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Filing# 171517695 E-Filed 04/21/2023 11:45:12 AM 3075
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
MARCIA SAMPSON & HERMAN FEARIN,
Case No.: CACE-21-007773
Plaintiff,
VS.
CITIZENS PROPERTY INSURANCE CORPORATION,
Defendant.
AMENDED NOTICE OF TAKING DEPOSITION DUCES TECUM
PLEASE TAKE Nol'IcE that the Marcia Sampson
plaintiff(s), & Herman Fearin, by and
through undersignedcounsel and pursuant to Rule 1.310 Fla.R.Civ.P.,will take the depositionupon
oral examination of EXPERT - CHRISTINE ALFANO, at the followingtime, date,and location:
Date: May 5,2023
Time: 2:00 pm Est.
Location: EsquireDeposition Solutions
Zoom to Follow
At the time of the deposition,the witness shall have in his or her possessionthe documents
in Exhibit "A" to this Notice. The deposition(s) The
will continue from day to day until coinpleted.
deposition(s) or for such other purposes
is/are being taken for the purpose of discovery, as are
and governing law and the Florida Rules of Civil Procedure.
permittedunder the applicable
If you are a who needs any accommodation in order to participate
person with a disability in
this proceeding,you are entitled,
at no cost to you, to the provision of certain assistance. Please
contact the ADA Coordinator, Room 470, 201 S.E. Sixth Street, Fort Lauderdale, Florida 33301,
954-831-7721 at least 7 days before your scheduled court appearance, or immediatelyupon receiving
LITIGATION & RECOVERY LAW CENTER, PL
16375 NE 18tliAvenue Suite 321 North Miami Beach, Florida 33162 305-760-2314 305-760-2498 (fax)
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/21/2023 11:45:11 AM.****
3075
this notification if the time before the scheduled appearance is less than 7 days;if you are hearingor
voice impaired,call 711.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY, that a true and correct copy of the foregoingwas providedby e-mail to:
John Hoffman, Esq. of LAW OFFICES OF HOFFMAN & HOFFMAN, P.A..
com; sandra@hoffmanpa.com;john@hoffmanpa.com) this April21, 2023.
LITIGATION & RECOVERY LAW CENTER, PL
16375 NE
18th Avenue, Suite 321
North Miami Beach, Florida 33162
Phone: (305)760-2314
Fax (305)760-2498
Direct email: alex(*LRLC.legal
Pleadingemail: service@losslitigators.com
By: /s/ Alex Stern
Alex Stern, Esquire
Fla. Bar No: 19592
Page 2 of 3
LITIGATION & RECOVERY LAW CENTER, PL
16375 NE 18tliAvenue Suite 321 North Miami Beach, Florida 33162 305-760-2314 305-760-2498 (fax)
3075
EXHIBIT "A"
ITEMS TO BE PRODUCED AT DEPOSITION
1. Your to
your inspectionat the property located at
entire file relating
3801 West Daffodil Lane, Miratnar, Florida 33025.
2.
Copies of correspondencefrom any source regardingthe damages arising
all out of this cause
of action, directed to the Defendant insurance company, its employees and/or agents, and any
documentation attached to said correspondencepertaining to the Plaintiff's claims.
3.
Copies of any and all documentation which you believe supports Defendant failure to pay the
benefits dueand owing to the Plaintiff(s).
4. Any and all surveillance reports, claimshistoryreports, or other investigation
reports prepared
by you, or on your behalf,with regardsto the Plaintiff(s)
property located at
3801 West Daffodil Lane, Miratnar, Florida 33025.
5. Any and all surveillance films,photographs,or audio
tapes taken by you or any one on your
behalf regardingthe Plaintiffs and/or
3801 West Daffodil Lane, Miratnar, Florida 33025.
6.
Any and statements taken by the Defendant of any witnesses with regards to any fact
all
relevant to any issue in this case, relating
to the Plaintiffs,
and/or
3801 West Daffodil Lane, Miratnar, Florida 33025.
7.
Any and all photographs in to
your possessionrelating this loss.
8.
Any and estimates of repairor statements concerning the nature and extent of
all damage to
property in this case preparedby you or on your behalf.
the subject
9.
Any and all writings,
your work on
memorandums, notes and/or other materials reflecting the
property located at 3801 West Daffodil Lane, Miratnar, Florida 33025.
