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Filing # 142881906 E-Filed 01/28/2022 03:10:24 PM
IN THE CIRCUIT COURT OF THE 11TH
JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
LOUISA DENIS CASE NO.: 2021-013651-CA-01
Plaintiff,
vs.
UNIVERSAL PROPERTY AND CASUALTY
INSURANCE COMPANY,
Defendant.
_____________________________________/
AMENDED NOTICE OF TAKING DEPOSITION DUCES TECUM
(Coordinated with Plaintiff’s Counsel)
PLEASE TAKE NOTICE that the undersigned attorney will take the deposition of:
NAME DATE TIME
Louisa Denis Thursday, February 03, 2022 10:00 AM
LOCATION: Esquire Deposition Solutions- Via Zoom (Zoom Link to be provided at a
later date).
Upon oral examination before a representative of Esquire Deposition Solutions, or any
other officer authorized by law to take deposition in the State of Florida. 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 both of the
foregoing, or for such other purposes as are permitted under the Florida Rules of Civil Procedure
and other applicable law. And, pursuant to Fla. R. Civ. P. 1.350, said Defendant requests the
deponent have the following items listed in Attachment “A” at the time and place of the foregoing
deposition, for purposes of inspection and/or copying by this Defendant.
LOUISA DENIS vs. UPCIC
CASE NO.: CACE-21-012241
Notice of Taking Deposition Duces Tecum
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via E-
service to: Moshe Rubinstein, Esq., Moshe Rubinstein Law Firm, P.A.
(moshe@moshelaw.com) counsel for Plaintiff, on this 28th day of January, 2021.
Attorney for Defendant
Universal Property & Casualty Ins. Co.
PO Box 9388
Fort Lauderdale, Florida 33310
Telephone: 954-958-3319
Toll-Free: 1-833-658-8594 (Judges Only)
Facsimile: 954-958-1262
By: /s/ Ryan Kelley
Ryan Kelley, Esq.
Fla. Bar No. 848751
For Service of Court Documents only:
Primary: upciceservice06@universalproperty.com
Secondary: mc0629@universalproperty.com
Tertiary: rk1207@universalproperty.com
For Scheduling Matters:
mc0629@universalproperty.com
*Please do not send any inquiries or scheduling matters to
upciceservice@universalproperty.com or upciceservice06@universalproperty.com.
LOUISA DENIS vs. UPCIC
CASE NO.: CACE-21-012241
Notice of Taking Deposition Duces Tecum
ATTACHMENT “A”
1. Copies of any and all correspondence between the Plaintiff and Defendant with
regard to this claim or the allegations contained within Plaintiff’s Complaint.
2. Copies of any and all correspondence between Plaintiff and any public adjuster
assisting with the claim with respect to the property located at 16071 NE 14 Avenue, North Miami
Beach, Florida 33162.
3. Copies of any and all correspondence between Plaintiff and any contractor,
repair/service company providing any services or preparing any estimate for repairs with respect
to any claimed damages in the Complaint.
4. Copies of any and all reports, drafts, charts, drawings, diagrams, and memoranda
and/or results of any testing showing or intending to show the cause of damage to Plaintiff’s
property located at 16071 NE 14 Avenue, North Miami Beach, Florida 33162 as asserted in the
Complaint.
5. Copies of any documents which support any claim for damages set forth in the
Complaint.
6. Copies of any and all repair estimates for alleged damages to Plaintiffs’ property
located at 16071 NE 14 Avenue, North Miami Beach, Florida 33162 that are claimed in the
Complaint.
7. Copies of any and all photographs or videotape taken of the property located at
16071 NE 14 Avenue, North Miami Beach, Florida 33162 prior to the alleged date of loss in the
Complaint. Please provide all photos or videos in electronic/digital format.
8. Copies of any and all photographs or videotape taken of the property located at
16071 NE 14 Avenue, North Miami Beach, Florida 33162 on or subsequent to the alleged date of
loss in the Complaint. Please provide all photos or videos in electronic/digital format.
