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Filing # 132194431 E-Filed 08/06/2021 01:39:15 PM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
EDMONDE JACQUES,
Plaintiff.
V
CASE NO.: CACE-21-007804
AVATAR PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
'
PLAINTIFF'S AMENDED NOTICE OF TAKING DEPOSITION DUCES TECUM
OF FIELD ADJUSTER, RIGOBERTO MORENO-PENA
YOU ARE HEREBY notified that Plaintiff,EDMONDE JACQUES, in the above-styled
will take the deposition by oral examination for purposes of discovery and for use as evidence in
said cause, or both, ofthe following individual.
DEPONENT:
RIGOBERTO MORENO-PENA, FIELD ADJUSTER
DATE:
TUESDAY 19, OCTOBER 2021
TIME:
9:00 A.M.
PLACE:
ESQUIRE SOLUTIONS Via
ZOOM
Said deposition will be taken before Esquire Solutions or any officer authorized to
administer oaths by the laws of the State of Florida, and a person who is neither a relative nor
employee of such attorney or counsel, and who is not financially interested in the action.
Said deposition to be taken pursuant to the Florida Rules of Civil Procedure in such cases
provided. The oral examination will continue from hour to hour and from day to day until
completed.
*The Deponent is hereby directed to bring at said time and place of the deposition, the
following:
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/06/2021 01:39:15 PM.****
CASE NO.: CACE-21-007804
DUCES TECUM
a) Any and all documentsrelated to property loss and/or inspectionreports in connection
with the Insured's property located at: 1220 SW 71st Terr, North Lauderdale, FL 33068, with
an approximatedate of loss of November 8, 2017 and Claim No: 20204525, including, but not
limited to, visual inspection report(s), inspection summary report, safety hazard reports, water
damage reports, deficiency reports, plumbing reports, color copies and copies of any and all
photographs or drawingsdepictingproperty damage, copies ofall receipts, warranties, and permits
related to any damage or repairs.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-
Mail and/or ePortal to Lea Tottle, Esquire, at
and leat@avatarins.com,
on this 61th day ofAugust 2021.
By:
/s/ Aaron D. Silvers
AARON D. SILVERS, ESQ.
Florida Bar No: 104811
JEREMY T. SCHILLING, ESQ.
Florida Bar No: 0098111
Schilling & Silvers PLLC
1700 NW 64?? St., Suite 460
Fort Lauderdale,FL 33309
T: 954-712-8877/F: 954-824-2201
Email :
2
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
EDMONDE JACQUES,
Plaintiffs,
V
CASE NO.: CACE-21-007804
AVATAR PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
i
SUBPOENA FOR DEPOSITION DUCES TECUM
THE STATE OF FLORIDA
TO:
Rigoberto Moreno-Pena
10421 NW 82nd Street / Apt 14
Doral, FL. 33178
YOU ARE HEREBY COMMANDED to appear before a person authorized by law to take
depositions at Esquire Solutions, Via Zoom - Link to be provided 1-2 days prior to the
deposition, October 19, 2021, at 9:00 A.M., for the taking ofyour deposition in this action.
This Subpoena shall remain in full force and effect until such deposition is
completed.
The Deponent is hereby directed to bring at said time and place the documents listed on
Plaintiff' s Notice of Taking Deposition Duces Tecum, attached hereto.
IF YOU FAIL TO APPEAR YOU MAY BE INCONTEMPT OF COURT.
You are subpoenaed to appear by the following attorneys, an unless excused from this
Subpoena by these attorneysor the Court, you shall respond to this Subpoena as directed.
DATED on this 6'Ith day of August 2021.
By:
/s/ Aaron D. Silvers
AARON D. SILVERS, ESQ.
Florida Bar No: 104811
JEREMY T. SCHILLING, ESQ.
