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Filing # 139442250 E-Filed 12/01/2021 10:26:14 AM
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT IN
AND FOR PALM BEACH COUNTY,
FLORIDA
QUANG VO, CASE NUMBER:
50-2021-CA-004846-XXXX-MB
Plaintiff,
v.
FEDNAT INSURANCE COMPANY,
Defendant.
/
AMENDED NOTICE OF TAKING DEPOSITION DUCES TECUM
COMES NOW the Plaintiff, Quang Vo, by and through the undersigned counsel, states
as follows: PLEASE TAKE NOTICE that a deposition will be taking place before Veritext
Legal, or some other Notary Public for the State of Florida at Large. Pursuant to Florida Rules of
Civil Procedure 1.310(b)(6), FedNat Insurance Company, shall designate one or more officers,
directors, or managing agents, or other persons who consent to do so, to testify on its behalf and
may state the matters on which each person designated will testify. The persons so designated
shall testify about matters known or reasonably available to the organization. The attomey for the
Plaintiff will be taking the deposition of the below listed individual at the following location, on
the following date and time:
DEPONENT; Defendant’s Corporate Representative
LOCATION; Via Zoom or other audio-video communication
DATE: March 29, 2022
TIME: 2:00 pm
1
'** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 12/01/2021 10:26:14 AM ***The deposition will be taken before an associate or deputy court reporter of Veritext
Legal or some other Notary Public for the State of Florida at Large who is not of counsel to the
parties or interested in the events of this cause. This deposition is 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. This deposition will continue from day to day until completed. The deponent
h hedule “A” and th nent should bring with them all iments 1 nisi
hi hi heduled “B”,
*“Documents for which Defendant has raised, or intends to raise, a privilege (e.g., claims
file documents) need not be produced to Plaintiff for examination as long as Defendant files
a privilege log, however these documents must be brought so that deponent may adequately
respond to non-privileged areas of inquiry***
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the forgoing was served via the
Florida Courts e-portal to counsel for the Defendant, Amida U. Frey, Esq. at
amida@cslawpartners.com; sarah@cslawpartners.com; nader@cslawpartners.com;
filings@cslawpartners.com; susan@cslawpartners.com; and jill@cslawpartners.com on this 1st
day of December 2021.
KS LAW GROUP, PLLC
Attorneys for Plaintiff
947 Longdale Avenue
Longwood, FL 32750
Telephone: (407) 960-6965
Facsimile: (407) 960-6996
Primary for E-Service: Eservice@KSLawGroup.net
Secondary E-Mail: KKrepfle@KSLawGroup.net
Tertiary E-Mail: Litparalegalb@KSLawGroup.net
3/Keitherine
KATHERINE A. KREPFLE, ESQ.
Florida Bar Number: 1010532
SEAN P. SCHULZ, ESQ.
Florida Bar Number: 1007728
2Schedule A ~ Areas of Inquiry
1. Defendant’s Answer and Affirmative Defenses.
2. The subject insurance policy issued by the Defendant to the Plaintiff(s).
3 The subject claim determination which is the basis of this suit.
4. Defendant’s responses to Plaintiff(s)’ interrogatories, request for production and
request for admissions.
5. All inspections of the property performed by the Defendant or its agents of the
subject property.
6. Any remediation services or work performed at the subject insured property since
the Date of Loss as referenced in the Complaint.
7. Any and all payments, if any made to the Plaintiff(s) or any other party in regards
to the claim which is the subject of the suit.
8. Any and all documents contained in the Defendant’s claim file as it related to the
subject insurance claim which is the subject of the suit including but not limited to all documents,
records, or other information prepared by the Defendant or obtained from the Plaintiff(s) or any
other third party in regards to the subject claim.
9. Any and all photographs, videos or other depictions of the subject insured property
that are in the possession of the Defendant.
10. Any and all conversations between the Plaintiff(s) and any of their agents and the
Defendant and their agents.
11. Any and all information related to any policy conditions, exclusions or other
portions of the policy that the Defendant relied upon and contends is the basis for failing to provide
coverage for the subject claim.Schedule B — Documents to be Produced
Ll. A complete and full copy of the subject claim file as maintained by the Defendant
or its agent(s) with regard to the Plaintiff(s)’ claim including but not limited to all photographs,
estimates, reports, telephone messages, notes, correspondences, checks, payment ledgers, audio or
video recordings of the Plaintiff(s) or insured property, witness statements, examination under oath
transcripts of the Plaintiff(s) or any third parties associated with the subject loss, or otherwise.
2. Copies of all checks or drafts issued by the Defendant to the Plaintiff(s), Plaintiff(s)
agents, or third parties. This request also includes copies of cleared checks.
3. All insurance policies in the possession of the Defendant which would benefit or
insure the Plaintiff(s) or subject property along with a declarations page attached to same and a
swom statement by a corporate officer attesting to the coverage and authenticity of the policy.
4. All notations made of any telephone calls form the Plaintiff(s) or the Plaintiff(s)
agents which were made at the time of the telephone call.
5. Any and all written communications between the Defendant and Plaintiff(s) or the
Plaintiff(s) agents.
6. Any and all claim correspondence sent to Plaintiff(s), the Plaintiff(s) agents or any
other party who had a party in the subject claim.
7. Any and all documents in Defendant’s possession including documents from
Plaintiff(s) or the Plaintiff(s) agents, any third party or otherwise evidencing, documenting, or
explaining the damage to the insured property which is the subject of the claim and suit.
