Preview
Filing# 137572950 E-Filed 10/29/2021 04:03:26 PM
THE CIRCUIT COURT OF THE 17TH
IN
JUDICIAL CIRCUIT IN AND FOR
ELORS ETIENNE AND ADJANIE BROWARD COUNTY, FLORIDA
ETIENNE,
CASE NO. CACE-21-010707
Plaintiffs,
V
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
i
NOTICE OF TAKING VIRTUAL DEPOSITION DUCES TECUM
(Coordinated with Opposing Counsel on October 28, 2021)
PLEASE TAKE NOTICE, that the undersigned attorney will take the deposition of:
Name: COLE DAVIDSON
Field Adjuster
Date: December 6, 2021
Time: 10:00 a.m.
Place: Virtual Deposition
88075?pwd==anVSVHdVbHc0VGJ4R-FhVT 1 ov02xOZz09
https://ucrinc.zoom.us/j/820685
Meeting ID: 820 6858 8075
Passcode: 640513
Deponents will be required to produce at the time of his/her deposition,all items requested in the
attached Subpoena Duces Tecum for Deposition.
Upon oral examination before a Court Reporter, Notary Public or any other officer authorized by Law to
take depositions in the State ofFlorida. The oral examination will continue from day to day until completed.
This deposition is being taken for the purpose of discovery, for use at trial,or for such other purposes as
are pennitted under the rules of the court.
PLEASE EMAIL A COPY OF YOUR ENTIRE CLAIMS FILE AT LEAST TEN (10) DAYS
BEFORE DEPOSITION DATE TO IN ORDER TO AVOID LAST MINUTE CANCELLATION
OF THIS DEPOSITION TO: SERVICE@FELDMANANDLOPEZ.COM
(Remainder ofpage leftblank intentionally,Certificate
of Service to follow)
1
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/29/2021 04:03:26 PM.****
SCHEDULE "A"
COMPLETE non-privileged file regarding Claim Number: FL20-0152820-P420
(Dates o f Loss- 1 1/8/2020) for Heritage Property & Insurance Company, Policy No.
1501-1706-1940; includingbut not limited to any and all photographs,videotapesof the
area where the subject incident occurred, reports, correspondence, calculations,notes,
memoranda, guidelines,publications,estimates, invoices, statements, inventories,and
all documents you have review.
THIS SUBPOENA DOESNOT SEEK MATERIALS THAT ARE WORK-PRODUCT
PROTECTED OR TO WHICH ATTORNEY-CLIENT PRIVILEGE ATTACHES OR
CLAIMS-HANDLING MATTERS
1. All non-privileged of this loss which
materials related to the inspectionand investigation
were performed by the field adjusteror estimator which were generatedpriorto the earlier
of the following:(1)90 days after the first loss notice, (2) the date of the denial of the
claim or (3) the date that a payment was made on the loss. We are not seeking any
documents prepared by the field or
investigator field adjusteror damage estimator that
were prepared in response to event or which were prepared in anticipation
any litigation
of litigation
or in anticipation became foreseeable.
of any event in which litigation
1. Any and all documents
non-privileged that you have reviewed, compiled or preparedin
connection with the expressiono f your opinion in this matter.
2. Any and all non-privileged documents non-privileged evidencing or tending to
evidence the dates and amounts of time expended by you in connection with this matter.
3. Any and all non-privileged documents evidencing or tending to evidence any
requests for services and opinions in this matter. Such documents include all message
slips, notes, correspondence,emails and the
diarynotes or entries, like.
4. Any and all documents or charts on this matter requiredor consulted by you in connection
with the expressiono f your opinion in this matter.
5. A current curriculum vitae or other compilation of biographicalor qualifications
information.
6. A list of all publicationsin which you had an authorshiprole or inputfor the past 5 years.
2
7. A list of all cases in which you have testified as an expert at either a depositionor in trial
for the past five years (includesufficient information where any transcript
may be located
i.e. court, and complete styleof cases includingcase number).
10. Any and all non-privileged etc. you consider to be
guidelines,reports, publications,
authoritative regardingthis case.
10. Any and all non-privilegedreports and bills for services rendered in this case.
11. Any and all non-privilegedrecords and/or reports, evaluations, summaries or written
opinionspreparedby you and any and all documentations referred to, mentioned in or
utilized in said report, evaluations,summaries or written opinionsor in the preparation
thereof.
You are subpoenaed to appear before the following attorney and unless excused from this
Subpoena by this attorney or the Court, you shall respond to this subpoena as directed. The oral
examination will continue from day to day until completed. This depositionis taken for the
purpose of discovery,for use of at trial,or for such other purposes as are permitted under the
rules of the Court.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true copy of the foregoing was furnished via electronic mail
to: Lindsay C. Tropnas, Esq., Universal Property & CasualtyInsurance Co., P.O. Box 9388, Fort
Lauderdale, FL 33310, lt0223@universalproperty.com;is0601@universalproperty.com;
jh0518@universalproperty.comon October 28, 2021.
Respectfullysubmitted,
FELDMAN & LOPEZ, P.A.
9990 SW 77th Avenue
Miami, FL 33156
Phone: (305) 779-5904
By: /s/ Carolina Lopez
Carolina Lopez, Esq.
