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Filing # 120989047 E-Filed 02/08/2021 01:06:07 PM
IN THE COUNTY COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA.
CASE NO: CACE-20-017617
HAVEN GROUP, INC.,
Plaintiff(s),
v.
CITIZENS PROPERTY INSURANCE
CORPORATION
Defendant.
CROSS 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
Corporate Representative of March 9, 2021 10:00AM
Haven Group, Inc. pursuant to
Fla. R. Civ. P 1.310(b)(6)
regarding the areas of inquiry
identified in Schedule A and
duces tecum request for
documents as identified in
Schedule B
Zoom Details:
https://zoom.us/j/99236561542?pwd=MTVXdzAwN3p2UXhsZVNTRENhbURGdz09
Meeting ID: 992 3656 1542
Passcode: 924455
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 02/08/2021 01:06:07 PM.****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.
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.
CERTIFICATE OF SERVICE
I 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 and/or was sent
by electronic mail on February 8, 2021 to:
Lynn Gambino Gambino, Esq., Esq. service@mineolaw.com;
THE MINEO SALCEDO LAW FIRM, lgambino@mineolaw.com;
P.A. hannettee@mineolaw.com
5600 Davie Road
Davie, FL 33314
(954) 463-8100
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
Florida Bar No. 116079/ E-mail: jennifer@hoffmanpa.com
Jorge Fernandez
Florida Bar No. 1015541 / E-mail: jfernandez@hoffmanpa.com
SCHEDULE A — AREAS OF INQUIRY
Each of the areas of inquiry listed below pertains to the property located at the following address:
LAW OFFICE OF HOFFMAN & HOFFMAN, P.A.
66 W. Flagler Street, Suite 200, Miami, Florida 33130 ~ Telephone: 305.372.2877 Fax: 305.372.287510954 Neptune Drive, Hollywood, FL 33026
is requested to designate as its corporate representative a person(s) having knowledge of the
following areas of inquiry:
1. All claims made by or on behalf of Plaintiff for the property located at the above referenced
address.
2. All steps taken by to investigate, adjust, and/or handle the claim(s) reported by or on behalf
of Plaintiff.
3. Inspections and knowledge of the above referenced property.
4. Estimates prepared by Haven Group, Inc. concerning the property located at the above
referenced address.
5. Services provided conceming the above referenced properties, including but not limited to all
dates when a representative on behalf of inspected the above referenced property and the dates
that was notified of a problem/loss/claim concerning the above referenced property.
6. Correspondence and communication between Haven Group, Inc. and Defendant.
7. Correspondence and communication between Haven Group Inc, and The Mineo Salcedo Law
Firm, P.A.
LAW OFFICE OF HOFFMAN & HOFFMAN, P.A.
66 W. Flagler Street, Suite 200, Miami, Florida 33130 ~ Telephone: 305.372.2877 Fax: 305.372.2875SCHEDULE B—DUCES TECUM REQUESTS
Each of the duces tecum requests listed below pertain to the property located at the following
address:
10954 Neptune Drive, Hollywood, FL 33026
is requested to produce the documents listed below at, or before, the deposition of Jason
Rothschild, or the corporate representative(s) from: Haven Group, Inc.
1. The organization’s complete file, both physical and digital, concerning the property identified
above.
2. All inspection notes, reports, diagrams, etc. related to the property identified above.
3. All invoices, estimates, and/or other financial documents related to the property identified
above.
4. All correspondence between Haven Group, Inc. and Defendant including all email
correspondence, written correspondence, and text messages.
5. All correspondence between Haven Group Inc, and The Mineo Salcedo Law Firm, P.A.
including all email correspondence.
6. All photographs and/or videos related to the property identified above.
7. All documents received by Haven Group, Inc. concerning the property identified above.
8. All written or computerized records made by Haven Group, Inc. concerning all
investigations/inspections performed by for the property identified above.
9. All estimates or reports prepared or received by Haven Group, Inc. concerning the property
identified above.
10. All activity logs, diaries, claim notes, or log notes created by any adjuster, claim
representative, manager, or supervisor of or any third parties during the adjustment of any claim
made concerning the property identified above.
LAW OFFICE OF HOFFMAN & HOFFMAN, P.A.
