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Filing# 141619766 E-Filed 01/08/2022 10:12:55 PM
IN THE CIRCUIT COURT OF THE 17,TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
IRMA QURESHI AND GEORGE GUERRERO, CASENO.: CACE21-007238
Plaintiff
VS.
PLEASE ADVISE OUR OFFICE
IF A TRANSLATOR IS NEEDED
UNIVERSAL PROPERTY & CASUALTY
FOR PLAINTIFF
INSURANCE COMPANY,
Defendant.
i
DEFENDANT'S AMENDED NOTICE OF TAKING DEPOSITION DUCES TECUM
(Coordinated with Plaintiff's
Counsel)
(Amended to Correct the date)
PLEASE TAKE NOTICE that,pursuant to the Florida Rules of Civil Procedure
1.310(b)(6), Defendant,
UNIVERSAL PROPERTY AND CASUALTY INSURANCE
COMPANY, will take the depositionset forth below:
NAME:
DATE/ TIME:
LOCATION:
Tuesday,
EsquireDepositionSolutions
Plaintiff.
May 3,2022
VIA ZOOM
IRMA QURESHI
at 10-OOAM
515 E. Las Olas Blvd, Ste 1300
Fort Lauderdale, FL. 33301
Tuesday,
Esquire Deposition Solutions
Plaintiff.
May 3,2022
VIA ZOOM
GEORGE GUERRERO
at
12:00PM
or
to
commence
upon
the
515 E. Las Olas Blvd, Ste 1300
completion
of
Irma
Fort Lauderdale, FL. 33301
Qureshi
Upon oral examination before a representativeof Esquire Deposition Solutions,or any
other officer authorized by law to take depositionin the State of Florida. The oral examination
will continue from day to day until completed. This depositionis being taken for the purpose of
discovery,for use at trial,
or both of the foregoing,or for such other purposes as are permitted
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/08/2022 10:12:55 PM.****
CASE NO.: CACE21-007238
Page 2 of 4
under the Florida Rules of Civil Procedure and other applicablelaw. And, pursuant to Fla. R.
Civ. P. 1.350, said Defendant requests the deponent have the followingitems listed in Schedule
"A" at the time and placeofthe foregoingdeposition,for purposes ofinspectionand/or copying
by this Defendant.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoingwas furnished via E-
Service to: Amy E. Ruiz, Esq., 1Taylor Espino Vega & Touron, PLLC., (ftouron@tevtlaw.com;
>th
aruiz@tevtlaw.com;avrey@tevtlaw.com)on this 81 day of January, 2022.
AttorneysMDefendant
Universal Property & Casualty Ins. Co.
P.O. Box 9388
Fort Lauderdale FL 33310
Telephone:1-833-658-8594
Facsimile: 954-958-1262
By-- /s/ Joshua D. Strudwick. Esq.
Joshua D. Strudwick, Esq.
Florida Bar No. 95761
For Service of Court Documents onlv:
Primary: upciceservice03@universalproperty.com
Secondary: sb0128@universalproperty.com
Tertiary:
js0730@universalproperty.com
For Scheduling Matters:
sb0128@universalproperty.com
Please do not send any inquiriesor scheduling matters to upciceservice@universalpropertv.com
or upciceservice03@universalproperty.com.
CASE NO.: CACE21-007238
Page 3 of 4
ATTACHMENT"A"
1.
Copies of any and all correspondence between Plaintiff(s)
and Defendant with
regardto this claim or the allegations
contained within Plaintiff(s)s'
Complaint.
2.
Copies of any and all correspondence between Plaintiff(s)
and any publicadjuster
assisting
with the claim with respect to the property located at 661 Alabama Ave, Fort Lauderdale,
FL. 33312.
3
Copies of any and all correspondence between Plaintiff(s)
and any contractor,
repair/service
company providing any services or preparingany estimate for repairswith respect
to any claimed damages in the Complaint.
4.
Copies of any and all reports, drafts,charts,drawings,diagrams,and memoranda
and/or results of any testingshowing or intendingto show the cause of damage to Plaintiff(s)'s
property located at 661 Alabama Ave, Fort Lauderdale, FL. 33312, as asserted in the Complaint.
5.
Copies of any documents which support any claim for damages set forth in the
Complaint
6.
Copies of any and all repairestimates for allegeddamages to Plaintiff(s)'s
property
located at 661 Alabama Ave, Fort Lauderdale, FL. 33312 that are claimed in the Complaint.
7.
Copies of any and all photographs or videotapetaken ofthe property located at 661
Alabama Ave, Fort Lauderdale,FL. 33312 priorto the allegeddate ofloss in the Complaint. Please
provideall photosor videos in electronic/digital
format.
