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Filing # 135243357 E-Filed 09/24/2021 10:31:30 AM
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 DEPOSITIONDUCES TECUM*
(Via Remote Video Conference/Zoom)
(Mutually Coordinatedwith Opposing Counsel)
(Please advise if an interpreter is 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 undersigned attorney will take the deposition of:
NAME: ANSELMO CARVALHO
DATE: JANUARY 4,2022
TIME: ll:OOAM and immediatelyfollowing:
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 deposition will
continue from day to day until completed. The deposition is being taken for the purposes as are
permitted under the applicable and governing rules, pursuant 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 09/24/2021 10:31:30 AM.****
CASE NO: CACE-21-003833 (02)
If you person with a disability who needs any accommodationin order
are a
to participate in 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 disability you can contact
the court through the Florida Relay Service by calling 711.
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 33020; on this 24th day of September
2021, pursuant to Rule 2.516.
COUNSEL FOR HERITAGE
PROPERTY & CASUALTY
INSURANCE COMPANY
1571 Sawgrass Corporate Parkway, 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
For service ofprocess, please also include:
CASE NO: CACE-21-003833 (02)
*SCIIEDULE "A"
1. Any and all documents showing the interest of the insured and 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 subject of this claim.
3. Any and all documents, including real estate disclosures, real estate contracts, closing
statements, appraisal reports and any other documents for the purchase of the property.
4. Copies of any and all documents evidencing damage to your property arising from 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 repair estimates, invoices, bills, statements or other documents for the damaged
property.
7. Any and alldocuments, including but not limited to bank statements, credit card statements,
invoices, receipts, bills, statements, proposals, estimates and/or canceled checks showing
repairs to the subject property at any time either before or after the loss alleged in this claim.
8. Original receipts of all items claimed.
9. Any and all documents, including but not limited to correspondence, estimates,
photographs, reports, letters of representation, contracts, invoices, bills, receipts, proposals
and/or statements exchanged between you and your public adjuster, 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
evaluating this claim, and/or which support or substantiate your claim.
Preview
Filing # 135243357 E-Filed 09/24/2021 10:31:30 AM 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 DEPOSITIONDUCES TECUM* (Via Remote Video Conference/Zoom) (Mutually Coordinatedwith Opposing Counsel) (Please advise if an interpreter is 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 undersigned attorney will take the deposition of: NAME: ANSELMO CARVALHO DATE: JANUARY 4,2022 TIME: ll:OOAM and immediatelyfollowing: 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 deposition will continue from day to day until completed. The deposition is being taken for the purposes as are permitted under the applicable and governing rules, pursuant 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 09/24/2021 10:31:30 AM.**** CASE NO: CACE-21-003833 (02) If you person with a disability who needs any accommodationin order are a to participate in 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 disability you can contact the court through the Florida Relay Service by calling 711. 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 33020; on this 24th day of September 2021, pursuant to Rule 2.516. COUNSEL FOR HERITAGE PROPERTY & CASUALTY INSURANCE COMPANY 1571 Sawgrass Corporate Parkway, 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 For service ofprocess, please also include: CASE NO: CACE-21-003833 (02) *SCIIEDULE "A" 1. Any and all documents showing the interest of the insured and 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 subject of this claim. 3. Any and all documents, including real estate disclosures, real estate contracts, closing statements, appraisal reports and any other documents for the purchase of the property. 4. Copies of any and all documents evidencing damage to your property arising from 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 repair estimates, invoices, bills, statements or other documents for the damaged property. 7. Any and alldocuments, including but not limited to bank statements, credit card statements, invoices, receipts, bills, statements, proposals, estimates and/or canceled checks showing repairs to the subject property at any time either before or after the loss alleged in this claim. 8. Original receipts of all items claimed. 9. Any and all documents, including but not limited to correspondence, estimates, photographs, reports, letters of representation, contracts, invoices, bills, receipts, proposals and/or statements exchanged between you and your public adjuster, 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 evaluating this claim, and/or which support or substantiate your claim.