On October 22, 2020 a
Party Discovery
was filed
involving a dispute between
Haven Group Inc,
and
Citizens Property Insurance Corporation,
for Other - Insurance Claim
in the District Court of Broward County.
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Filing # 124112937 E-Filed 03/31/2021 03:09:26 PM
IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
HAVEN GROUP, INC., CASE NO: CACE-20-017617
Plaintiffs,
VS.
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
/
SECOND RE NOTICE OF TAKING DEPOSITION DUCES TECUM
Changes date of Deposition only
PLEASE TAKE NOTICE that the undersigned will take the deposition of:
NAME: Mickey McDaniel, Field Adjuster
DATE: April 28, 2021
TIME: 2:00 p.m.
PLACE: Universal Court Reporting
Via Zoom
Zoom Link to be provided 24 hours prior to Deposition
REPORTER: Universal Court Reporting
Said deposition will be taken before Universal Court Reporting 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.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/31/2021 03:09:25 PM.****Said witness is to bring with him the following:
1. Any and all correspondence between you and Plaintiff or anyone acting on
the Plaintiff's behalf.
2. Any and all written or recorded statements of the Plaintiff, her agents,
and/or representatives.
3. Any and all photographs and/or video of the Plaintiff's property and/or her
contents.
4. Any and all documents you received regarding Plaintiff's claim prior to
your inspection of the property.
5. Any and all reports, estimates or other documents you generated after your
inspection of the property.
6. Any and all reports or correspondence retained in connection with the
investigation of Plaintiff's Claim.
7. Any and all documents relied upon by you in generating your report or
findings after your inspection of the property.
8. Any and all handwritten notes taken by you in connection with your
investigation of Plaintiffs claim, including but not limited to, any notes on the jacket of
any folders.CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished via electronic mail this 31“ day of March, 2021 to: Jennifer Valiyi, Esq., Law Offices
of Hoffman & Hoffman, P.A., 66 W. Flagler Street, Suite 200, Miami, FL 33130:
eservice@hoffmanpa.com paralegal.red@hoffmanpa.com jennifer@hoffmanpa.com
By: /s/ is
LYNN GAMBINO, ESQ.
Florida Bar No: 558524
THE MINEO SALCEDO LAW FIRM, P.A.
Attorneys for Plaintiffs
5600 Davie Road
Davie, FL 33314
T: (954) 463-8100
F; (954) 463-8106
service@mineolaw.com
Lgambino@mineolaw.com
Document Filed Date
March 31, 2021
Case Filing Date
October 22, 2020
Category
Other - Insurance Claim
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Filing # 124112937 E-Filed 03/31/2021 03:09:26 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA HAVEN GROUP, INC., CASE NO: CACE-20-017617 Plaintiffs, VS. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. / SECOND RE NOTICE OF TAKING DEPOSITION DUCES TECUM Changes date of Deposition only PLEASE TAKE NOTICE that the undersigned will take the deposition of: NAME: Mickey McDaniel, Field Adjuster DATE: April 28, 2021 TIME: 2:00 p.m. PLACE: Universal Court Reporting Via Zoom Zoom Link to be provided 24 hours prior to Deposition REPORTER: Universal Court Reporting Said deposition will be taken before Universal Court Reporting 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. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/31/2021 03:09:25 PM.****Said witness is to bring with him the following: 1. Any and all correspondence between you and Plaintiff or anyone acting on the Plaintiff's behalf. 2. Any and all written or recorded statements of the Plaintiff, her agents, and/or representatives. 3. Any and all photographs and/or video of the Plaintiff's property and/or her contents. 4. Any and all documents you received regarding Plaintiff's claim prior to your inspection of the property. 5. Any and all reports, estimates or other documents you generated after your inspection of the property. 6. Any and all reports or correspondence retained in connection with the investigation of Plaintiff's Claim. 7. Any and all documents relied upon by you in generating your report or findings after your inspection of the property. 8. Any and all handwritten notes taken by you in connection with your investigation of Plaintiffs claim, including but not limited to, any notes on the jacket of any folders.CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via electronic mail this 31“ day of March, 2021 to: Jennifer Valiyi, Esq., Law Offices of Hoffman & Hoffman, P.A., 66 W. Flagler Street, Suite 200, Miami, FL 33130: eservice@hoffmanpa.com paralegal.red@hoffmanpa.com jennifer@hoffmanpa.com By: /s/ is LYNN GAMBINO, ESQ. Florida Bar No: 558524 THE MINEO SALCEDO LAW FIRM, P.A. Attorneys for Plaintiffs 5600 Davie Road Davie, FL 33314 T: (954) 463-8100 F; (954) 463-8106 service@mineolaw.com Lgambino@mineolaw.com