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Filing# 181246151 E-Filed 09/06/2023 04:30:21 PM
INTHE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NUMBER: CACE 21-016141
AUBREY BURGHER,
Plaintiff,
V
CITIZENS PROPERTY INSURANCE
CORPORATION, a Florida governmental
entity,
Defendant.
DEFENDANT'S NOTICE OF TAKING DEPOSITION DUCES TECUM
NOTICE is hereby given that at the we will take the
time and place herein specified,
depositionduces tecum of the Corporate Representative(s) from Brickhouse Inspections, Inc.
pursuant to Fla. R. Civ. P. 1.310(b)(6)as follows:
Name: The designated Corporate Representative(s) from Brickhouse
Inspections, Inc. with respect to the subject matters set forth in
Schedule "A" and about the documents listed in Schedule "B", which
are both attached to this notice following the Certificate of Service.
I)ate: September 14, 2023
Time: 10:00am
Place: US Legal via ZOOM virtual video conference
upon oral examination, before US Legal, Notary Public, or any other notary public or officer
authorized by law to take depositionsin the State of Florida. The oral examination will continue
from day to day until completed.This depositionis being taken for the purpose of discovery,for
or for such other purposes as are permittedunder the rules of the Court.
use at trial,
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/06/2023 04:30:21 PM.****
Audrey Burgher et al. v. Citizens
Court Case No: CACE-21-016141
Page 20f4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoingNotice of Taking
Deposition Duces Tecum of the Corporate Representative(s)
from Brickhouse Inspections,
Inc.
Pursuant to Fla. R. Civ. P. 1.310(B)(6)was served on September 6,2023 to counsel of record,
Manny M. Tarich, Esq., The Tarich Law Firm, PA, 1946 Tyler Street,Hollywood, Florida 33020
via the Florida Electronic Filing Portal, as well as via Personal Service to the Corporate
Representativefor Brickhouse Inspections,
Inc. at 18131 NE ,th
10? Avenue, North Miami Beach,
Florida 33162.
VERNIS & BOWLING OF BROWARD, P.A.
Attorneysfor Defendant, Citizens Property
Insurance Corporation
5821 Hollywood Boulevard
Hollywood, Florida 33021
Phone: (954) 927-5330
Fax: (954) 927-5320
Primary: PFouts@florida-law.com
Secondary:AYost@florida-law.com
By-. /sl Paulette R. Fonts, Esq.
Paulette R. Fouts, Esquire
Florida Bar No: 0078697
Audrey Burgher et al. v. Citizens
Court Case No: CACE-21-016141
Page 30f4
SCHEDULE "A" - SUBJECT MATTERS TO BE QUESTIONED UPON
All subject matters of inquiry below pertain to the Plaintiff's Hurricane Irma
claim, including its supplements and/or subsequent claims, filed with Citizens Property
Insurance Company and associated with policy number 02820640 and claim number 001-
00-266423.
1. All matters set forth in Plaintiff's Complaint.
2. All matters set forth in Plaintiff's discovery responses that pertain to Brickhouse
Inc.
Inspections,
3. All communications between Brickhouse Inspections,
Inc., its agents, employees, and/or
and Citizens Property Insurance Company,
representatives its agents, employees, and/or
representatives.
4. The historyof this claim's handling between Citizens Property Insurance Company, and
Brickhouse Inspections,
Inc.
5. The historyof this claim's handling between the Defendant and Brickhouse Inspections,
Inc.
6. All areas or elements of the subjectproperty that have been repairedor replacedas a
result of damage allegedto have been caused by the subjectloss.
7. All areas or elements of the subjectproperty which remain unrepaired from damage
allegedto have been caused by the subjectloss.
8. All actual repairor replacement expenses incurred relatingto damage allegedto have
been caused by the subjectloss.
9- The names and current contact information of all experts, professionals,
contractors,
and/or other tradesmen that have any knowledge of any of the damages being claimed in
this action.
10. Any and all repairs,replacements,renovations, remediation work, etc. performed by
Inc. or any of its agents, employees and/or representatives
Brickhouse Inspections, at the
subjectproperty in relation to the subjectloss.
