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Filing# 155453250 E-Filed 08/16/2022 04:12:21 PM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT,
IN AND FOR BROWARD COUNTY, FLORIDA
JORGE CALVEIRO AND CASE NO: CACE-21-003788
DEBORAH CALVEIRO,
Plaintiffs,
VS.
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
i
NOTICE OF TAKING VIDEO DEPOSITION DUCES TECUM*
YOU ARE HEREBY NOTIFIED that the undersigned will take the following video
deposition:
DEPONENT: Jeremy Brown
DATE: August 30,2022
TIME: 10:30 AM
VIA: Zoom Video Communications ("Zoom"): Zoom link
Meeting ID and Password to be provided at a later date,
prior to deposition
VIDEOGRAPHER: Magna Legal Services
upon oral examination before an official court reporter authorized by law to take depositions.
This depositionis being taken for purposes of discovery,for use as evidence, and for such other
uses and purposes as are permitted under the Florida Rules of Civil Procedure and other
applicablelaw and shall continue from day to day until completed. Said videography services
will be provided by Magna Legal Services.
Deponent shall bringthe followingat the time of said deposition:
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/16/2022 04:12:21 PM.****
See attached Exhibit "A"
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on August 16, 2022, the foregoing was electronically
filed
through the Florida Courts E-FilingPortal which will send a notice of electronic filingto Max B.
Blackman, Esquire,Kanner & Pintaluga,P.A., 925 S. Federal Highway, Boca Raton, FL 33432
(mblackman@kpattorney. corn).
/s/ Ivelis Holt
IVELIS HOLT, ESQ.
Florida Bar No. 127606
Dean, Ringers,Morgan & Lawton, P.A.
Post Office Box 2928
Orlando, Florida 32802-2928
Tel: 407-422-4310 Fax: 407-648-0233
E-Service: IHeservice@drml-law.com
Attorneys for Defendant
cc: Magna Legal Services
Via-Email: Scheduling@MagnaLS.com
(866) 624-6221
Seven Penn Center
1635 Market Street,W Floor
,th
PA 19103
Philadelphia,
:Coordinated with opposing counsel on 8/15/22.
EXHIBIT "A"
1. A professionalrdsumd or curriculum vitae summarizing your professionalqualifications.
2. Copies of all scientific and technical publicationsauthored by you.
3. All time records, diaries, and bills prepared and rendered in connection with your
and evaluation of the issues involved in the lawsuit.
investigation
4. Your complete and evaluation of the issues
file in connection with your investigation
involved in the lawsuit,including, but not limited to
(a) all documents furnished to you by anyone;
(b) all documents obtained or created by you;
(c) alldocuments you reviewed, referred to or relied upon in arrivingat any of your
opinions or conclusions concerning the issues involved in the lawsuit, including,
but not limited to, all scientific and technical articles,publications,codes,
standards,and other literature;
(d) all photographs,or other exhibits or documents of any kind
models, illustrations,
which you intend or contemplate using to explain,illustrate or support your
testimony at trial.
5. All records concerning other cases for which you may have testified in depositionor at
trial,for whom you testified, you testified about and the name and
the area of expertise
address of the attorney who retained you, the date(s)of depositions,
etc.
6. Any and all collegetranscr*tsand other academic records.
7. All photographs viewed and/or taken by or for you in connection with this case.
8. All published standards, such as those published by the American National Standards
OSHA Regulations or those of any other recognized authority,used or referred
Institute,
to you in formulatingyour opinions in connection with this case.
9. All safetymanuals which you regard as authoritative in connection with this case.
10. Any written instructions or package inserts pertainingto the product,which you have
reviewed.
11. Any government publicationssuch as Consumer Product Safety reports, which you have
examined in formulatingyour opinionin connection with this case.
12. Any records indicatingthe time spent on your undertaking and hourly charges in
connection with this case.
13. Reports of any other experts, which you have reviewed.
14. Any published monographs, treatises,manuals, textbooks or other documents used as a
reference by you in connection with this case.
15. Copies of any correspondence between you or your office and counsel for the plaintiff.
16. Copies of any correspondence written by you or received from others with whom you
have consulted in connection with this case.
17. Any memoranda reviewed, which was prepared by the attorney engaging you, an
a paralegalor an adjusterin connection with this case.
investigator,
18. Any other document or writing of any kind or description,
which you have viewed in
formulatingyour conclusion in connection with this case.
19. Any and all charts, diagrams, overlays,graphs, photographic enlargements, or other
demonstrative aids prepared or to be used by you at trial or in aid of your opinions and/or
testimony.
