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Filing # 124075711 E-Filed 03/31/2021 10:33:17 AM
IN THE CIRCUIT COURT OF THE 17™
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO. CACE-20-017607
JEAN HEDGE and ROBERT HEDGE,
Plaintiff,
vs.
OMEGA INSURANCE COMPANY,
Defendant.
/
NOTICE OF TAKING DEPOSITION DUCES TECUM
(DATE CLEARED WITH OPPOSING COUNSEL)
(Please advise if an interpreter is needed)
PLEASE TAKE NOTICE that the undersigned attorney will take the deposition, by oral
examination, of:
DEPONENT DATE/TIME LOCATION
Robert Hedge, Tenant May 25, 2021 at 2:15 p.m. Deposition will be held via Zoom —
link to be sent by Veritext
**Note: If the witness requires a
physical location, please advise.
Before Veritext, a Notary Public or before his duly designated representative, who is not of counsel
to the parties or interested in the event of the cause. These depositions are being taken for the
purpose of discovery, for use at trial, or for such other purposes as are permitted under the Florida
Rules of Civil Procedure, and shall continue from day to day until completed.
The witnesses are to have with them, at the time and place noted, the articles listed on the
attached Schedule "A" for inspection and/or copying.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/31/2021 10:33:16 AM.****By
Primary
Primary
Secondary
Attomeys
for
MARSHALL DENNEHEY
WARNER COLEMAN &
GOGGIN
/s/Michael A. Packer
Michael A. Packer
Florida Bar No.: 121479
mapacker@mdwcg.com
Isabel Andreacchi
Florida Bar No. 92906
iiandreacchi@mdweg.com
Kayla L. Barnett
Florida Bar No. 121777
kibarnett@mdweg.com
2400 E. Commercial Blvd.,
Suite 1100
Fort Lauderdale, FL 33308
Phone: (954) 847-4920
acdechane@mdweg.com
trvalentin@mdwcg.com
pleadingsftl@mdweg.com
OMEGA INSURANCE
COMPANY,
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true copy of the foregoing Notice of Taking Deposition
Duces Tecum was sent by electronic mail this 31% day of March, 2021, to Peter Mineo, Jr., Esq.,
The Mineo Salcedo Law Firm, P.A., 5600 Davie Road, Davie, FL 33314, Service@mineolaw.com.
cc: Veritext
s/ Kayla L. Barnett
Kayla L. BarnettSCHEDULE “A”
DEFINITIONS
1. The term “documents” means and includes, without limitation, all writings of any
kind, including the originals and all non-identical copies or drafts, whether printed, recorded,
stored, or reproduced by any mechanical or electronic process or written or produced by hand,
including computer tapes (and backup tapes), whether different from the original by reason of any
notation made on such copy or draft or otherwise including, without limitation, correspondence,
memoranda, notes, diaries, statistics, letters, e-mail, electronic computer files, telegrams, minutes,
contracts, reports, accident reports, incident reports, studies, calculations, computations, surveys,
checks, statements, receipts, returns, summaries, pamphlets, books, prospectuses, circulars, trade
letters, advertisements, interoffice communications, offers, notations of any sort of
conversation(s), telephone calls, meetings or other communications, bulletins, printed matter,
computer print-outs, teletypes, facsimiles, invoices, work sheets and all drafts, alterations,
modifications, changes, and amendments of any of the foregoing, graphic or aural writs, records
or representations of any kind including, without limitation, photographs, charts, graphs,
microfiche, microfilm, videotape, recordings, motion pictures; and electronic, mechanical or
electric records or representations of any kind including, without limitation, tapes, cassettes and
disc recordings, and writings and printed material of every kind, whether or not the document is
out of your possession, custody or control.
2. The term “correspondence” means any tangible object that conveys information or
memorializes information that was conveyed in tangible or oral form including, but not limited to,
writings, letters, memoranda, electronic mail (otherwise known as “e-mail”), facsimiles, reports,
notes, telegrams and interoffice communication.
3. The term “relating to” as used herein is defined to mean evidencing, referring to,
pertaining to, consisting of, reflecting, concerning, or in any way logically or factually connected
with the matters discussed.
