Preview
Filing # 127571501 E-Filed 05/26/2021 12:06:12 PM
JHR/kxh/60110-1629
IN THE CIRCUIT COURT OF THE 11TH
JUDICIAL CIRCUIT IN AND FOR MIAMI-
DADE COUNTY, FLORIDA
CASE NO. 19-016161 CA 01 (11)
FLORIDA BAR NO. 50230
GUILLERMO DOMINGUEZ and INGRID
DOMINGUEZ,
Plaintiff,
vs.
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendants.
/
RE-NOTICE OF TAKING VIDEOTAPED DEPOSITION (DUCES TECUM)*
PLEASE ADVISE IF AN INTERPRETER IS NECESSARY
TO: J.P. Gonzalez-Sirgo, Esq., J.P. Gonzalez-Sirgo P.A., 814 Ponce de Leon Blvd.
#504, Coral Gables FL 33134;
YOU, as attorneys of record, are hereby notified that on June 8, 2021 at 2:00PM, at
Phipps Reporting via Zoom, Defendant, CITIZENS PROPERTY INSURANCE
CORPORATION, will take the deposition by oral examination for purposes of discovery
and for use as evidence in said cause, or both, of the following:
GRANT RENNE
MIAMI FORT LAUDERDALE TAMPA WEST PALM BEACH NEW YORK
100 S.E. Second Street, Suite 2600
1600 W. Commercial Boulevard, Suite 201
400 N. Ashley Drive, Suite 1150
824 U.S. Highway One, Suite 305
90 Park Avenue, Suite 2300
Miami, Florida 33131 Fort Lauderdale, Florida 33309
Tampa, Florida 33602 North Palm Beach, Florida 33408New York, New York 10016
Tel:786-425-1045 Fax: 786-425-3905
Tel: 954-848-2460 Fax: 954-848-2470
Tel: 813-223-6021 Fax: 813-223-6024
Tel: 561-624-8233 Fax: 561-624-8940
Tel: (212) 336-8100
www.boydlawgroup.com
Said deposition will be taken before a Notary Public or any officer authorized to
administer oaths by the laws of the State of Florida, and a person who is neither a relative,
nor employee of such attorney or counsel, and who is not financially interested in the action.
Said deposition to be taken pursuant to the Florida Rules of Civil Procedure in such cases
provided. The said oral examination will continue from hour to hour and from day to day
until completed. Said deponent shall have present at deposition the following:
* 1. A professional resume or curriculum vitae summarizing your professional
qualifications.
2. Copies of all scientific and technical publications authored by you.
3. All time records, diaries, and bills prepared and rendered in connection
with your investigation and evaluation of the issues involved in the lawsuit.
4. Your complete file in connection with your investigation and evaluation of
the issues involved in the lawsuit, including but not limited to:
(a) All documents furnished to you by anyone;
(b) All documents obtained or created by you;
(c) All documents you reviewed, referred to, or relied upon in arriving at any of
your opinions or conclusions concerning the issues involved in the lawsuit,
including but not limited to all scientific and technical articles, publications,
codes, standards, and other literature;
(d) All models, illustrations, photographs, or other exhibits or documents of any
kind which you intend or contemplate using to explain, illustrate, or support
your testimony at trial.
AND
Please produce documents prepared and/or reviewed regarding your inspection(s)/work
performed of the insured property located at 12778 NW 102 Place, Hialeah Gardens,
Miami-Dade County, FL 33018:
1. All documents you have reviewed in preparation for this deposition
2. All reports and correspondence prepared by you or on your behalf
regarding your inspection(s) of the insured property.
3. Any and all tapes, video and audio prepared by you or on your behalf
regarding your inspection(s) of the insured property.
4. Any and all photographs and original negatives prepared by you or on your
behalf regarding your inspection(s) of the insured property.
MIAMI FORT LAUDERDALE TAMPA WEST PALM BEACH NEW YORK
100 S.E. Second Street, Suite 2600
1600 W. Commercial Boulevard, Suite 201
400 N. Ashley Drive, Suite 1150
824 U.S. Highway One, Suite 305
90 Park Avenue, Suite 2300
Miami, Florida 33131 Fort Lauderdale, Florida 33309
Tampa, Florida 33602 North Palm Beach, Florida 33408New York, New York 10016
Tel:786-425-1045 Fax: 786-425-3905
Tel: 954-848-2460 Fax: 954-848-2470
Tel: 813-223-6021 Fax: 813-223-6024
Tel: 561-624-8233 Fax: 561-624-8940
Tel: (212) 336-8100
www.boydlawgroup.com
5. Copies of all documentation of whatever kind or nature in your possession,
custody or control concerning the subject loss.
