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Filing# 139326527 E-Filed 1 1/30/2021 10:50:50 AM
IN THE CIRCUIT COURT OF THE
17th JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
IRMA QURESHI, an individual, and
GENERAL JURISDICTION DIVISION
GEORGE GUERRERO, an individual,
CASE NO- CACE 2021-007238 (08)
Plaintiffs,
V
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY, a Florida
corporation,
Defendant.
i
PLAINTIFFS' NOTICE OF TAKING DEPOSITION DUCES TECUMI OF
CORPORATE REPRESENTATIVE PURSUANT TO FLA. R. CIV. P. 1.310(b)(6)
Please take notice that at the time,placeand date specifiedbelow before an officer who is
authorized to take depositionsin the State of Florida, Irma Qureshi & George Guerrero
("Plaintiffs"),
will take the depositionofthe followingperson(s):
DATE AND
NAME
PLACE
TIME
Corporate
Representative
of
Phipps Reporting
Universal
Property
& Casualty
Wednesday
Via Zoom
Insurance Company who can testify April 13, 2022
(Zoom link will be at a time
as to the topicsand subjectslisted in
at 10:00 a.m. 2
before the depositionis set to
the Schedule "A"
occur).
1
Please bringall documents necessary to respond to all areas of inquirylisted in the Schedule "A"
below. Plaintiffs are not requesting actual production of the documents. Instead,Plaintiffs
request that Defendant's corporate representative
bring all documents necessary to answer all
questionsrelated to the areas of inquirylisted in the Schedule "A."
2 Date and time coordinated with Defendant's counsel on November 24,2021.
RUIZ I GETMAN LAW, PLLC
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/30/2021 10:50:48 AM.****
CASE NO.: CACE 2021-007238 (08)
Said depositionwill be taken upon oral examination before a Notary Public in and for the
State of Florida,or any other officer duly authorized to administer oaths by the laws in the State
of Florida. The depositionwill continue from hour to hour and from day to day until completed.
The depositionis beingtaken for the purpose of discovery,for use at trial,or both ofthe foregoing,
or for such other purposes as are permittedunder the applicableand governing rules,and to have
with you at said time and placethe documents contained in the Schedule "A" attached hereto.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 30th day ofNovember 2021, a true and correct copy
ofthis document is being served on Joshua Strudwick, Esq. at: sb0128@universalproperty.coin:
Upciceservice03@universalproperty.comand js0730@universalproperty.comfrom Universal
Property & CasualtyInsurance Company, P.O. Box 9388 Fort Lauderdale, Florida 33309.
Respectfullysubmitted,
/s/ Amy E. Ruiz
Amy E. Ruiz, FBN: 99129
ARuiz@RuizGetmanLaw.com
Steven J. Getman, FBN: 67198
SGetman@RuizGetmanLaw.com
Ruiz 1Getman Law, PLLC
6800 SW 40th Street,#394
Miami, Florida 33155
Telephone: 305.978.6311
Facsimile: 305.397.2760
Attorneysfor Plaintiffs,
Irma Qureshi & George
Guerrero
,, 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, 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 calling711.,,
-2.
RUIZ I GETMAN LAW, PLLC
CASE NO.: CACE 2021-007238 (08)
SCHEDULE "A"
1.
Identifyby full name and company title all those persons who participatedin making the
decisions by or on behalf of Defendant in determiningthe value of Plaintiffs' damages (if
any) and determiningwho will inspectPlaintiffs' property for the subjectclaim.
2.
All facts and circumstances regarding Defendant's investigationand valuation of
Plaintiffs' claim.
3.
Factual bases and all policylanguage upon which Defendant's Answer is based, including
all denials and affirmative defenses raised by Defendant in this cause.
4.
Defendant's responses to Plaintiffs' discoveryrequests and all facts and policylanguage
which support Defendant's responses to Plaintiffs' discoveryrequests.
5.
All photographstaken by Defendant and/or Defendant's agent(s)for the subjectclaim.
6.
All correspondence and documents exchanged between Defendant and Plaintiffs
(includinghis representatives)
relatingto the subjectclaim.