Page 3 of 3
LITIGATION & RECOVERY LAW CENTER, PL
16375 NE 18tliAvenue Suite 321 North Miami Beach, Florida 33162 305-760-2314 305-760-2498 (fax)
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Filing# 171517695 E-Filed 04/21/2023 11:45:12 AM 3075 IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA MARCIA SAMPSON & HERMAN FEARIN, Case No.: CACE-21-007773 Plaintiff, VS. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. AMENDED NOTICE OF TAKING DEPOSITION DUCES TECUM PLEASE TAKE Nol'IcE that the Marcia Sampson plaintiff(s), & Herman Fearin, by and through undersignedcounsel and pursuant to Rule 1.310 Fla.R.Civ.P.,will take the depositionupon oral examination of EXPERT - CHRISTINE ALFANO, at the followingtime, date,and location: Date: May 5,2023 Time: 2:00 pm Est. Location: EsquireDeposition Solutions Zoom to Follow At the time of the deposition,the witness shall have in his or her possessionthe documents in Exhibit "A" to this Notice. The deposition(s) The will continue from day to day until coinpleted. deposition(s) or for such other purposes is/are being taken for the purpose of discovery, as are and governing law and the Florida Rules of Civil Procedure. permittedunder the applicable If you are a who needs any accommodation in order to participate person with a disability in this proceeding,you are entitled, at no cost to you, to the provision of certain assistance. Please contact the ADA Coordinator, Room 470, 201 S.E. Sixth Street, Fort Lauderdale, Florida 33301, 954-831-7721 at least 7 days before your scheduled court appearance, or immediatelyupon receiving LITIGATION & RECOVERY LAW CENTER, PL 16375 NE 18tliAvenue Suite 321 North Miami Beach, Florida 33162 305-760-2314 305-760-2498 (fax) *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/21/2023 11:45:11 AM.**** 3075 this notification if the time before the scheduled appearance is less than 7 days;if you are hearingor voice impaired,call 711. CERTIFICATE OF SERVICE I HEREBY CERTIFY, that a true and correct copy of the foregoingwas providedby e-mail to: John Hoffman, Esq. of LAW OFFICES OF HOFFMAN & HOFFMAN, P.A.. com; sandra@hoffmanpa.com;john@hoffmanpa.com) this April21, 2023. LITIGATION & RECOVERY LAW CENTER, PL 16375 NE 18th Avenue, Suite 321 North Miami Beach, Florida 33162 Phone: (305)760-2314 Fax (305)760-2498 Direct email: alex(*LRLC.legal Pleadingemail: service@losslitigators.com By: /s/ Alex Stern Alex Stern, Esquire Fla. Bar No: 19592 Page 2 of 3 LITIGATION & RECOVERY LAW CENTER, PL 16375 NE 18tliAvenue Suite 321 North Miami Beach, Florida 33162 305-760-2314 305-760-2498 (fax) 3075 EXHIBIT "A" ITEMS TO BE PRODUCED AT DEPOSITION 1. Your to your inspectionat the property located at entire file relating 3801 West Daffodil Lane, Miratnar, Florida 33025. 2. Copies of correspondencefrom any source regardingthe damages arising all out of this cause of action, directed to the Defendant insurance company, its employees and/or agents, and any documentation attached to said correspondencepertaining to the Plaintiff's claims. 3. Copies of any and all documentation which you believe supports Defendant failure to pay the benefits dueand owing to the Plaintiff(s). 4. Any and all surveillance reports, claimshistoryreports, or other investigation reports prepared by you, or on your behalf,with regardsto the Plaintiff(s) property located at 3801 West Daffodil Lane, Miratnar, Florida 33025. 5. Any and all surveillance films,photographs,or audio tapes taken by you or any one on your behalf regardingthe Plaintiffs and/or 3801 West Daffodil Lane, Miratnar, Florida 33025. 6. Any and statements taken by the Defendant of any witnesses with regards to any fact all relevant to any issue in this case, relating to the Plaintiffs, and/or 3801 West Daffodil Lane, Miratnar, Florida 33025. 7. Any and all photographs in to your possessionrelating this loss. 8. Any and estimates of repairor statements concerning the nature and extent of all damage to property in this case preparedby you or on your behalf. the subject 9. Any and all writings, your work on memorandums, notes and/or other materials reflecting the property located at 3801 West Daffodil Lane, Miratnar, Florida 33025. Page 3 of 3 LITIGATION & RECOVERY LAW CENTER, PL 16375 NE 18tliAvenue Suite 321 North Miami Beach, Florida 33162 305-760-2314 305-760-2498 (fax)