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Filing # 135752586 E-Filed 10/01/2021 01:59:41 PM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
BRAD MCBRIDE AND MICHELE MCBRIDE,
Plaintiffs, Case No.: CACE-21-010744
V
PRIVILEGE UNDERWRITERS
RECIPROCAL EXCHANGE,
Defendant.
I
RE-NOTICE OF TAKING DEPOSITIONDUCES TECUM
PLEASE TAKE NOTICE that the undersigned will take the deposition of the following
person(s) on the dates and times indicatedbelow:
Name Date/Time Location
BRAD MCBRIDE Tuesday, December 7,2021 MCS Group
at 10:00 AM EST Zoom Videoconference
(link to be provided)
MICHELE MCBRIDE Tuesday, December 7,2021 MCS Group
at 1:00 PM EST, or immediately Zoom Videoconference
following the deposition of Brad (link to be provided)
McBride
Before MCS Group, a notary public or other person authorized by law to take depositions,
and to bring with him/her the documentslisted on the attached Schedule A.
The deposition is being taken for the purposes of discovery, for use at trial, or for any other
purpose for which it may be used under the laws o f the State o f Florida.
Dated: October 1,2021
Respectfully submitted,
CLAUSEN MILLER P.C.
/s/
Douglas M. Cohen
Douglas M. Cohen, Esq.
Florida Bar No: 40857
7744676.1
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/01/2021 01:59:41 PM.****
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing has been furnished to Nicole
Rosenfeld, Esq., Rosenfeld Nitch PA, AttorneyfbrPlaint(09, 14310 SW 8th Street, Suite 2198,
Miami, Florida 33184, via the Florida Courts E-File Portal to: this
1st day of October, 2021.
CLAUSEN MILLER P.C.
/s/
Douglas M. Cohen
Douglas M. Cohen, Esq.
Florida Bar No: 40857
4830 West Kennedy Blvd. #600
Tampa, Florida 33609
Phone:(813) 519-1013
dcohen@clausen.com
lbaez@clausen.com
karmour@clausen.com
CounselMDefendant
7744676.1
SCHEDULE A
1. Plaintiffs' policies of insurance issued by any insurance carrier for five years prior
to the date of loss for the subject house.
2. All installation
orders, repair orders, invoices, contracts, subcontracts, and written
documentsregarding installation, repair or modifications, to any part of the home from the date of
purchase to the present including but not exclusive of roofers who have inspected, repaired or
visited the subject house.
3. All bills, statements or estimates for
repair and loss of the building or contents
thereofrelated and caused by the incident described in the Complaint.
4. Photographstaken following the incident described in the Complaint purporting to
show damage thereto.
5. Any and all statements made by any Defendant, their agents, servants, adjusters,
independent adjusters, local adjusters, witnesses or employees, relating to or pertaining to the
incidents described in the Complaint including any written or recorded statements.
6. Copy of all documentsbetween you and any public adjuster hired by insured at any
time for the incident described in the Complaint.
7. Copy of any contracts, invoices or agreements between insured and any contractors
relating to repairs ofthe subject house.
8 Copies of all purchase and sale records of the subject house since the date of
original purchase until today including but not limited to all inspection reports, financing
statements, etc.
9. Any drawings, exhibits, photographs, videotapes, diagrams or documenting
evidence relating to any matter o f the controversyintended to be used at trial.
10. Copies of all applications for and/or claims for benefits and/or claims for payments
submitted by or behalfofinsured you to any insurance company or any other source whatsoever
on
for any benefits claimed to be due as a result of the incident described in the Complaint.
11. All documents which refer or relate to any prior insurance claims concerning the
subject residence including without limitation claims made, correspondence with insurance
carriers, and/or agents, payments, reservation of rights and any payments and any documents
relating in any way to any litigation.
12. Copies ofall correspondence,memoranda or other documentsbetween you and this
Defendant.
