Preview
Filing# 158717739 E-Filed 10/06/2022 02:26:00 PM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT IN
AND FOR BROWARD COUNTY,
FLORIDA
ANTONIO ALFARO and DIANAALFARO,
CASE NO.: CACE-21-007201
Plaintiffs,
V
TYPTAP INSURANCE COMPANY,
Defendant.
NOTICE OF TAKING DEPOSITION DUCES TECUM
(Date/time agreed upon by all parties)
PLEASE ADVISE IF AN INTERPRETER IS NEEDED
PLEASE TAKE NOTICE that, pursuant to Rule 1.310 (b) of the Florida Rules of
Civil Procedure, the undersigned attorneys will take the depositions of.
NAME: Corporate Representative of Trueview Mold
DATE: November 15, 2022
TIME: 10:00 A.M.
LOCATION: Via Zoom, Magna Legal Services (866) 624-6221
The deposition is being taken purposes of discovery and for use at trial,
for the or for such
other purposes as are permitted under the Florida Rules of Civil Procedure. The
deposition will continue from day to day until completed.
The deponent is directed to produce for inspection or copying at the time of the deposition
the documents called for in the attached SCHEDULE A [and as to any documents over
which a claim of privilegeis asserted, a privilegelog per Rule 1.280(b)(5)].
In an expedite the deposition, Defendant's counsel requests that the requested
effort to
documents responsive to SCHEDULE A be produced at least five (5) days before the
date of the deposition, to allow the parties to conduct the deposition quickly and
efficiently.This will eliminate the need for Defendant's counsel having to review the
documents for the first time at the deposition with the deponent. Defendant will reimburse
deponent for all reasonable costs associated with producing the requested documents
priorto the deposition.
is claimed to apply to the requested
Further, to the extent any privilegeor confidentiality
COLE, SCOTT & KISSANE, P.A.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/06/2022 02:25:59 PM.****
CASE NO.: CACE-21-007201
documents, the deponent is directed to bring such responsive documents to the
deposition so that they can fullyanswer all of counsel's questioning. However, a privilege
log as contemplated under Florida Rule of Civil Procedure 1.280(b)(5) may be produced
in lieu of the actual documents over which such claim is asserted. Any such privileged
documents are nonetheless requested to be available at the deposition for the
deponent to review during the deposition in order to fully answer all questions;
Defendant stipulates that such review of documents over which a privilege claim
has been asserted by any deponent will not be deemed as a waiver of any claimed
privilege.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 6th day of October, 2022, a true and correct copy
of the foregoing was filed with the Clerk of Miami-Dade County by using the Florida Courts
e-Filing Portal, which will send an automatic e-mail message to the following parties
registered with the e-FilingPortal system: Maximo A. Santiago, Esq,, Your Insurance
Attorney,PLLC,via3@you rinsu ranceattomey.com;eservice@you rinsuranceattorney.com
,
2601 South Bayshore Drive, 18th Floor, Coconut Grove, FL 33133, (888) 570-
5677/(888) 745-5677 (F),Attorney for Plaintiffs,Diana Arevalo and Antonio Alfaro.
COLE, SCOTT & KISSANE, P.A.
Counsel for Defendant TYPTAP
INSURANCE COMPANY
Esperante Building
222 Lakeview Avenue, Suite 120
West Palm Beach, Florida 33401
Telephone (561) 383-9233
Facsimile (561) 683-8977
Primary e-mail: stephen.harber@csklegal.corn
Secondary e-mail: jacqueline.meyer@csklegal.corn
Alternate e-mail: WPBFirstParty@csklegal.corn
By: /s/ Jacqueline P. Meyer
STEPHEN N. HARBER
Florida Bar No.: 96374
JACQUELINE P. MEYER
Florida Bar No.: 1010785
0365.1428-00
Page 2
COLE, SCOTT & KISSANE, P.A.
ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-9200 -
(561) 683-8977 FAX
CASE NO.: CACE-21-007201
SCHEDULE A
DOCUMENTS TO BE PRODUCED
Your entire file in this case. This includes, but is not limited to, the following:
o Emails to and from anyone related to this case;
All attachments to the emails to and from anyone related to this case;
All field notes, handwritten notes and electronic notes;
. Print outs of all computer/web-based programs that contain information
regarding this case;
o Any and all reports you prepared or furnished in this case.
o Any and all reports which were furnished to you in this case.
All estimates of damages.
All photos (includingjpg/nativeformat);
o All documents, invoices, receipts, contracts, etc., provided to you related to
this case.