Preview
Filing# 155453250 E-Filed 08/16/2022 04:12:21 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA JORGE CALVEIRO AND CASE NO: CACE-21-003788 DEBORAH CALVEIRO, Plaintiffs, VS. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. i NOTICE OF TAKING VIDEO DEPOSITION DUCES TECUM* YOU ARE HEREBY NOTIFIED that the undersigned will take the following video deposition: DEPONENT: Jeremy Brown DATE: August 30,2022 TIME: 10:30 AM VIA: Zoom Video Communications ("Zoom"): Zoom link Meeting ID and Password to be provided at a later date, prior to deposition VIDEOGRAPHER: Magna Legal Services upon oral examination before an official court reporter authorized by law to take depositions. This depositionis being taken for purposes of discovery,for use as evidence, and for such other uses and purposes as are permitted under the Florida Rules of Civil Procedure and other applicablelaw and shall continue from day to day until completed. Said videography services will be provided by Magna Legal Services. Deponent shall bringthe followingat the time of said deposition: *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/16/2022 04:12:21 PM.**** See attached Exhibit "A" CERTIFICATE OF SERVICE I HEREBY CERTIFY that on August 16, 2022, the foregoing was electronically filed through the Florida Courts E-FilingPortal which will send a notice of electronic filingto Max B. Blackman, Esquire,Kanner & Pintaluga,P.A., 925 S. Federal Highway, Boca Raton, FL 33432 (mblackman@kpattorney. corn). /s/ Ivelis Holt IVELIS HOLT, ESQ. Florida Bar No. 127606 Dean, Ringers,Morgan & Lawton, P.A. Post Office Box 2928 Orlando, Florida 32802-2928 Tel: 407-422-4310 Fax: 407-648-0233 E-Service: IHeservice@drml-law.com Attorneys for Defendant cc: Magna Legal Services Via-Email: Scheduling@MagnaLS.com (866) 624-6221 Seven Penn Center 1635 Market Street,W Floor ,th PA 19103 Philadelphia, :Coordinated with opposing counsel on 8/15/22. EXHIBIT "A" 1. A professionalrdsumd or curriculum vitae summarizing your professionalqualifications. 2. Copies of all scientific and technical publicationsauthored by you. 3. All time records, diaries, and bills prepared and rendered in connection with your and evaluation of the issues involved in the lawsuit. investigation 4. Your complete and evaluation of the issues file in connection with your investigation involved in the lawsuit,including, but not limited to (a) all documents furnished to you by anyone; (b) all documents obtained or created by you; (c) alldocuments you reviewed, referred to or relied upon in arrivingat any of your opinions or conclusions concerning the issues involved in the lawsuit, including, but not limited to, all scientific and technical articles,publications,codes, standards,and other literature; (d) all photographs,or other exhibits or documents of any kind models, illustrations, which you intend or contemplate using to explain,illustrate or support your testimony at trial. 5. All records concerning other cases for which you may have testified in depositionor at trial,for whom you testified, you testified about and the name and the area of expertise address of the attorney who retained you, the date(s)of depositions, etc. 6. Any and all collegetranscr*tsand other academic records. 7. All photographs viewed and/or taken by or for you in connection with this case. 8. All published standards, such as those published by the American National Standards OSHA Regulations or those of any other recognized authority,used or referred Institute, to you in formulatingyour opinions in connection with this case. 9. All safetymanuals which you regard as authoritative in connection with this case. 10. Any written instructions or package inserts pertainingto the product,which you have reviewed. 11. Any government publicationssuch as Consumer Product Safety reports, which you have examined in formulatingyour opinionin connection with this case. 12. Any records indicatingthe time spent on your undertaking and hourly charges in connection with this case. 13. Reports of any other experts, which you have reviewed. 14. Any published monographs, treatises,manuals, textbooks or other documents used as a reference by you in connection with this case. 15. Copies of any correspondence between you or your office and counsel for the plaintiff. 16. Copies of any correspondence written by you or received from others with whom you have consulted in connection with this case. 17. Any memoranda reviewed, which was prepared by the attorney engaging you, an a paralegalor an adjusterin connection with this case. investigator, 18. Any other document or writing of any kind or description, which you have viewed in formulatingyour conclusion in connection with this case. 19. Any and all charts, diagrams, overlays,graphs, photographic enlargements, or other demonstrative aids prepared or to be used by you at trial or in aid of your opinions and/or testimony.