9. Copies of any and all photographs or videotape taken of the area(s) of the interior
of the home located at 16071 NE 14 Avenue, North Miami Beach, Florida 33162 to which you are
claiming damages in this Complaint. Please provide all photos or videos in electronic/digital
format.
10. Copies of any and all invoices, cancelled checks or other evidence of payment for
repairs, remodels or renovations made to 16071 NE 14 Avenue, North Miami Beach, Florida
33162 relative to the Loss alleged in the Complaint.
11. Copies of any and all invoices, cancelled checks or other evidence of payment for
repairs, remodels or renovations made to 16071 NE 14 Avenue, North Miami Beach, Florida
33162 after the date of loss.
LOUISA DENIS vs. UPCIC
CASE NO.: CACE-21-012241
Notice of Taking Deposition Duces Tecum
12. Copies of any and all invoices, cancelled checks or other evidence of payment for
repairs, remodels or renovations made to 16071 NE 14 Avenue, North Miami Beach, Florida
33162 for the five (5) years prior to the date of loss.
13. Copies of any and all inspections, appraisals or other investigations for the property located
at 16071 NE 14 Avenue, North Miami Beach, Florida 33162 prior to the date of purchase.
14. Copies of any and all rules or regulation violations notices or correspondence issued
by any homeowners or condominium association regarding the property located at 16071 NE 14
Avenue, North Miami Beach, Florida 33162 for the three (3) year period prior to the date of loss.
15. Copies of any and all rules or regulation violations notices or correspondence issued
by any homeowners or condominium association regarding the property located at 16071 NE 14
Avenue, North Miami Beach, Florida 33162 subsequent to the date of loss.
16. Copies of any and all ordinance or code violations notices or correspondence issued
by any city/county municipality regarding the property located at 16071 NE 14 Avenue, North
Miami Beach, Florida 33162 for the three (3) year period prior to the date of loss.
17. Copies of any and all ordinance or code violations notices or correspondence issued
by any city/county municipality regarding the property located at 16071 NE 14 Avenue, North
Miami Beach, Florida 33162 subsequent to the date of loss.
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Filing # 142881906 E-Filed 01/28/2022 03:10:24 PM IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA LOUISA DENIS CASE NO.: 2021-013651-CA-01 Plaintiff, vs. UNIVERSAL PROPERTY AND CASUALTY INSURANCE COMPANY, Defendant. _____________________________________/ AMENDED NOTICE OF TAKING DEPOSITION DUCES TECUM (Coordinated with Plaintiff’s Counsel) PLEASE TAKE NOTICE that the undersigned attorney will take the deposition of: NAME DATE TIME Louisa Denis Thursday, February 03, 2022 10:00 AM LOCATION: Esquire Deposition Solutions- Via Zoom (Zoom Link to be provided at a later date). Upon oral examination before a representative of Esquire Deposition Solutions, or any other officer authorized by law to take deposition in the State of Florida. 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 both of the foregoing, or for such other purposes as are permitted under the Florida Rules of Civil Procedure and other applicable law. And, pursuant to Fla. R. Civ. P. 1.350, said Defendant requests the deponent have the following items listed in Attachment “A” at the time and place of the foregoing deposition, for purposes of inspection and/or copying by this Defendant. LOUISA DENIS vs. UPCIC CASE NO.: CACE-21-012241 Notice of Taking Deposition Duces Tecum CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via E- service to: Moshe Rubinstein, Esq., Moshe Rubinstein Law Firm, P.A. (moshe@moshelaw.com) counsel for Plaintiff, on this 28th day of January, 2021. Attorney for Defendant Universal Property & Casualty Ins. Co. PO Box 9388 Fort Lauderdale, Florida 33310 Telephone: 954-958-3319 Toll-Free: 1-833-658-8594 (Judges Only) Facsimile: 954-958-1262 By: /s/ Ryan Kelley Ryan Kelley, Esq. Fla. Bar No. 848751 For Service of Court Documents only: Primary: upciceservice06@universalproperty.com Secondary: mc0629@universalproperty.com Tertiary: rk1207@universalproperty.com For Scheduling Matters: mc0629@universalproperty.com *Please do not send any inquiries or scheduling matters to upciceservice@universalproperty.com or upciceservice06@universalproperty.com. LOUISA DENIS vs. UPCIC CASE NO.: CACE-21-012241 Notice of Taking Deposition Duces Tecum ATTACHMENT “A” 1. Copies of any and all correspondence between the Plaintiff and Defendant with regard to this claim or the allegations contained within Plaintiff’s Complaint. 