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Filing# 174485370 E-Filed 06/02/2023 12:44:20 PM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE-2021-007238
IRMA QURESHI, and
GEORGE GUERRERO,
Plaintiffs,
V
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
i
DEFENDANT'S NOTICE OF FILING CIVIL SUPERSEDEAS BOND
Defendant, Universal Property & Casualty Insurance Company ("Universal"),
pursuant to
Florida Rule of Appellate Procedure 9.310(b)(1),gives notice of filingthe attached civil
supersedeasbond which triggersan automatic stay of execution on the final judgment pending
review by the Fourth District Court of Appeal.
CERTIFICATE OF SERVICE
WE CERTIFY that a true and correct copy o f the foregoingdocument has been served on
all counsel of record via automatic email from the Florida Courts e-FilingPortal on June 2,2023,
in compliance with Florida Rule of Judicial Administration 2.516(b)(1).
Ryan Gala, Esq.
Florida Bar No. 85001
Patrick Walkington, Esq.
Florida Bar No. 1011470
Trial Counsel for Defendant
Universal Property & CasualtyIns. Co.
P.O. Box 9388
Ft. Lauderdale, Florida 33310
Telephone: 1-833-658-8594
Facsimile: 954-958-1262
For Service of Court Documents only
Primary:upciceservice02@universalproperty.com
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/02/2023 12:44:19 PM.****
Secondary: rg0714@universalproperty.com>
Tertiary:
pw0517@universalproperty.com
-and-
LINK & ROCKENBACH, PA
AppellateCounsel for Defendant
1555 Palm Beach Lakes Blvd., Suite 930
West Palm Beach, FL 33401
Telephone: 561-847-4408
Facsimile: 561-855-2891
Emails. david@linkrocklaw.com
com
kara@linkrocklaw.
lynn@linkrocklaw.com
BY: /sl David A. Noel
DAVID A. NOEL, ESQ.
Florida Bar No.: 0688231
2
Bond No: 21BSBJB2602
INTHE 17th Judicial Circuit COURT OF THE STATE OF Florida
IN AND FOR Broward COUNTY
Irma Qureshi and George Guerrero
SUPERSEDEAS AND COST
BOND ON APPEAL
Plaintiff
)
CASE NO: CACE 2021-007238 ( 08)
V.
Universal Property & Casualty
Insurance Company
Defendant
KNOW ALL MEN BY THESE PRESENTS, That we. Universal Property & Casualty Insurance Company
the DEFENDANT above named as Principal(s),and Hartford Fire Insurance Company , a
corporation, organized under the laws of the State of Connecticut and authorized to transact business of
surety in the State of Florida as Surety, are held and firmly bound unto
,
Irma Qureshi and George Guerrero
the PLAINTIFF above named in the just and full sum of Seventy-Three Thousand Four Hundred Seventy-Nine
DOLLARS ($73,479.00 ),for which sum, well and truly to be paid, we bind ourselves, our and each ofour heirs,
executors, administrators, successors and assigns, jointly and severally, firmly by these presents.
SIGNED with our seals, and dated this 1st day of June 2023
THE CONDITION OF THIS OBLIGATION IS SUCH, that WHEREAS, the above named PLAINTIFF on
the26th day of May , 2023 in the above entitled action and Court, recovered judgment against the
,
DEFENDANT above named for the sum of Fi fty Seven Thousand Eight Hundred Thirty Six and DOLLARS
83/100
($57,836.83
AND WHEREAS, The above named Principal(s)has heretofore given due and proper notice that they appeal from said decision
17th Judicial Court ofthe State of Florida
andjudgment of said Circuit Court to the
NOW, THEREFORE, ifthe said Principal Universal Property & Casualty Insurance Company
shall pay to Irma Oureshi and George Guerrero
the PLAINTIFF ,
above named, all costs and damages that may be awarded against
Universal Property & Casualty Insurance Company on the appeal, or on the dismissal thereof, and shall satisfyand
perform the judgment or order appealed from, in case it shall be affirmed, and any judgment or order which the said Court of Appeals
may render or make, or order to be rendered or made by said Superior Court Florida not exceeding, however
the penalty of this bond. then this obligation to be void; otherwise to remain in full force and effect.
