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Filing # 146670182 E-Filed 03/29/2022 10:34:42 PM
IN THE CIRCUIT COURT OF THE
15TH JUDICIAL CIRCUIT, IN AND FOR.
PALM BEACH, FLORIDA
QUANG VO, CIVIL DIVISION
Plaintiff(s), CASE NO: 50-2021-CA-004846
vs.
FEDNAT INSURANCE COMPANY,
Defendant(s),
/
NOTICE OF PRODUCTION FROM NO!
TO: All attorneys listed on the Certificate of Service below;
YOU ARE NOTIFIED that after 10 days from the date of electronic service of this notice, and if no
objection is received from any party, the undersigned will issue or apply to the clerk of this court issuance of the
attached subpoena(s) directed to the Records Custodians of:
Dick Lambert Inspections
2866 Spring Chase Lane
Marianna, FL, 32446
Triumph Property Services
3600 S. Congress Avenue, Suite L
Boynton Beach, FL, 33426
to produce the items listed at the time and place specified in the subpoena.
CASE NO: 50-2021-CA-004846
CHEN. DAIAARCACUAAIINTY Cl INGEDU ARDIIV7ZN FLED N2INAINNN 40-24-49 DNA
PILL. PAL DLA VUUINE TT, FL, JUOL IE mDNUeeY, ULLIAN, voremeue. WU.otte civCERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing document was filed electronically and
was sent by E-mail from the Florida Courts' E-Filing Portal system to: Katherine Krepfle, Esq.
KKrepfle@KSLawGroup.net, KS LAW GROUP, PLLC, 947 Longdale Avenue, Longwood, FL, 32750 on this
29" day of March, 2022.
Carabotta Steakley, PLLC
Attorney for Defendant
12000 Biscayne Blvd. Suite 703
North Miami, FL 33181 Telephone
Number: 305-874-7337
Fax Number: 786-456-5327
By: /s/ Ellie Einhorn
Ellie Einhorn, Esq.
FBN. 111466
76395
CASE NO: 50-2021-CA-00484676395 - 1
IN THE CIRCUIT COURT OF THE
15TH JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH, FLORIDA
QUANG Vo,
Plaintifi(s),
VS.
FEDNAT INSURANCE COMPANY,
Defendani(s), CIVIL DIVISION
/ CASE NO: 50-2021-CA-004846
SUBPOENA DUCES TECUM
THE STATE OF FLORIDA
Dick Lambert Inspections
TO: 2866 Spring Chase Lane
Marianna, FL 32446
YOU ARE COMMANDED to appear at or mail to: Unisource Discovery, 555 NE 15th
Street, 9t* Floor, 934-A, Miami, FL 33132 fifteen (15) days from the date of service and to have
with you at that time and place the following regarding the below-named individual:
Re: NAME: Quane Vo DOR: — SSN: AKA:
See Attachment.
These items will be inspected and may be copied at that time. You will not be required to surrender
the original items. YOU may comply with this subpoena by providing legible copies of the items to
be produced to UNISOURCE DISCOVERY, the agent of the attorney whose name appears on this
ypoena on or before the scheduled date of production. “The records requested will be used for this
Hine antes and ill bn wateennd aw dactensind ofan Te satntn 2? Dianna an. Hn
On Gy aia Win Us TewineG GF GeswOyea aueT ligation is CoMpieis.” Picase Contact Wein
directly and send all Medical Records, Bills, Films and all other items necessary for compliance to
555 NE 15th Street, 9th Floor, 934-A, Miami, FL 33132, Tel: 866-580-0002, Fax: 866-580-9070
and thereby eliminating your appearance at the time and place specified above. DO NOT SEND
RECORDS TO LAW OFFICE. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL
BE TAKEN. PLEASE ATTACH A COPY OF THIS SUBPOENA TO THE RECORDS PROVIDED.
****RECORDS CUSTODIAN - Please DO NOT Conv Records without written annroval
and/or prepayment if the cost exceeds $100.00****
CASE NO: 50-2021-CA-004846CERTIFICATE OF NOTICE
Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45 CFR Parts 160 and
164, CFR 164.512 and FRCP 1.351, I hereby certify that I have complied with the regulations and requirements to
obtain patient health information and that the representations below are true and correct:
1.
If you fail to:
Q)
Q)
GB)
Ihave made a good faith attempt to provide written notice to the above-named patient that his/her
protected health information has been subpoenaed.
