Motion to Compel Discovery -

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                          Filing # 103667751 E-Filed 02/20/2020 08:44:43 PM

IN THE CIRCUIT COURT OF THE
TWENTIETH JUDICIAL CIRCUIT,

IN AND FOR COLLIER COUNTY,

FLORIDA

CASE NUMBER: 11-2019-CA-002013-0001-XX
Patricia and Frank Matteo,

Plaintiff,
vs.

United Property & Casualty Insurance Company

Defendant.
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PLAINTIFF’S MOTION TO COMPEL DEPOSITION

COMES NOW the Plaintiffs, PATRICIA AND FRANK MATTEO, by and through the
undersigned counsel, and pursuant to Florida Rules of Civil Procedure 1.280 and 1.380, hereby
files this Motion to Compel Deposition against, UNITED PROPERTY & CASUALTY
INSURANCE COMPANY, and for grounds therefore states:

1. Plaintiff initiated this action for breach of contract against Defendant on or about
May 29, 2019.

2. On June 20, 2019, Plaintiff sent a letter to Defendant requesting deposition dates
for Defendant’s field adjuster and Defendant’s corporate representative in this case (Attached
hereto as Exhibit “A”).

3. After receiving no response, Plaintiff sent another letter on J…