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Filing # 140787416 E-Filed 12/21/2021 04:04:22 PM
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,
ve
FEDNAT INSURANCE COMPANY,
Defendant.
/
PLAINTIFF'S NOTICE OF FILING
PLEASE TAKE NOTICE that the undersigned hereby files with the Clerk of Court:
1. Return of Service for Jose Vasallo, which was served on December 7, 2021, is
attached hereto as Exhibit “A.”
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 21st
day of December, 2021.
KS LAW GROUP, PLLC
Attorneys for Plaintiffs
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: Litparalegal6@KSLawGroup.net
3 / ‘Keitherine Ke. Kipfe
KATHERINE A. KREPFLE, ESQ.
Florida Bar Number: 1010532
SEAN P. SCHULZ. ESO.
Florida Bar Number: 1007728
CHEN. DAIAARCACUAAIINTY Cl INGEDU ARDIIV7ZA FLEDY 491941INNNA NAANA-ND DN
HILLY. PAL DLA VUUINE TT, PL, JUOL I mDnNueey, ULL, 1are eu.) ute. civFiling # 138871044 E-Filed 11/19/2021 10:29:27 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.
/
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 pursuant to Florida Rules of Civil Procedure 1.310 a
deposition will be taking place before Orange Legal. or some other Notary Public for the State of
Florida at Large. The attorney for the Plaintiff will be taking the deposition of the below listed
individual at the following location, on the following date and time:
DEPONENT: Jose Vasallo — Defendant’s Field Adjuster
LOCATION: Via Zoom or other audio-video communication
DATE: March 30, 2022
TIME: 2:00pm
Il he taken before an associate or dennty court renorter of Orange 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 should
"* FILED: PALM BEACH COUNTY. FL JOSEPH ABRUZZO, CLERK. 11/19/2021 10:29:27 AM ***The deponent’s entire file related to this matter;
Current resume and curriculum vitae;
All current professional licenses, certifications or related qualification documents;
eee
Any and all documents, reports, photographs, in electronic and paper format (if
possible) the deponent gathered, placed in their file, collected or in any other way
relied upon in making any decision, opinions, observations or other actions of this
claim;
5. Any photographs taken or relied upon in their original format;
Any reports generated including all revisions;
7. Any reports reviewed;
*Documents for which Defendant has raised, or intends to raise, a privilege need not be
produced to Plaintiff for examination as long as Defendant files a sufficient privilege log
related to the allegedly privileged documents; however, these documents must be brought
so that deponent may adequately respond to non-privileged areas of inquiry*
(CERTIFICATE OF SERVICE ON THE NEXT PAGE)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 19th
day of November 2021.
KS LAW GROUP, PLLC
Attomeys for Plaintiffs
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: Litparalegal4@KSLawGroup.net
KATHERINE A. KREPFLE, ESQ.
Florida Bar Number: 1010532
SEAN P. SCHULZ, ESQ.
Florida Bar Number: 1007728
Copy: VeritextIN 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.
/
SUBPOENA FOR DEPOSITION DUCES TECUM
THE STATE OF FLORIDA
TO: Jose Vasallo
1821 SW 21st Ln.
Oana Carol BT 22001
ape UGra. ri S5771
YOU ARE COMMANDED to appear before a person authorized by law to take
deposition via Zoom or other audio-video communication on March 30, 2022, at 2:00 p.m. to
give testimony in this action and to permit the inspection and copying of designated documents
or tangible things in your possession, control and custody including the following:
1.
FY bs
The deponent’s entire file related to this matter;
Current resume and curriculum vitae;
All current professional licenses, certifications or related qualification documents;
Any and all documents, reports, photographs, in electronic and paper format (if
possible) the deponent gathered, placed in their file, collected or in any other way
relied upon in making any decision, opinions, observations or other actions of this
claim;
Any photographs taken or relied upon in their original format;
. Any reports generated including all revisions;
7. Any reports reviewed;
*Documents for which Defendant has raised, or intends to raise, a privilege need not
be produced to Plaintiff for examination as long as Defendant files a sufficient privilege
Page 1 of 2log related to the allegedly privileged documents; however, these documents must be
brought so that deponent may adequately respond to non-privileged areas of inquiry*
‘You are subpoenaed to appear by the below attorney and unless you are excused from
this Subpoena by this attorney or the Court, you shall respond to this Subpoena as directed.
If you fail to appear, you may be in contempt of Court.
Dated on this 22nd day of November 2021.
