arrow left
arrow right
  • VO, QUANG V FEDNAT INSURANCE COMPANY CONTRACT & DEBT document preview
  • VO, QUANG V FEDNAT INSURANCE COMPANY CONTRACT & DEBT document preview
  • VO, QUANG V FEDNAT INSURANCE COMPANY CONTRACT & DEBT document preview
  • VO, QUANG V FEDNAT INSURANCE COMPANY CONTRACT & DEBT document preview
  • VO, QUANG V FEDNAT INSURANCE COMPANY CONTRACT & DEBT document preview
  • VO, QUANG V FEDNAT INSURANCE COMPANY CONTRACT & DEBT document preview
  • VO, QUANG V FEDNAT INSURANCE COMPANY CONTRACT & DEBT document preview
  • VO, QUANG V FEDNAT INSURANCE COMPANY CONTRACT & DEBT document preview
						
                                

Preview

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 MEETING LINK: PLEASE FORWARD THE LINK TO ALL PARTIES THAT WILL PARTICIPATE IN THE SESSION. If you have already provided Veritext with the name and email address of other participants, they will receive this link directly in a separate email from Veritext. KEN=IIUI a4Ual \AdUACUISIOIVIEIGUISED 1 igS.Weritext.comn Participating via Meeting ID/Password, Video Teleconference or Conference Call: If you would like to participate via Meeting ID/Password, Video Teleconference or Conference call, click the link above within an hour of the scheduled start time, identify yourself and click Show My Meeting ID/Password and Additional Session Details. Sharing the meeting link with non-narties or unaffiliated individuals could affect the security of the session. TECHNICAL SUPPORT: * FOR TECHNICAL SUPPORT BEFORE OR DURING THE PROCEEDING: 855-440-4861 | remote@veritext.com © FOR QUESTIONS REGARDING YOUR UPCOMING VERITEXT VIRTUAL SESSION: 305-376-8800 | calendarfla@veritext.com + TEST YOUR EQUIPMENT: We strongly encourage participants to test the actual equipment and the Internet connection that they will be using in advance of the remote proceeding. This self test typically takes 3 to S minutes. TEST THE SYSTEM Thank you for choosing Veritext for your upcoming proceeding.Mlinses se wasn haraern View a5 Wenpage