66 W. Flagler Street, Suite 200, Miami, Florida 33130 ~ Telephone: 305.372.2877 Fax: 305.372.2875
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Filing # 120989047 E-Filed 02/08/2021 01:06:07 PM IN THE COUNTY COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA. CASE NO: CACE-20-017617 HAVEN GROUP, INC., Plaintiff(s), v. CITIZENS PROPERTY INSURANCE CORPORATION Defendant. CROSS 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 Corporate Representative of March 9, 2021 10:00AM Haven Group, Inc. pursuant to Fla. R. Civ. P 1.310(b)(6) regarding the areas of inquiry identified in Schedule A and duces tecum request for documents as identified in Schedule B Zoom Details: https://zoom.us/j/99236561542?pwd=MTVXdzAwN3p2UXhsZVNTRENhbURGdz09 Meeting ID: 992 3656 1542 Passcode: 924455 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 02/08/2021 01:06:07 PM.****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. 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. CERTIFICATE OF SERVICE I 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 and/or was sent by electronic mail on February 8, 2021 to: Lynn Gambino Gambino, Esq., Esq. service@mineolaw.com; THE MINEO SALCEDO LAW FIRM, lgambino@mineolaw.com; P.A. hannettee@mineolaw.com 5600 Davie Road Davie, FL 33314 (954) 463-8100 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 Florida Bar No. 116079/ E-mail: jennifer@hoffmanpa.com Jorge Fernandez Florida Bar No. 1015541 / E-mail: jfernandez@hoffmanpa.com SCHEDULE A — AREAS OF INQUIRY Each of the areas of inquiry listed below pertains to the property located at the following address: LAW OFFICE OF HOFFMAN & HOFFMAN, P.A. 66 W. Flagler Street, Suite 200, Miami, Florida 33130 ~ Telephone: 305.372.2877 Fax: 305.372.287510954 Neptune Drive, Hollywood, FL 33026 is requested to designate as its corporate representative a person(s) having knowledge of the following areas of inquiry: 1. All claims made by or on behalf of Plaintiff for the property located at the above referenced address. 2. All steps taken by to investigate, adjust, and/or handle the claim(s) reported by or on behalf of Plaintiff. 3. Inspections and knowledge of the above referenced property. 4. Estimates prepared by Haven Group, Inc. concerning the property located at the above referenced address. 5. Services provided conceming the above referenced properties, including but not limited to all dates when a representative on behalf of inspected the above referenced property and the dates that was notified of a problem/loss/claim concerning the above referenced property. 6. Correspondence and communication between Haven Group, Inc. and Defendant. 7. Correspondence and communication between Haven Group Inc, and The Mineo Salcedo Law Firm, P.A. LAW OFFICE OF HOFFMAN & HOFFMAN, P.A. 66 W. Flagler Street, Suite 200, Miami, Florida 33130 ~ Telephone: 305.372.2877 Fax: 305.372.2875SCHEDULE B—DUCES TECUM REQUESTS Each of the duces tecum requests listed below pertain to the property located at the following address: 10954 Neptune Drive, Hollywood, FL 33026 is requested to produce the documents listed below at, or before, the deposition of Jason Rothschild, or the corporate representative(s) from: Haven Group, Inc. 1. The organization’s complete file, both physical and digital, concerning the property identified above. 2. All inspection notes, reports, diagrams, etc. related to the property identified above. 3. All invoices, estimates, and/or other financial documents related to the property identified above. 4. All correspondence between Haven Group, Inc. and Defendant including all email correspondence, written correspondence, and text messages. 5. All correspondence between Haven Group Inc, and The Mineo Salcedo Law Firm, P.A. including all email correspondence. 6. All photographs and/or videos related to the property identified above. 7. All documents received by Haven Group, Inc. concerning the property identified above. 8. All written or computerized records made by Haven Group, Inc. concerning all investigations/inspections performed by for the property identified above. 9. All estimates or reports prepared or received by Haven Group, Inc. concerning the property identified above. 10. All activity logs, diaries, claim notes, or log notes created by any adjuster, claim representative, manager, or supervisor of or any third parties during the adjustment of any claim made concerning the property identified above. LAW OFFICE OF HOFFMAN & HOFFMAN, P.A. 66 W. Flagler Street, Suite 200, Miami, Florida 33130 ~ Telephone: 305.372.2877 Fax: 305.372.2875