Audrey Burgher et al. v. Citizens
Court Case No: CACE-21-016141
Page 40f4
SCHEDULE"B" - DOCUMENTS TO BE PRODUCED
1. Any and all
plats,maps, blueprints, property sketches, etc. with regard to Brickhouse
Inc. and/or the property located at 2140 SW 87?h Way, Hollywood, FL
Inspections,
33025;
2. Any and all contractsbetween the Insured,Aubrey Burgher and the Plaintiff,Brickhouse
Inc.
Inspections, with respect to the property located at 2140 SW 87?h Way, Hollywood,
FL 33025;
3. Any and all by Brickhouse Inspections,Inc. and/or its
contracts held and/or entered into
with respect to the property located at 2140 SW
agents, employees and/or representatives
87th Way, Hollywood, FL 33025;
4. Any and all correspondence with regard Brickhouse Inspections,
Inc. and/or the property
located at 2140 SW 871 ith
Way, Hollywood, FL 33025;
5. Any and all digitalcopies of photographs or videos with regard to Brickhouse
Inspections,Inc. and/or the property located at 2140 SW 87?h Way, Hollywood, FL
33025;
6. Any and all with regard to Brickhouse Inspections,
permit applications Inc. and/or the
property located at 2140 SW 87th Way, Hollywood, FL 33025;
7. Any and all permit inspectionreports, etc. with regard to
permits,permit applications,
and/or the property located at 2140 SW 87 Way,
ith
Brickhouse Inspections,Inc.
Hollywood, FL 33025;
8. Any and all estimates, invoices, proposals, receipts etc. with regard to Brickhouse
Inspections,Inc. and/or the property located at 2140 SW 87?h Way, Hollywood, FL
33025;
9. Any and all inspectionreports with regard Brickhouse Inspections,Inc. and/or the
property located at 2140 SW 87th Way, Hollywood, FL 33025;
10. Any and all correspondence with regard to Brickhouse Inspections,Inc. and/or the
property located at 2140 SW 87th Way, Hollywood, FL 33025;
11. Any and photographs, thermal imagery, videos, etc., with metadata intact and in color,
all
with regard to Brickhouse Inspections,Inc. and/or the property located at 2140
7th
87 SW
Way, Hollywood, FL 33025;
12. Any and dry logs,timesheets, air testingreports, moisture readings and/or reports,
all
mold testingreports, certificates of completion and/or satisfaction,
etc. with regard to
Brickhouse Inspections,Inc. and/or the property located at 2140 SW 87M Way,
Hollywood, FL 33025;
Preview
Filing# 181246151 E-Filed 09/06/2023 04:30:21 PM INTHE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NUMBER: CACE 21-016141 AUBREY BURGHER, Plaintiff, V CITIZENS PROPERTY INSURANCE CORPORATION, a Florida governmental entity, Defendant. DEFENDANT'S NOTICE OF TAKING DEPOSITION DUCES TECUM NOTICE is hereby given that at the we will take the time and place herein specified, depositionduces tecum of the Corporate Representative(s) from Brickhouse Inspections, Inc. pursuant to Fla. R. Civ. P. 1.310(b)(6)as follows: Name: The designated Corporate Representative(s) from Brickhouse Inspections, Inc. with respect to the subject matters set forth in Schedule "A" and about the documents listed in Schedule "B", which are both attached to this notice following the Certificate of Service. I)ate: September 14, 2023 Time: 10:00am Place: US Legal via ZOOM virtual video conference upon oral examination, before US Legal, Notary Public, or any other notary public or officer authorized by law to take depositionsin the State of Florida. The oral examination will continue from day to day until completed.This depositionis being taken for the purpose of discovery,for or for such other purposes as are permittedunder the rules of the Court. use at trial, *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/06/2023 04:30:21 PM.**** Audrey Burgher et al. v. Citizens Court Case No: CACE-21-016141 Page 20f4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoingNotice of Taking Deposition Duces Tecum of the Corporate Representative(s) from Brickhouse Inspections, Inc. Pursuant to Fla. R. Civ. P. 1.310(B)(6)was served on September 6,2023 to counsel of record, Manny M. Tarich, Esq., The Tarich Law Firm, PA, 1946 Tyler Street,Hollywood, Florida 33020 via the Florida Electronic Filing Portal, as well as via Personal Service to the Corporate Representativefor Brickhouse Inspections, Inc. at 18131 NE ,th 10? Avenue, North Miami Beach, Florida 33162. VERNIS & BOWLING OF BROWARD, P.A. Attorneysfor Defendant, Citizens