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Filing# 168297860 E-Filed 03/08/2023 01:13:12 PM
INTHE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO: CACE-21-007300 (21)
JORGE BARO SUAREZ, CHRISTIE BARO,
and ZACHARY BARO,
Plaintiffs,
V
CITIZENS PROPERTY INSURANCE
CORPORATION, a Florida governmental
entity,
Defendant.
i
DEFENDANT'S NOTICE OF TAKING VIRTUAL DEPOSITION DUCES TECUM
NOTICE is hereby given you that at the time and placeherein specified,
we will take the
virtual depositionvia ZOOM Meeting upon oral examination of:
Name: Christopher C. Thompson, P.E. with respect to the subject matters set
forth in the Duces Tecum - Schedule A, which are attached to this
notice following the Certificate of Service.
I)ate: Wednesday, March 15, 2023
Time: 10:00 a.m.
Place: US Legal Support via Zoom - link to be provided
DEPONENT SHALL PROVIDE DOCUMENTS IN THE ATTACHED SCHEDULE "A"
upon virtual oral examination, before US Legal Support, Notary Public, or any other
notary public or officer authorized by law to take depositionsin the State of Florida. The oral
examination will continue from day to day until completed.This deposition
is being taken for the
purpose of discovery,for use at or for such other purposes as are permittedunder the rules
trial,
of the Court.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/08/2023 01:13:12 PM.****
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy ofthe foregoing was served to counsel
o f record on March 8th,
2023 via the Florida Electronic FilingPortal.
VERNIS & BOWLING OF BROWARD, P.A.
AttorneysMDefendant, Citizens Property
Insurance Corporation
5821 Hollywood Boulevard
Hollywood, FL 33021
Tel: (954) 927-5330
Fax: (954) 927-5320
Primary email: PFouts@florida-law.com
Secondary Email: Ayost@florida-law.com
By- /s/ Paulette R. Fonts, Esq.
PAULETTE R. FOUTS, ESQ.
FL Bar No: 078697
cc: US Legal Support
SCHEDULE "A"
Your entire f\le with regard to Jorge Baro Suarez, Christie Baro and Zachary Baro,
includingbut not limited to:
1. Your complete file in this matter includingbut not limited to any and all
photographs,
videotapes of the area where the subject incident occurred, reports, correspondence,
calculations,notes, memoranda, guidelines, publications,estimates,invoices, statements,
inventories,and all documents you have reviewed.
2. Any and all documents that you have reviewed, compiled or prepared in connection with
the expressiono f your opinionsin this matter.
3. Any and all documents evidencing or tending to evidence the dates and amounts of time
expended by you in connection with this matter.
4. Any and documents evidencing or tending to evidence any requests for services and
all
opinionsin this matter. Such documents include all message slips,
diarynotes or entries,
notes, correspondence, emails and the like.
5. Any and all documents or charts on this matter requiredor consulted by you in connection
with the expressiono f your opinion in this matter.
6. A current curriculum vitae or other compilation of biographicalor qualifications
information.
7. A list of all publicationsin which you had an authorshiprole or input for the past five (5)
years.
8. A list of all cases in which you have testified as an expert at either a depositionor in trial
for the past five years (includesufficient information where any transcripts
may be located;
i.e.,
court, and complete styleof cases includingcase number).
9. Any and all guidelines,reports, publications,etc., you consider to be authoritative
regardingthis case.
10. Any and all bills or invoices for services rendered in this case.
11. Any and all records and/or reports, evaluations,summaries or written opinionspreparedby
you and any and all documentation referred to, mentioned in or utilized in said reports,
evaluations,summaries or written opinionsor in the preparation
thereof.
12. Any and all documents showing the amount ofmoney charged by you to opposing counsel
for the services rendered in this ofwhether such chargeshave been paid or
case, regardless
are currentlyoutstanding.
13. Any and all documents showing the amount of money actuallypaid to you to by opposing
counsel for the services rendered in this case.
14. Any and all documents showing the amount ofmoney charged by you to opposing counsel
during the last three (3) years for record reviews, inspections,reports, documents,
and trial or depositiontestimony,regardlessof whether such
examinations, consultations,
fees are outstandingor have been paid.
15. Any and all documents showing the amount of money actuallypaid to you to by opposing
counsel during the last three (3)years for records reviews, inspections,
reports, documents,
examinations, consultations,and trial or depositiontestimony.
16. Any and all Xactimate files in .esx format relating
to the property located at 251 SW 621
ind
Terrace, Plantation,FL 33317.
17. Any and all correspondence (includingelectronic correspondence) between you and any
to the property located at 251
other party relating SW 62ind Terrace, Plantation,FL 33317.
J
18. Any and all photographs or videos of the property located at 251 SW 62
ind
Terrace,
Plantation,FL 33317.