4. The term “and” as well as “or” as used herein shall be read and applied as though
interchangeable and shall be construed either disjunctively or conjunctively so as to require the
fullest and most complete disclosure of all required information and documents.
5. The term “property” refers to the property located at 2920 SW 174" Way, Miramar,
FL 33029.
6. The term “the time of the loss” or “as a result of the loss” means the loss as
described in Plaintiffs’ Complaint.
7. The term “you” or “your” refers to the Plaintiffs, JEAN HEDGE and ROBERT
HEDGE.PLEASE BRING WITH YOU THE FOLLOWING ITEMS AS INDICATED
1. Your driver's license or identification card.
2. Any and all agreements for representation between yourself and any individual or
business entity representing you in this action. This request does not seek
agreements for legal representation.
3. Any and all agreements for representation between yourself and any individual or
business entity representing you in this action that evidence the fees, fee
arrangements or fee schedules for the services of a public adjuster and/or loss
consultant and/or estimator.
4. All documents and correspondence from you to any third-party, including any
public adjuster and/or insurance agent relating to this loss. This request does not
contemplate any documents or correspondence protected by attorney-client
privilege.
5. All documents and correspondence to you from any third-party, including any
public adjuster and/or insurance agent relating to this loss. This request does not
contemplate any documents or correspondence protected by attorney-client
privilege.
6. All documents and correspondence to you from he Insureds relating to this loss.
This request does not contemplate any documents or correspondence protected by
attorney-client privilege.
7. Any and all documents submitted to OMEGA INSURANCE COMPANY, and/or
its agents or representatives related to claim 3300341865 by you and/or your
representatives.
8. Any and all correspondence submitted to OMEGA INSURANCE COMPANY,
and/or its agents or representatives related to claim 3300341865 by you and/or your
representatives.
9. Any and all documents relating to damages claimed for the loss, including but not
limited to estimates, work orders, proposals, statements, invoices, or contracts.
10. Any and all bills incurred as a result of the loss.
11. Any and all documents evidencing repairs or replacement of damaged property,
including but not limited to invoices, statements, contracts, or work orders for
damages claimed for the loss.
12. Any and all Notices of Commencement.13.
14.
15.
16.
18.
19.
20.
21.
22.
23.
24.
25.
26.
Any and all applications for building permits.
Any and all documents evidencing repairs or replacement of damaged personal
property (i.e. contents), including but not limited to bills, invoices, statements,
contracts, or work orders as a result of the loss.
Any and all payments for repairs or replacement of damaged property for the loss,
including but not limited to, cancelled checks, bills of sale, receipts, credit card
statements, ATM receipts, and bank statements.
Any and all documents evidencing your purchase of the property, including but not
limited to closing documents, inspections and sales contract for the purchase of the
property.
Any and all photographs, videos, and diagrams demonstrating the damages you are
claiming as a result of the loss.
Your IRS income-tax return for the years: 2017, 2018, and 2019. Please bring
original documents for this request.
Any and all documents evidencing your payment of the monthly mortgage for the
property. Please bring original documents for this request.
All documents evidencing all repairs, including prior repairs, to any area of the
property that is being claimed in your.
All documents evidencing your efforts to protect the property from further damage
as relating to the loss.
All documents prepared by third parties relating to the loss, including but not
limited to any inspection or evaluation performed of the property.
All documents evidencing the remodeling, renovation, additions, maintenance or
repairs to the property in the last five (5) years.
If Plaintiff has refinanced the property at any time since purchasing the property,
bring all copies of all inspection and/or appraisal reports prepared in conjunction
with the refinance of the property.
All expert and/or consultant reports in support of the claim that the property has
sustained damage on or about September 10, 2017.
All photographs and/or videos which depict the property prior to the alleged loss
on or about September 10, 2017.27.
28.
29.
30.
Any and all photographs, videos, and diagrams demonstrating the damages for
claim number 3300341865.
Any and all documents evidencing repairs or replacement of damaged property,
including but not limited to invoices, statements, contracts, or work orders for
damages claimed for claim number 3300341865.
