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Filing # 123044362 E-Filed 03/12/2021 05:42:20 PM
IN THE COUNTY COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO: CACE-20-017617
HAVEN GROUP, INC.,
Plaintiffs),
v.
CITIZENS PROPERTY INSURANCE
CORPORATION
Defendant.
/
NOTICE OF VIDEOTAPED DEPOSITION DUCES TECUM
(PLEASE NOTIFY IF AN INTERPRETER WILL BE REQUIRED)
PLEASE TAKE NOTICE that the Defendant, CITIZENS PROPERTY INSURANCE
CORPORATION, by and through its undersigned counsel, will take the videotaped
deposition of the witness listed below via Zoom Pursuant to the Supreme Court of
Florida Administrative Order AOSC20-16, on the following date and time:
NAME DATE TIME
Erick Conzalez with Advantage PA
regarding duces tecum request for April 2, 2021 10:00 AM
documents as identified in Schedule A
The deposition will take place upon oral examination(s) before National
Reporting Service, Notary Public in and for the State of Florida at Large, or some other
officer duly authorized by law to take depositions. The deposition will be videotaped by
Jennifer Valiyi, Esq., and/or employees of the Law Offices of Hoffman & Hoffman, P.A.
The deposition will continue from day to day until completed. The deposition is being
taken for the purpose of discovery, for use at trial, and/or for such other purposes as are
permitted under the applicable and governing rules.
LAW OFFICE OF HOFFMAN & HOFFMAN P.A.
66 W. Flagler Street, Suite 200, Miami, Florida 33130 ~ Telephone: 305.372.2877 Fax:
305.372.2875
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/12/2021 05:42:20 PM.****Zoom Details:
https://z0om.us/j/96176212644?pwd=d0U1YTRuSUQwc016S3ppNDRsYzVG
QTO9
Meeting ID: 961 7621 2644
Passcode: 731157
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was
furnished via Email, pursuant to Fla. R. Jud. Admin. 2.516(b)(1) via transmission of
Notice of Electronic Filing generated by eservice@myflcourtaccess.com or by
EFileMadeEasy.com, on March 12, 2021 to:
Lynn Gambino Gambino, Esq., Esq. service@mineolaw.com;
THE MINEO SALCEDO LAW FIRM, P.A. lgambino@mineolaw.com;
5600 Davie Road hannettee@mineolaw.com
Davie, FL 33314
LAW OFFICES OF HOFFMAN & HOFFMAN, P.A.
66 W. Flagler Street, Suite 200, Miami, Florida 33130
Telephone: 305.372.2877 / Facsimile: 305.372.2875
EService E-mail: eservice@hoffmanpa.com
By: — /s/ Jorge Fernandez, Esq.
John D. Hoffman, Esq.
Board Certified Civil Trial Lawyer
Florida Bar No. 825859 / E-mail: john@hoffmanpa.com
Jennifer Valiyi, Esq.
Florida Bar No. 116079 / E-mail: jennifer@hoffmanpa.com
Jorge Fernandez, Esq.
Florida Bar No. 1015541 / E-mail:
jfernandez@hoffmanpa.com
LAW OFFICE OF HOFFMAN & HOFFMAN P.A.
66 W. Flagler Street, Suite 200, Miami, Florida 33130 ~ Telephone: 305.372.2877 Fax:
305.372.2875SCHEDULE A
The deponent is requested to have the following documents with him at the time of the
deposition:
1. Your complete file concerning the Plaintiff, HAVEN GROUP, INC., and the property
located at 10954 Neptune Drive, Hollywood, FL 33026.
2. All documents, in electronic and printed format, concerning the property located at
10954 Neptune Drive, Hollywood, FL 33026.
3. All photographs, video tapes, sketched drawings, proposals, and notes concerning the
property located at 10954 Neptune Drive, Hollywood, FL 33026. relating to the claim
made by Plaintiff, HAVEN GROUP, INC..
4. All invoices related to the property located at 10954 Neptune Drive, Hollywood, FL
33026
5. All inspection notes, reports, correspondence, messages, moisture reading logs,
proposals and/or estimates related to the property located at 10954 Neptune Drive,
Hollywood, FL 33026.
6. All checks and/or documents reflecting payment made to Advantage PA and/or its
agents regarding the property located at 10954 Neptune Drive, Hollywood, FL 33026.
7. All permits acquired for repairs and/or any work performed at 10954 Neptune Drive,
Hollywood, FL 33026.
8. All timesheets, punch tickets, and employment records showing the time spent
working related to the property located at 10954 Neptune Drive, Hollywood, FL 33026.
9. All reports completed by third parties in your possession relating to the property
located at 10954 Neptune Drive, Hollywood, FL 33026.
10. All contracts and/or letters of representation related to the property located at 10954
Neptune Drive, Hollywood, FL 33026.
11. All documents provided by any party to Advantage PA for review regarding the
property located at 10954 Neptune Drive, Hollywood, FL 33026.
LAW OFFICE OF HOFFMAN & HOFFMAN P.A.