-3.
RUIZ I GETMAN LAW, PLLC
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Filing# 139326527 E-Filed 1 1/30/2021 10:50:50 AM IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA IRMA QURESHI, an individual, and GENERAL JURISDICTION DIVISION GEORGE GUERRERO, an individual, CASE NO- CACE 2021-007238 (08) Plaintiffs, V UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, a Florida corporation, Defendant. i PLAINTIFFS' NOTICE OF TAKING DEPOSITION DUCES TECUMI OF CORPORATE REPRESENTATIVE PURSUANT TO FLA. R. CIV. P. 1.310(b)(6) Please take notice that at the time,placeand date specifiedbelow before an officer who is authorized to take depositionsin the State of Florida, Irma Qureshi & George Guerrero ("Plaintiffs"), will take the depositionofthe followingperson(s): DATE AND NAME PLACE TIME Corporate Representative of Phipps Reporting Universal Property & Casualty Wednesday Via Zoom Insurance Company who can testify April 13, 2022 (Zoom link will be at a time as to the topicsand subjectslisted in at 10:00 a.m. 2 before the depositionis set to the Schedule "A" occur). 1 Please bringall documents necessary to respond to all areas of inquirylisted in the Schedule "A" below. Plaintiffs are not requesting actual production of the documents. Instead,Plaintiffs request that Defendant's corporate representative bring all documents necessary to answer all questionsrelated to the areas of inquirylisted in the Schedule "A." 2 Date and time coordinated with Defendant's counsel on November 24,2021. RUIZ I GETMAN LAW, PLLC *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/30/2021 10:50:48 AM.**** CASE NO.: CACE 2021-007238 (08) Said depositionwill be taken upon oral examination before a Notary Public in and for the State of Florida,or any other officer duly authorized to administer oaths by the laws in the State of Florida. The depositionwill continue from hour to hour and from day to day until completed. The depositionis beingtaken for the purpose of discovery,for use at trial,or both ofthe foregoing, or for such other purposes as are permittedunder the applicableand governing rules,and to have with you at said time and placethe documents contained in the Schedule "A" attached hereto. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 30th day ofNovember 2021, a true and correct copy ofthis document is being served on Joshua Strudwick, Esq. at: sb0128@universalproperty.coin: Upciceservice03@universalproperty.comand js0730@universalproperty.comfrom Universal Property & CasualtyInsurance Company, P.O. Box 9388 Fort Lauderdale, Florida 33309. Respectfullysubmitted, /s/ Amy E. Ruiz Amy E. Ruiz, FBN: 99129 ARuiz@RuizGetmanLaw.com Steven J. Getman, FBN: 67198 SGetman@RuizGetmanLaw.com Ruiz 1Getman Law, PLLC 6800 SW 40th Street,#394 Miami, Florida 33155 Telephone: 305.978.6311 Facsimile: 305.397.2760 Attorneysfor Plaintiffs, Irma Qureshi & George Guerrero ,, 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, 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 calling711.,, -2. RUIZ I GETMAN LAW, PLLC CASE NO.: CACE 2021-007238 (08) SCHEDULE "A" 1. Identifyby full name and company title all those persons who participatedin making the decisions by or on behalf of Defendant in determiningthe value of Plaintiffs' damages (if any) and determiningwho will inspectPlaintiffs' property for the subjectclaim. 2. All facts and circumstances regarding Defendant's investigationand valuation of Plaintiffs' claim. 3. Factual bases and all policylanguage upon which Defendant's Answer is based, including all denials and affirmative defenses raised by Defendant in this cause. 4. Defendant's responses to Plaintiffs' discoveryrequests and all facts and policylanguage which support Defendant's responses to Plaintiffs' discoveryrequests. 5. All photographstaken by Defendant and/or Defendant's agent(s)for the subjectclaim. 6. All correspondence and documents exchanged between Defendant and Plaintiffs (includinghis representatives) relatingto the subjectclaim. -3. RUIZ I GETMAN LAW, PLLC