Any and all payments for repairs or replacement of damaged property for the loss,
including but not limited to, cancelled checks, bills of sale, receipts, credit card
statements, ATM receipts, and bank statements related to claim number
3300341865.
Any and all documents or other items you believe OMEGA INSURANCE
COMPANY should review in considering your claim.
Preview
Filing # 124075711 E-Filed 03/31/2021 10:33:17 AM IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. CACE-20-017607 JEAN HEDGE and ROBERT HEDGE, Plaintiff, vs. OMEGA INSURANCE COMPANY, Defendant. / NOTICE OF TAKING DEPOSITION DUCES TECUM (DATE CLEARED WITH OPPOSING COUNSEL) (Please advise if an interpreter is needed) PLEASE TAKE NOTICE that the undersigned attorney will take the deposition, by oral examination, of: DEPONENT DATE/TIME LOCATION Robert Hedge, Tenant May 25, 2021 at 2:15 p.m. Deposition will be held via Zoom — link to be sent by Veritext **Note: If the witness requires a physical location, please advise. Before Veritext, a Notary Public or before his duly designated representative, who is not of counsel to the parties or interested in the event of the cause. These depositions are being taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted under the Florida Rules of Civil Procedure, and shall continue from day to day until completed. The witnesses are to have with them, at the time and place noted, the articles listed on the attached Schedule "A" for inspection and/or copying. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/31/2021 10:33:16 AM.****By Primary Primary Secondary Attomeys for MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN /s/Michael A. Packer Michael A. Packer Florida Bar No.: 121479 mapacker@mdwcg.com Isabel Andreacchi Florida Bar No. 92906 iiandreacchi@mdweg.com Kayla L. Barnett Florida Bar No. 121777 kibarnett@mdweg.com 2400 E. Commercial Blvd., Suite 1100 Fort Lauderdale, FL 33308 Phone: (954) 847-4920 acdechane@mdweg.com trvalentin@mdwcg.com pleadingsftl@mdweg.com OMEGA INSURANCE COMPANY, CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true copy of the foregoing Notice of Taking Deposition Duces Tecum was sent by electronic mail this 31% day of March, 2021, to Peter Mineo, Jr., Esq., The Mineo Salcedo Law Firm, P.A., 5600 Davie Road, Davie, FL 33314, Service@mineolaw.com. cc: Veritext s/ Kayla L. Barnett Kayla L. BarnettSCHEDULE “A” DEFINITIONS 1. The term “documents” means and includes, without limitation, all writings of any kind, including the originals and all non-identical copies or drafts, whether printed, recorded, stored, or reproduced by any mechanical or electronic process or written or produced by hand, including computer tapes (and backup tapes), whether different from the original by reason of any notation made on such copy or draft or otherwise including, without limitation, correspondence, memoranda, notes, diaries, statistics, letters, e-mail, electronic computer files, telegrams, minutes, contracts, reports, accident reports, incident reports, studies, calculations, computations, surveys, checks, statements, receipts, returns, summaries, pamphlets, books, prospectuses, circulars, trade letters, advertisements, interoffice communications, offers, notations of any sort of conversation(s), telephone calls, meetings or other communications, bulletins, printed matter, computer print-outs, teletypes, facsimiles, invoices, work sheets and all drafts, alterations, modifications, changes, and amendments of any of the foregoing, graphic or aural writs, records or representations of any kind including, without limitation, photographs, charts, graphs, microfiche, microfilm, videotape, recordings, motion pictures; and electronic, mechanical or electric records or representations of any kind including, without limitation, tapes, cassettes and disc recordings, and writings and printed material of every kind, whether or not the document is out of your possession, custody or control. 2. The term “correspondence” means any tangible object that conveys information or memorializes information that was conveyed in tangible or oral form including, but not limited to, writings, letters, memoranda, electronic mail (otherwise known as “e-mail”), facsimiles, reports, notes, telegrams and interoffice communication. 3. The term “relating to” as used herein is defined to mean evidencing, referring to, pertaining to, consisting of, reflecting, concerning, or in any way logically or factually connected with the matters discussed. 4. The term “and” as well as “or” as used herein shall be read and applied as though interchangeable and shall be construed either disjunctively or conjunctively so as to require the fullest and most complete disclosure of all required information and documents. 5. The term “property” refers to the property located at 2920 SW 174" Way, Miramar, FL 33029. 