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Filing # 147418859 E-Filed 04/11/2022 11:03:31 AM
IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT
IN AND FOR BREVARD COUNTY, FLORIDA
ANTHONY DAVIS, JR.,
Case No.: 2020-CA-024628
Plaintiff,
vs.
SECURITY FIRST INSURANCE
COMPANY,
Defendant.
/
SUBPOENA DUCES TECUM FOR DEPOSITION
THE STATE OF FLORIDA:
TO: Dennis James
Triad Restoration Services
2801 Alt 19
Dunedin, FL 34698
YOU ARE COMMANDED TO APPEAR before a person authorized by law to take depositions on May
18, 2022 at 9:00 A.M. via Remote Videoconference Appearance (e.g. Zoom)' appearance, for the taking of your
deposition in this action provide to Defense Counsel the items listed in the attached Exhibit “A” on or before May
11, 2022 as well as bring them with you to the deposition on May 18, 2022 **Additionally, you must have an
audio and video connection so that the court reporter can visually identify you when administering the oath,
in accordance with Florida Supreme Court Order AOS20-16 relating to COVID-19 Emergency Procedures
for the Administering of Oaths Via Remote Audio-Video Communication Equipment.**
If you fail to appear, you may be in contempt of court. You are subpoenaed to appear by the undersigned
attorney and unless excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as
directed.
DATED on April 11, 2022.
Ashley Ward-Singleton, Esq. for the Clerk of the Court
BY: /s/ Ashley Ward-Singleton
Ashley Ward-Singleton, Esq. FBN: 89426 ASHLEY WARD-SINGLETON
Jennifer L. Velazco, Esq. FBN: 27199
Quintairos, Prieto, Wood & Boyer, P.A.
1410 N. Westshore Blvd., 2nd Floor
Tampa, Florida 33607
813-286-8818 (Telephone) 813-286-9998 (Facsimile)
Attorneys for Defendants
If you are a person with a disability who needs any accommodation in order to participate in a court
proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact Court
Administration at (321) 633.2171x2. If you are hearing or voice impaired, call (800) 955.8771; Or write to:
Court Administration, Moore Justice Center, 2825 Judge Fran Jamieson Way, Viera, Florida 32940.
1 Videoconference Link to be provided under separate cover.
Filing 147418859 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX
EXHIBIT “A”
COLOR copies of all documents in your possession, custody, or control, which relate to the subject
property at 4835 Key Biscayne Drive, Titusville, FL 32780 (“subject property”), the Plaintiff, the
Insureds, and/or this lawsuit, including, but not limited to, the specific categories of documents
identified in the following paragraphs.
COLOR copies of all field notes, notes, daily logs, diaries, calendars, timelines, or similar
documents made by you or any other person or entity purporting to record events or conditions at
the subject property.
COLOR copies of all documents provided to you by the Plaintiff and Insureds in the above-
captioned cause, or their attorneys, representatives, or consultants.
A list of all matters in which you have been retained as a consulting or testimonial expert, whether
or not you actually testified at trial, for the past five (5) years.
A list of all matters in which you have been deposed in the past four (4) years.
All correspondence sent or received by you to or from any person or party regarding the subject
property, and/or the Plaintiff and Insureds.
COLOR copies of all faxes, letters, correspondence, reports, drafts of reports, memoranda,
inspection reports, drawings, field notes, samples, logs, data, photographs, videotapes, diagrams,
charts, drawings, sketches, blueprints, or any other documents depicting or analyzing the condition
of the subject property, or the cause of damage at that location.
COLOR copies of all repair protocols, estimates, work orders, contracts, or invoices prepared for or
by you related to any services performed at the subject property.
Copies of all receipts, checks, or other documentation evidencing all payments made to you and/or
your company for any services performed in connection with the subject property at, the Plaintiff
and Insureds, and/or this lawsuit.
10. A list of the personnel who performed any services on behalf of you and/or your company
regarding the subject property.
11 COLOR copies of all documents and materials relied upon by you in formulating your opinions in
this case, including, but not limited to studies, reports, photographs, scientific literature, county
and/or city records, third party data, logs, or any other data collected by you or others.
