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Filing # 132474498 E-Filed 08/11/2021 02:16:51 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
RICARDO ALVAREZ and
ERIDANIANUNEZ DE ALVAREZ,
CASE NO.: CACE-21-009649
Plaintiff,
VS.
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant,
CROSS-NOTICEOF TAKING VIDEO-TAPED DEPOSITIONDUCES TECUM
PLEASE TAKE NOTICE that the undersignedattorney will take the videotaped deposition duces
tecum of:
NAME:
Plaintiff,Ricardo Alvarez
DATE:
September 15, 2021
TIME:
11:00 AM
PLACE:
Via Zoom
Upon oral examinationbefore
Veritext Court Reporting ("Veritext
Legal Solutions"). Which will be conductedvirtually, Notary Public, or any other Notary Public or
officer authorizedby law to take depositions in the State of Florida and to have with you at the
aforementionedtime and place or provide via mail to arrive on the said date, the following items
listed in the attached SCHEDULE "A".
The oral examinationwill continue from day to day until completed. The deposition is being
taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/11/2021 02:16:51 PM.****
under the Rules of Court. In accordancewith the American with DisabilitiesAct of 1990, persons
needing special accommodationsto participate in this proceedingshould contact the Court ADA
Coordinator at (305) 375-2006,no later than seven (7) days priorto the proceeding to arrange for
such accommodations. Ifhearing impaired,telephone the Court TDD Coordinator at (305) 375-2007.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true copy of the foregoingwas provided,via Electronic Mail to:
Mr. ChristopherA. Narchet, Esq., The Property Advocates, P.A., 2525 Ponce de Leon Boulevard,
Suite 600, Coral Gables, Florida 33134
on this 11th day of
August 2021.
LYDECKER I DIAZ
Attorneys for Defendant
1221 Brickell Avenue, 19th Floor
Miami, Florida 33131
(305) 416-3180 Telephone
(305) 416-3190 Facsimile
For service of Documents only:
By-. /s/ Jason T. Gutknecht
Jason T. Gutknecht
Florida Bar Number:1015862
Michelle Diverio, Esq.
Florida Bar Number: 60392 Page 3 of
3
Schedule "A"
1) All correspondencebetweenyou and the insurancecompanyand/or its representatives.
2) All contracts, letters of representation, between you and any of your agents, assignees or
representatives.
3) All photographsof the property in your possession, custody or control. If possible, please provide
color photographs.
4) All invoices, receipts, or any proofofpaymentmade to contractors, any representative, experts,
loss consultants, water mitigation companiesand/or public adjusters.
5) All documents in any format regardingany aspect of your claim.
6) All documents showing any repairs made to the property after the date of loss.
7) Any documents showing any repairs made to the property five years prior the date ofloss.
8) All contact information.
9) All inspection reports, opinions, expert reports in connection with your claim.
10) All estimates of damages from contractor, handyman, plumber, loss consultant,public adjuster,
estimator, water Mitigation Companyand/or any other qualifiedindividual or corporation.
11) All contracts for sale of the property and corresponding inspection reports made on the
property.
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Filing # 132474498 E-Filed 08/11/2021 02:16:51 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA RICARDO ALVAREZ and ERIDANIANUNEZ DE ALVAREZ, CASE NO.: CACE-21-009649 Plaintiff, VS. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant, CROSS-NOTICEOF TAKING VIDEO-TAPED DEPOSITIONDUCES TECUM PLEASE TAKE NOTICE that the undersignedattorney will take the videotaped deposition duces tecum of: NAME: Plaintiff,Ricardo Alvarez DATE: September 15, 2021 TIME: 11:00 AM PLACE: Via Zoom Upon oral examinationbefore Veritext Court Reporting ("Veritext Legal Solutions"). Which will be conductedvirtually, Notary Public, or any other Notary Public or officer authorizedby law to take depositions in the State of Florida and to have with you at the aforementionedtime and place or provide via mail to arrive on the said date, the following items listed in the attached SCHEDULE "A". The oral examinationwill continue from day to day until completed. The deposition is being taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/11/2021 02:16:51 PM.**** under the Rules of Court. In accordancewith the American with DisabilitiesAct of 1990, persons needing special accommodationsto participate in this proceedingshould contact the Court ADA Coordinator at (305) 375-2006,no later than seven (7) days priorto the proceeding to arrange for such accommodations. Ifhearing impaired,telephone the Court TDD Coordinator at (305) 375-2007. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoingwas provided,via Electronic Mail to: Mr. ChristopherA. Narchet, Esq., The Property Advocates, P.A., 2525 Ponce de Leon Boulevard, Suite 600, Coral Gables, Florida 33134 on this 11th day of August 2021. LYDECKER I DIAZ Attorneys for Defendant 1221 Brickell Avenue, 19th Floor Miami, Florida 33131 (305) 416-3180 Telephone (305) 416-3190 Facsimile For service of Documents only: By-. /s/ Jason T. Gutknecht Jason T. Gutknecht Florida Bar Number:1015862 Michelle Diverio, Esq. Florida Bar Number: 60392 Page 3 of 3 Schedule "A" 1) All correspondencebetweenyou and the insurancecompanyand/or its representatives. 2) All contracts, letters of representation, between you and any of your agents, assignees or representatives. 3) All photographsof the property in your possession, custody or control. If possible, please provide color photographs. 4) All invoices, receipts, or any proofofpaymentmade to contractors, any representative, experts, loss consultants, water mitigation companiesand/or public adjusters. 5) All documents in any format regardingany aspect of your claim. 6) All documents showing any repairs made to the property after the date of loss. 7) Any documents showing any repairs made to the property five years prior the date ofloss. 8) All contact information. 9) All inspection reports, opinions, expert reports in connection with your claim. 10) All estimates of damages from contractor, handyman, plumber, loss consultant,public adjuster, estimator, water Mitigation Companyand/or any other qualifiedindividual or corporation. 11) All contracts for sale of the property and corresponding inspection reports made on the property.