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Filing # 130521356 E-Filed 07/13/2021 10:21:09 AM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
GENERAL JURISDICTIONDIVISION
CASE NO. CACE-21-007509
LESLIE BOYARSKY and DAVID
BOYARSKY,
Plaintiffs,
V
HOMEOWNERS CHOICE PROPERTY
& CASUALTY INSURANCE
COMPANY, INC., a Florida corporation,
Defendant.
AMENDED NOTICE OF TAKING DEPOSITIONS) DUCES TECUM
(This deposition(s)was coordinated withcounselfor Defendant.)
(Cancels Deposition schedulefor 12/2/2021)
To:
Jacqueline P. Meyer, Esq.
Attorneyfor Homeowners Choice Property & Casualty Insurance Company, Inc.
222 Lakeview Avenue
Suite 120, West Palm Beach, FL 33401
PLEASE TAKE NOTICE that the undersigned law firm will take the deposition(s) of:
Deponent
Date & Time
Location
Schedules
Ian Paguandas- Field
December 8th, 2021 at
Schedule
U. S Legal Via Zoom
Adjuster
2:00 P.M.
upon oral examination before the above listed court reporter, Reporting Service, Notary Public, or
any other Notary Public or other officer authorized by law to take depositions in the State of
Florida. The oral examinations will continue from day to day until completed. The depositions are
being taken for the purposeofdiscovery,for use at trial, or for such other purposes as are permitted
under Florida Rules of Civil Procedure 1.280, 1.310, 1.350, 1.360, 1.380, 1.390, and 1.410.
The attached Schedule "A" outlines what each deponent is to provide to Plaintiffs'
Counsel(via email, facsimile, regular mail, expressmail, or personaldelivery) AT LEAST five
(5) days PRIOR to appearingat his/her/itsrespective deposition.
File Ref: 12501 - Notice ofTaking Deposition Duces Tecum
Page 1 of3
*** FILED: BROWARDCOUNTY, FL BRENDA D. FORMAN, CLERK 07/13/2021 10:21:09 AM.****
Ian Paguandas shall provide the documents listed on Schedule "A" to Plaintiff's
counselon or by 5:00 pm on November26th, 2021
(BROWARD)
AMERICANS WITH DISABILITIES ACT. If you are a person with a disability who
needs any accommodation in order to participatein this proceeding, you are entitled, at no cost to
you, to the provision of certain assistance. Please contact the ADA Coordinator, Room 470, 201
S.E. Sixth Street, Fort Lauderdale, Florida 33301, 954-831-7721 at least 7 days before your
scheduled court appearance, or immediatelyupon receiving this notificationifthe time before the
scheduled appearance is less than 7 days; ifyou are hearing or voice impaired, call 711.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on July 2,2021, a true and correct copy of the foregoing was
emailed to: Jacqueline P. Meyer,
.
Respectfully submitted,
/s/ Tressie George III
Florida Professional Law Group, PLLC
Tressie George III, Esq.
Florida Bar No. 73495
4600 Sheridan St., Suite 303
Hollywood, FL 33021
Tel. (954) 284-0900
Fax. (954) 284-0747
E-mail: tgeorge@flplg.com
E-mail: eservice@flplg.com
Attorneysfor Plaintiffs,Leslie Boyarsky and David
Boyarsky
File Ref: 12501 - Notice ofTaking Deposition Duces Tecum
Page 2 of3
SCHEDULE "A"
Each deponent shall provide the following documents to Plaintiffs' Counsel at least five (5)
davs prior to appearingat his/her/itsrespective deposition:
1.
Deponent's Curriculum Vitae or Resume with detailed experience and
employment.
2.
Deponent'sinformationon current and expired professionallicenses.
3
Deponent's informationon any professionalinsurance.
4.
Any and all documentation, pictures, emails, logs, and correspondence regarding
subject property claim for 1100 Cedar Falls Dr, Weston, FL, 33327-1716 which have not
previously been provided.
5.
Any treatises, authorities, books, codes, statutes or any other dictum which you
used to base your opinion for the property claim of 1100 Cedar Falls Dr, Weston, FL, 33327-1716.
