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Filing # 142265029 E-Filed 01/19/2022 03:37:47 PM
IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT
IN AND FOR LAKE COUNTY, FLORIDA
MICHAEL HORNER, CASE NO.: 2021-CA-001494
Plaintiff,
UNIVERSAL PROPERTY AND
CASUALTY INSURANCE COMPANY,
Defendant.
AMENDED NOTICE OF TAKING VIDEO-RECORDED DEPOSITION DUCES TECUM
PLEASE TAKE NOTICE that at 10:30 a.m., on Wednesday, February
23, 2022, Via Zoom (link attached hereto as Exhibit “A”), the
undersigned will take the video-recorded deposition of Jeffery
Hill, upon oral examination before Landmark Reporting, Inc., a
Notary Public, or any other notary public or officer authorized by
law to take depositions in the State of Florida. The oral
examination will continue until testimony shall be completed. The
deponent shall have with him at said time and place the documents
listed in Schedule “A” attached hereto.
This deposition is being taken for the purpose of discovery,
for use at trial, or for such other purpose as authorized by law
and the Florida Rules of Civil Procedure.
This deposition will be recorded via zoom in addition to other
methods of recording.
Amended Notice of Taking Video-Recorded Deposition Duces Tecum
Horner V. Universal Property and Casualty Ins. Co.
Page 1 of 5
FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 01/20/2022 09:53:19 AMPLEASE BE GOVERNED ACCORDINGLY.
th
Dated this the | day of January 2022.
LAW OFFICE OF ZACHARY J.
McCO! , PLLC
Cc
f
i Zachaxy J. McCormick
Florida Bar No. 086137
O Andrew Buchmann
Florida Bar No. 1024988
P.O. Box 1116
210 N. Texas Ave.,
Tavares, FL 32778
Zach@attorneycfl.com
Info@attorneycfl.com
(352) 742-7474
NOTICE TO PERSONS WITH DISABILITIES: If you are a person with a
disability who needs any accommodation in order to participate in
this proceeding, ‘you are entitled, at no cost to you, to the
provision of certain assistance. Please contact the attorney who
is named below at 210 N. Texas Avenue, Tavares, FL 32778 (352-742-
7474), within two (2) working days of your receipt of this.
Amended Notice of Taking Video-Recorded Deposition Duces Tecum
Horner V. Universal Property and Casualty Ins. Co.
Page 2 of 5CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and accurate copy of the
foregoing “Amended Notice of Taking Video-Recorded Deposition
Duces Tecum” has been furnished to Counsel for Defendant, Jason R.
Urbanowicz, Esq. at 491 Montgomery Place, Suite 2001, Altamonte
Springs, FL 32714, 3jul1010@universalproperty.com,
upciceservice05@universalproperty.com and
1b1101@universalproperty.com and that service thereon has been
affected by one or more of the following: hand delivery/electronic
transmission/US Postal Service on this the day of January
2022.
ZAC! J. MCCORMICK,
ATTORNEY AT LAW PLLC
Zachary J. McCormick
Florida Bar No. 086137
O Andrew Buchmann
Florida Bar No. 1024988
P.O. Box 1116
210 N. Texas Ave.,
Tavares, FL 32778
Zach@attorneycfl.com
Info@attorneycfl.com
(352) 742-7474
Amended Notice of Taking Video-Recorded Deposition Duces Tecum
Horner V. Universal Property and Casualty Ins. Co.
Page 3 of 5SCHEDULE “A”
DOCUMENTS REQUESTED
1. All documents related to the Defendant’s August 16, 2018
admission of liability and/or admission of coverage (as found in
Defendant’s letter to Mr. Horner dated August 16, 2018 and attached
hereto for reference). For additional reference, the relevant
portion of the sentence cited-to above (and in the below-listed
requests), reads “..your claimed damages are covered...”.
a.A complete copy of the Defendant’s agent, Jeffrey
Hill’s, inspection report that he conducted on July 26,
2018, of the Property.
b. Any and all documents referencing the inspection of the
Property conducted by Jeffrey Hill on July 26, 2018.
c. Any and all correspondence between the Defendant and its
agent Jeffrey Hill, referencing the Property.
d.A complete list of all licenses and certifications of
the Defendant’s agent, Jeffrey Hill. Although not an
exclusive list for production, special focus should be
placed on those credentials which qualify him to perform
inspections of real property damaged by weather.
Amended Notice of Taking Video-Recorded Deposition Duces Tecum
Horner V. Universal Property and Casualty Ins. Co.
Page 4 of 5Exhibit “A”
Topic: Plaintiff's Deposition of Jeffrey Hill in RE: Horner v. Universal Property Insurance -2021-CA-
1494
Time: Feb 23, 2022 10:30 AM Eastern Time (US and Canada)
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Amended Notice of Taking Video-Recorded Deposition Duces Tecum
Horner V. Universal Property and Casualty Ins. Co.
