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Filing# 137456649 E-Filed 10/28/2021 12:20:42 PM
IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO: CACE-21-003833 (02)
ANSELMO CARVALHO and MARILENE
CARVALHO,
Petitioners,
VS.
HERITAGE PROPERTY AND
CASUALTY INSURANCE COMPANY,
Respondent.
i
AMENDED NOTICE OF TAKING DEPOSITION DUCES TECUM*
(Via Remote Video Conference/Zoom)
(Mutually Coordinated with Opposing Counsel)
(Please advise ifan interpreteris needed)
(Amended as to name of deponent)
TO: Scott Klotzman, Esquire
Law Offices of Scott Klotzman, P.A.
2719 Hollywood Boulevard
Hollywood, Florida 33020
PLEASE TAKE NOTICE that the undersignedattorney will take the depositionof:
NAME: ANSELMO CARVALHO
DATE: JANUARY 12, 2022
TIME: ll:OOAM and immediately following:
NAME: MARILENE CARVALHO
PLACE: Via Remote Video Conference/ Zoom
(We will forward the link once we receive same)
upon oral examination before a Court Reporter, Notary Public in and for the State of Florida at
Large, or some other officer duly authorized by law to take depositions. The depositionwill
continue from day to day until completed. The depositionis being taken for the purposes as are
and governingrules,pursuant
permittedunder the applicable to Florida Rules of Civil Procedure.
THE WITNESSES ARE REQUESTED TO BRING TO THE DEPOSITION ALL ITEMS
IN THE ATTACHED SCHEDULE "A".
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/28/2021 12:20:42 PM.****
CASE NO: CACE-21-003833 (02)
who needs any accommodation in order
If you are a person with a disability
to participatein this proceeding, you are entitled,at no cost to you, to the
provision of certain assistance. Please contact the ADA
Coordinator, Room
20140, 201 S.E. Sixth Street, Fort Lauderdale, Florida 33301, 954-831-7721
at least 7 days before your scheduled court appearance, or immediately
upon receiving this notification if the time before the scheduled
appearance
is less than 7 days. If you have a hearing or voice disabilityyou can contact
the court through the Florida Relay Service by calling711.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via
electronic mail to Luis M. Perez, Esq., Law Offices of Scott Klotzman, P.A., 2001 Tyler Street,
Suite 5, Hollywood, FL on this 28th day of October 2021,
33020; eservice@scottklotzman.com;
pursuant to Rule 2.516.
COUNSEL FOR HERITAGE
PROPERTY & CASUALTY
INSURANCE COMPANY
1571 Sawgrass CorporateParkway, Suite
400
Sunrise, Florida 33323
Office: (954) 315-1450
Facsimile: (954) 533-3202
By-. /s/ Eric N. Simon
Eric N. Simon, ESQUIRE
Florida Bar No.: 110435
esimon@heritagepci.com
For service ofprocess,pleasealso include:
stmolina@heritagepci.com:
ymarquez@heritagepci.com
CASE NO: CACE-21-003833 (02)
*SCIIEDULE "A"
1. Any and documents showing the interest of the insured and
all all others in the property
involved and all encumbrances or liens on the property.
2. Any and all documents showing any other insurance, which may cover this loss. This
includes a copy of any insurance policy other than the policy under which you have made
this claim which may cover all or part of the loss alleged in this claim and/or which may
cover the property which is the subjectof this claim.
3. Any and documents, includingreal estate disclosures,real estate contracts, closing
all
reports and any other documents for the purchase of the property.
statements, appraisal
4. Copies of any and all documents evidencing damage to your property arisingfrom the loss
at issue.
5. Copies of any and all photographs and video evidencing damage to your property arising
from the loss at issue.
6. Any and all repairestimates,invoices,bills,statements or other documents for the damaged
property.
7. Any and documents, includingbut not limited to bank statements, credit card statements,
all
invoices, receipts,bills,statements, proposals,estimates and/or canceled checks showing
repairsto the subjectproperty at any time either before or after the loss allegedin this claim.
8. of all items claimed.
Originalreceipts
9. Any and all including but not limited to correspondence, estimates,
documents,
of representation,
photographs, reports, letters contracts, invoices,bills,receipts,proposals
and/or statements exchanged between you and your publicadjuster, or any third party that is
relevant to the loss at issue.