The written notice Provided sufficient information about this litigation or Proceeding i in which the
neatactad Lanlth infaena ad tr mavenit tha alia, tha annet
PrOcccieS Heath MGMatGH 1S TEGuEStEG tS Permit is patient UG TaiSe aii GujeCtioN tS Wis COUT OF
administrative tribunal; and
The time for the patient to raise objections to the court or administrative tribunal has elapsed and;
no objections were filed; or all objections filed by the patient were resolved by the court or
administrative tribunal and the disclosure being sought are consistent with such resolution.
appear as specified; or
furnish the records instead of appearing as provided above; or
object to this subpoena,
you may be in contempt of court. You are subpoenaed to appear by the following attorney, and unless excused from
this subpoena by this attorney or the court, you shall respond to this subpoena as directed.
DATED on:
Carabotta Steakley, PLLC
Attorney for Defendant
12000 Biscayne Blvd. Suite 703 North
Miami. FL, 33181
By.
Ellie Einhorn, Esq. FBN:
111466
CASE NO: 50-2021-CA-004846Plaintiff/Applicant: QUANG VO
Mofandant/D sonandant: ETN AT TNCITD ANCE Case Number: 50-2021-CA-004846
Detendant Respondent! PEDNAT INSURANCE
COMPANY |
Attachment
Order # 76395
Location # |
Records of Quang Vo
AKA
Date of Birth
Social Security
*IF YOU HAVE ANY QUESTIONS, PLEASE CONTACT UNISOURCE DISCOVERY AT 866-
580-0002, SUPPORT@UNISOURCEDISCOVERY.NET OR VIA FAX 866-580-9070.
PLEASE ALSO BE SURE TO SIGN AND DATE THE DECLARATION OF CUSTODIAN OF
RECORDS PAGE/CUSTODIAN AFFIDAVIT*
1. Your entire file, in any form, in connection with the investigation, evaluation, and/or inspection
of the property owned by Quang Vo (“Plaintiff”) at 9428 Fox Trot Ln, Boca Raton, Florida 33496
(“Property”), by you or any representative of Triumph Property Services on or about August 27, 2020.
2. All correspondence in any form, whether written, typed, computer generated and/or electronic mail,
between Triumph Property Services, its agents, employees, and/or representatives and Plaintiff, their
agents and/or representatives concerning the Plaintiff and/or the Property.
3. All contracts, estimates, bids, quotes, work orders, permit applications, and/or proposals relating to
the Property and/or Plaintiff from August 27, 2020 to the present.
4. All reports, memoranda, calculations, notes, whether written or recorded on any type of recorded
media (including computer discs and CD ROMs), related to the aforementioned Property and/or
Plaintiff.
5. All invoices, receipts, copies of checks or other billing information related to the Plaintiff and/or the
Property.
6. All photographs, videotapes, drawings or any other type of visual representation depicting the
interior and/or exterior of the Property.
7. All documents evidencing payment to Triumph Property Services, for the amount due on the invoice,
including but not limited to cancelled checks, bank statements evidencing a deposit of funds into any
account held by Triumph Property Services, for any repairs and/or work performed on the Property by
Triumph Property Services, as set forth in documents evidencing credit card charges for said repairs.
CASE NO: 50-2021-CA-0048468. Conies of all professional licenses issued to Triumnh Pronerty Services, by the State of Florida.
9. Any and all electronic files maintained in the regular course of business that are responsive to the
above 8 requests are required to be produced to Defendant in their electronic, pristine, native format.
CASE NO: 50-2021-CA-00484676395 -2
IN THE CIRCUIT COURT OF THE
15TH JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH, FLORIDA
QUANG VO,
Plaintiff(s),
vs.
FEDNAT INSURANCE COMPANY,
Defendant(s), CIVIL DIVISION
/ CASE NO: 50-2021-CA-004846
SUBPOENA DUCES TECUM
THE STATE OF FLORIDA
Triumph Property Services
TO: 3600S. Congress Avenue, Suite L
Boynton Beach, FL 33426
YOU ARE COMMANDED to appear at or mail to: Unisource Discovery, 555 NE 15th
Street, 9t* Floor, 934-A, Miami, FL 33132 fifteen (15) days from the date of service and to have
with you at that time and place the following regarding the below-named individual:
Re: NAME: Quane Vo DOR: — SSN: AKA:
See Attachment.