6. Copies of all correspondence, notices, reports or other communications
between you and your representatives and plaintiffs and their
representatives regarding the loss at the insured property.
7. Copies of all documents in your possession, custody or control relating to
the insured property, including but not limited to: photographs, videotapes,
CD’s, DVD’s, video-tapes, estimates, appraisals, repair records, sketches,
drawings, field notes, estimates for damage(s), reports relied upon by you,
reports prepared by you or reports prepared by you or on your behalf of
the plaintiff regarding the loss at the insured property.
8. Copies of all property damage inventories, estimates or reports prepared
and received by you.
9. Copies of all other documents relied upon by you including all books, tables,
depreciation tables, guides, price lists, whatsoever used by you in
determining the valuation of the property or property damage sustained by
the Plaintiff, the methods of computation used by you in arriving at
valuation figures for the property, all reports, calculations, estimates and
the like relied upon by you in arriving at any and all figures used in
determining the damage to the property.
10. Any and all documents, statements, notes, measurements, test results and
related materials relied upon by you in preparation of your report.
WE HEREBY CERTIFY that a copy of the foregoing was filed with the Clerk of
the Court using the Florida Courts E-Filing Portal on May 26, 2021, to be served this date
on the above-named addresses via transmission of Notice of Electronic Filing generated by
eservice@myflcourtaccess.com.
BOYD RICHARDS PARKER & COLONNELLI, P.L.
Attorneys for Defendant
1600 W. Commercial Boulevard, Suite 201
Fort Lauderdale, FL 33309
(954) 848-2460
(954) 848-2470 FAX
Service of pleadings: servicefll@boydlawgroup.com
BY: /s/ William E. Peters Jr.
WILLIAM E. PETERS JR.
cc: (Phipps Reporting)
MIAMI FORT LAUDERDALE TAMPA WEST PALM BEACH NEW YORK
100 S.E. Second Street, Suite 2600
1600 W. Commercial Boulevard, Suite 201
400 N. Ashley Drive, Suite 1150
824 U.S. Highway One, Suite 305
90 Park Avenue, Suite 2300
Miami, Florida 33131 Fort Lauderdale, Florida 33309
Tampa, Florida 33602 North Palm Beach, Florida 33408New York, New York 10016
Tel:786-425-1045 Fax: 786-425-3905
Tel: 954-848-2460 Fax: 954-848-2470
Tel: 813-223-6021 Fax: 813-223-6024
Tel: 561-624-8233 Fax: 561-624-8940
Tel: (212) 336-8100
www.boydlawgroup.com
Preview
Filing # 127571501 E-Filed 05/26/2021 12:06:12 PM JHR/kxh/60110-1629 IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI- DADE COUNTY, FLORIDA CASE NO. 19-016161 CA 01 (11) FLORIDA BAR NO. 50230 GUILLERMO DOMINGUEZ and INGRID DOMINGUEZ, Plaintiff, vs. CITIZENS PROPERTY INSURANCE CORPORATION, Defendants. / RE-NOTICE OF TAKING VIDEOTAPED DEPOSITION (DUCES TECUM)* PLEASE ADVISE IF AN INTERPRETER IS NECESSARY TO: J.P. Gonzalez-Sirgo, Esq., J.P. Gonzalez-Sirgo P.A., 814 Ponce de Leon Blvd. #504, Coral Gables FL 33134; YOU, as attorneys of record, are hereby notified that on June 8, 2021 at 2:00PM, at Phipps Reporting via Zoom, Defendant, CITIZENS PROPERTY INSURANCE CORPORATION, will take the deposition by oral examination for purposes of discovery and for use as evidence in said cause, or both, of the following: GRANT RENNE MIAMI FORT LAUDERDALE TAMPA WEST PALM BEACH NEW YORK 100 S.E. Second Street, Suite 2600 1600 W. Commercial Boulevard, Suite 201 400 N. Ashley Drive, Suite 1150 824 U.S. Highway One, Suite 305 90 Park Avenue, Suite 2300 Miami, Florida 33131 Fort Lauderdale, Florida 33309 Tampa, Florida 33602 North Palm Beach, Florida 33408New York, New York 10016 Tel:786-425-1045 Fax: 786-425-3905 Tel: 954-848-2460 Fax: 954-848-2470 Tel: 813-223-6021 Fax: 813-223-6024 Tel: 561-624-8233 Fax: 561-624-8940 Tel: (212) 336-8100 www.boydlawgroup.com Said deposition will be taken before a Notary Public or any officer authorized to administer oaths by the laws of the State of Florida, and a person who is neither a relative, nor employee of such attorney or counsel, and who is not financially interested in the action. Said deposition to be taken pursuant to the Florida Rules of Civil Procedure in such cases provided. The said oral examination will continue from hour to hour and from day to day until completed. Said deponent shall have present at deposition the following: * 1. A professional resume or curriculum vitae summarizing your professional qualifications. 2. Copies of all scientific and technical publications authored by you. 3. All time records, diaries, and bills prepared and rendered in connection with your investigation and evaluation of the issues involved in the lawsuit. 