10. Copies of any and all documents not already requested which may assist Heritage in
evaluatingthis claim, and/or which support or substantiate your claim.
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Filing# 137456649 E-Filed 10/28/2021 12:20:42 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO: CACE-21-003833 (02) ANSELMO CARVALHO and MARILENE CARVALHO, Petitioners, VS. HERITAGE PROPERTY AND CASUALTY INSURANCE COMPANY, Respondent. i AMENDED NOTICE OF TAKING DEPOSITION DUCES TECUM* (Via Remote Video Conference/Zoom) (Mutually Coordinated with Opposing Counsel) (Please advise ifan interpreteris needed) (Amended as to name of deponent) TO: Scott Klotzman, Esquire Law Offices of Scott Klotzman, P.A. 2719 Hollywood Boulevard Hollywood, Florida 33020 PLEASE TAKE NOTICE that the undersignedattorney will take the depositionof: NAME: ANSELMO CARVALHO DATE: JANUARY 12, 2022 TIME: ll:OOAM and immediately following: NAME: MARILENE CARVALHO PLACE: Via Remote Video Conference/ Zoom (We will forward the link once we receive same) upon oral examination before a Court Reporter, Notary Public in and for the State of Florida at Large, or some other officer duly authorized by law to take depositions. The depositionwill continue from day to day until completed. The depositionis being taken for the purposes as are and governingrules,pursuant permittedunder the applicable to Florida Rules of Civil Procedure. THE WITNESSES ARE REQUESTED TO BRING TO THE DEPOSITION ALL ITEMS IN THE ATTACHED SCHEDULE "A". *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/28/2021 12:20:42 PM.**** CASE NO: CACE-21-003833 (02) who needs any accommodation in order If you are a person with a disability to participatein this proceeding, you are entitled,at no cost to you, to the provision of certain assistance. Please contact the ADA Coordinator, Room 20140, 201 S.E. Sixth Street, Fort Lauderdale, Florida 33301, 954-831-7721 at least 7 days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days. If you have a hearing or voice disabilityyou can contact the court through the Florida Relay Service by calling711. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via electronic mail to Luis M. Perez, Esq., Law Offices of Scott Klotzman, P.A., 2001 Tyler Street, Suite 5, Hollywood, FL on this 28th day of October 2021, 33020; eservice@scottklotzman.com; pursuant to Rule 2.516. COUNSEL FOR HERITAGE PROPERTY & CASUALTY INSURANCE COMPANY 1571 Sawgrass CorporateParkway, Suite 400 Sunrise, Florida 33323 Office: (954) 315-1450 Facsimile: (954) 533-3202 By-. /s/ Eric N. Simon Eric N. Simon, ESQUIRE Florida Bar No.: 110435 esimon@heritagepci.com For service ofprocess,pleasealso include: stmolina@heritagepci.com: ymarquez@heritagepci.com CASE NO: CACE-21-003833 (02) *SCIIEDULE "A" 1. Any and documents showing the interest of the insured and all all others in the property involved and all encumbrances or liens on the property. 2. Any and all documents showing any other insurance, which may cover this loss. This includes a copy of any insurance policy other than the policy under which you have made this claim which may cover all or part of the loss alleged in this claim and/or which may cover the property which is the subjectof this claim. 3. Any and documents, includingreal estate disclosures,real estate contracts, closing all reports and any other documents for the purchase of the property. statements, appraisal 4. Copies of any and all documents evidencing damage to your property arisingfrom the loss at issue. 5. Copies of any and all photographs and video evidencing damage to your property arising from the loss at issue. 6. Any and all repairestimates,invoices,bills,statements or other documents for the damaged property. 7. Any and documents, includingbut not limited to bank statements, credit card statements, all invoices, receipts,bills,statements, proposals,estimates and/or canceled checks showing repairsto the subjectproperty at any time either before or after the loss allegedin this claim. 8. of all items claimed. Originalreceipts 9. Any and all including but not limited to correspondence, estimates, documents, of representation, photographs, reports, letters contracts, invoices,bills,receipts,proposals and/or statements exchanged between you and your publicadjuster, or any third party that is relevant to the loss at issue. 10. Copies of any and all documents not already requested which may assist Heritage in evaluatingthis claim, and/or which support or substantiate your claim.