Page 5 of 5
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Filing # 142265029 E-Filed 01/19/2022 03:37:47 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR LAKE COUNTY, FLORIDA MICHAEL HORNER, CASE NO.: 2021-CA-001494 Plaintiff, UNIVERSAL PROPERTY AND CASUALTY INSURANCE COMPANY, Defendant. AMENDED NOTICE OF TAKING VIDEO-RECORDED DEPOSITION DUCES TECUM PLEASE TAKE NOTICE that at 10:30 a.m., on Wednesday, February 23, 2022, Via Zoom (link attached hereto as Exhibit “A”), the undersigned will take the video-recorded deposition of Jeffery Hill, upon oral examination before Landmark Reporting, Inc., a Notary Public, or any other notary public or officer authorized by law to take depositions in the State of Florida. The oral examination will continue until testimony shall be completed. The deponent shall have with him at said time and place the documents listed in Schedule “A” attached hereto. This deposition is being taken for the purpose of discovery, for use at trial, or for such other purpose as authorized by law and the Florida Rules of Civil Procedure. This deposition will be recorded via zoom in addition to other methods of recording. Amended Notice of Taking Video-Recorded Deposition Duces Tecum Horner V. Universal Property and Casualty Ins. Co. Page 1 of 5 FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 01/20/2022 09:53:19 AMPLEASE BE GOVERNED ACCORDINGLY. th Dated this the | day of January 2022. LAW OFFICE OF ZACHARY J. McCO! , PLLC Cc f i Zachaxy J. McCormick Florida Bar No. 086137 O Andrew Buchmann Florida Bar No. 1024988 P.O. Box 1116 210 N. Texas Ave., Tavares, FL 32778 Zach@attorneycfl.com Info@attorneycfl.com (352) 742-7474 NOTICE TO PERSONS WITH DISABILITIES: If you are a person with a disability who needs any accommodation in order to participate in this proceeding, ‘you are entitled, at no cost to you, to the provision of certain assistance. Please contact the attorney who is named below at 210 N. Texas Avenue, Tavares, FL 32778 (352-742- 7474), within two (2) working days of your receipt of this. Amended Notice of Taking Video-Recorded Deposition Duces Tecum Horner V. Universal Property and Casualty Ins. Co. Page 2 of 5CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and accurate copy of the foregoing “Amended Notice of Taking Video-Recorded Deposition Duces Tecum” has been furnished to Counsel for Defendant, Jason R. Urbanowicz, Esq. at 491 Montgomery Place, Suite 2001, Altamonte Springs, FL 32714, 3jul1010@universalproperty.com, upciceservice05@universalproperty.com and 1b1101@universalproperty.com and that service thereon has been affected by one or more of the following: hand delivery/electronic transmission/US Postal Service on this the day of January 2022. ZAC! J. MCCORMICK, ATTORNEY AT LAW PLLC Zachary J. McCormick Florida Bar No. 086137 O Andrew Buchmann Florida Bar No. 1024988 P.O. Box 1116 210 N. Texas Ave., Tavares, FL 32778 Zach@attorneycfl.com Info@attorneycfl.com (352) 742-7474 Amended Notice of Taking Video-Recorded Deposition Duces Tecum Horner V. Universal Property and Casualty Ins. Co. Page 3 of 5SCHEDULE “A” DOCUMENTS REQUESTED 1. All documents related to the Defendant’s August 16, 2018 admission of liability and/or admission of coverage (as found in Defendant’s letter to Mr. Horner dated August 16, 2018 and attached hereto for reference). For additional reference, the relevant portion of the sentence cited-to above (and in the below-listed requests), reads “..your claimed damages are covered...”. a.A complete copy of the Defendant’s agent, Jeffrey Hill’s, inspection report that he conducted on July 26, 2018, of the Property. b. Any and all documents referencing the inspection of the Property conducted by Jeffrey Hill on July 26, 2018. c. Any and all correspondence between the Defendant and its agent Jeffrey Hill, referencing the Property. d.A complete list of all licenses and certifications of the Defendant’s agent, Jeffrey Hill. Although not an exclusive list for production, special focus should be placed on those credentials which qualify him to perform inspections of real property damaged by weather. Amended Notice of Taking Video-Recorded Deposition Duces Tecum Horner V. Universal Property and Casualty Ins. Co. Page 4 of 5Exhibit “A” Topic: Plaintiff's Deposition of Jeffrey Hill in RE: Horner v. Universal Property Insurance -2021-CA- 1494 Time: Feb 23, 2022 10:30 AM Eastern Time (US and Canada) Join Zoom Meeting https://us02web.zoom.us/j/85114376051?pwd=QS9BYnAxMWZTY3FZME9pZGhSL1duZz09 Meeting ID: 851 1437 6051 Passcode: 907014 One tap mobile +13126266799,,85 11437605 1#,,,,*907014# US (Chicago) +19294362866,,85114376051#,,,,*907014# US (New York) Dial by your location +1 312 626 6799 US (Chicago) +1 929 436 2866 US (New York) +1 301 715 8592 US (Washington DC) +1346 248 7799 US (Houston) +1 669 900 6833 US (San Jose) +1 253 215 8782 US (Tacoma) Meeting ID: 851 1437 6051 Passcode: 907014 Find your local number: https://usO2web.zoom.us/u/kpTQc3uSh Amended Notice of Taking Video-Recorded Deposition Duces Tecum Horner V. Universal Property and Casualty Ins. Co. Page 5 of 5