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Filing # 149400119 E-Filed 05/11/2022 03:17:19 PM
IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT
IN AND FOR MIAMI-DADE COUNTY, FLORIDA
ORTELIO ARCIA, SARA ARCIA
AND TATIANA L. ARCIA,
Plaintiff, CASE NO.: 2021-023146-CA-01
vs.
SOUTHERN FIDELITY INSURANCE
COMPANY,
Defendant.
/
NOTICE OF TAKING DEPOSITION DUCES TECUM
PLEASE TAKE NOTICE that the undersigned attorney will take the following
depositions:
Deponent Date Time Location
Antonio Prieto, Field Adjuster who 7/1/2022 2:00 p.m. Boss Reporting
inspected the subject loss. Via zoom video conference.
Upon oral examination before a Notary Public or officer authorized by law to take depositions in
the State of Florida. The deposition will continue from hour to hour and from day to day until
completed. The deposition is being taken for the purpose of discovery, for use at trial, or both
foregoing, or for such other purposes as are permitted under the applicable and governing rules,
and to have with you at said time and place the documents contained in the Schedule “A” attached
hereto.
The witness is required to bring with him/her, at the time and place of said deposition,
the documents requested in the attached “Schedule A.”
[CERTIFICATE OF SERVICE ON FOLLOWING PAGE]
GRANDE LAW, P.A.
8603 South Dixie Highway, Suite 205, Pinecrest, FL 33156 ∙ Tel: (305) 307-8052 ∙ Fax: (305) 938-5047
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served via the
e-filing portal on this 11th day of May 2022 which will send notice to all registered parties.
GRANDE LAW, P.A.
Attorneys for Plaintiff
8603 South Dixie Highway, Suite 205
Pinecrest, Florida 33156
Telephone: (305) 307-8052
Facsimile: (305) 938-5047
eservice@grande-law.com
By: s/ Daniel Grande
DANIEL GRANDE, ESQUIRE
Florida Bar No. 55900
GRANDE LAW, P.A.
8603 South Dixie Highway, Suite 205, Pinecrest, FL 33156 ∙ Tel: (305) 307-8052 ∙ Fax: (305) 938-5047
SCHEDULE
“A”
YOU ARE TO BRING WITH YOU, AT THE TIME OF YOUR DEPOSITION, THE
FOLLOWING:
1. Your entire file/s as it pertains to the property of Ortelio Arcia, Sara Arcia and Tatiana
L. Arcia at 1960 Southwest 23rd Terrace, Miami, FL 33145 (hereinafter referred to as
the “subject property”).
2. Any and all materials you reviewed in this matter, including, but not Limited to,
correspondence, photographs, reports, books, articles, literature, films, tests,
experiments, statements, or other reference materials that you used or are relying on.
3. Any and all reports, estimates, and/or appraisals you, your agents, employees or
subcontractors, prepared regarding the subject property.
4. Any and all reports, estimates, and/or appraisals you, your agents, employees or
subcontractors, were provided regarding the subject property.
5. Any and all photographs which were taken by you, your agents, employees or
subcontractors, depicting the subject property.
6. Any and all films, videos, or audio tapes taken by you, your agents, employees or
subcontractors, depicting the subject property.
7. Any and all films, videos, or audio tapes provided to you, your agents, or employees
depicting the subject property.
8. Any and all permits pulled by you, your agents, employees, or subcontractors, for the
subject property.
9. Any and all correspondence, emails, letters, facsimiles, sent or received by you, your
agents, employees, or subcontractors, that pertain to the subject property.
10. Any and all notes, writings, memoranda, which you, your agents, employees, or
subcontractors, have prepared regarding the subject property, regardless of whether you
relied on it for the work performed on the subject property.
11. Any and all printouts from computers, laptops, tablets, phones, used by you or your
agents, employees, or subcontractors, regarding the subject property.
12. Any and all schematics, blueprints, plans, drawings in your possession for the subject
property.
13. Any and all invoices or proposals for any work you performed on the subject property.
GRANDE LAW, P.A.