These items will be inspected and may be copied at that time. You will not be required to surrender
the original items. YOU may comply with this subpoena by providing legible copies of the items to
be produced to UNISOURCE DISCOVERY, the agent of the attorney whose name appears on this
ypoena on or before the scheduled date of production. “The records requested will be used for this
Haw ante and wrll La vateenad aw dasteaviad afiaw Hinat Amanlata? Dianna anntan
iG GIy aiid Will be Tetummed GF destroyed afer litigation is complete.” Please Contact tien
directly and send all Medical Records, Bills, Films and all other items necessary for compliance to
555 NE 15th Street, 9th Floor, 934-A, Miami, FL 33132, Tel: 866-580-0002, Fax: 866-580-9070
and thereby eliminating your appearance at the time and place specified above. DO NOT SEND
RECORDS TO LAW OFFICE. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL
BE TAKEN. PLEASE ATTACH A COPY OF THIS SUBPOENA TO THE RECORDS PROVIDED.
****RECORDS CUSTODIAN - Please DO NOT Conv Records without written annroval
and/or prepayment if the cost exceeds $100.00****
CASE NO: 50-2021-CA-004846CERTIFICATE OF NOTICE
Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45 CFR Parts 160 and
164, CFR 164.512 and FRCP 1.351, I hereby certify that I have complied with the regulations and requirements to
obtain patient health information and that the representations below are true and correct:
1.
If you fail to:
Q)
Q)
GB)
Ihave made a good faith attempt to provide written notice to the above-named patient that his/her
protected health information has been subpoenaed.
The written notice Provided sufficient information about this litigation or Proceeding i in which the
neatactad Lanlth infaena ad tr mavenit tha alia, tha annet
PrOcccieS Heath MGMatGH 1S TEGuEStEG tS Permit is patient UG TaiSe aii GujeCtioN tS Wis COUT OF
administrative tribunal; and
The time for the patient to raise objections to the court or administrative tribunal has elapsed and;
no objections were filed; or all objections filed by the patient were resolved by the court or
administrative tribunal and the disclosure being sought are consistent with such resolution.
appear as specified; or
furnish the records instead of appearing as provided above; or
object to this subpoena,
you may be in contempt of court. You are subpoenaed to appear by the following attorney, and unless excused from
this subpoena by this attorney or the court, you shall respond to this subpoena as directed.
DATED on:
Carabotta Steakley, PLLC
Attorney for Defendant
12000 Biscayne Blvd. Suite 703 North
Miami. FL, 33181
By.
Ellie Einhorn, Esq. FBN:
111466
CASE NO: 50-2021-CA-004846Plaintiff/Applicant: QUANG VO
Mofandant/D sonandant: ETN AT TNCITD ANCE Case Number: 50-2021-CA-004846
Detendant Respondent! PEDNAT INSURANCE
COMPANY |
Attachment
Order # 76395
Location # 2
Records of Quang Vo
AKA
Date of Birth
Social Security
*IF YOU HAVE ANY QUESTIONS, PLEASE CONTACT UNISOURCE DISCOVERY AT 866-
580-0002, SUPPORT@UNISOURCEDISCOVERY.NET OR VIA FAX 866-580-9070.
PLEASE ALSO BE SURE TO SIGN AND DATE THE DECLARATION OF CUSTODIAN OF
RECORDS PAGE/CUSTODIAN AFFIDAVIT*
1. Your entire file, in any form, in connection with the investigation, evaluation, and/or inspection of
the property owned by Quang Vo (“Plaintiff”) at 9428 Fox Trot Ln, Boca Raton, Florida 33496
(“Property”), by you or any representative of Triumph Property Services on or about August 27, 2020.
2. All correspondence in any form, whether written, typed, computer generated and/or electronic mail,
between Triumph Property Services, its agents, employees, and/or representatives and Plaintiff, their
agents and/or representatives concerning the Plaintiff and/or the Property.
3. All contracts, estimates, bids, quotes, work orders, permit applications, and/or proposals relating to
the Property and/or Plaintiff from August 27, 2020 to the present.
4. All reports, memoranda, calculations, notes, whether written or recorded on any type of recorded
media (including computer discs and CD ROMs), related to the aforementioned Property and/or
Plaintiff.
5. All invoices, receipts, copies of checks or other billing information related to the Plaintiff and/or the
Property.
6. All photographs, videotapes, drawings or any other type of visual representation depicting the interior
and/or exterior of the Property.
7. All documents evidencing payment to Triumph Property Services, for the amount due on the invoice,
including but not limited to cancelled checks, bank statements evidencing a deposit of funds into any
account held by Triumph Property Services, for any repairs and/or work performed on the Property by
Triumph Property Services, as set forth in documents evidencing credit card charges for said repairs.
