requested dates for the depositions via separate emails sent on June 21, 2021, September 16, 2021, September 20, 2021, September 22, 2021, October 26, 2021. To date, Defendant has not provided any dates. See Composite Exhibit “C” '** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 11/18/2021 11:26:58 AM ***6. Plaintiffs are prejudiced by Defendant’s failure to provide dates for the deposition as it prevents Plaintiffs from conducting discovery and efficiently preparing the case for trial. WHEREFORE, Plaintiffs respectfully request that this Court enter an order compelling the deposition of Defendant, Alan Densen, and any other relief this Court deems just and proper. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the was filed electronically and was sent by E-Mail from the Florida’s Court’s E-Filing Portal system, unless other noted below, on all counsel or parties of record listed below, this 18" day of November 2021. The foregoing document has also been sent from the undersigned counsel by E-Mail to all counsel or parties of record listed below. LAW OFFICES OF ROBERT J. SMITI Attn: Tamar K. Solarin, Esq. 4443 Lyons Road, Suite 206 Coconut Creek, FL 33073 Telephone: (954) 334-3050 Toll Free: (877) 250-9958 Attorney Direct: (954) 767-1384 Fax: (877) 838-0840 FTLAUDERDALELEGAL@ALLSTATE.COM Respectfully submitted, SCHULER, HALVORSON, WEISSER, ZOELLER & OVERBECK, P.A. 1615 Forum Place, Suite 4D West Palm Beach, FL 33401 Telephone: (561) 689-8180 Facsimile: (888) 969-0199 Attomeys for Plaintiff hjoss@shw-law.com; darriaga@shw-law.com: wzoeller@shw-law.com; tcoffey@shw-law.com By:_/s/Harrison A. Joss, Esquire William D. Zoeller, Esq. Florida Bar No: 155233 Harrison A. Joss, Esq. Florida Bar No.: 118289Exhibit A From: Romero, Kelly J. Sent: Wednesday, June 16, 2021 11:14 AM To: Amanda Coates ; Eric C. Hayden Subject: Harris et al vs. Densen-0569004542.1 - WE NEED THE ZOOM DETAILS FOR DEPO SET WITH OUR CLIENT ON MONDAY JUNE 21ST AT 2PM PLEASE Importance: High Good Morning, Zoom Depo of Alan Densen is set June 21* at 2pm we will need the zoom details before the end of day tomorrow so | can relate that to our client, we are off on Friday in honor of Juneteenth, thank you. Kelly J. Romero Legal Admin/Scheduler for Angelina Capece & Chuck Obianagu Law Offices of Robert J. Smith, P.A. Staff Counsel for Allstate 110 S.E. 6th. Street, Suite 1800 Fort Lauderdale, Florida 33301 PRINCIPAL E-MAIL ADDRESS FOR SERVICE OF PLEADINGS: FtLauderdaleLegal@Allstate.com Personal e-mail address: Kelly.Romero@Allstate.com Telephone: 954-767-1396 Fax: 877-838-0840 ATTENTION: Due to concerns regarding the COVID-19 virus, please be advised that Allstate Staff Counsel — Fort Lauderdale is operating with limited on-site staffing. During this time, please serve all pleadings and other documentation via e-mail to to FtLauderdaleLegal@allstate.com Thank you for attention and patience. ALSO: During COVID 19 Pandemic, we are working remotely and request that you NOT mail anything to our office. If you must mail, call us in advance so we can make arrangements, but kindly email or fax if possible. Thank you.Exhibit B @ie\o/o/6) Trial Attorneys with offices in West Palm Beach and Delray Beach. For more information, please visit our website at http: / /www.shw-law.com, Disclaimer: This e-mail is intended only for the individual(s) or entity(s) named within the message. This e-mail might contain legally privileged and confidential information. If you properly received this e-mail as a client or retained expert, please hold it in confidence to protect the attorney-client or work product privileges. Should the intended recipient forward or disclose this message to another person or party, that action could constitute a waiver of the attorney-client privilege. If the reader of this message is not the intended recipient, or the agent responsible to deliver it to the intended recipient, you are hereby notified that any review, dissemination, distribution or copying of this communication is prohibited by the sender and to do So might constitute a violation of the Electronic Communications Privacy Act, 18 U.S.C. section 2510-2521. If this communication was received in error we apologize for the intrusion. Please notify us by reply e-mail and delete the original message. Nothing in this e-mail message shall, in and of itself, create an attorney-client relationship with the sender. This e- mail address is unable to receive attached files that pose a cyber security risk along with files in excess of 10MB in size. Contact the sender for information on file transmission. From: Eric C. Hayden Sent: Friday, June 18, 2021 5:26 PM To: Romero, Kelly J, Cc: Solarin, Tamar ; Amanda Coates Subject: RE: Harris et al vs, Densen-0569004542.1 - REGARDING ZOOM DEPO OF ALAN DENSEN Kelly, We are cancelling this deposition to avoid incurring a late cancellation charge from the court reporter as we have not received a response from your office as to how your client