6. The term “the time of the loss” or “as a result of the loss” means the loss as described in Plaintiffs’ Complaint. 7. The term “you” or “your” refers to the Plaintiffs, JEAN HEDGE and ROBERT HEDGE.PLEASE BRING WITH YOU THE FOLLOWING ITEMS AS INDICATED 1. Your driver's license or identification card. 2. Any and all agreements for representation between yourself and any individual or business entity representing you in this action. This request does not seek agreements for legal representation. 3. Any and all agreements for representation between yourself and any individual or business entity representing you in this action that evidence the fees, fee arrangements or fee schedules for the services of a public adjuster and/or loss consultant and/or estimator. 4. All documents and correspondence from you to any third-party, including any public adjuster and/or insurance agent relating to this loss. This request does not contemplate any documents or correspondence protected by attorney-client privilege. 5. All documents and correspondence to you from any third-party, including any public adjuster and/or insurance agent relating to this loss. This request does not contemplate any documents or correspondence protected by attorney-client privilege. 6. All documents and correspondence to you from he Insureds relating to this loss. This request does not contemplate any documents or correspondence protected by attorney-client privilege. 7. Any and all documents submitted to OMEGA INSURANCE COMPANY, and/or its agents or representatives related to claim 3300341865 by you and/or your representatives. 8. Any and all correspondence submitted to OMEGA INSURANCE COMPANY, and/or its agents or representatives related to claim 3300341865 by you and/or your representatives. 9. Any and all documents relating to damages claimed for the loss, including but not limited to estimates, work orders, proposals, statements, invoices, or contracts. 10. Any and all bills incurred as a result of the loss. 11. Any and all documents evidencing repairs or replacement of damaged property, including but not limited to invoices, statements, contracts, or work orders for damages claimed for the loss. 12. Any and all Notices of Commencement.13. 14. 15. 16. 18. 19. 20. 21. 22. 23. 24. 25. 26. Any and all applications for building permits. Any and all documents evidencing repairs or replacement of damaged personal property (i.e. contents), including but not limited to bills, invoices, statements, contracts, or work orders as a result of the loss. Any and all payments for repairs or replacement of damaged property for the loss, including but not limited to, cancelled checks, bills of sale, receipts, credit card statements, ATM receipts, and bank statements. Any and all documents evidencing your purchase of the property, including but not limited to closing documents, inspections and sales contract for the purchase of the property. Any and all photographs, videos, and diagrams demonstrating the damages you are claiming as a result of the loss. Your IRS income-tax return for the years: 2017, 2018, and 2019. Please bring original documents for this request. Any and all documents evidencing your payment of the monthly mortgage for the property. Please bring original documents for this request. All documents evidencing all repairs, including prior repairs, to any area of the property that is being claimed in your. All documents evidencing your efforts to protect the property from further damage as relating to the loss. All documents prepared by third parties relating to the loss, including but not limited to any inspection or evaluation performed of the property. All documents evidencing the remodeling, renovation, additions, maintenance or repairs to the property in the last five (5) years. If Plaintiff has refinanced the property at any time since purchasing the property, bring all copies of all inspection and/or appraisal reports prepared in conjunction with the refinance of the property. All expert and/or consultant reports in support of the claim that the property has sustained damage on or about September 10, 2017. All photographs and/or videos which depict the property prior to the alleged loss on or about September 10, 2017.27. 28. 29. 30. Any and all photographs, videos, and diagrams demonstrating the damages for claim number 3300341865. Any and all documents evidencing repairs or replacement of damaged property, including but not limited to invoices, statements, contracts, or work orders for damages claimed for claim number 3300341865. Any and all payments for repairs or replacement of damaged property for the loss, including but not limited to, cancelled checks, bills of sale, receipts, credit card statements, ATM receipts, and bank statements related to claim number 3300341865. Any and all documents or other items you believe OMEGA INSURANCE COMPANY should review in considering your claim.