8. Any and all documents in the possession of the Defendant which the Defendant
relied upon and contends is the basis for failing to provide coverage for the subject claim.
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Filing # 139442250 E-Filed 12/01/2021 10:26:14 AM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA QUANG VO, CASE NUMBER: 50-2021-CA-004846-XXXX-MB Plaintiff, v. FEDNAT INSURANCE COMPANY, Defendant. / AMENDED NOTICE OF TAKING DEPOSITION DUCES TECUM COMES NOW the Plaintiff, Quang Vo, by and through the undersigned counsel, states as follows: PLEASE TAKE NOTICE that a deposition will be taking place before Veritext Legal, or some other Notary Public for the State of Florida at Large. Pursuant to Florida Rules of Civil Procedure 1.310(b)(6), FedNat Insurance Company, shall designate one or more officers, directors, or managing agents, or other persons who consent to do so, to testify on its behalf and may state the matters on which each person designated will testify. The persons so designated shall testify about matters known or reasonably available to the organization. The attomey for the Plaintiff will be taking the deposition of the below listed individual at the following location, on the following date and time: DEPONENT; Defendant’s Corporate Representative LOCATION; Via Zoom or other audio-video communication DATE: March 29, 2022 TIME: 2:00 pm 1 '** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 12/01/2021 10:26:14 AM ***The deposition will be taken before an associate or deputy court reporter of Veritext Legal or some other Notary Public for the State of Florida at Large who is not of counsel to the parties or interested in the events of this cause. This deposition is 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. This deposition will continue from day to day until completed. The deponent h hedule “A” and th nent should bring with them all iments 1 nisi hi hi heduled “B”, *“Documents for which Defendant has raised, or intends to raise, a privilege (e.g., claims file documents) need not be produced to Plaintiff for examination as long as Defendant files a privilege log, however these documents must be brought so that deponent may adequately respond to non-privileged areas of inquiry*** CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the forgoing was served via the Florida Courts e-portal to counsel for the Defendant, Amida U. Frey, Esq. at amida@cslawpartners.com; sarah@cslawpartners.com; nader@cslawpartners.com; filings@cslawpartners.com; susan@cslawpartners.com; and jill@cslawpartners.com on this 1st day of December 2021. KS LAW GROUP, PLLC Attorneys for Plaintiff 947 Longdale Avenue Longwood, FL 32750 Telephone: (407) 960-6965 Facsimile: (407) 960-6996 Primary for E-Service: Eservice@KSLawGroup.net Secondary E-Mail: KKrepfle@KSLawGroup.net Tertiary E-Mail: Litparalegalb@KSLawGroup.net 3/Keitherine KATHERINE A. KREPFLE, ESQ. Florida Bar Number: 1010532 SEAN P. SCHULZ, ESQ. Florida Bar Number: 1007728 2Schedule A ~ Areas of Inquiry 1. Defendant’s Answer and Affirmative Defenses. 2. The subject insurance policy issued by the Defendant to the Plaintiff(s). 3 The subject claim determination which is the basis of this suit. 4. Defendant’s responses to Plaintiff(s)’ interrogatories, request for production and request for admissions. 5. All inspections of the property performed by the Defendant or its agents of the subject property. 6. Any remediation services or work performed at the subject insured property since the Date of Loss as referenced in the Complaint. 7. Any and all payments, if any made to the Plaintiff(s) or any other party in regards to the claim which is the subject of the suit. 8. Any and all documents contained in the Defendant’s claim file as it related to the subject insurance claim which is the subject of the suit including but not limited to all documents, records, or other information prepared by the Defendant or obtained from the Plaintiff(s) or any other third party in regards to the subject claim. 9. Any and all photographs, videos or other depictions of the subject insured property that are in the possession of the Defendant. 10. Any and all conversations between the Plaintiff(s) and any of their agents and the Defendant and their agents. 11. Any and all information related to any policy conditions, exclusions or other portions of the policy that the Defendant relied upon and contends is the basis for failing to provide coverage for the subject claim.Schedule B — Documents to be Produced Ll. A complete and full copy of the subject claim file as maintained by the Defendant or its agent(s) with regard to the Plaintiff(s)’ claim including but not limited to all photographs, estimates, reports, telephone messages, notes, correspondences, checks, payment ledgers, audio or video recordings of the Plaintiff(s) or insured property, witness statements, examination under oath transcripts of the Plaintiff(s) or any third parties associated with the subject loss, or otherwise. 2. Copies of all checks or drafts issued by the Defendant to the Plaintiff(s), Plaintiff(s) agents, or third parties. This request also includes copies of cleared checks. 3. All insurance policies in the possession of the Defendant which would benefit or insure the Plaintiff(s) or subject property along with a declarations page attached to same and a swom statement by a corporate officer attesting to the coverage and authenticity of the policy. 4. All notations made of any telephone calls form the Plaintiff(s) or the Plaintiff(s) agents which were made at the time of the telephone call. 5. Any and all written communications between the Defendant and Plaintiff(s) or the Plaintiff(s) agents. 6. Any and all claim correspondence sent to Plaintiff(s), the Plaintiff(s) agents or any other party who had a party in the subject claim. 7. Any and all documents in Defendant’s possession including documents from Plaintiff(s) or the Plaintiff(s) agents, any third party or otherwise evidencing, documenting, or explaining the damage to the insured property which is the subject of the claim and suit. 8. Any and all documents in the possession of the Defendant which the Defendant relied upon and contends is the basis for failing to provide coverage for the subject claim.