8
Copies of any and all photographs or videotapetaken ofthe property located at 661
Alabama Ave, Fort Lauderdale, FL. 33312 on or subsequent to the allegeddate of loss in the
Complaint. Please provide all photos or videos in electronic/digital
format.
9-
Copies of any and all photographs or videotape taken of the area(s)of the interior
of the home located at 661 Alabama Ave, Fort Lauderdale, FL. 33312 to which you are claiming
damages in this Complaint. Please provide all photos or videos in electronic/digital
format.
10.
Copies of any and all invoices,cancelled checks or other evidence of payment for
repairs,remodels or renovations made to 661 Alabama Ave, Fort Lauderdale, FL. 33312 relative
to the Loss allegedin the Complaint.
11.
Copies of any and all invoices,cancelled checks or other evidence ofpayment for
repairs,
remodels or renovations made to 661 Alabama Ave, Fort Lauderdale, FL. 33312 after the
date of loss.
12.
Copies of any and all invoices,cancelled checks or other evidence of payment for
repairs,
remodels or renovations made to 661 Alabama Ave, Fort Lauderdale, FL. 33312 for the
five (5)years priorto the date of loss.
CASE NO.: CACE21-007238
Page 4 of 4
13.
Copies of any and all inspections,
appraisalsor other investigations
for the property
located at 661 Alabama Ave, Fort Lauderdale, FL. 33312 priorto the date of purchase.
14.
Copies of any and all rules or regulationviolations notices, or correspondence
issued by any homeowners or condominium association regardingthe property located at 661
Alabama Ave, Fort Lauderdale, FL. 33312 for the three (3)year periodpriorto the date of loss.
15.
Copies of any and all rules or regulationviolations notices, or correspondence
issued by any homeowners or condominium association regarding the property located at 661
Alabama Ave, Fort Lauderdale, FL. 33312 subsequentto the date of loss.
16.
Copies of any and all ordinance or code violations notices, or correspondence
issued by any city/countymunicipalityregardingthe property located at 661 Alabama Ave, Fort
Lauderdale, FL. 33312 for the three (3)year period priorto the date of loss.
17.
Copies of any and all ordinance or code violations notices, or correspondence
issued by any city/countymunicipalityregardingthe property located at 661 Alabama Ave, Fort
Lauderdale, FL. 33312 subsequent to the date of loss.
Preview
Filing# 141619766 E-Filed 01/08/2022 10:12:55 PM IN THE CIRCUIT COURT OF THE 17,TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA IRMA QURESHI AND GEORGE GUERRERO, CASENO.: CACE21-007238 Plaintiff VS. PLEASE ADVISE OUR OFFICE IF A TRANSLATOR IS NEEDED UNIVERSAL PROPERTY & CASUALTY FOR PLAINTIFF INSURANCE COMPANY, Defendant. i DEFENDANT'S AMENDED NOTICE OF TAKING DEPOSITION DUCES TECUM (Coordinated with Plaintiff's Counsel) (Amended to Correct the date) PLEASE TAKE NOTICE that,pursuant to the Florida Rules of Civil Procedure 1.310(b)(6), Defendant, UNIVERSAL PROPERTY AND CASUALTY INSURANCE COMPANY, will take the depositionset forth below: NAME: DATE/ TIME: LOCATION: Tuesday, EsquireDepositionSolutions Plaintiff. May 3,2022 VIA ZOOM IRMA QURESHI at 10-OOAM 515 E. Las Olas Blvd, Ste 1300 Fort Lauderdale, FL. 33301 Tuesday, Esquire Deposition Solutions Plaintiff. May 3,2022 VIA ZOOM GEORGE GUERRERO at 12:00PM or to commence upon the 515 E. Las Olas Blvd, Ste 1300 completion of Irma Fort Lauderdale, FL. 33301 Qureshi Upon oral examination before a representativeof Esquire Deposition Solutions,or any other officer authorized by law to take depositionin the State of Florida. The oral examination will continue from day to day until completed. This depositionis being taken for the purpose of discovery,for use at trial, or both of the foregoing,or for such other purposes as are permitted *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/08/2022 10:12:55 PM.**** CASE NO.: CACE21-007238 Page 2 of 4 under the Florida Rules of Civil Procedure and other applicablelaw. And, pursuant to Fla. R. Civ. P. 1.350, said Defendant requests the deponent have the followingitems listed in Schedule "A" at the time and placeofthe foregoingdeposition,for purposes ofinspectionand/or copying by this Defendant. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoingwas furnished via E- Service to: Amy E. Ruiz, Esq., 1Taylor Espino Vega & Touron, PLLC., (ftouron@tevtlaw.com; >th aruiz@tevtlaw.com;avrey@tevtlaw.com)on this 81 day of January, 2022. AttorneysMDefendant Universal Property & Casualty Ins. Co. P.O. Box 9388 Fort Lauderdale FL 33310 Telephone:1-833-658-8594 Facsimile: 954-958-1262 By-- /s/ Joshua D. Strudwick. Esq. Joshua D. Strudwick, Esq. Florida Bar No. 95761 For Service of Court Documents onlv: Primary: upciceservice03@universalproperty.com Secondary: sb0128@universalproperty.com Tertiary: js0730@universalproperty.com For Scheduling Matters: sb0128@universalproperty.com Please do not send any inquiriesor scheduling matters to upciceservice@universalpropertv.com or upciceservice03@universalproperty.com. CASE NO.: CACE21-007238 Page 3 of 4 ATTACHMENT"A" 1. Copies of any and all correspondence between Plaintiff(s) and Defendant with regardto this claim or the allegations contained within Plaintiff(s)s' Complaint. 2. Copies of any and all correspondence between Plaintiff(s) and any publicadjuster assisting with the claim with respect to the property located at 661 Alabama Ave, Fort Lauderdale, FL. 33312. 3 Copies of any and all correspondence between Plaintiff(s) and any contractor, repair/service company providing any services or preparingany estimate for repairswith respect to any claimed damages in the Complaint. 4. Copies of any and all reports, drafts,charts,drawings,diagrams,and memoranda and/or results of any testingshowing or intendingto show the cause of damage to Plaintiff(s)'s property located at 661 Alabama Ave, Fort Lauderdale, FL. 33312, as asserted in the Complaint. 5. Copies of any documents which support any claim for damages set forth in the Complaint 6. Copies of any and all repairestimates for allegeddamages to Plaintiff(s)'s property located at 661 Alabama Ave, Fort Lauderdale, FL. 33312 that are claimed in the Complaint. 7. Copies of any and all photographs or videotapetaken ofthe property located at 661 Alabama Ave, Fort Lauderdale,FL. 33312 priorto the allegeddate ofloss in the Complaint. Please provideall photosor videos in electronic/digital format. 8 Copies of any and all photographs or videotapetaken ofthe property located at 661 Alabama Ave, Fort Lauderdale, FL. 33312 on or subsequent to the allegeddate of loss in the Complaint. Please provide all photos or videos in electronic/digital format. 9- Copies of any and all photographs or videotape taken of the area(s)of the interior of the home located at 661 Alabama Ave, Fort Lauderdale, FL. 33312 to which you are claiming damages in this Complaint. Please provide all photos or videos in electronic/digital format. 10. Copies of any and all invoices,cancelled checks or other evidence of payment for repairs,remodels or renovations made to 661 Alabama Ave, Fort Lauderdale, FL. 33312 relative to the Loss allegedin the Complaint. 11. Copies of any and all invoices,cancelled checks or other evidence ofpayment for repairs, remodels or renovations made to 661 Alabama Ave, Fort Lauderdale, FL. 33312 after the date of loss. 12. Copies of any and all invoices,cancelled checks or other evidence of payment for repairs, remodels or renovations made to 661 Alabama Ave, Fort Lauderdale, FL. 33312 for the five (5)years priorto the date of loss. CASE NO.: CACE21-007238 Page 4 of 4 13. Copies of any and all inspections, appraisalsor other investigations for the property located at 661 Alabama Ave, Fort Lauderdale, FL. 33312 priorto the date of purchase. 14. Copies of any and all rules or regulationviolations notices, or correspondence issued by any homeowners or condominium association regardingthe property located at 661 Alabama Ave, Fort Lauderdale, FL. 33312 for the three (3)year periodpriorto the date of loss. 15. Copies of any and all rules or regulationviolations notices, or correspondence issued by any homeowners or condominium association regarding the property located at 661 Alabama Ave, Fort Lauderdale, FL. 33312 subsequentto the date of loss. 16. Copies of any and all ordinance or code violations notices, or correspondence issued by any city/countymunicipalityregardingthe property located at 661 Alabama Ave, Fort Lauderdale, FL. 33312 for the three (3)year period priorto the date of loss. 17. Copies of any and all ordinance or code violations notices, or correspondence issued by any city/countymunicipalityregardingthe property located at 661 Alabama Ave, Fort Lauderdale, FL. 33312 subsequent to the date of loss.