CASE NO: 50-2021-CA-0048468. Conies of all professional licenses issued to Triumnh Pronerty Services, by the State of Florida.
9. Any and all electronic files maintained in the regular course of business that are responsive to the
above 8 requests are required to be produced to Defendant in their electronic, pristine, native format.
CASE NO: 50-2021-CA-004846
Preview
Filing # 146670182 E-Filed 03/29/2022 10:34:42 PM IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT, IN AND FOR. PALM BEACH, FLORIDA QUANG VO, CIVIL DIVISION Plaintiff(s), CASE NO: 50-2021-CA-004846 vs. FEDNAT INSURANCE COMPANY, Defendant(s), / NOTICE OF PRODUCTION FROM NO! TO: All attorneys listed on the Certificate of Service below; YOU ARE NOTIFIED that after 10 days from the date of electronic service of this notice, and if no objection is received from any party, the undersigned will issue or apply to the clerk of this court issuance of the attached subpoena(s) directed to the Records Custodians of: Dick Lambert Inspections 2866 Spring Chase Lane Marianna, FL, 32446 Triumph Property Services 3600 S. Congress Avenue, Suite L Boynton Beach, FL, 33426 to produce the items listed at the time and place specified in the subpoena. CASE NO: 50-2021-CA-004846 CHEN. DAIAARCACUAAIINTY Cl INGEDU ARDIIV7ZN FLED N2INAINNN 40-24-49 DNA PILL. PAL DLA VUUINE TT, FL, JUOL IE mDNUeeY, ULLIAN, voremeue. WU.otte civCERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing document was filed electronically and was sent by E-mail from the Florida Courts' E-Filing Portal system to: Katherine Krepfle, Esq. KKrepfle@KSLawGroup.net, KS LAW GROUP, PLLC, 947 Longdale Avenue, Longwood, FL, 32750 on this 29" day of March, 2022. Carabotta Steakley, PLLC Attorney for Defendant 12000 Biscayne Blvd. Suite 703 North Miami, FL 33181 Telephone Number: 305-874-7337 Fax Number: 786-456-5327 By: /s/ Ellie Einhorn Ellie Einhorn, Esq. FBN. 111466 76395 CASE NO: 50-2021-CA-00484676395 - 1 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH, FLORIDA QUANG Vo, Plaintifi(s), VS. FEDNAT INSURANCE COMPANY, Defendani(s), CIVIL DIVISION / CASE NO: 50-2021-CA-004846 SUBPOENA DUCES TECUM THE STATE OF FLORIDA Dick Lambert Inspections TO: 2866 Spring Chase Lane Marianna, FL 32446 YOU ARE COMMANDED to appear at or mail to: Unisource Discovery, 555 NE 15th Street, 9t* Floor, 934-A, Miami, FL 33132 fifteen (15) days from the date of service and to have with you at that time and place the following regarding the below-named individual: Re: NAME: Quane Vo DOR: — SSN: AKA: See Attachment. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. YOU may comply with this subpoena by providing legible copies of the items to be produced to UNISOURCE DISCOVERY, the agent of the attorney whose name appears on this ypoena on or before the scheduled date of production. “The records requested will be used for this Hine antes and ill bn wateennd aw dactensind ofan Te satntn 2? Dianna an. Hn On Gy aia Win Us TewineG GF GeswOyea aueT ligation is CoMpieis.” Picase Contact Wein directly and send all Medical Records, Bills, Films and all other items necessary for compliance to 555 NE 15th Street, 9th Floor, 934-A, Miami, FL 33132, Tel: 866-580-0002, Fax: 866-580-9070 and thereby eliminating your appearance at the time and place specified above. DO NOT SEND RECORDS TO LAW OFFICE. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. PLEASE ATTACH A COPY OF THIS SUBPOENA TO THE RECORDS PROVIDED. ****RECORDS CUSTODIAN - Please DO NOT Conv Records without written annroval and/or prepayment if the cost exceeds $100.00**** CASE NO: 50-2021-CA-004846CERTIFICATE OF NOTICE Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45 CFR Parts 160 and 164, CFR 164.512 and FRCP 1.351, I hereby certify that I have complied with the regulations and requirements to obtain patient health information and that the representations below are true and correct: 1. If you fail to: Q) Q) GB) Ihave made a good faith attempt to provide written notice to the above-named patient that his/her protected health information has been subpoenaed. The written notice Provided sufficient information about this litigation or Proceeding i in which the neatactad Lanlth infaena ad tr mavenit tha alia, tha annet PrOcccieS Heath MGMatGH 1S TEGuEStEG tS Permit is patient UG TaiSe aii GujeCtioN tS Wis COUT OF administrative tribunal; and The time for the patient