was going to appear for Monday's deposition. The Notice of Cancellation will be filed shortly, and my office will be in touch to re-schedule the deposition. Sincerely, Eric C. Hayden, Esq. Civil Trial Lawyer Schuler, Halvorson, Weisser, Zoeller, Overbeck, & Baxter P.A. 1615 Forum Place 4D West Palm Beach, FL 33401 (561) 689-8180 (561) 684-9683 attorneys at lew (B3\) aTrial Attorneys serving the Entire State of Florida. For more information, please visit our website at http: //www.shw-law.com/ Disclaimer: This e-mail is intended only for the individual(s) or entity(s) named within the message. This e-mail might contain legally privileged and confidential information. If you properly received this e-mail as a client or retained expert, please hold it in confidence to protect the attorney-client or work product privileges. Should the intended recipient forward or disclose this message to another person or party, that action could constitute a waiver of the attorney-client privilege. If the reader of this message is not the intended recipient, or the agent responsible to deliver it to the intended recipient, you are hereby notified that any review, dissemination, distribution or copying of this communication is prohibited by the sender and to do so might constitute a violation of the Electronic Communications Privacy Act, 18 U.S.C. section 2510-2521. If this communication was received in error we apologize for the intrusion. Please notify us by reply e-mail and delete the original message. Nothing in this e-mail message shall, in and of itself, create an attorney-client relationship with the sender. This e- mail address is unable to receive attached files that pose a cyber security risk along with files in excess of 10MB in size. Contact the sender for information on file transmission. From: Amanda Coates Sent: Friday, June 18, 2021 2:51 PM To: Romero, Kelly J. ; Eric C. Hayden Ce: Solarin, Tamar Subject: RE: Harris et al vs. Densen-0569004542.1 - REGARDING ZOOM DEPO OF ALAN DENSEN Good morning, Mr. Hayden is not in agreement to allow the Defendant to appear for his deposition by call in, he may appear in person at our Court Reporter's office or will need to appear by video conferencing through zoom. Please advise as to how this issue may be resolved. Does he have the option of appearing in your office and appearing via video conference from there so he may be assisted on June 21, 2021? Kind Regards, Amanda. Coatey Litigation Paralegal for Eric C. Hayden, Esq. Schuler, Halvorson, Weisser, Zoeller, Overbeck, & Baxter P.A. 1615 Forum Place 4D West Palm Beach, FL 33401 (561) 689-8180 (561) 684-9683 SCHULER HALVORSON WEISSERComposite Exhibit 'C Diana Ar aga From: Diana Arriaga Sent: Tuesday, October 26, 2021 4:21 PM To: Romero, Kelly J. Subject: RE: Harris et al vs. Densen-0569004542.1 Good afternoon, Can you please advise as to the status of your client's deposition dates? Diana M. Arriaga, FRP to Michael D. Dickenson, Esq. & Harrison A. Jos SCHULER _ .. HALVORSON . WEISSER ‘. ZOELLER _- 4 OVERBECK BAXTER 1615 Forum Place, Suite 4D West Palm Beach, FL 33401 (561)689-8180 — Telephone (561)684-9683 — Fax (800)689-8180 — Toll Free Esq. Best Lenvvers BEST LAW FIRMS, This electronic message transmission contains information from the law offices of SCHULER, HALVORSON, WEISSER, ZOELLER OVERBECK, BAXTER, P.A. which may be confidential or privileged. The information is intended for the use of the individual or entity named above. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the contents of this information is prohibited. laimer: This e-mail is intended only for the individual(s) or entity(s) named within the message. This e-mail might contain legally privileged and confidential information. If you properly received this e-mail as a client or retained expert, please hold it in confidence to protect the attorney-client or work product privileges. Should the intended recipient forward or disclose this message to another person or party, that action could constitute a waiver of the attorney-client privilege. If the reader of this message is not the intended recipient, or the agent responsible to deliver it to the intended recipient, you are hereby notified that any review, dissemination, distribution or copying of this communication is prohibited by the sender and to do so might constitute a violation of the Electronic Communications Privacy Act, 18 U.S.C. section 2510-2521. if this communication was received in error we apologize for the intrusion. Please notify us by reply e-mail and delete the original message. Nothing in this e-mail message shall, in and of itself, create an attorney-client relationship with the sender. From: Romero, Kelly J. Sent: Wednesday, October 6, 2021 7:35 AM To: Diana Arriaga Subject: Harris et al vs. Densen-0569004542.1 Importance: High Good Morning, | have not been able to confirm dates to set the deposition of Alan Densen, October 12" will not work for Tamar. | will gather date/times