Florida Bar No. 1000488
service@feldmanandlopez.com
3
Preview
Filing# 137572950 E-Filed 10/29/2021 04:03:26 PM THE CIRCUIT COURT OF THE 17TH IN JUDICIAL CIRCUIT IN AND FOR ELORS ETIENNE AND ADJANIE BROWARD COUNTY, FLORIDA ETIENNE, CASE NO. CACE-21-010707 Plaintiffs, V UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. i NOTICE OF TAKING VIRTUAL DEPOSITION DUCES TECUM (Coordinated with Opposing Counsel on October 28, 2021) PLEASE TAKE NOTICE, that the undersigned attorney will take the deposition of: Name: COLE DAVIDSON Field Adjuster Date: December 6, 2021 Time: 10:00 a.m. Place: Virtual Deposition 88075?pwd==anVSVHdVbHc0VGJ4R-FhVT 1 ov02xOZz09 https://ucrinc.zoom.us/j/820685 Meeting ID: 820 6858 8075 Passcode: 640513 Deponents will be required to produce at the time of his/her deposition,all items requested in the attached Subpoena Duces Tecum for Deposition. Upon oral examination before a Court Reporter, Notary Public or any other officer authorized by Law to take depositions in the State ofFlorida. The oral examination will continue from day to day until completed. This deposition is being taken for the purpose of discovery, for use at trial,or for such other purposes as are pennitted under the rules of the court. PLEASE EMAIL A COPY OF YOUR ENTIRE CLAIMS FILE AT LEAST TEN (10) DAYS BEFORE DEPOSITION DATE TO IN ORDER TO AVOID LAST MINUTE CANCELLATION OF THIS DEPOSITION TO: SERVICE@FELDMANANDLOPEZ.COM (Remainder ofpage leftblank intentionally,Certificate of Service to follow) 1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/29/2021 04:03:26 PM.**** SCHEDULE "A" COMPLETE non-privileged file regarding Claim Number: FL20-0152820-P420 (Dates o f Loss- 1 1/8/2020) for Heritage Property & Insurance Company, Policy No. 1501-1706-1940; includingbut not limited to any and all photographs,videotapesof the area where the subject incident occurred, reports, correspondence, calculations,notes, memoranda, guidelines,publications,estimates, invoices, statements, inventories,and all documents you have review. THIS SUBPOENA DOESNOT SEEK MATERIALS THAT ARE WORK-PRODUCT PROTECTED OR TO WHICH ATTORNEY-CLIENT PRIVILEGE ATTACHES OR CLAIMS-HANDLING MATTERS 1. All non-privileged of this loss which materials related to the inspectionand investigation were performed by the field adjusteror estimator which were generatedpriorto the earlier of the following:(1)90 days after the first loss notice, (2) the date of the denial of the claim or (3) the date that a payment was made on the loss. We are not seeking any documents prepared by the field or investigator field adjusteror damage estimator that were prepared in response to event or which were prepared in anticipation any litigation of litigation or in anticipation became foreseeable. of any event in which litigation 1. Any and all documents non-privileged that you have reviewed, compiled or preparedin connection with the expressiono f your opinion in this matter. 2. Any and all non-privileged documents non-privileged evidencing or tending to evidence the dates and amounts of time expended by you in connection with this matter. 3. Any and all non-privileged documents evidencing or tending to evidence any requests for services and opinions in this matter. Such documents include all message slips, notes, correspondence,emails and the diarynotes or entries, like. 4. Any and all documents or charts on this matter requiredor consulted by you in connection with the expressiono f your opinion in this matter. 5. A current curriculum vitae or other compilation of biographicalor qualifications information. 6. A list of all publicationsin which you had an authorshiprole or inputfor the past 5 years. 2 7. A list of all cases in which you have testified as an expert at either a depositionor in trial for the past five years (includesufficient information where any transcript may be located i.e. court, and complete styleof cases includingcase number). 10. Any and all non-privileged etc. you consider to be guidelines,reports, publications, authoritative regardingthis case. 10. Any and all non-privilegedreports and bills for services rendered in this case. 11. Any and all non-privilegedrecords and/or reports, evaluations, summaries or written opinionspreparedby you and any and all documentations referred to, mentioned in or utilized in said report, evaluations,summaries or written opinionsor in the preparation thereof. You are subpoenaed to appear before the following attorney and unless excused from this Subpoena by this attorney or the Court, you shall respond to this subpoena as directed. The oral examination will continue from day to day until completed. This depositionis taken for the purpose of discovery,for use of at trial,or for such other purposes as are permitted under the rules of the Court. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing was furnished via electronic mail to: Lindsay C. Tropnas, Esq., Universal Property & CasualtyInsurance Co., P.O. Box 9388, Fort Lauderdale, FL 33310, lt0223@universalproperty.com;is0601@universalproperty.com; jh0518@universalproperty.comon October 28, 2021. Respectfullysubmitted, FELDMAN & LOPEZ, P.A. 9990 SW 77th Avenue Miami, FL 33156 Phone: (305) 779-5904 By: /s/ Carolina Lopez Carolina Lopez, Esq. Florida Bar No. 1000488 service@feldmanandlopez.com 3