8603 South Dixie Highway, Suite 205, Pinecrest, FL 33156 ∙ Tel: (305) 307-8052 ∙ Fax: (305) 938-5047
Preview
Filing # 149400119 E-Filed 05/11/2022 03:17:19 PM IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA ORTELIO ARCIA, SARA ARCIA AND TATIANA L. ARCIA, Plaintiff, CASE NO.: 2021-023146-CA-01 vs. SOUTHERN FIDELITY INSURANCE COMPANY, Defendant. / NOTICE OF TAKING DEPOSITION DUCES TECUM PLEASE TAKE NOTICE that the undersigned attorney will take the following depositions: Deponent Date Time Location Antonio Prieto, Field Adjuster who 7/1/2022 2:00 p.m. Boss Reporting inspected the subject loss. Via zoom video conference. Upon oral examination before a Notary Public or officer authorized by law to take depositions in the State of Florida. The deposition will continue from hour to hour and from day to day until completed. The deposition is being taken for the purpose of discovery, for use at trial, or both foregoing, or for such other purposes as are permitted under the applicable and governing rules, and to have with you at said time and place the documents contained in the Schedule “A” attached hereto. The witness is required to bring with him/her, at the time and place of said deposition, the documents requested in the attached “Schedule A.” [CERTIFICATE OF SERVICE ON FOLLOWING PAGE] GRANDE LAW, P.A. 8603 South Dixie Highway, Suite 205, Pinecrest, FL 33156 ∙ Tel: (305) 307-8052 ∙ Fax: (305) 938-5047 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served via the e-filing portal on this 11th day of May 2022 which will send notice to all registered parties. GRANDE LAW, P.A. Attorneys for Plaintiff 8603 South Dixie Highway, Suite 205 Pinecrest, Florida 33156 Telephone: (305) 307-8052 Facsimile: (305) 938-5047 eservice@grande-law.com By: s/ Daniel Grande DANIEL GRANDE, ESQUIRE Florida Bar No. 55900 GRANDE LAW, P.A. 8603 South Dixie Highway, Suite 205, Pinecrest, FL 33156 ∙ Tel: (305) 307-8052 ∙ Fax: (305) 938-5047 SCHEDULE “A” YOU ARE TO BRING WITH YOU, AT THE TIME OF YOUR DEPOSITION, THE FOLLOWING: 1. Your entire file/s as it pertains to the property of Ortelio Arcia, Sara Arcia and Tatiana L. Arcia at 1960 Southwest 23rd Terrace, Miami, FL 33145 (hereinafter referred to as the “subject property”). 2. Any and all materials you reviewed in this matter, including, but not Limited to, correspondence, photographs, reports, books, articles, literature, films, tests, experiments, statements, or other reference materials that you used or are relying on. 3. Any and all reports, estimates, and/or appraisals you, your agents, employees or subcontractors, prepared regarding the subject property. 4. Any and all reports, estimates, and/or appraisals you, your agents, employees or subcontractors, were provided regarding the subject property. 5. Any and all photographs which were taken by you, your agents, employees or subcontractors, depicting the subject property. 6. Any and all films, videos, or audio tapes taken by you, your agents, employees or subcontractors, depicting the subject property. 7. Any and all films, videos, or audio tapes provided to you, your agents, or employees depicting the subject property. 8. Any and all permits pulled by you, your agents, employees, or subcontractors, for the subject property. 9. Any and all correspondence, emails, letters, facsimiles, sent or received by you, your agents, employees, or subcontractors, that pertain to the subject property. 10. Any and all notes, writings, memoranda, which you, your agents, employees, or subcontractors, have prepared regarding the subject property, regardless of whether you relied on it for the work performed on the subject property. 11. Any and all printouts from computers, laptops, tablets, phones, used by you or your agents, employees, or subcontractors, regarding the subject property. 12. Any and all schematics, blueprints, plans, drawings in your possession for the subject property. 13. Any and all invoices or proposals for any work you performed on the subject property. GRANDE LAW, P.A. 8603 South Dixie Highway, Suite 205, Pinecrest, FL 33156 ∙ Tel: (305) 307-8052 ∙ Fax: (305) 938-5047