12. A COLOR copy of your complete file regarding the investigation performed at the subject
property.
Filing 147418859 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX
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Filing # 147418859 E-Filed 04/11/2022 11:03:31 AM IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT IN AND FOR BREVARD COUNTY, FLORIDA ANTHONY DAVIS, JR., Case No.: 2020-CA-024628 Plaintiff, vs. SECURITY FIRST INSURANCE COMPANY, Defendant. / SUBPOENA DUCES TECUM FOR DEPOSITION THE STATE OF FLORIDA: TO: Dennis James Triad Restoration Services 2801 Alt 19 Dunedin, FL 34698 YOU ARE COMMANDED TO APPEAR before a person authorized by law to take depositions on May 18, 2022 at 9:00 A.M. via Remote Videoconference Appearance (e.g. Zoom)' appearance, for the taking of your deposition in this action provide to Defense Counsel the items listed in the attached Exhibit “A” on or before May 11, 2022 as well as bring them with you to the deposition on May 18, 2022 **Additionally, you must have an audio and video connection so that the court reporter can visually identify you when administering the oath, in accordance with Florida Supreme Court Order AOS20-16 relating to COVID-19 Emergency Procedures for the Administering of Oaths Via Remote Audio-Video Communication Equipment.** If you fail to appear, you may be in contempt of court. You are subpoenaed to appear by the undersigned attorney and unless excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as directed. DATED on April 11, 2022. Ashley Ward-Singleton, Esq. for the Clerk of the Court BY: /s/ Ashley Ward-Singleton Ashley Ward-Singleton, Esq. FBN: 89426 ASHLEY WARD-SINGLETON Jennifer L. Velazco, Esq. FBN: 27199 Quintairos, Prieto, Wood & Boyer, P.A. 1410 N. Westshore Blvd., 2nd Floor Tampa, Florida 33607 813-286-8818 (Telephone) 813-286-9998 (Facsimile) Attorneys for Defendants If you are a person with a disability who needs any accommodation in order to participate in a court proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact Court Administration at (321) 633.2171x2. If you are hearing or voice impaired, call (800) 955.8771; Or write to: Court Administration, Moore Justice Center, 2825 Judge Fran Jamieson Way, Viera, Florida 32940. 1 Videoconference Link to be provided under separate cover. Filing 147418859 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX EXHIBIT “A” COLOR copies of all documents in your possession, custody, or control, which relate to the subject property at 4835 Key Biscayne Drive, Titusville, FL 32780 (“subject property”), the Plaintiff, the Insureds, and/or this lawsuit, including, but not limited to, the specific categories of documents identified in the following paragraphs. COLOR copies of all field notes, notes, daily logs, diaries, calendars, timelines, or similar documents made by you or any other person or entity purporting to record events or conditions at the subject property. COLOR copies of all documents provided to you by the Plaintiff and Insureds in the above- captioned cause, or their attorneys, representatives, or consultants. A list of all matters in which you have been retained as a consulting or testimonial expert, whether or not you actually testified at trial, for the past five (5) years. A list of all matters in which you have been deposed in the past four (4) years. All correspondence sent or received by you to or from any person or party regarding the subject property, and/or the Plaintiff and Insureds. COLOR copies of all faxes, letters, correspondence, reports, drafts of reports, memoranda, inspection reports, drawings, field notes, samples, logs, data, photographs, videotapes, diagrams, charts, drawings, sketches, blueprints, or any other documents depicting or analyzing the condition of the subject property, or the cause of damage at that location. COLOR copies of all repair protocols, estimates, work orders, contracts, or invoices prepared for or by you related to any services performed at the subject property. Copies of all receipts, checks, or other documentation evidencing all payments made to you and/or your company for any services performed in connection with the subject property at, the Plaintiff and Insureds, and/or this lawsuit. 10. A list of the personnel who performed any services on behalf of you and/or your company regarding the subject property. 11 COLOR copies of all documents and materials relied upon by you in formulating your opinions in this case, including, but not limited to studies, reports, photographs, scientific literature, county and/or city records, third party data, logs, or any other data collected by you or others. 12. A COLOR copy of your complete file regarding the investigation performed at the subject property. Filing 147418859 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX