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Filing# 137050800 E-Filed 10/21/2021 05:14:44 PM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY,
FLORIDA
IRMA HIDALGO AND
JUAN HIDALGO,
CIRCUIT CIVIL DIVISION
Plaintiffs,
V
CACE-21-010671
CITIZENS PROPERTY
INSURANCE CORPORATION,
Defendant.
i
NOTICE OF TAKING VIDEO DEPOSITION DUCES TECUM
(datecleared with Ashley from Attorney Aguila's office by email on 10/21/21)
(Pleaseadvise if an interpreter
will be required)
PLEASE TAKE NOTICE that the undersigned will take the deposition,by oral
examination, of the person(s)named below, at the time, date and placeindicated:
NAME
DATE AND TIME
PLACE
Juan Hidalgo
January 28, 2021
Universal
Court
at 11:00 a.m.
Reporting via Zoom*
Irma Hidalgo
Immediately following
Same
* Join Zoom Meeting
https://ucrinc.zoom.us/i/84981659372?pwd=d H BLekc2YVZKRDdh N i9BRVR4M 1d RZz09
Meeting ID: 849 8165 9372
Passcode: 838262
Before an associate or deputy court reporter of the office of Universal Court Reporting or before
their duly designatedrepresentative,
who is not ofcounsel to the partiesor interested in the events
of the cause. You are to bringwith you to this depositionany and all items listed on the attached
EXHIBIT "A" This depositionis being taken for the purpose of discoveryfor use at trial,or for
such other purposes as are permittedunder the Florida Rules of Civil Procedure.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/21/2021 05:14:43 PM.****
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy ofthe foregoingwas furnished by
eservice to Carlos C. Aguila,Esq.,Aguila Law, to carlos@aguilapa.com and mail@aguilapa.com on
October 21,2021.
DUTTON LAW GROUP, P.A.
800 West Cypress Creek Road, Suite 400
Fort Lauderedale, Florida 33309
(954) 773-8312
By: /s/ JeffreyW. Golovin
JEFFREY W. GOLOVIN, ESQ.
Florida Bar No: 724351
SCOTT W. DUTTON, ESQ.
Florida Bar No: 486019
EXHIBIT "A"
1.
Government issued identification.
2.
Any and all photographs taken by anyone, including but not limited to you, on or
subsequent to the allegeddate of loss,showing or depictingany of the areas allegedto be
damaged as a result of this loss.
3.
Any and all photographs taken by anyone, includingbut not limited to you, on or priorto
the allegeddate of loss,showing or depictingany of the areas allegedto be damaged as a
result of this loss.
4.
Any and all video recordingstaken by anyone, includingbut not limited to you, on or
subsequent to the allegeddate of loss,showing or depictingany of the areas allegedto be
damaged as a result of this loss.
5.
Any and all video recordingstaken by anyone, includingbut not limited to you, on or
priorto the allegeddate of loss,showing or depictingany of the areas allegedto be
damaged as a result of this loss.
6.
True copiesof any and all statements taken from the Defendant, CITIZENS PROPERTY
INSURANCE CORPORATION and/or from any agent, servant, or employee of said
Defendant as a result of the allegedincident.
7.
True copiesof any correspondence,letters,or other writingssent by you or any of your
agents/attorneys
to CITIZENS PROPERTY INSURANCE CORPORATION or any of its
agents.
8.
True copies of any correspondence, letters,or other writings sent by CITIZENS
PROPERTY INSURANCE CORPORATION or any of its agents to you or any of your
agents/attorneys.
9.
True copiesof any correspondence,letters,
or other writingssent by you or your agents to
any insurance company regardingthe damages that are the subjectmatter of this lawsuit.
10. True copiesof any and all itemized lists of damage, bills,
receipts,
invoices,etc. supporting
the claim for real and personalproperty, which is the subjectof this lawsuit
11. Any and all photographs of the structure claimed to be damaged, both before and after the
occurrence of the claimed damage.
12. Any and all photographsof items ofpersonalproperty claimed to be damaged, both before
and after the occurrence of the claimed damage.
13. Any and all rece*ts,invoices,cancelled checks, credit card receiptsand statements or other
documentation for the originalpurchase of the items of personalproperty claimed to have
been damaged.
14. Any and all receipts,
invoices,cancelled checks, credit card receiptsand statements or other
documentation reflectingreplacement purchase of the items of personalproperty claimed
to have been damaged.
15. Any and all receipts,
invoices,cancelled checks, credit card receipts
and statements or other
documentation reflectingrepairof or to the structure claimed to have been damaged.
16. Any and all receipts,
invoices,cancelled checks, credit card receiptsand statements or other
documentation reflecting
payment for additional livingexpenses.
17. Any and all originalnotes, deeds, title certificates,
mortgages, or securityinstruments of
any kind showing or tendingto show the existence ofdebts owed to you on property owned
by you or property in which you have a securityinterest.
18. Any and all insurance policiesinsuringloss to any property real or personalwhich you own
alone or jointlywith any other person, includingbut not limited to any other policyof
insurance that would providecoverage for the loss claimed.
19. Any and all bills of sale,deeds, contracts or other documents showing transfer of any and
all real property which you own alone or jointlywith any other person, executed by you
personallyor jointlywith any other person duringthe years of 2004 through 2021.
20. Any and all applications,
bills of sale,deeds, contracts or other documents showing the
terms and conditions of the refinancingof any mortgage had on any and all real property
which you own alone orjointlywith any otherperson,executed by you personallyorjointly
with any other person duringthe years 2004 through 2021.
21. Any and all bills of sale,contracts, receipts,
invoices or other documents for reconstruction,
repair,or redecoratingof your home during the years 2004 through 2021.
22. Any and all invoices,cancelled checks, rece*ts,or any other documentation in any form
whatsoever, created by, on behalf of, or to any individuals who affected any repairsin
response to the subjectloss.
23. Any and all documents relatingto any water damage to the home priorto the date of loss
allegedin the Complaint.
24. Any and all documents relating
to any damage to the home priorto the date of loss alleged
in the Complaint.
25. Rece*ts, invoices, and/or payments for any repairsto the home's plumbing systems or
sanitarysystem or domestic water system priorto the date of loss allegedin the Complaint.
26. Copies of all electric utilitybills for the home for the month in which the allegedloss
occurred.
27. Copies of all electric utilitybills for the home for the six (6)month period subsequent to
the allegeddate of loss.
28. Copies of all water and sewer utility
bills for the home for the six (6)month periodprior
to the allegeddate of loss.
29. Copies of all water and sewer utility
bills for the home for the month in which the alleged
loss occurred.
30. Copies of all water and sewer utilitybills for the home for the six (6) month period
subsequentto the allegeddate of loss.
31. All documents pertainingto the purchase of the insured home in 2004 includingbut not
limited to contracts, HUD statements, inspectionreports, photographs,disclaimers,real
estate listing
agreements.
32. Any and all documents regardingchanges in ownership,includingQuit Claim Deeds from
2004 to present.
Preview
Filing# 137050800 E-Filed 10/21/2021 05:14:44 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA IRMA HIDALGO AND JUAN HIDALGO, CIRCUIT CIVIL DIVISION Plaintiffs, V CACE-21-010671 CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. i NOTICE OF TAKING VIDEO DEPOSITION DUCES TECUM (datecleared with Ashley from Attorney Aguila's office by email on 10/21/21) (Pleaseadvise if an interpreter will be required) PLEASE TAKE NOTICE that the undersigned will take the deposition,by oral examination, of the person(s)named below, at the time, date and placeindicated: NAME DATE AND TIME PLACE Juan Hidalgo January 28, 2021 Universal Court at 11:00 a.m. Reporting via Zoom* Irma Hidalgo Immediately following Same * Join Zoom Meeting https://ucrinc.zoom.us/i/84981659372?pwd=d H BLekc2YVZKRDdh N i9BRVR4M 1d RZz09 Meeting ID: 849 8165 9372 Passcode: 838262 Before an associate or deputy court reporter of the office of Universal Court Reporting or before their duly designatedrepresentative, who is not ofcounsel to the partiesor interested in the events of the cause. You are to bringwith you to this depositionany and all items listed on the attached EXHIBIT "A" This depositionis being taken for the purpose of discoveryfor use at trial,or for such other purposes as are permittedunder the Florida Rules of Civil Procedure. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/21/2021 05:14:43 PM.**** CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy ofthe foregoingwas furnished by eservice to Carlos C. Aguila,Esq.,Aguila Law, to carlos@aguilapa.com and mail@aguilapa.com on October 21,2021. DUTTON LAW GROUP, P.A. 800 West Cypress Creek Road, Suite 400 Fort Lauderedale, Florida 33309 (954) 773-8312 By: /s/ JeffreyW. Golovin JEFFREY W. GOLOVIN, ESQ. Florida Bar No: 724351 SCOTT W. DUTTON, ESQ. Florida Bar No: 486019 EXHIBIT "A" 1. Government issued identification. 2. Any and all photographs taken by anyone, including but not limited to you, on or subsequent to the allegeddate of loss,showing or depictingany of the areas allegedto be damaged as a result of this loss. 3. Any and all photographs taken by anyone, includingbut not limited to you, on or priorto the allegeddate of loss,showing or depictingany of the areas allegedto be damaged as a result of this loss. 4. Any and all video recordingstaken by anyone, includingbut not limited to you, on or subsequent to the allegeddate of loss,showing or depictingany of the areas allegedto be damaged as a result of this loss. 5. Any and all video recordingstaken by anyone, includingbut not limited to you, on or priorto the allegeddate of loss,showing or depictingany of the areas allegedto be damaged as a result of this loss. 6. True copiesof any and all statements taken from the Defendant, CITIZENS PROPERTY INSURANCE CORPORATION and/or from any agent, servant, or employee of said Defendant as a result of the allegedincident. 7. True copiesof any correspondence,letters,or other writingssent by you or any of your agents/attorneys to CITIZENS PROPERTY INSURANCE CORPORATION or any of its agents. 8. True copies of any correspondence, letters,or other writings sent by CITIZENS PROPERTY INSURANCE CORPORATION or any of its agents to you or any of your agents/attorneys. 9. True copiesof any correspondence,letters, or other writingssent by you or your agents to any insurance company regardingthe damages that are the subjectmatter of this lawsuit. 10. True copiesof any and all itemized lists of damage, bills, receipts, invoices,etc. supporting the claim for real and personalproperty, which is the subjectof this lawsuit 11. Any and all photographs of the structure claimed to be damaged, both before and after the occurrence of the claimed damage. 12. Any and all photographsof items ofpersonalproperty claimed to be damaged, both before and after the occurrence of the claimed damage. 13. Any and all rece*ts,invoices,cancelled checks, credit card receiptsand statements or other documentation for the originalpurchase of the items of personalproperty claimed to have been damaged. 14. Any and all receipts, invoices,cancelled checks, credit card receiptsand statements or other documentation reflectingreplacement purchase of the items of personalproperty claimed to have been damaged. 15. Any and all receipts, invoices,cancelled checks, credit card receipts and statements or other documentation reflectingrepairof or to the structure claimed to have been damaged. 16. Any and all receipts, invoices,cancelled checks, credit card receiptsand statements or other documentation reflecting payment for additional livingexpenses. 17. Any and all originalnotes, deeds, title certificates, mortgages, or securityinstruments of any kind showing or tendingto show the existence ofdebts owed to you on property owned by you or property in which you have a securityinterest. 18. Any and all insurance policiesinsuringloss to any property real or personalwhich you own alone or jointlywith any other person, includingbut not limited to any other policyof insurance that would providecoverage for the loss claimed. 19. Any and all bills of sale,deeds, contracts or other documents showing transfer of any and all real property which you own alone or jointlywith any other person, executed by you personallyor jointlywith any other person duringthe years of 2004 through 2021. 20. Any and all applications, bills of sale,deeds, contracts or other documents showing the terms and conditions of the refinancingof any mortgage had on any and all real property which you own alone orjointlywith any otherperson,executed by you personallyorjointly with any other person duringthe years 2004 through 2021. 21. Any and all bills of sale,contracts, receipts, invoices or other documents for reconstruction, repair,or redecoratingof your home during the years 2004 through 2021. 22. Any and all invoices,cancelled checks, rece*ts,or any other documentation in any form whatsoever, created by, on behalf of, or to any individuals who affected any repairsin response to the subjectloss. 23. Any and all documents relatingto any water damage to the home priorto the date of loss allegedin the Complaint. 24. Any and all documents relating to any damage to the home priorto the date of loss alleged in the Complaint. 25. Rece*ts, invoices, and/or payments for any repairsto the home's plumbing systems or sanitarysystem or domestic water system priorto the date of loss allegedin the Complaint. 26. Copies of all electric utilitybills for the home for the month in which the allegedloss occurred. 27. Copies of all electric utilitybills for the home for the six (6)month period subsequent to the allegeddate of loss. 28. Copies of all water and sewer utility bills for the home for the six (6)month periodprior to the allegeddate of loss. 29. Copies of all water and sewer utility bills for the home for the month in which the alleged loss occurred. 30. Copies of all water and sewer utilitybills for the home for the six (6) month period subsequentto the allegeddate of loss. 31. All documents pertainingto the purchase of the insured home in 2004 includingbut not limited to contracts, HUD statements, inspectionreports, photographs,disclaimers,real estate listing agreements. 32. Any and all documents regardingchanges in ownership,includingQuit Claim Deeds from 2004 to present.