13.Any and all contracts, agreements, job files, specifications, notes, memoranda,
correspondence, submittals, photographs (including progress photos), videos, reports by design
7744676.1
professionals, diagrams, calculations, invoices, purchase orders, change orders, requests for
information, requests for clarification, reports, logs, journals, job diaries, receipts, accounting
records, writings, all plans and specifications and amendments, structural calculations, shop
drawings, as built drawings, city inspector punch lists and sign out sheets, schedules,
correspondence concerning the subject home.
14. Any and all documents comprising the contract between Plaintiffs and any other
entity for workperformed on the subject house within the 10 years prior to the subject loss
including but not exclusive of roofers who have inspected,repaired or visited the subject house.
15. Any and all contracts, subcontracts, or other documents regarding the work
performed by any design professional contractor, subcontractor, supplier, agent or employer on
the subject house within the 10 years prior to the subject loss.
16. Any and all photographspertaining to the subject loss.
17. Any and all reports or analysis prepared by any expert or consultant for the benefit
of you regarding the cost of repair for the subject home arising from the subject loss.
18. Any and all change orders, appealed orders, work orders, and proposals for changes
in the work performed on the Project, whether or not approved, made a part of any contract or
subcontract or actually performed.
19. All statements not produced in response to the preceding two paragraphs.
20. All documents supporting the claim for money damage in the lawsuit not produced
in response to the preceding paragraphs.
21. A report of each person who the Plaintiffs expects to call as an expert witness at
trial.
22. All photographs,diagrams,videotapes, etc., in the Plaintiffs' possessionrelating to
the allegations contained in Plaintiffs' Complaint.
23. All photographs depicting the scene ofthe loss alleged in the Plaintiffs' Complaint.
24. All reports and any other investigative material prepared by any other party or non-
party that the Plaintiffs contributed to by any means that relate to the subject matter of the
Plaintiffs' Complaint.
25. Copies of all documents including letters, estimates, reports and all correspondence
between you and your insurance company for any homeownerinsurance claims other than the one
in this action.
7744676.1
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Filing # 135752586 E-Filed 10/01/2021 01:59:41 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA BRAD MCBRIDE AND MICHELE MCBRIDE, Plaintiffs, Case No.: CACE-21-010744 V PRIVILEGE UNDERWRITERS RECIPROCAL EXCHANGE, Defendant. I RE-NOTICE OF TAKING DEPOSITIONDUCES TECUM PLEASE TAKE NOTICE that the undersigned will take the deposition of the following person(s) on the dates and times indicatedbelow: Name Date/Time Location BRAD MCBRIDE Tuesday, December 7,2021 MCS Group at 10:00 AM EST Zoom Videoconference (link to be provided) MICHELE MCBRIDE Tuesday, December 7,2021 MCS Group at 1:00 PM EST, or immediately Zoom Videoconference following the deposition of Brad (link to be provided) McBride Before MCS Group, a notary public or other person authorized by law to take depositions, and to bring with him/her the documentslisted on the attached Schedule A. The deposition is being taken for the purposes of discovery, for use at trial, or for any other purpose for which it may be used under the laws o f the State o f Florida. Dated: October 1,2021 Respectfully submitted, CLAUSEN MILLER P.C. /s/ Douglas M. Cohen Douglas M. Cohen, Esq. Florida Bar No: 40857 7744676.1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/01/2021 01:59:41 PM.**** CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been furnished to Nicole Rosenfeld, Esq., Rosenfeld Nitch PA, AttorneyfbrPlaint(09, 14310 SW 8th Street, Suite 2198, Miami, Florida 33184, via the Florida Courts E-File Portal to: this 1st day of October, 2021. CLAUSEN MILLER P.C. /s/ Douglas M. Cohen Douglas M. Cohen, Esq. Florida Bar No: 40857 4830 West Kennedy Blvd. #600 Tampa, Florida 33609 Phone:(813) 519-1013 dcohen@clausen.com lbaez@clausen.com karmour@clausen.com CounselMDefendant 7744676.1 SCHEDULE A 1. Plaintiffs' policies of insurance issued by any insurance carrier for five years prior to the date of loss for the subject house. 