Property Insurance Corporation 5821 Hollywood Boulevard Hollywood, Florida 33021 Phone: (954) 927-5330 Fax: (954) 927-5320 Primary: PFouts@florida-law.com Secondary:AYost@florida-law.com By-. /sl Paulette R. Fonts, Esq. Paulette R. Fouts, Esquire Florida Bar No: 0078697 Audrey Burgher et al. v. Citizens Court Case No: CACE-21-016141 Page 30f4 SCHEDULE "A" - SUBJECT MATTERS TO BE QUESTIONED UPON All subject matters of inquiry below pertain to the Plaintiff's Hurricane Irma claim, including its supplements and/or subsequent claims, filed with Citizens Property Insurance Company and associated with policy number 02820640 and claim number 001- 00-266423. 1. All matters set forth in Plaintiff's Complaint. 2. All matters set forth in Plaintiff's discovery responses that pertain to Brickhouse Inc. Inspections, 3. All communications between Brickhouse Inspections, Inc., its agents, employees, and/or and Citizens Property Insurance Company, representatives its agents, employees, and/or representatives. 4. The historyof this claim's handling between Citizens Property Insurance Company, and Brickhouse Inspections, Inc. 5. The historyof this claim's handling between the Defendant and Brickhouse Inspections, Inc. 6. All areas or elements of the subjectproperty that have been repairedor replacedas a result of damage allegedto have been caused by the subjectloss. 7. All areas or elements of the subjectproperty which remain unrepaired from damage allegedto have been caused by the subjectloss. 8. All actual repairor replacement expenses incurred relatingto damage allegedto have been caused by the subjectloss. 9- The names and current contact information of all experts, professionals, contractors, and/or other tradesmen that have any knowledge of any of the damages being claimed in this action. 10. Any and all repairs,replacements,renovations, remediation work, etc. performed by Inc. or any of its agents, employees and/or representatives Brickhouse Inspections, at the subjectproperty in relation to the subjectloss. Audrey Burgher et al. v. Citizens Court Case No: CACE-21-016141 Page 40f4 SCHEDULE"B" - DOCUMENTS TO BE PRODUCED 1. Any and all plats,maps, blueprints, property sketches, etc. with regard to Brickhouse Inc. and/or the property located at 2140 SW 87?h Way, Hollywood, FL Inspections, 33025; 2. Any and all contractsbetween the Insured,Aubrey Burgher and the Plaintiff,Brickhouse Inc. Inspections, with respect to the property located at 2140 SW 87?h Way, Hollywood, FL 33025; 3. Any and all by Brickhouse Inspections,Inc. and/or its contracts held and/or entered into with respect to the property located at 2140 SW agents, employees and/or representatives 87th Way, Hollywood, FL 33025; 4. Any and all correspondence with regard Brickhouse Inspections, Inc. and/or the property located at 2140 SW 871 ith Way, Hollywood, FL 33025; 5. Any and all digitalcopies of photographs or videos with regard to Brickhouse Inspections,Inc. and/or the property located at 2140 SW 87?h Way, Hollywood, FL 33025; 6. Any and all with regard to Brickhouse Inspections, permit applications Inc. and/or the property located at 2140 SW 87th Way, Hollywood, FL 33025; 7. Any and all permit inspectionreports, etc. with regard to permits,permit applications, and/or the property located at 2140 SW 87 Way, ith Brickhouse Inspections,Inc. Hollywood, FL 33025; 8. Any and all estimates, invoices, proposals, receipts etc. with regard to Brickhouse Inspections,Inc. and/or the property located at 2140 SW 87?h Way, Hollywood, FL 33025; 9. Any and all inspectionreports with regard Brickhouse Inspections,Inc. and/or the property located at 2140 SW 87th Way, Hollywood, FL 33025; 10. Any and all correspondence with regard to Brickhouse Inspections,Inc. and/or the property located at 2140 SW 87th Way, Hollywood, FL 33025; 11. Any and photographs, thermal imagery, videos, etc., with metadata intact and in color, all with regard to Brickhouse Inspections,Inc. and/or the property located at 2140 7th 87 SW Way, Hollywood, FL 33025; 12. Any and dry logs,timesheets, air testingreports, moisture readings and/or reports, all mold testingreports, certificates of completion and/or satisfaction, etc. with regard to Brickhouse Inspections,Inc. and/or the property located at 2140 SW 87M Way, Hollywood, FL 33025;