to raise objections to the court or administrative tribunal has elapsed and; no objections were filed; or all objections filed by the patient were resolved by the court or administrative tribunal and the disclosure being sought are consistent with such resolution. appear as specified; or furnish the records instead of appearing as provided above; or object to this subpoena, you may be in contempt of court. You are subpoenaed to appear by the following attorney, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. DATED on: Carabotta Steakley, PLLC Attorney for Defendant 12000 Biscayne Blvd. Suite 703 North Miami. FL, 33181 By. Ellie Einhorn, Esq. FBN: 111466 CASE NO: 50-2021-CA-004846Plaintiff/Applicant: QUANG VO Mofandant/D sonandant: ETN AT TNCITD ANCE Case Number: 50-2021-CA-004846 Detendant Respondent! PEDNAT INSURANCE COMPANY | Attachment Order # 76395 Location # | Records of Quang Vo AKA Date of Birth Social Security *IF YOU HAVE ANY QUESTIONS, PLEASE CONTACT UNISOURCE DISCOVERY AT 866- 580-0002, SUPPORT@UNISOURCEDISCOVERY.NET OR VIA FAX 866-580-9070. PLEASE ALSO BE SURE TO SIGN AND DATE THE DECLARATION OF CUSTODIAN OF RECORDS PAGE/CUSTODIAN AFFIDAVIT* 1. Your entire file, in any form, in connection with the investigation, evaluation, and/or inspection of the property owned by Quang Vo (“Plaintiff”) at 9428 Fox Trot Ln, Boca Raton, Florida 33496 (“Property”), by you or any representative of Triumph Property Services on or about August 27, 2020. 2. All correspondence in any form, whether written, typed, computer generated and/or electronic mail, between Triumph Property Services, its agents, employees, and/or representatives and Plaintiff, their agents and/or representatives concerning the Plaintiff and/or the Property. 3. All contracts, estimates, bids, quotes, work orders, permit applications, and/or proposals relating to the Property and/or Plaintiff from August 27, 2020 to the present. 4. All reports, memoranda, calculations, notes, whether written or recorded on any type of recorded media (including computer discs and CD ROMs), related to the aforementioned Property and/or Plaintiff. 5. All invoices, receipts, copies of checks or other billing information related to the Plaintiff and/or the Property. 6. All photographs, videotapes, drawings or any other type of visual representation depicting the interior and/or exterior of the Property. 7. All documents evidencing payment to Triumph Property Services, for the amount due on the invoice, including but not limited to cancelled checks, bank statements evidencing a deposit of funds into any account held by Triumph Property Services, for any repairs and/or work performed on the Property by Triumph Property Services, as set forth in documents evidencing credit card charges for said repairs. CASE NO: 50-2021-CA-0048468. Conies of all professional licenses issued to Triumnh Pronerty Services, by the State of Florida. 9. Any and all electronic files maintained in the regular course of business that are responsive to the above 8 requests are required to be produced to Defendant in their electronic, pristine, native format. CASE NO: 50-2021-CA-00484676395 -2 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH, FLORIDA QUANG VO, Plaintiff(s), vs. FEDNAT INSURANCE COMPANY, Defendant(s), CIVIL DIVISION / CASE NO: 50-2021-CA-004846 SUBPOENA DUCES TECUM THE STATE OF FLORIDA Triumph Property Services TO: 3600S. Congress Avenue, Suite L Boynton Beach, FL 33426 YOU ARE COMMANDED to appear at or mail to: Unisource Discovery, 555 NE 15th Street, 9t* Floor, 934-A, Miami, FL 33132 fifteen (15) days from the date of service and to have with you at that time and place the following regarding the below-named individual: Re: NAME: Quane Vo DOR: — SSN: AKA: See Attachment. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. YOU may comply with this subpoena by providing legible copies of the items to be produced to UNISOURCE DISCOVERY, the agent of the attorney whose name appears on this ypoena on or before the scheduled date of production. “The records requested will be used for this Haw ante and wrll La vateenad aw dasteaviad afiaw Hinat Amanlata? Dianna anntan iG GIy aiid Will be Tetummed GF destroyed afer litigation is complete.” Please Contact tien directly and send all Medical Records, Bills, Films and all other items necessary for compliance to 555 NE 15th Street, 9th Floor, 934-A, Miami, FL 33132, Tel: 866-580-0002, Fax: 866-580-9070 and thereby eliminating your appearance at the time and place specified above. DO NOT SEND RECORDS TO LAW OFFICE. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. PLEASE ATTACH A COPY OF THIS SUBPOENA TO THE RECORDS PROVIDED. ****RECORDS CUSTODIAN - Please DO NOT Conv Records without written annroval and/or prepayment if the cost exceeds $100.00**** CASE NO: 50-2021-CA-004846CERTIFICATE OF NOTICE Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45 CFR Parts 160 and 164, CFR 164.512 and FRCP 1.351, I hereby certify that I have complied with the regulations and requirements to obtain patient health information and that the representations below are true and correct: 1. If you fail to: Q) Q) GB) Ihave made a good faith attempt to provide written notice to the above-named patient that his/her protected health information has been subpoenaed. The written notice Provided sufficient information about this litigation or Proceeding i in which the neatactad Lanlth infaena ad tr mavenit tha alia, tha annet PrOcccieS Heath MGMatGH 1S TEGuEStEG tS Permit is patient UG TaiSe aii GujeCtioN tS Wis COUT OF administrative tribunal; and The time for the patient to raise objections to the court or administrative tribunal has elapsed and; no objections were filed; or all objections filed by the patient were resolved by the court or administrative tribunal and the disclosure being sought are consistent with such resolution. appear as specified; or furnish the records instead of appearing as provided above; or object to this subpoena, you may be in contempt of court. You are subpoenaed to appear by the following attorney, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. DATED on: Carabotta Steakley, PLLC Attorney for Defendant 12000 Biscayne Blvd. Suite 703 North Miami. FL, 33181 By. Ellie Einhorn, Esq. FBN: 111466 CASE NO: 50-2021-CA-004846Plaintiff/Applicant: QUANG VO Mofandant/D sonandant: ETN AT TNCITD ANCE Case Number: 50-2021-CA-004846 Detendant Respondent! PEDNAT INSURANCE COMPANY | Attachment Order # 76395 Location # 2 Records of Quang Vo AKA Date of Birth Social Security *IF YOU HAVE ANY QUESTIONS, PLEASE CONTACT UNISOURCE DISCOVERY AT 866- 580-0002, SUPPORT@UNISOURCEDISCOVERY.NET OR VIA FAX 866-580-9070. PLEASE ALSO BE SURE TO SIGN AND DATE THE DECLARATION OF CUSTODIAN OF RECORDS PAGE/CUSTODIAN AFFIDAVIT* 1. Your entire file, in any form, in connection with the investigation, evaluation, and/or inspection of the property owned by Quang Vo (“Plaintiff”) at 9428 Fox Trot Ln, Boca Raton, Florida 33496 (“Property”), by you or any representative of Triumph Property Services on or about August 27, 2020. 2. All correspondence in any form, whether written, typed, computer generated and/or electronic mail, between Triumph Property Services, its agents, employees, and/or representatives and Plaintiff, their agents and/or representatives concerning the Plaintiff and/or the Property. 3. All contracts, estimates, bids, quotes, work orders, permit applications, and/or proposals relating to the Property and/or Plaintiff from August 27, 2020 to the present. 4. All reports, memoranda, calculations, notes, whether written or recorded on any type of recorded media (including computer discs and CD ROMs), related to the aforementioned Property and/or Plaintiff. 5. All invoices, receipts, copies of checks or other billing information related to the Plaintiff and/or the Property. 6. All photographs, videotapes, drawings or any other type of visual representation depicting the interior and/or exterior of the Property. 7. All documents evidencing payment to Triumph Property Services, for the amount due on the invoice, including but not limited to cancelled checks, bank statements evidencing a deposit of funds into any account held by Triumph Property Services, for any repairs and/or work performed on the Property by Triumph Property Services, as set forth in documents evidencing credit card charges for said repairs. CASE NO: 50-2021-CA-0048468. Conies of all professional licenses issued to Triumnh Pronerty Services, by the State of Florida. 9. Any and all electronic files maintained in the regular course of business that are responsive to the above 8 requests are required to be produced to Defendant in their electronic, pristine, native format. CASE NO: 50-2021-CA-004846