66 W. Flagler Street, Suite 200, Miami, Florida 33130 ~ Telephone: 305.372.2877 Fax:
305.372.2875
Preview
Filing # 123044362 E-Filed 03/12/2021 05:42:20 PM IN THE COUNTY COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO: CACE-20-017617 HAVEN GROUP, INC., Plaintiffs), v. CITIZENS PROPERTY INSURANCE CORPORATION Defendant. / NOTICE OF VIDEOTAPED DEPOSITION DUCES TECUM (PLEASE NOTIFY IF AN INTERPRETER WILL BE REQUIRED) PLEASE TAKE NOTICE that the Defendant, CITIZENS PROPERTY INSURANCE CORPORATION, by and through its undersigned counsel, will take the videotaped deposition of the witness listed below via Zoom Pursuant to the Supreme Court of Florida Administrative Order AOSC20-16, on the following date and time: NAME DATE TIME Erick Conzalez with Advantage PA regarding duces tecum request for April 2, 2021 10:00 AM documents as identified in Schedule A The deposition will take place upon oral examination(s) before National Reporting Service, Notary Public in and for the State of Florida at Large, or some other officer duly authorized by law to take depositions. The deposition will be videotaped by Jennifer Valiyi, Esq., and/or employees of the Law Offices of Hoffman & Hoffman, P.A. The deposition will continue from day to day until completed. The deposition is being taken for the purpose of discovery, for use at trial, and/or for such other purposes as are permitted under the applicable and governing rules. LAW OFFICE OF HOFFMAN & HOFFMAN P.A. 66 W. Flagler Street, Suite 200, Miami, Florida 33130 ~ Telephone: 305.372.2877 Fax: 305.372.2875 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/12/2021 05:42:20 PM.****Zoom Details: https://z0om.us/j/96176212644?pwd=d0U1YTRuSUQwc016S3ppNDRsYzVG QTO9 Meeting ID: 961 7621 2644 Passcode: 731157 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via Email, pursuant to Fla. R. Jud. Admin. 2.516(b)(1) via transmission of Notice of Electronic Filing generated by eservice@myflcourtaccess.com or by EFileMadeEasy.com, on March 12, 2021 to: Lynn Gambino Gambino, Esq., Esq. service@mineolaw.com; THE MINEO SALCEDO LAW FIRM, P.A. lgambino@mineolaw.com; 5600 Davie Road hannettee@mineolaw.com Davie, FL 33314 LAW OFFICES OF HOFFMAN & HOFFMAN, P.A. 66 W. Flagler Street, Suite 200, Miami, Florida 33130 Telephone: 305.372.2877 / Facsimile: 305.372.2875 EService E-mail: eservice@hoffmanpa.com By: — /s/ Jorge Fernandez, Esq. John D. Hoffman, Esq. Board Certified Civil Trial Lawyer Florida Bar No. 825859 / E-mail: john@hoffmanpa.com Jennifer Valiyi, Esq. Florida Bar No. 116079 / E-mail: jennifer@hoffmanpa.com Jorge Fernandez, Esq. Florida Bar No. 1015541 / E-mail: jfernandez@hoffmanpa.com LAW OFFICE OF HOFFMAN & HOFFMAN P.A. 66 W. Flagler Street, Suite 200, Miami, Florida 33130 ~ Telephone: 305.372.2877 Fax: 305.372.2875SCHEDULE A The deponent is requested to have the following documents with him at the time of the deposition: 1. Your complete file concerning the Plaintiff, HAVEN GROUP, INC., and the property located at 10954 Neptune Drive, Hollywood, FL 33026. 2. All documents, in electronic and printed format, concerning the property located at 10954 Neptune Drive, Hollywood, FL 33026. 3. All photographs, video tapes, sketched drawings, proposals, and notes concerning the property located at 10954 Neptune Drive, Hollywood, FL 33026. relating to the claim made by Plaintiff, HAVEN GROUP, INC.. 4. All invoices related to the property located at 10954 Neptune Drive, Hollywood, FL 33026 5. All inspection notes, reports, correspondence, messages, moisture reading logs, proposals and/or estimates related to the property located at 10954 Neptune Drive, Hollywood, FL 33026. 6. All checks and/or documents reflecting payment made to Advantage PA and/or its agents regarding the property located at 10954 Neptune Drive, Hollywood, FL 33026. 7. All permits acquired for repairs and/or any work performed at 10954 Neptune Drive, Hollywood, FL 33026. 8. All timesheets, punch tickets, and employment records showing the time spent working related to the property located at 10954 Neptune Drive, Hollywood, FL 33026. 9. All reports completed by third parties in your possession relating to the property located at 10954 Neptune Drive, Hollywood, FL 33026. 10. All contracts and/or letters of representation related to the property located at 10954 Neptune Drive, Hollywood, FL 33026. 11. All documents provided by any party to Advantage PA for review regarding the property located at 10954 Neptune Drive, Hollywood, FL 33026. LAW OFFICE OF HOFFMAN & HOFFMAN P.A. 66 W. Flagler Street, Suite 200, Miami, Florida 33130 ~ Telephone: 305.372.2877 Fax: 305.372.2875