L zR-
Universal Property & Casualty Insurance Company
Principal
Accepted by: Hartford Fire Insurance Company
C-).N Surety
Judge Stephen P. Farmer, Attorney-in-Fact
Dated:
Direct Inquiries/Claims
to:
POWER OF ATTORNEY THE HARTFORD
One
BOND, Dll
Hartford Plaza
Hartford, Connecticut 06155
Bond.Claims@thehartford.com
call: 888-266-3488 or fax: 860-757-5835
KNOW ALL PERSONS BY THESE PRESENTS THAT: Agency Name: BROWN & BROWN OF FLORIDA INC
Agency Code: 21-220889
X Hartford Fire Insurance
Company, a corporationduly
organizedunder the laws ofthe State of Connecticut
Hartford Casualty Insurance
Company, a corporationduly
organized under the laws of the State of Indiana
Hartford Accident and
Indemnity Company, a
corporationduly organized under the laws of the State of Connecticut
Hartford Underwriters Insurance a
Company, corporationduly organized under the laws of the State of Connecticut
Twin City Fire Insurance
Company, a
corporationduly organized under the laws of the State of indiana
Hartford Insurance Company of Illinois,a
corporationduly organizedunder the laws of the State of Illinois
Hartford Insurance Company of the Midwest, a
corporationduly organized under the laws of the State of Indiana
Hartford Insurance Company of the Southeast, a
corporationduly organized under the laws of the State of Florida
having their home office in Hartford, Connecticut (hereinaftercollectively
referred to as the
Stephen P. Farmer "Companies")do hereby make, constitute and appoint
its true and lawful to sign
Attorney-in-Fact, its name as surety(ies)
only as
delineated above by and to execute, seal and
followingbond, undertaking, contract or written instrument: acknowledge the
,
Bond No. 21BSBJB2602
Naming Universal Property & Casualty Insurance
Company as Principal,
and Irma Qureshi and George Guerrero as
Obligee,
in the amount of See Bond
Form(s) on behalf of Company in its business of
contracts and executing or guaranteeing the fidelityof persons, guaranteeing the
guaranteeing bonds and undertakings required or permitted in performance of
any actions or proceedingsallowed by law.
In Witness and as authorized by a Resolution of the Board
Whereof, of Directors of the
have caused these presents to be Companies on May 23, 2016 the Companies
signed by its Assistant Vice President and its corporate seals to be hereto
Secretary. Further, pursuant to Resolution of the Board of Directors of the affixed,
duly attested by its Assistant
and will be bound
Companies, the Companies hereby unambiguously affirm that
by any mechanicallyapplied signatures appliedto this Power of they are
Attorney.
A.iBZ
MM.MA 16-*.-M,G
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Cbhuhi
WiYGW3 CSBDULGSCAI.
L-?UUM
4/-
Shelby Wiggins, Assistant Secretary Joelle L. LaPierre, Assistant Vice President
STATE OF FLORIDA 1
7 ss. Lake Mary
COUNTY OF SEMINOLE )
On this 20th day of May, 2021 before me
personally came Joelle LaPierre, to me known, who
being by me duly sworn, did depose and say: that
,
(s)he resides in Seminole County, State of Florida; that
(s)he is the Assistant Vice President of the
executed the above instrument; that Companies, the corporations described in and which
(s)he knows the seals of the said corporations; that the seals affixed to the said
that they were so affixed by instrument are such corporate seals;
authorityof the Boards of Directors of said corporations and that
(s)he signed his/her name thereto by like
authority.
,
: ,.-
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+rm8..133
Jessica Ciccone
..PM. My Commission HH 122280
Expires June 20,2025
I, the undersigned, Assistant Vice
President of the Companies, DO HEREBY CERTIFY that the
of the Power of Attorney executed above and foregoing is a true and correct
copy by said Companies, which is still in full force effective as of June 1, 2023.
Signed and sealed in Lake Mary, Florida.
G.PZ@#?id.' *MF?f?