2. Copies of any and all correspondence between Plaintiff and any public adjuster assisting with the claim with respect to the property located at 16071 NE 14 Avenue, North Miami Beach, Florida 33162. 3. Copies of any and all correspondence between Plaintiff and any contractor, repair/service company providing any services or preparing any estimate for repairs with respect to any claimed damages in the Complaint. 4. Copies of any and all reports, drafts, charts, drawings, diagrams, and memoranda and/or results of any testing showing or intending to show the cause of damage to Plaintiff’s property located at 16071 NE 14 Avenue, North Miami Beach, Florida 33162 as asserted in the Complaint. 5. Copies of any documents which support any claim for damages set forth in the Complaint. 6. Copies of any and all repair estimates for alleged damages to Plaintiffs’ property located at 16071 NE 14 Avenue, North Miami Beach, Florida 33162 that are claimed in the Complaint. 7. Copies of any and all photographs or videotape taken of the property located at 16071 NE 14 Avenue, North Miami Beach, Florida 33162 prior to the alleged date of loss in the Complaint. Please provide all photos or videos in electronic/digital format. 8. Copies of any and all photographs or videotape taken of the property located at 16071 NE 14 Avenue, North Miami Beach, Florida 33162 on or subsequent to the alleged date of loss in the Complaint. Please provide all photos or videos in electronic/digital format. 9. Copies of any and all photographs or videotape taken of the area(s) of the interior of the home located at 16071 NE 14 Avenue, North Miami Beach, Florida 33162 to which you are claiming damages in this Complaint. Please provide all photos or videos in electronic/digital format. 10. Copies of any and all invoices, cancelled checks or other evidence of payment for repairs, remodels or renovations made to 16071 NE 14 Avenue, North Miami Beach, Florida 33162 relative to the Loss alleged in the Complaint. 11. Copies of any and all invoices, cancelled checks or other evidence of payment for repairs, remodels or renovations made to 16071 NE 14 Avenue, North Miami Beach, Florida 33162 after the date of loss. LOUISA DENIS vs. UPCIC CASE NO.: CACE-21-012241 Notice of Taking Deposition Duces Tecum 12. Copies of any and all invoices, cancelled checks or other evidence of payment for repairs, remodels or renovations made to 16071 NE 14 Avenue, North Miami Beach, Florida 33162 for the five (5) years prior to the date of loss. 13. Copies of any and all inspections, appraisals or other investigations for the property located at 16071 NE 14 Avenue, North Miami Beach, Florida 33162 prior to the date of purchase. 14. Copies of any and all rules or regulation violations notices or correspondence issued by any homeowners or condominium association regarding the property located at 16071 NE 14 Avenue, North Miami Beach, Florida 33162 for the three (3) year period prior to the date of loss. 15. Copies of any and all rules or regulation violations notices or correspondence issued by any homeowners or condominium association regarding the property located at 16071 NE 14 Avenue, North Miami Beach, Florida 33162 subsequent to the date of loss. 16. Copies of any and all ordinance or code violations notices or correspondence issued by any city/county municipality regarding the property located at 16071 NE 14 Avenue, North Miami Beach, Florida 33162 for the three (3) year period prior to the date of loss. 17. Copies of any and all ordinance or code violations notices or correspondence issued by any city/county municipality regarding the property located at 16071 NE 14 Avenue, North Miami Beach, Florida 33162 subsequent to the date of loss.