Preview
Filing# 137718338 E-Filed 11/02/2021 11:41:23 AM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE-21-003847
SPENCER LIEBMANN
Plaintiff(s),
V
LIGHTHOUSE PROPERTY INSURANCE CORPORATION FKA PREPARED INSURANCE
COMPANY
Defendant.
i
NOTICE OF TAKING VIDEO-TAPED DEPOSITIONDUCES TECUM
PLEASE TAKE NOTICE that the SPENCER
plaintiff(s), LIEBMANN by and through
undersigned counsel and pursuant to Rule 1.310 Fla.R.Civ.P.,will take the depositionupon oral
examination of CHUCK WILLEN, at the followingtime, date,and location:
I)ate: January 20,2022
Time: 10:00am
Location: Zoom
httns://courtscribes.zoom.us/i/97001895961?nwd=VU#zdUFkTmO5V2NIUS80dEpJ
c3duZz09
Meeting ID: 970 0189 5961
Passcode: 005790
At the time ofthe deposition,the witness shall have in his or her possessionthe documents
in Exhibit "A" to this Notice. The deposition(s)
will continue from day to day until completed.
The deposition(s)
is/are being taken for the purpose of discovery,or for such other purposes as are
permittedunder the applicableand governing law and the Florida Rules of Civil Procedure.
Levin Litigation,PLLC
3475 Sheridan Street,Ste. 311 Hollywood, Florida 33021
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/02/2021 11:41:22 AM.****
If you are a person with a disabilitywho needs any accommodation in
order to participatein this proceeding, you are entitled,at no cost to you, to the
provision of certain assistance. Please contact the ADA Coordinator, Diana
Sobel, 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 are hearing or voice impaired, call 711.
Dated November 2,2021.
Respectfully,
/s/ Yitzhak S. Levin
Yitzhak S. Levin, Esq.
FBN: 116901
Levin Litigation,PLLC
Counsel for Plaintiff
3475 Sheridan Street,Suite 311
Hollywood, FL 330211
ylevin@levinlitigation.com
service@levinlitigation.com
Page 2 of 3
Levin Litigation,PLLC
3475 Sheridan Street, Ste. 311 Hollywood, Florida 33021
EXHIBIT"A"
ITEMS TO BE PRODUCED AT DEPOSITION
1. Your entire file relatingto your inspectionat the property located at 12632 Burning Tree lane
33071
Coral Springs,Fl.
2. Copies ofall correspondencefrom any source regardingthe damages arisingout of this cause
of action, directed to the Defendant insurance company, its employees and/or agents, and
any documentation attached to said correspondencepertainingto the Plaintiff's claims.
3. Copies of any and all documentation which you believe supports Defendant failure to pay
the benefits due and owing to the Plaintiff(s).
4. Any and all surveillance reports, claims history reports, or other investigation reports
prepared by you, or on your behalf,with regardsto the Plaintiff(s)
property located at 12632
Burning Tree Lane Coral Springs,Fl. 33071
5. Any and surveillance films, photographs, or audio tapes taken by you or any one on
all
your behalfregardingthe Plaintiffs and/or 12632 Burning Tree Lane Coral Springs,Fl. 33071
6. Any and all statements taken by the Defendant of any witnesses with regards to any
fact relevant to
any issue in this case, and/or 12632 Burning Tree
relatingto the Plaintiffs,
Lane Coral Springs,Fl. 33071
7. Any and all photographs in your possessionrelatingto this loss.
8. Any and all estimates of repairor statements concerning the nature and extent of damage
to the subjectproperty in this case preparedby you or on your behalf.
9. Any and all writings,memorandums, notes and/or other materials reflecting
your work on
the property located at 12632 Burning Tree Lane Coral Springs,Fl. 33071
Page 3 of 3
Levin Litigation,PLLC
3475 Sheridan Street, Ste. 311 Hollywood, Florida 33021
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE-21-003847
SPENCER LIEBMANN
Plaintiff(s),
V
LIGHTHOUSE PROPERTY INSURANCE CORPORATION FKA PREPARED INSURANCE
COMPANY
Defendant.
i
SUBPOENA DUCES TECUM FOR VIDEO-TAPED DEPOSITION
THE STATE OF FLORIDA:
TO: CHUCK WILLEN
5545 S. ORANGE AVE
ORLANDO, FLORIDA 32809
YOU ARE HEREBY COMMANDED to appear for the taking of your depositionin the above styled
cause at the following time, date and location before an officer authorized to take depositionsin
the State of Florida:
Date :
January 20,2022
Time : 10:OOam
Location: Zoorn
https://courtscribes.zoom.us/j/97001895961?pwd=VU4zdUFkTmQ5V2NIUS80dEpJc3d
UZZ09
1Meeting ID: 970 0189 5961
Passcode: 005790
You are directed tohave with you at that time and place the documents and items specifiedin
Exhibit "A" to this subpoena. These items will be inspectedand photocopied or reproduced at that
time. You will not be requiredto surrender the originalitems.
You may have the rightto objectto the production of the documents and items listed in Exhibit
"A" of this Subpoena, by giving written notice to the attorney whose name appears on this
Levin Litigation,PLLC
3475 Sheridan Street, Ste. 311 Hollywood, Florida 33021
Subpoena. A person responding to a subpoena to produce documents shall produce them as they
are kept in the ordinarycourse of business or shall organizeand label them to correspondwith the
categorieslisted in Exhibit "A" of this Subpoena. When information subjectto a subpoena is
withheld on a claim that it is privilegedor subjectto protectionas trial preparationmaterials,the
claim shall be made expressly and shall be supported by a descriptionof the nature of the
documents, communications or thingsnot produced that is sufficient to enable the demanding party
to contest the claim. This is a deposition;sworn testimony will be taken.
IF YOU FAIL to:
(a)appear as specific; (b)furnish the records instead of appearingas provided;or
(c)objectto thissubpoena, You MAY BE IN CONTEMPT OF COURT. You are subpoenaed to appear
by the following attorneys, and unless excused from this Subpoena by these attorneys or the Court,
you shall respond to this Subpoena as directed.
Dated November 2,2021.
Respectfully,
/s/ Yitzhak S. Levin
Yitzhak S. Levin, Esq.
FBN: 116901
Levin Litigation,PLLC
Counsel for Plaintiff
3475 Sheridan Street,Suite 311
Hollywood, FL 330211
ylevin@levinlitigation.com
service@levinlitigation.com
If you are aperson with a disabilitywho needs any accommodation in order to
participate in this proceeding, you are entitled,at no cost to you, to the
provision of certain assistance. Please contact the ADA Coordinator, Diana
Sobel, 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 are hearing or voice impaired, call 711.
Page 2 of 3
Levin Litigation,PLLC
3475 Sheridan Street, Ste. 311 Hollywood, Florida 33021
EXHIBIT"A"
ITEMS TO BE PRODUCED AT DEPOSITION
1. Your entire file relatingto your inspectionat the property located at 12632 Burning Tree Lane
Coral Springs,FL. 33071
2. Copies ofall correspondencefrom any source regardingthe damages arisingout of this cause
of action, directed to the Defendant insurance company, its employees and/or agents, and
any documentation attached to said correspondencepertainingto the Plaintiff's claims.
3. Copies of any and all documentation which you believe supports Defendant failure to pay
the benefits due and owing to the Plaintiff(s).
4. Any and all surveillance reports, claims history reports, or other investigation reports
prepared by you, or on your behalf,with regardsto the Plaintiff(s)
property located at 12632
Burning Tree Lane Coral Springs,Fl. 33071
5. Any and surveillance films, photographs, or audio tapes taken by you or any one on
all
your behalfregardingthe Plaintiffs and/or 12632 Burning Tree Lane Coral Springs,Fl. 33071
6. Any and all statements taken by the Defendant of any witnesses with regards to any
fact relevant to
any issue in this case, and/or 12632 Burning Tree
relatingto the Plaintiffs,
Lane Coral Springs,Fl. 33071
7. Any and all photographs in your possessionrelatingto this loss.
8. Any and all estimates of repairor statements concerning the nature and extent of damage
to the subjectproperty in this case preparedby you or on your behalf.
9. Any and all writings,memorandums, notes and/or other materials reflecting
your work on
the property located at 12632 Burning Tree Lane Coral Springs,Fl. 33071
Page 3 of 3
Levin Litigation,PLLC
3475 Sheridan Street, Ste. 311 Hollywood, Florida 33021
Preview
Filing# 137718338 E-Filed 11/02/2021 11:41:23 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-21-003847 SPENCER LIEBMANN Plaintiff(s), V LIGHTHOUSE PROPERTY INSURANCE CORPORATION FKA PREPARED INSURANCE COMPANY Defendant. i NOTICE OF TAKING VIDEO-TAPED DEPOSITIONDUCES TECUM PLEASE TAKE NOTICE that the SPENCER plaintiff(s), LIEBMANN by and through undersigned counsel and pursuant to Rule 1.310 Fla.R.Civ.P.,will take the depositionupon oral examination of CHUCK WILLEN, at the followingtime, date,and location: I)ate: January 20,2022 Time: 10:00am Location: Zoom httns://courtscribes.zoom.us/i/97001895961?nwd=VU#zdUFkTmO5V2NIUS80dEpJ c3duZz09 Meeting ID: 970 0189 5961 Passcode: 005790 At the time ofthe deposition,the witness shall have in his or her possessionthe documents in Exhibit "A" to this Notice. The deposition(s) will continue from day to day until completed. The deposition(s) is/are being taken for the purpose of discovery,or for such other purposes as are permittedunder the applicableand governing law and the Florida Rules of Civil Procedure. Levin Litigation,PLLC 3475 Sheridan Street,Ste. 311 Hollywood, Florida 33021 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/02/2021 11:41:22 AM.**** If you are a person with a disabilitywho needs any accommodation in order to participatein this proceeding, you are entitled,at no cost to you, to the provision of certain assistance. Please contact the ADA Coordinator, Diana Sobel, 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 are hearing or voice impaired, call 711. Dated November 2,2021. Respectfully, /s/ Yitzhak S. Levin Yitzhak S. Levin, Esq. FBN: 116901 Levin Litigation,PLLC Counsel for Plaintiff 3475 Sheridan Street,Suite 311 Hollywood, FL 330211 ylevin@levinlitigation.com service@levinlitigation.com Page 2 of 3 Levin Litigation,PLLC 3475 Sheridan Street, Ste. 311 Hollywood, Florida 33021 EXHIBIT"A" ITEMS TO BE PRODUCED AT DEPOSITION 1. Your entire file relatingto your inspectionat the property located at 12632 Burning Tree lane 33071 Coral Springs,Fl. 2. Copies ofall correspondencefrom any source regardingthe damages arisingout of this cause of action, directed to the Defendant insurance company, its employees and/or agents, and any documentation attached to said correspondencepertainingto the Plaintiff's claims. 3. Copies of any and all documentation which you believe supports Defendant failure to pay the benefits due and owing to the Plaintiff(s). 4. Any and all surveillance reports, claims history reports, or other investigation reports prepared by you, or on your behalf,with regardsto the Plaintiff(s) property located at 12632 Burning Tree Lane Coral Springs,Fl. 33071 5. Any and surveillance films, photographs, or audio tapes taken by you or any one on all your behalfregardingthe Plaintiffs and/or 12632 Burning Tree Lane Coral Springs,Fl. 33071 6. Any and all statements taken by the Defendant of any witnesses with regards to any fact relevant to any issue in this case, and/or 12632 Burning Tree relatingto the Plaintiffs, Lane Coral Springs,Fl. 33071 7. Any and all photographs in your possessionrelatingto this loss. 8. Any and all estimates of repairor statements concerning the nature and extent of damage to the subjectproperty in this case preparedby you or on your behalf. 