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Keith D. Dozois, Assistant Vice President
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Filing# 174485370 E-Filed 06/02/2023 12:44:20 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-2021-007238 IRMA QURESHI, and GEORGE GUERRERO, Plaintiffs, V UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. i DEFENDANT'S NOTICE OF FILING CIVIL SUPERSEDEAS BOND Defendant, Universal Property & Casualty Insurance Company ("Universal"), pursuant to Florida Rule of Appellate Procedure 9.310(b)(1),gives notice of filingthe attached civil supersedeasbond which triggersan automatic stay of execution on the final judgment pending review by the Fourth District Court of Appeal. CERTIFICATE OF SERVICE WE CERTIFY that a true and correct copy o f the foregoingdocument has been served on all counsel of record via automatic email from the Florida Courts e-FilingPortal on June 2,2023, in compliance with Florida Rule of Judicial Administration 2.516(b)(1). Ryan Gala, Esq. Florida Bar No. 85001 Patrick Walkington, Esq. Florida Bar No. 1011470 Trial Counsel for Defendant Universal Property & CasualtyIns. Co. P.O. Box 9388 Ft. Lauderdale, Florida 33310 Telephone: 1-833-658-8594 Facsimile: 954-958-1262 For Service of Court Documents only Primary:upciceservice02@universalproperty.com *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/02/2023 12:44:19 PM.**** Secondary: rg0714@universalproperty.com> Tertiary: pw0517@universalproperty.com -and- LINK & ROCKENBACH, PA AppellateCounsel for Defendant 1555 Palm Beach Lakes Blvd., Suite 930 West Palm Beach, FL 33401 Telephone: 561-847-4408 Facsimile: 561-855-2891 Emails. david@linkrocklaw.com com kara@linkrocklaw. lynn@linkrocklaw.com BY: /sl David A. Noel DAVID A. NOEL, ESQ. Florida Bar No.: 0688231 2 Bond No: 21BSBJB2602 INTHE 17th Judicial Circuit COURT OF THE STATE OF Florida IN AND FOR Broward COUNTY Irma Qureshi and George Guerrero SUPERSEDEAS AND COST BOND ON APPEAL Plaintiff ) CASE NO: CACE 2021-007238 ( 08) V. Universal Property & Casualty Insurance Company Defendant KNOW ALL MEN BY THESE PRESENTS, That we. Universal Property & Casualty Insurance Company the DEFENDANT above named as Principal(s),and Hartford Fire Insurance Company , a corporation, organized under the laws of the State of Connecticut and authorized to transact business of surety in the State of Florida as Surety, are held and firmly bound unto , Irma Qureshi and George Guerrero the PLAINTIFF above named in the just and full sum of Seventy-Three Thousand Four Hundred Seventy-Nine DOLLARS ($73,479.00 ),for which sum, well and truly to be paid, we bind ourselves, our and each ofour heirs, executors, administrators, successors and assigns, jointly and severally, firmly by these presents. SIGNED with our seals, and dated this 1st day of June 2023 THE CONDITION OF THIS OBLIGATION IS SUCH, that WHEREAS, the above named PLAINTIFF on the26th day of May , 2023 in the above entitled action and Court, recovered judgment against the , DEFENDANT above named for the sum of Fi fty Seven Thousand Eight Hundred Thirty Six and DOLLARS 83/100 ($57,836.83 AND WHEREAS, The above named Principal(s)has heretofore given due and proper notice that they appeal from said decision 17th Judicial Court ofthe State of Florida andjudgment of said Circuit Court to the NOW, THEREFORE, ifthe said Principal Universal Property & Casualty Insurance Company shall pay to Irma Oureshi and George Guerrero the PLAINTIFF , above named, all costs and damages that may be awarded against Universal Property & Casualty Insurance Company on the appeal, or on the dismissal thereof, and shall satisfyand perform the judgment or order appealed from, in case it shall be affirmed, and any judgment or order which the said Court of Appeals may render or make, or order to be rendered or made by said Superior Court Florida not exceeding, however the penalty of this bond. then this obligation to be void; otherwise to remain in full force