Respectfully submitted,
KS LAW GROUP, PLLC
Attorneys for Plaintiffs
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: Litparalegal4@KSLawGroup.net
3b fs (Keithorine ZB. Kiopfle
KATHERINE A. KREPFLE, ESQ.
Florida Bar Number: 1010532
SEAN P. SCHULZ, ESQ.
Florida Bar Number: 1007728
Page 2 of 2RETURN OF SERVICE
State of Florida County of PALM BEACH Circuit Court
Case Number: 50-2021-CA-004846-XXXX-MB_ Court Date: 3/30/2022 2:00 pm
QUANG VO PKP2021007307
vs.
Defendant:
FEDNAT INSURANCE COMPANY
For:
KATHERINE KREPFLE, ESQ.
KS LAW GROUP, PLLC.
947 LONGDALE AVENUE
LONGWOOD, FL 32750
Received by Central Florida Process on the 22nd day of November, 2021 at 2:36 pm to be served on JOSE VASALLO, 1821
gwoistl N gaol aa0g41
1, Dexter Carrasco, do hereby affirm that on the 7th day of December, 2021 at 6:35 pm, |:
INDIVIDUALLY/PERSONALLY served in accordance with F.S. 48.031 by delivering a true copy of the SUBPOENA FOR
DEPOSITION DUCES TECUM AND NOTICE OF TAKING DEPOSITION DUCES TECUM with the date and hour of service
endorsed thereon by me, to: JOSE VASALLO at the address of: 1821 S.W. 21st Lane, Cape Coral, FL 33991, and informed
sald person of the contents therein, in compliance with state statutes,
Description of Person Served: Age: 50s, Sex: M, Race/Skin Color; Hispanic, Height: 5'9", Weight: 250, Hair: gray, Glasses:
N
I certify that | am over the age of 18, have no interest in the above action, and am a Certified Process Server, in good
standing, in the judicial circuit in which the process was served. Under penalties of perjury,| declare that | have read the
foregoing Return of Service and the facts stated are true and correct. NO NOTARY REQUIRED PURSUANT TO F.S. 92-525
(2).
Central Florida Process
1516 E. Colonial Drive
Ste. 201
Orlando, FL 32803
(407) 709-8707
Our Job Serial Number: PKP-2021007307
Copyright © 1992-2021 Database Services, Ine, - Procoss Server's Tosibox V8.1¢j2/6/28 @ Li Barn
Ye 105875
IN THE CIRCUIT COURT OF THE
nero oNTH ITMDICIAL CIRCUIT IN
ACH COUNTY,
POSS Tans
Q
AND FOR PALM
FLORIDA
QUANG VO, CASE NUMBER:
50-2021-CA-004846-XXXX-MB
Plaintiff,
v.
FEDNAT INSURANCE COMPANY,
Defendant.
/
SUBPOENA FOR DEPOSITION DUCES TECUM
THE STATE OF FLORIDA
TO: Jose Vasallo
1821 SW 21st Ln.
Cann
wpe
YOU ARE COMMANDED to appear before a person authorized by law to take
deposition via Zoom or other audio-video communication on March 30, 2022, at 2:00 p.m. to
give testimony in this action and to permit the inspection and copying of designated documents
or tangible things in your possession, control and custody including the following:
1, The deponent’s entire file related to this matter;
2. Current resume and curriculum vitae;
3. All current professional licenses, certifications or related qualification documents;
4.
Any, and all documents, reports, photographs, in clectronic and paper format (if
possible) the deponent gathered, placed in their file, collected or in any other way
gelled upon in ng any decision, opinions, observations or other actions of this
claim; :
5. Any photographs taken or relied upon in their original format;
6. Any reports generated including all revisions;
7. Any reports reviewed;
ante fax wh
“Documents for y s raised, or intends to raise, a privilege need not
be produced to Plaintiff for examination as long as Defendant files a sufficient privilege
Noefendant
Page J of 2From: salendadfa@veritext.com
To:
Subject: Veritext Virtual Invitation | QUANG VO v. FEDNAT INSURANCE COMPANY | 3/30/2022 | 4965262 | FA Jose Vasallo
Date: Wednesday, November 24, 2021 3:16:53 PM
Your Assignment #4965262 is Scheduled and the meeting link is available below.
PROCEEDING DETAILS:
* CASE: QUANG VO v. FEDNAT INSURANCE COMPANY
* WITNESS: FA Jose Vasallo
* DATE & TIME: Wednesday, Mar 30 2022 2:00PM (Eastern Time (US & Canada))
* ASSIGNMENT #: 4965262
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KEN=IIUI a4Ual \AdUACUISIOIVIEIGUISED 1
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