Page 3
COLE, SCOTT & KISSANE, P.A.
ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-9200 -
(561) 683-8977 FAX
Preview
Filing# 158717739 E-Filed 10/06/2022 02:26:00 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA ANTONIO ALFARO and DIANAALFARO, CASE NO.: CACE-21-007201 Plaintiffs, V TYPTAP INSURANCE COMPANY, Defendant. NOTICE OF TAKING DEPOSITION DUCES TECUM (Date/time agreed upon by all parties) PLEASE ADVISE IF AN INTERPRETER IS NEEDED PLEASE TAKE NOTICE that, pursuant to Rule 1.310 (b) of the Florida Rules of Civil Procedure, the undersigned attorneys will take the depositions of. NAME: Corporate Representative of Trueview Mold DATE: November 15, 2022 TIME: 10:00 A.M. LOCATION: Via Zoom, Magna Legal Services (866) 624-6221 The deposition is being taken purposes of discovery and for use at trial, for the or for such other purposes as are permitted under the Florida Rules of Civil Procedure. The deposition will continue from day to day until completed. The deponent is directed to produce for inspection or copying at the time of the deposition the documents called for in the attached SCHEDULE A [and as to any documents over which a claim of privilegeis asserted, a privilegelog per Rule 1.280(b)(5)]. In an expedite the deposition, Defendant's counsel requests that the requested effort to documents responsive to SCHEDULE A be produced at least five (5) days before the date of the deposition, to allow the parties to conduct the deposition quickly and efficiently.This will eliminate the need for Defendant's counsel having to review the documents for the first time at the deposition with the deponent. Defendant will reimburse deponent for all reasonable costs associated with producing the requested documents priorto the deposition. is claimed to apply to the requested Further, to the extent any privilegeor confidentiality COLE, SCOTT & KISSANE, P.A. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/06/2022 02:25:59 PM.**** CASE NO.: CACE-21-007201 documents, the deponent is directed to bring such responsive documents to the deposition so that they can fullyanswer all of counsel's questioning. However, a privilege log as contemplated under Florida Rule of Civil Procedure 1.280(b)(5) may be produced in lieu of the actual documents over which such claim is asserted. Any such privileged documents are nonetheless requested to be available at the deposition for the deponent to review during the deposition in order to fully answer all questions; Defendant stipulates that such review of documents over which a privilege claim has been asserted by any deponent will not be deemed as a waiver of any claimed privilege. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 6th day of October, 2022, a true and correct copy of the foregoing was filed with the Clerk of Miami-Dade County by using the Florida Courts e-Filing Portal, which will send an automatic e-mail message to the following parties registered with the e-FilingPortal system: Maximo A. Santiago, Esq,, Your Insurance Attorney,PLLC,via3@you rinsu ranceattomey.com;eservice@you rinsuranceattorney.com , 2601 South Bayshore Drive, 18th Floor, Coconut Grove, FL 33133, (888) 570- 5677/(888) 745-5677 (F),Attorney for Plaintiffs,Diana Arevalo and Antonio Alfaro. COLE, SCOTT & KISSANE, P.A. Counsel for Defendant TYPTAP INSURANCE COMPANY Esperante Building 222 Lakeview Avenue, Suite 120 West Palm Beach, Florida 33401 Telephone (561) 383-9233 Facsimile (561) 683-8977 Primary e-mail: stephen.harber@csklegal.corn Secondary e-mail: jacqueline.meyer@csklegal.corn Alternate e-mail: WPBFirstParty@csklegal.corn By: /s/ Jacqueline P. Meyer STEPHEN N. HARBER Florida Bar No.: 96374 JACQUELINE P. MEYER Florida Bar No.: 1010785 0365.1428-00 Page 2 COLE, SCOTT & KISSANE, P.A. ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-9200 - (561) 683-8977 FAX CASE NO.: CACE-21-007201 SCHEDULE A DOCUMENTS TO BE PRODUCED Your entire file in this case. This includes, but is not limited to, the following: o Emails to and from anyone related to this case; All attachments to the emails to and from anyone related to this case; All field notes, handwritten notes and electronic notes; . Print outs of all computer/web-based programs that contain information regarding this case; o Any and all reports you prepared or furnished in this case. o Any and all reports which were furnished to you in this case. All estimates of damages. All photos (includingjpg/nativeformat); o All documents, invoices, receipts, contracts, etc., provided to you related to this case. Page 3 COLE, SCOTT & KISSANE, P.A. ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-9200 - (561) 683-8977 FAX