and effect. L zR- Universal Property & Casualty Insurance Company Principal Accepted by: Hartford Fire Insurance Company C-).N Surety Judge Stephen P. Farmer, Attorney-in-Fact Dated: Direct Inquiries/Claims to: POWER OF ATTORNEY THE HARTFORD One BOND, Dll Hartford Plaza Hartford, Connecticut 06155 Bond.Claims@thehartford.com call: 888-266-3488 or fax: 860-757-5835 KNOW ALL PERSONS BY THESE PRESENTS THAT: Agency Name: BROWN & BROWN OF FLORIDA INC Agency Code: 21-220889 X Hartford Fire Insurance Company, a corporationduly organizedunder the laws ofthe State of Connecticut Hartford Casualty Insurance Company, a corporationduly organized under the laws of the State of Indiana Hartford Accident and Indemnity Company, a corporationduly organized under the laws of the State of Connecticut Hartford Underwriters Insurance a Company, corporationduly organized under the laws of the State of Connecticut Twin City Fire Insurance Company, a corporationduly organized under the laws of the State of indiana Hartford Insurance Company of Illinois,a corporationduly organizedunder the laws of the State of Illinois Hartford Insurance Company of the Midwest, a corporationduly organized under the laws of the State of Indiana Hartford Insurance Company of the Southeast, a corporationduly organized under the laws of the State of Florida having their home office in Hartford, Connecticut (hereinaftercollectively referred to as the Stephen P. Farmer "Companies")do hereby make, constitute and appoint its true and lawful to sign Attorney-in-Fact, its name as surety(ies) only as delineated above by and to execute, seal and followingbond, undertaking, contract or written instrument: acknowledge the , Bond No. 21BSBJB2602 Naming Universal Property & Casualty Insurance Company as Principal, and Irma Qureshi and George Guerrero as Obligee, in the amount of See Bond Form(s) on behalf of Company in its business of contracts and executing or guaranteeing the fidelityof persons, guaranteeing the guaranteeing bonds and undertakings required or permitted in performance of any actions or proceedingsallowed by law. In Witness and as authorized by a Resolution of the Board Whereof, of Directors of the have caused these presents to be Companies on May 23, 2016 the Companies signed by its Assistant Vice President and its corporate seals to be hereto Secretary. Further, pursuant to Resolution of the Board of Directors of the affixed, duly attested by its Assistant and will be bound Companies, the Companies hereby unambiguously affirm that by any mechanicallyapplied signatures appliedto this Power of they are Attorney. A.iBZ MM.MA 16-*.-M,G 'ji? iii. ?Wmr ./4/E.iZX .t#*. ' Cbhuhi WiYGW3 CSBDULGSCAI. L-?UUM 4/- Shelby Wiggins, Assistant Secretary Joelle L. LaPierre, Assistant Vice President STATE OF FLORIDA 1 7 ss. Lake Mary COUNTY OF SEMINOLE ) On this 20th day of May, 2021 before me personally came Joelle LaPierre, to me known, who being by me duly sworn, did depose and say: that , (s)he resides in Seminole County, State of Florida; that (s)he is the Assistant Vice President of the executed the above instrument; that Companies, the corporations described in and which (s)he knows the seals of the said corporations; that the seals affixed to the said that they were so affixed by instrument are such corporate seals; authorityof the Boards of Directors of said corporations and that (s)he signed his/her name thereto by like authority. , : ,.- .i. A.2-= +rm8..133 Jessica Ciccone ..PM. My Commission HH 122280 Expires June 20,2025 I, the undersigned, Assistant Vice President of the Companies, DO HEREBY CERTIFY that the of the Power of Attorney executed above and foregoing is a true and correct copy by said Companies, which is still in full force effective as of June 1, 2023. Signed and sealed in Lake Mary, Florida. G.PZ@#?id.' *MF?f? { K...-.......#LS.1 9??:1)) El M??Ti?? ?Ii??*7*?-&5) ludG :.)8 iii?D.JN*C * ...LM 4'Ei>f' MM L.+TWTO . .1/ /7.i E f Keith D. Dozois, Assistant Vice President