Attorneys for Plaintiff
Florida Bar No: 0098111
Schilling & Silvers PLLC
1700 NW 64?? St., Suite 460
Fort Lauderdale, FL 33309
T: 954-712-8877/F: 954-824-2201
Email :
1
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Filing # 132194431 E-Filed 08/06/2021 01:39:15 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA EDMONDE JACQUES, Plaintiff. V CASE NO.: CACE-21-007804 AVATAR PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. ' PLAINTIFF'S AMENDED NOTICE OF TAKING DEPOSITION DUCES TECUM OF FIELD ADJUSTER, RIGOBERTO MORENO-PENA YOU ARE HEREBY notified that Plaintiff,EDMONDE JACQUES, in the above-styled will take the deposition by oral examination for purposes of discovery and for use as evidence in said cause, or both, ofthe following individual. DEPONENT: RIGOBERTO MORENO-PENA, FIELD ADJUSTER DATE: TUESDAY 19, OCTOBER 2021 TIME: 9:00 A.M. PLACE: ESQUIRE SOLUTIONS Via ZOOM Said deposition will be taken before Esquire Solutions or any officer authorized to administer oaths by the laws of the State of Florida, and a person who is neither a relative nor employee of such attorney or counsel, and who is not financially interested in the action. Said deposition to be taken pursuant to the Florida Rules of Civil Procedure in such cases provided. The oral examination will continue from hour to hour and from day to day until completed. *The Deponent is hereby directed to bring at said time and place of the deposition, the following: *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/06/2021 01:39:15 PM.**** CASE NO.: CACE-21-007804 DUCES TECUM a) Any and all documentsrelated to property loss and/or inspectionreports in connection with the Insured's property located at: 1220 SW 71st Terr, North Lauderdale, FL 33068, with an approximatedate of loss of November 8, 2017 and Claim No: 20204525, including, but not limited to, visual inspection report(s), inspection summary report, safety hazard reports, water damage reports, deficiency reports, plumbing reports, color copies and copies of any and all photographs or drawingsdepictingproperty damage, copies ofall receipts, warranties, and permits related to any damage or repairs. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E- Mail and/or ePortal to Lea Tottle, Esquire, at and leat@avatarins.com, on this 61th day ofAugust 2021. By: /s/ Aaron D. Silvers AARON D. SILVERS, ESQ. Florida Bar No: 104811 JEREMY T. SCHILLING, ESQ. Florida Bar No: 0098111 Schilling & Silvers PLLC 1700 NW 64?? St., Suite 460 Fort Lauderdale,FL 33309 T: 954-712-8877/F: 954-824-2201 Email : 2 IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA EDMONDE JACQUES, Plaintiffs, V CASE NO.: CACE-21-007804 AVATAR PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. i SUBPOENA FOR DEPOSITION DUCES TECUM THE STATE OF FLORIDA TO: Rigoberto Moreno-Pena 10421 NW 82nd Street / Apt 14 Doral, FL. 33178 YOU ARE HEREBY COMMANDED to appear before a person authorized by law to take depositions at Esquire Solutions, Via Zoom - Link to be provided 1-2 days prior to the deposition, October 19, 2021, at 9:00 A.M., for the taking ofyour deposition in this action. This Subpoena shall remain in full force and effect until such deposition is completed. The Deponent is hereby directed to bring at said time and place the documents listed on Plaintiff' s Notice of Taking Deposition Duces Tecum, attached hereto. IF YOU FAIL TO APPEAR YOU MAY BE INCONTEMPT OF COURT. You are subpoenaed to appear by the following attorneys, an unless excused from this Subpoena by these attorneysor the Court, you shall respond to this Subpoena as directed. DATED on this 6'Ith day of August 2021. By: /s/ Aaron D. Silvers AARON D. SILVERS, ESQ. Florida Bar No: 104811 JEREMY T. SCHILLING, ESQ. Attorneys for Plaintiff Florida Bar No: 0098111 Schilling & Silvers PLLC 1700 NW 64?? St., Suite 460 Fort Lauderdale, FL 33309 T: 954-712-8877/F: 954-824-2201 Email : 1