19. Any and all to the property located at 251
estimates relating SW 62 nd Terrace, Plantation,
FL 33317.
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Filing# 168297860 E-Filed 03/08/2023 01:13:12 PM INTHE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO: CACE-21-007300 (21) JORGE BARO SUAREZ, CHRISTIE BARO, and ZACHARY BARO, Plaintiffs, V CITIZENS PROPERTY INSURANCE CORPORATION, a Florida governmental entity, Defendant. i DEFENDANT'S NOTICE OF TAKING VIRTUAL DEPOSITION DUCES TECUM NOTICE is hereby given you that at the time and placeherein specified, we will take the virtual depositionvia ZOOM Meeting upon oral examination of: Name: Christopher C. Thompson, P.E. with respect to the subject matters set forth in the Duces Tecum - Schedule A, which are attached to this notice following the Certificate of Service. I)ate: Wednesday, March 15, 2023 Time: 10:00 a.m. Place: US Legal Support via Zoom - link to be provided DEPONENT SHALL PROVIDE DOCUMENTS IN THE ATTACHED SCHEDULE "A" upon virtual oral examination, before US Legal Support, Notary Public, or any other notary public or officer authorized by law to take depositionsin the State of Florida. The oral examination will continue from day to day until completed.This deposition is being taken for the purpose of discovery,for use at or for such other purposes as are permittedunder the rules trial, of the Court. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/08/2023 01:13:12 PM.**** CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy ofthe foregoing was served to counsel o f record on March 8th, 2023 via the Florida Electronic FilingPortal. VERNIS & BOWLING OF BROWARD, P.A. AttorneysMDefendant, Citizens Property Insurance Corporation 5821 Hollywood Boulevard Hollywood, FL 33021 Tel: (954) 927-5330 Fax: (954) 927-5320 Primary email: PFouts@florida-law.com Secondary Email: Ayost@florida-law.com By- /s/ Paulette R. Fonts, Esq. PAULETTE R. FOUTS, ESQ. FL Bar No: 078697 cc: US Legal Support SCHEDULE "A" Your entire f\le with regard to Jorge Baro Suarez, Christie Baro and Zachary Baro, includingbut not limited to: 1. Your complete file in this matter includingbut not limited to any and all photographs, videotapes of the area where the subject incident occurred, reports, correspondence, calculations,notes, memoranda, guidelines, publications,estimates,invoices, statements, inventories,and all documents you have reviewed. 2. Any and all documents that you have reviewed, compiled or prepared in connection with the expressiono f your opinionsin this matter. 3. Any and all documents evidencing or tending to evidence the dates and amounts of time expended by you in connection with this matter. 4. Any and documents evidencing or tending to evidence any requests for services and all opinionsin this matter. Such documents include all message slips, diarynotes or entries, notes, correspondence, emails and the like. 5. Any and all documents or charts on this matter requiredor consulted by you in connection with the expressiono f your opinion in this matter. 6. A current curriculum vitae or other compilation of biographicalor qualifications information. 7. A list of all publicationsin which you had an authorshiprole or input for the past five (5) years. 8. A list of all cases in which you have testified as an expert at either a depositionor in trial for the past five years (includesufficient information where any transcripts may be located; i.e., court, and complete styleof cases includingcase number). 9. Any and all guidelines,reports, publications,etc., you consider to be authoritative regardingthis case. 10. Any and all bills or invoices for services rendered in this case. 11. Any and all records and/or reports, evaluations,summaries or written opinionspreparedby you and any and all documentation referred to, mentioned in or utilized in said reports, evaluations,summaries or written opinionsor in the preparation thereof. 12. Any and all documents showing the amount ofmoney charged by you to opposing counsel for the services rendered in this ofwhether such chargeshave been paid or case, regardless are currentlyoutstanding. 13. Any and all documents showing the amount of money actuallypaid to you to by opposing counsel for the services rendered in this case. 14. Any and all documents showing the amount ofmoney charged by you to opposing counsel during the last three (3) years for record reviews, inspections,reports, documents, and trial or depositiontestimony,regardlessof whether such examinations, consultations, fees are outstandingor have been paid. 15. Any and all documents showing the amount of money actuallypaid to you to by opposing counsel during the last three (3)years for records reviews, inspections, reports, documents, examinations, consultations,and trial or depositiontestimony. 16. Any and all Xactimate files in .esx format relating to the property located at 251 SW 621 ind Terrace, Plantation,FL 33317. 17. Any and all correspondence (includingelectronic correspondence) between you and any to the property located at 251 other party relating SW 62ind Terrace, Plantation,FL 33317. J 18. Any and all photographs or videos of the property located at 251 SW 62 ind Terrace, Plantation,FL 33317. 19. Any and all to the property located at 251 estimates relating SW 62 nd Terrace, Plantation, FL 33317.