File Ref: 12501 - Notice ofTaking Deposition Duces Tecum
Page 3 of3
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Filing # 130521356 E-Filed 07/13/2021 10:21:09 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA GENERAL JURISDICTIONDIVISION CASE NO. CACE-21-007509 LESLIE BOYARSKY and DAVID BOYARSKY, Plaintiffs, V HOMEOWNERS CHOICE PROPERTY & CASUALTY INSURANCE COMPANY, INC., a Florida corporation, Defendant. AMENDED NOTICE OF TAKING DEPOSITIONS) DUCES TECUM (This deposition(s)was coordinated withcounselfor Defendant.) (Cancels Deposition schedulefor 12/2/2021) To: Jacqueline P. Meyer, Esq. Attorneyfor Homeowners Choice Property & Casualty Insurance Company, Inc. 222 Lakeview Avenue Suite 120, West Palm Beach, FL 33401 PLEASE TAKE NOTICE that the undersigned law firm will take the deposition(s) of: Deponent Date & Time Location Schedules Ian Paguandas- Field December 8th, 2021 at Schedule U. S Legal Via Zoom Adjuster 2:00 P.M. upon oral examination before the above listed court reporter, Reporting Service, Notary Public, or any other Notary Public or other officer authorized by law to take depositions in the State of Florida. The oral examinations will continue from day to day until completed. The depositions are being taken for the purposeofdiscovery,for use at trial, or for such other purposes as are permitted under Florida Rules of Civil Procedure 1.280, 1.310, 1.350, 1.360, 1.380, 1.390, and 1.410. The attached Schedule "A" outlines what each deponent is to provide to Plaintiffs' Counsel(via email, facsimile, regular mail, expressmail, or personaldelivery) AT LEAST five (5) days PRIOR to appearingat his/her/itsrespective deposition. File Ref: 12501 - Notice ofTaking Deposition Duces Tecum Page 1 of3 *** FILED: BROWARDCOUNTY, FL BRENDA D. FORMAN, CLERK 07/13/2021 10:21:09 AM.**** Ian Paguandas shall provide the documents listed on Schedule "A" to Plaintiff's counselon or by 5:00 pm on November26th, 2021 (BROWARD) AMERICANS WITH DISABILITIES ACT. If you are a person with a disability who needs any accommodation in order to participatein this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact the ADA Coordinator, Room 470, 201 S.E. Sixth Street, Fort Lauderdale, Florida 33301, 954-831-7721 at least 7 days before your scheduled court appearance, or immediatelyupon receiving this notificationifthe time before the scheduled appearance is less than 7 days; ifyou are hearing or voice impaired, call 711. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on July 2,2021, a true and correct copy of the foregoing was emailed to: Jacqueline P. Meyer, . Respectfully submitted, /s/ Tressie George III Florida Professional Law Group, PLLC Tressie George III, Esq. Florida Bar No. 73495 4600 Sheridan St., Suite 303 Hollywood, FL 33021 Tel. (954) 284-0900 Fax. (954) 284-0747 E-mail: tgeorge@flplg.com E-mail: eservice@flplg.com Attorneysfor Plaintiffs,Leslie Boyarsky and David Boyarsky File Ref: 12501 - Notice ofTaking Deposition Duces Tecum Page 2 of3 SCHEDULE "A" Each deponent shall provide the following documents to Plaintiffs' Counsel at least five (5) davs prior to appearingat his/her/itsrespective deposition: 1. Deponent's Curriculum Vitae or Resume with detailed experience and employment. 2. Deponent'sinformationon current and expired professionallicenses. 3 Deponent's informationon any professionalinsurance. 4. Any and all documentation, pictures, emails, logs, and correspondence regarding subject property claim for 1100 Cedar Falls Dr, Weston, FL, 33327-1716 which have not previously been provided. 5. Any treatises, authorities, books, codes, statutes or any other dictum which you used to base your opinion for the property claim of 1100 Cedar Falls Dr, Weston, FL, 33327-1716. File Ref: 12501 - Notice ofTaking Deposition Duces Tecum Page 3 of3