with our client and let you know before the end of the week, thank you. Kelly J. Romero Legal Admin/Scheduler for Angelina Capece & Chuck Obianagu Litigation Services The Law Offices of Robert J. Smith Staff Counsel All Staff Members are Employees of Allstate Insurance Company This Office is not a Partnership or a Corporation 4443 Lyons Road, Suite 206 Coconut Creek, FL 33073 PRINCIPAL E-MAIL ADDRESS FOR SERVICE OF PLEADINGS: FtLauderdaleLegal@Allstate.com Personal E-Mail Address, not for service of pleadings: Kelly.Romero@Allstate.com Telephone: 954.767.1396 Toll Free: 877-250-9958 Fax: 877-838-0840 Connect by Skype or Teams Telephone: 954-767-1396 Fax: 877-838-0840Diana Ar ga From: Diana Arriaga Sent: Wednesday, September 22, 2021 9:42 AM To: "KELLY.ROMERO@Allstate.com’; 'Solarin, Tamar’ Ce: Harrison A. Joss Subject: RE: Initial Request or reset Defendant's deposition - RE: Harris et al vs. Densen-0569004542.1 - REGARDING ZOOM DEPO OF ALAN DENSEN 2nd Request Good morning, Following up on this. Please advise. If we don’t hear from by Friday, September 24, 2021, we will schedule the deposition for October 5". Thank you, Diana M. Arriaga, FRP to Michael D. Dickenson, Esq. SCHULER HALVORSON », WEISSER * * ZORLLER ©: (OVERBECK BAXTER 1615 Forum Place, Suite 4D West Palm Beach, FL 33401 (561)689-8180 - Telephone (561)684-9683 — Fax (800)689-8180 — Toll Free Emails: Mdickenson@shw-law.com; Darriaga@shw-law.com This electronic message transmission contains information from the law offices of SCHULER, HALVORSON, WEISSER, ZOELLER OVERBECK, BAXTER, P.A. which may be confidential or privileged. The information is intended for the use of the individual or entity named above. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the contents of this information is prohibited. Disclaimer: This e-mail is intended only for the individual(s) or entity(s) named within the message. This e-mail might contain legally privileged and confidential information. If you properly received this e-mail as a client or retained expert, please hold it in confidence to Protect the attorney-client or work product privileges. Should the intended recipient forward or disclose this message to another person or party, that action could constitute a waiver of the attorney-client privilege. If the reader of this message is not the intended recipient, or the agent responsible to deliver it to the intended recipient, you are hereby notified that any review, dissemination, distribution or copying of this communication is prohibited by the sender and to do so might constitute a violation of the Electronic Communications Privacy Act, 18 U.S.C. section 2510-2521. If this communication was received in error we apologize for the intrusion. Please notify us by reply e-mail and delete the original message. Nothing in this e-mail message shall, in and of itself, create an attorney-client relationship with the sender.From: Diana Arriaga Sent: Monday, September 20, 2021 1:12 PM To: KELLY. ROMERO @AlIstate.com; Solarin, Tamar Cc: Harrison A. Joss Subject: RE: Initial Request or reset Defendant's deposition - RE: Harris et al vs. Densen-0569004542.1 - REGARDING ZOOM DEPO OF ALAN DENSEN 2nd Request Good afternoon, | wanted to follow up on this. Please advise if 10/5; 10/6/; 10/7 all at 10am will work for your client. Thank you, Diana M. Arriaga, FRP to Michael D. Dickenson, Esq. -SCHULER © HALVORSON ~ WEISSER » ZOELLER | OVERBECK “BAXTER at law 1615 Forum Place, Suite 4D West Palm Beach, FL 33401 (561)689-8180 — Telephone (561)684-9683 — Fax (800)689-8 180 — Toll Free Emails: Mdickenson@shw-law.com; Darriaga@shw-law.com This electronic message transmission contains information from the law offices of SCHULER, HALVORSON, WEISSER, ZOELLER OVERBECK, BAXTER, P.A. which may be confidential or privileged. The information is intended for the use of the individual or entity named above. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the contents of this information is prohibited. Disclaimer: This e-mail is intended only for the individual(s) or entity(s) named within the message. This e-mail might contain legally privileged and confidential information. If you properly received this e-mail as a client or retained expert, please hold it in confidence to protect the attorney-client or work product privileges. Should the intended recipient forward or disclose this message to another person or party, that action could constitute a waiver of the attorney-client privilege. If the reader of this message is not the intended recipient, or the agent responsible to deliver it to the intended recipient, you are hereby notified that any review, dissemination, distribution or copying of this communication is prohibited by the sender and to do so might constitute a violation of the Electronic Communications Privacy Act, 18 U.S.C. section 2510-2521. If this communication was received in error we apologize for the intrusion. Please notify us by reply e-mail and delete the original