4. Your complete file in connection with your investigation and evaluation of the issues involved in the lawsuit, including but not limited to: (a) All documents furnished to you by anyone; (b) All documents obtained or created by you; (c) All documents you reviewed, referred to, or relied upon in arriving at any of your opinions or conclusions concerning the issues involved in the lawsuit, including but not limited to all scientific and technical articles, publications, codes, standards, and other literature; (d) All models, illustrations, photographs, or other exhibits or documents of any kind which you intend or contemplate using to explain, illustrate, or support your testimony at trial. AND Please produce documents prepared and/or reviewed regarding your inspection(s)/work performed of the insured property located at 12778 NW 102 Place, Hialeah Gardens, Miami-Dade County, FL 33018: 1. All documents you have reviewed in preparation for this deposition 2. All reports and correspondence prepared by you or on your behalf regarding your inspection(s) of the insured property. 3. Any and all tapes, video and audio prepared by you or on your behalf regarding your inspection(s) of the insured property. 4. Any and all photographs and original negatives prepared by you or on your behalf regarding your inspection(s) of the insured property. MIAMI FORT LAUDERDALE TAMPA WEST PALM BEACH NEW YORK 100 S.E. Second Street, Suite 2600 1600 W. Commercial Boulevard, Suite 201 400 N. Ashley Drive, Suite 1150 824 U.S. Highway One, Suite 305 90 Park Avenue, Suite 2300 Miami, Florida 33131 Fort Lauderdale, Florida 33309 Tampa, Florida 33602 North Palm Beach, Florida 33408New York, New York 10016 Tel:786-425-1045 Fax: 786-425-3905 Tel: 954-848-2460 Fax: 954-848-2470 Tel: 813-223-6021 Fax: 813-223-6024 Tel: 561-624-8233 Fax: 561-624-8940 Tel: (212) 336-8100 www.boydlawgroup.com 5. Copies of all documentation of whatever kind or nature in your possession, custody or control concerning the subject loss. 6. Copies of all correspondence, notices, reports or other communications between you and your representatives and plaintiffs and their representatives regarding the loss at the insured property. 7. Copies of all documents in your possession, custody or control relating to the insured property, including but not limited to: photographs, videotapes, CD’s, DVD’s, video-tapes, estimates, appraisals, repair records, sketches, drawings, field notes, estimates for damage(s), reports relied upon by you, reports prepared by you or reports prepared by you or on your behalf of the plaintiff regarding the loss at the insured property. 8. Copies of all property damage inventories, estimates or reports prepared and received by you. 9. Copies of all other documents relied upon by you including all books, tables, depreciation tables, guides, price lists, whatsoever used by you in determining the valuation of the property or property damage sustained by the Plaintiff, the methods of computation used by you in arriving at valuation figures for the property, all reports, calculations, estimates and the like relied upon by you in arriving at any and all figures used in determining the damage to the property. 10. Any and all documents, statements, notes, measurements, test results and related materials relied upon by you in preparation of your report. WE HEREBY CERTIFY that a copy of the foregoing was filed with the Clerk of the Court using the Florida Courts E-Filing Portal on May 26, 2021, to be served this date on the above-named addresses via transmission of Notice of Electronic Filing generated by eservice@myflcourtaccess.com. BOYD RICHARDS PARKER & COLONNELLI, P.L. Attorneys for Defendant 1600 W. Commercial Boulevard, Suite 201 Fort Lauderdale, FL 33309 (954) 848-2460 (954) 848-2470 FAX Service of pleadings: servicefll@boydlawgroup.com BY: /s/ William E. Peters Jr. WILLIAM E. PETERS JR. cc: (Phipps Reporting) MIAMI FORT LAUDERDALE TAMPA WEST PALM BEACH NEW YORK 100 S.E. Second Street, Suite 2600 1600 W. Commercial Boulevard, Suite 201 400 N. Ashley Drive, Suite 1150 824 U.S. Highway One, Suite 305 90 Park Avenue, Suite 2300 Miami, Florida 33131 Fort Lauderdale, Florida 33309 Tampa, Florida 33602 North Palm Beach, Florida 33408New York, New York 10016 Tel:786-425-1045 Fax: 786-425-3905 Tel: 954-848-2460 Fax: 954-848-2470 Tel: 813-223-6021 Fax: 813-223-6024 Tel: 561-624-8233 Fax: 561-624-8940 Tel: (212) 336-8100 www.boydlawgroup.com