9. Any and all writings,memorandums, notes and/or other materials reflecting your work on the property located at 12632 Burning Tree Lane Coral Springs,Fl. 33071 Page 3 of 3 Levin Litigation,PLLC 3475 Sheridan Street, Ste. 311 Hollywood, Florida 33021 IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-21-003847 SPENCER LIEBMANN Plaintiff(s), V LIGHTHOUSE PROPERTY INSURANCE CORPORATION FKA PREPARED INSURANCE COMPANY Defendant. i SUBPOENA DUCES TECUM FOR VIDEO-TAPED DEPOSITION THE STATE OF FLORIDA: TO: CHUCK WILLEN 5545 S. ORANGE AVE ORLANDO, FLORIDA 32809 YOU ARE HEREBY COMMANDED to appear for the taking of your depositionin the above styled cause at the following time, date and location before an officer authorized to take depositionsin the State of Florida: Date : January 20,2022 Time : 10:OOam Location: Zoorn https://courtscribes.zoom.us/j/97001895961?pwd=VU4zdUFkTmQ5V2NIUS80dEpJc3d UZZ09 1Meeting ID: 970 0189 5961 Passcode: 005790 You are directed tohave with you at that time and place the documents and items specifiedin Exhibit "A" to this subpoena. These items will be inspectedand photocopied or reproduced at that time. You will not be requiredto surrender the originalitems. You may have the rightto objectto the production of the documents and items listed in Exhibit "A" of this Subpoena, by giving written notice to the attorney whose name appears on this Levin Litigation,PLLC 3475 Sheridan Street, Ste. 311 Hollywood, Florida 33021 Subpoena. A person responding to a subpoena to produce documents shall produce them as they are kept in the ordinarycourse of business or shall organizeand label them to correspondwith the categorieslisted in Exhibit "A" of this Subpoena. When information subjectto a subpoena is withheld on a claim that it is privilegedor subjectto protectionas trial preparationmaterials,the claim shall be made expressly and shall be supported by a descriptionof the nature of the documents, communications or thingsnot produced that is sufficient to enable the demanding party to contest the claim. This is a deposition;sworn testimony will be taken. IF YOU FAIL to: (a)appear as specific; (b)furnish the records instead of appearingas provided;or (c)objectto thissubpoena, You MAY BE IN CONTEMPT OF COURT. You are subpoenaed to appear by the following attorneys, and unless excused from this Subpoena by these attorneys or the Court, you shall respond to this Subpoena as directed. Dated November 2,2021. Respectfully, /s/ Yitzhak S. Levin Yitzhak S. Levin, Esq. FBN: 116901 Levin Litigation,PLLC Counsel for Plaintiff 3475 Sheridan Street,Suite 311 Hollywood, FL 330211 ylevin@levinlitigation.com service@levinlitigation.com If you are aperson with a disabilitywho needs any accommodation in order to participate in this proceeding, you are entitled,at no cost to you, to the provision of certain assistance. Please contact the ADA Coordinator, Diana Sobel, 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 are hearing or voice impaired, call 711. Page 2 of 3 Levin Litigation,PLLC 3475 Sheridan Street, Ste. 311 Hollywood, Florida 33021 EXHIBIT"A" ITEMS TO BE PRODUCED AT DEPOSITION 1. Your entire file relatingto your inspectionat the property located at 12632 Burning Tree Lane Coral Springs,FL. 33071 2. Copies ofall correspondencefrom any source regardingthe damages arisingout of this cause of action, directed to the Defendant insurance company, its employees and/or agents, and any documentation attached to said correspondencepertainingto the Plaintiff's claims. 3. Copies of any and all documentation which you believe supports Defendant failure to pay the benefits due and owing to the Plaintiff(s). 4. Any and all surveillance reports, claims history reports, or other investigation reports prepared by you, or on your behalf,with regardsto the Plaintiff(s) property located at 12632 Burning Tree Lane Coral Springs,Fl. 33071 5. Any and surveillance films, photographs, or audio tapes taken by you or any one on all your behalfregardingthe Plaintiffs and/or 12632 Burning Tree Lane Coral Springs,Fl. 33071 6. Any and all statements taken by the Defendant of any witnesses with regards to any fact relevant to any issue in this case, and/or 12632 Burning Tree relatingto the Plaintiffs, Lane Coral Springs,Fl. 33071 7. Any and all photographs in your possessionrelatingto this loss. 8. Any and all estimates of repairor statements concerning the nature and extent of damage to the subjectproperty in this case preparedby you or on your behalf. 9. Any and all writings,memorandums, notes and/or other materials reflecting your work on the property located at 12632 Burning Tree Lane Coral Springs,Fl. 33071 Page 3 of 3 Levin Litigation,PLLC 3475 Sheridan Street, Ste. 311 Hollywood, Florida 33021