message. Nothing in this e-mail message shall, in and of itself, create an attorney-client relationship with the sender. From: Diana Arriaga Sent: Thursday, September 16, 2021 8:57 AM To: KELLY.ROMERO@Allstate.com; Solarin, Tamar Cc: Harrison A. Joss Subject: RE: Initial Request or reset Defendant's deposition - RE: Harris et al vs. Densen-0569004542.1 - REGARDING 2ZOOM DEPO OF ALAN DENSEN Importance: High Good morning, Mr. Harrison Joss will be the new attorney for the Plaintiffs. Please direct all future correspondence to our attention. That being said, we would like to re-schedule the Deposition of the Defendant. To avoid any issues, and to make it easier for the Defendant, we will set this Deposition at a Court Reporter’s office. Mr. Joss is available on any of the following dates: 10/5; 10/6/; 10/7 at 10am. Thank you and | look forward to hearing from you. Diana M. Arriaga, FRP to Michael D. Dickenson, Esq. SCHULER HALVORSON / \WEISSER ~ ZOELLER OVERBECK BAXTER attri at hae 1615 Forum Place, Suite 4D West Palm Beach, FL 33401 (561)689-8180 — Telephone (561 )684-9683 — Fax (800)689-8180 — Toll Free Emails: Mdickenson@shw-law.com; Darriaga@shw-law.com LORIDA ECISTERED PARALEGA pra This electronic message transmission contains information from the law offices of SCHULER, HALVORSON, WEISSER, ZOELLER OVERBECK, BAXTER, P.A. which may be confidential or privileged. The information is intended for the use of the individual or entity named above. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the contents of this information is prohibited. laimer: This e-mail is intended only for the individual(s) or entity(s) named within the message. This e-mail might contain legally privileged and confidential information. If you properly received this e-mail as a client or retained expert, please hold it in confidence to protect the attorney-client or work product privileges. Should the intended recipient forward or disclose this message to another person or party, that action could constitute a waiver of the attorney-client privilege. If the reader of this message is not the intended recipient, or the agent responsible to deliver it to the intended recipient, you are hereby notified that any review, dissemination, distribution or copying of this communication is prohibited by the sender and to do so might constitute a violation of the Electronic Communications Privacy Act, 18 U.S.C. section 2510-2521. If this communication was received in error we apologize for the intrusion. Please notify us by reply e-mail and delete the original message. Nothing in this e-mail message shall, in and of itself, create an attorney-client relationship with the sender. From: Amanda Coates Sent: Monday, June 21, 2021 1:16 PM To: Romero, Kelly J. Cc: Solarin, Tamar ; Eric C. Hayden Subject: Initial Request or reset Defendant's deposition - RE: Harris et al vs. Densen-0569004542.1 - REGARDING ZOOM DEPO OF ALAN DENSEN Importance: High Good afternoon, Please provide your client’s availability for his deposition as soon as possible. We have not heard back from your office and as you know his deposition was supposed to be occurring today at 2:00 p.m. Since your client is unable to attend by video conferencing we can conduct his deposition in person. Please advise. | look forward to hearing from you. Kind Regards, Amanda. Coutey Litigation Paralegal for Eric C. Hayden, Esq. Schuler, Halvorson, Weisser, Zoeller, Overbeck, & Baxter P.A. 1615 Forum Place 4D West Palm Beach, FL 33401 (561) 689-8180 (561) 684-9683 Trial Attorneys with offices in West Palm Beach and Delray Beach. For more information, please visit our website at http://www. shw-law.com/ Disclaimer: This e-mail is intended only for the individual(s) or entity(s) named within the message. This e-mail might contain legally privileged and confidential information. If you properly received this e-mail as a client or retained expert, please hold it in confidence to protect the attorney-client or work product privileges. Should the intended recipient forward or disclose this message to another person or party, that action could constitute a waiver of the attorney-client privilege. If the reader of this message is not the intended recipient, or the agent responsible to deliver it to the intended recipient, you are hereby notified that any review, dissemination, distribution or copying of this communication is prohibited by the sender and to do so might constitute a violation of the Electronic Communications Privacy Act, 18 U.S.C. section 2510-2521. If this communication was received in error we apologize for the intrusion. Please notify us by reply e-mail and delete the original message. Nothing in this e-mail message shall, in and of itself, create an attorney-client relationship with the sender. This e- mail address is unable to receive attached files that pose a cyber security risk along with files in excess of 10MB in size. Contact the sender for information on file transmission.