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Filing# 139336450 E-Filed 1 1/30/2021 11:52:55 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.
'
PLAINTIFFS' NOTICE OF TAKING DEPOSITION DUCES TECUMI
Please take notice that at the time, place and 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):
NAME
DATE AND TIME
PLACE
Gyula Papp
Phipps Reporting
c/o Prodigy Assurance Adjusters
Thursday
Via Zoom
4613 North UniversityDrive
April 28,2022
(Zoom link will be providedat a
Ste 582
at 10:00 a.m. 2
time before the depositionis set to
Coral Springs,Florida 33067
occur).
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 being taken for the purpose of discovery,for use at trial,or both ofthe foregoing,
1
DUCES TECUM Deponent is required to bring with him to the depositionon the date and
time specifiedall items listed in the attached "Schedule "A.,,
2 Date and time coordinated with Defendant's counsel via email on November 24,2021
RUIZ I GETMAN LAW, PLLC
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/30/2021 11:52:55 AM.****
CASE NO.: CACE 2021-007238 (08)
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 & Casualty Insurance 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
receivingthis 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"
YOU ARE TO BRING WITH YOU, AT THE TIME OF YOUR DEPOSITION, THE
FOLLOWING:3
1.
Any and all photographs which were taken by you, your agents, employees, or
subcontractors depictingPlaintiffs' property located at 661 Alabama Avenue, Fort
Lauderdale, Florida 33312 (hereinafter
referred to as the "subjectproperty").
2.
Any and all films,videos, or audio tapes taken by you, your agents, employees, or
subcontractors,depictingthe subjectproperty for the subjectclaim.
3.
Any and all films,videos, or audio tapes providedto you, your agents, employees,
or subcontractors depictingthe subjectproperty for the subjectclaim.
4.
Any and all recorded statements taken by you, your agents, employees, or
subcontractors of Plaintiffs,
relatingto the subjectclaim.
5.
Any and all estimates preparedby you, your agents, employees,or subcontractors,
for the subjectclaim.
6.
Any and all correspondence sent to Plaintiffs (orany of their representatives)
by
you, your agents, employees, or subcontractors relating
to the subjectclaim.
7.
Any and all correspondencesent to you, your agents, employees, or subcontractors
from Plaintiffs (orany of their representatives)
relatingto the subjectclaim.
8.
A copy ofyour most up-to-dateresume/curriculum vitae.
This request is intended to seek a complete copy ofyour file and none ofthese requests should
be read or interpreted narrowly to the exclusion of any records.
3 Each request includes any files maintained by Gyula Papp, in either paper or electronic
format.
-3.
RUIZ I GETMAN LAW, PLLC
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Filing# 139336450 E-Filed 1 1/30/2021 11:52:55 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. ' PLAINTIFFS' NOTICE OF TAKING DEPOSITION DUCES TECUMI Please take notice that at the time, place and 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): NAME DATE AND TIME PLACE Gyula Papp Phipps Reporting c/o Prodigy Assurance Adjusters Thursday Via Zoom 4613 North UniversityDrive April 28,2022 (Zoom link will be providedat a Ste 582 at 10:00 a.m. 2 time before the depositionis set to Coral Springs,Florida 33067 occur). 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 being taken for the purpose of discovery,for use at trial,or both ofthe foregoing, 1 DUCES TECUM Deponent is required to bring with him to the depositionon the date and time specifiedall items listed in the attached "Schedule "A.,, 2 Date and time coordinated with Defendant's counsel via email on November 24,2021 RUIZ I GETMAN LAW, PLLC *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/30/2021 11:52:55 AM.**** CASE NO.: CACE 2021-007238 (08) 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 & Casualty Insurance 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 receivingthis 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" YOU ARE TO BRING WITH YOU, AT THE TIME OF YOUR DEPOSITION, THE FOLLOWING:3 1. Any and all photographs which were taken by you, your agents, employees, or subcontractors depictingPlaintiffs' property located at 661 Alabama Avenue, Fort Lauderdale, Florida 33312 (hereinafter referred to as the "subjectproperty"). 2. Any and all films,videos, or audio tapes taken by you, your agents, employees, or subcontractors,depictingthe subjectproperty for the subjectclaim. 3. Any and all films,videos, or audio tapes providedto you, your agents, employees, or subcontractors depictingthe subjectproperty for the subjectclaim. 4. Any and all recorded statements taken by you, your agents, employees, or subcontractors of Plaintiffs, relatingto the subjectclaim. 5. Any and all estimates preparedby you, your agents, employees,or subcontractors, for the subjectclaim. 6. Any and all correspondence sent to Plaintiffs (orany of their representatives) by you, your agents, employees, or subcontractors relating to the subjectclaim. 7. Any and all correspondencesent to you, your agents, employees, or subcontractors from Plaintiffs (orany of their representatives) relatingto the subjectclaim. 8. A copy ofyour most up-to-dateresume/curriculum vitae. This request is intended to seek a complete copy ofyour file and none ofthese requests should be read or interpreted narrowly to the exclusion of any records. 3 Each request includes any files maintained by Gyula Papp, in either paper or electronic format. -3. RUIZ I GETMAN LAW, PLLC