2. All installation orders, repair orders, invoices, contracts, subcontracts, and written documentsregarding installation, repair or modifications, to any part of the home from the date of purchase to the present including but not exclusive of roofers who have inspected, repaired or visited the subject house. 3. All bills, statements or estimates for repair and loss of the building or contents thereofrelated and caused by the incident described in the Complaint. 4. Photographstaken following the incident described in the Complaint purporting to show damage thereto. 5. Any and all statements made by any Defendant, their agents, servants, adjusters, independent adjusters, local adjusters, witnesses or employees, relating to or pertaining to the incidents described in the Complaint including any written or recorded statements. 6. Copy of all documentsbetween you and any public adjuster hired by insured at any time for the incident described in the Complaint. 7. Copy of any contracts, invoices or agreements between insured and any contractors relating to repairs ofthe subject house. 8 Copies of all purchase and sale records of the subject house since the date of original purchase until today including but not limited to all inspection reports, financing statements, etc. 9. Any drawings, exhibits, photographs, videotapes, diagrams or documenting evidence relating to any matter o f the controversyintended to be used at trial. 10. Copies of all applications for and/or claims for benefits and/or claims for payments submitted by or behalfofinsured you to any insurance company or any other source whatsoever on for any benefits claimed to be due as a result of the incident described in the Complaint. 11. All documents which refer or relate to any prior insurance claims concerning the subject residence including without limitation claims made, correspondence with insurance carriers, and/or agents, payments, reservation of rights and any payments and any documents relating in any way to any litigation. 12. Copies ofall correspondence,memoranda or other documentsbetween you and this Defendant. 13.Any and all contracts, agreements, job files, specifications, notes, memoranda, correspondence, submittals, photographs (including progress photos), videos, reports by design 7744676.1 professionals, diagrams, calculations, invoices, purchase orders, change orders, requests for information, requests for clarification, reports, logs, journals, job diaries, receipts, accounting records, writings, all plans and specifications and amendments, structural calculations, shop drawings, as built drawings, city inspector punch lists and sign out sheets, schedules, correspondence concerning the subject home. 14. Any and all documents comprising the contract between Plaintiffs and any other entity for workperformed on the subject house within the 10 years prior to the subject loss including but not exclusive of roofers who have inspected,repaired or visited the subject house. 15. Any and all contracts, subcontracts, or other documents regarding the work performed by any design professional contractor, subcontractor, supplier, agent or employer on the subject house within the 10 years prior to the subject loss. 16. Any and all photographspertaining to the subject loss. 17. Any and all reports or analysis prepared by any expert or consultant for the benefit of you regarding the cost of repair for the subject home arising from the subject loss. 18. Any and all change orders, appealed orders, work orders, and proposals for changes in the work performed on the Project, whether or not approved, made a part of any contract or subcontract or actually performed. 19. All statements not produced in response to the preceding two paragraphs. 20. All documents supporting the claim for money damage in the lawsuit not produced in response to the preceding paragraphs. 21. A report of each person who the Plaintiffs expects to call as an expert witness at trial. 22. All photographs,diagrams,videotapes, etc., in the Plaintiffs' possessionrelating to the allegations contained in Plaintiffs' Complaint. 23. All photographs depicting the scene ofthe loss alleged in the Plaintiffs' Complaint. 24. All reports and any other investigative material prepared by any other party or non- party that the Plaintiffs contributed to by any means that relate to the subject matter of the Plaintiffs' Complaint. 25. Copies of all documents including letters, estimates, reports and all correspondence between you and your insurance company for any homeownerinsurance claims other than the one in this action. 7744676.1