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Filing # 171929080 E-Filed 04/27/2023 11:39:36 AM
IN THE CIRCUIT COURT OF THE 18TH
JUDICIAL CIRCUIT, IN AND FOR
BREVARD COUNTY, FLORIDA
CASE NO.: 2022-CA-040480
IRENE DAYTON AND TRAVIS DAYTON,
Plaintiffs,
vs.
FIRST PROTECTIVE INSURANCE
COMPANY d/b/a FRONTLINE INSURANCE,
Defendant.
NOTICE OF PRODUCTION FROM NON-PARTY
(Mail in Records Only)
YOU ARE NOTIFIED that after ten (10) days from the date of service of this Notice, the
undersigned will issue the attached Subpoenas pursuant to Florida Rules of Civil Procedure 1.351
and directed to:
1 City of Cocoa Utilities
c/o Records Custodian
351 Shearer Blvd.
Cocoa, FL 32922
(321) 433-8700
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that on the 27" day of April, 2023, we electronically filed the
foregoing document with the Clerk of the Court using the Florida Courts E-Filing Portal. We
also certify that the foregoing document is being served this day on Michael J. Friedman, Esquire
at FRIEDMAN LEGAL at mfriedman@friedmanlegalfl.com; nmoss@friedmanlegalfl.com &
Filing 171929080 | DAYTON VS FIRST PROTECTIVE 05-2022-CA-040480-XXXX-XX
pleadings@friedmanlegalfl.com by the Florida Courts E-Filing Portal, or in some other
authorized manner for those counsel or parties who are not authorized to receive electronic Notices
of Electronic Filing.
THE TEEBAGY & MEDEIROS
LAW GROUP, PLLC
Attorneys for Defendant
P.O. Box 221647
West Palm Beach, FL 33422
Telephone: (561) 229-0280
Facsimile: (561) 229-0281
Primary Email: eservice@thetmlaw.com
By: ___/s/Steven C. Teebagy
Steven C. Teebagy, Esquire
Non-Service Email: steebagy@thetmlaw.com
Florida Bar No.: 64823
Crystalin Medeiros, Esquire
Non-Service Email: cmedeiros@thetmlaw.com
Florida Bar No.: 56342
Filing 171929080 | DAYTON VS FIRST PROTECTIVE 05-2022-CA-040480-XXXX-XX
IN THE CIRCUIT COURT OF THE 18TH
JUDICIAL — CIRCUIT. IN AND FOR
BREVARD COUNTY, FLORIDA
CASE NO.: 2022-CA-040480
IRENE DAYTON AND TRAVIS DAYTON.
Plaintiffs,
VS.
FIRST PROTECTIVE INSURANCE
COMPANY d/b/a FRONTLINE INSURANCE.
Defendant
SUBPOENA DUCES TECUM
(Mail-In Records Only)
THE STATE OF FLORIDA:
TO: City of Cocoa Utilities
c/o Records Custodian
351 Shearer Blvd.
Cocoa, FL 32922
(321) 433-8700
YOU ARE COMMANDED TO APPEAR AT THE TEEBAGY AND MEDEIROS
LAW GROUP, PLLC., 470 COLUMBIA DRIVE, UNIT A201, WEST PALM BEACH, FL
33422, or mail the documents to P.O. Box 221647, West Palm Beach, FL 33422, (Please note, in
the alternative, the documents can be sent electronically to eservice@thetmlaw.com), on or before
4:00 p.m. on Monday, May 31, 2023, and to have with you at that time and place the following
items.
Copies of any all-monthly invoices, bills, and usage/ meters logs from January 1,
2021, through January 1, 2023, as it relates to the account / property owned by
TRAVIS DAYTON and/or IRENE DAYTON for the property located at 27508.
Courtenay Phwy., Merritt Island, FL_32952 including but not limited to any
service requests, outages or repairs made, or needed during the time frame
indicated.
Filing 171929080 | DAYTON VS FIRST PROTECTIVE 05-2022-CA-040480-XXXX-XX
These items will be inspected and may be copied at that time. You will not be required to surrender
the original items. You may comply with this Subpoena by providing legible copies of the items
to be produced to the attorney whose name appears on this subpoena on or before the scheduled
date of production. You may condition the preparation of the copies upon the payment in advance
of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose
name appears on this subpoena and thereby eliminate your appearance at the time and place
specified above. You have the right to object to the production pursuant to this Subpoena at any
time before production by giving written notice to the attorney whose name appears on this
Subpoena. This will not be a deposition. No testimony will be taken.
IF YOU FAIL TO:
appear as specified; or
XX _ furnish the records instead of appearing as provided above; or
object to this subpoena;
you may be in contempt of Court. You are subpoenaed to appear by the following attorney, and
unless excused from this Subpoena by this attorney or the Court, you shall respond to this
Subpoena as directed.
DATED this day of May, 2023.
FOR THE COURT
By:
St DRAF wre
Fla. Bar Now 36345
THE TEEBAGY & MEDEIROS LAW
GROUP, PLLC.
Attorneys for Defendant
P.O. Box 221647
West Palm Beach, FL 33422
Telephone: (561) 229-0280
Facsimile: (561) 229-0281
Primary Email: eservice(@thetmlaw.com
Filing 171929080 | DAYTON VS FIRST PROTECTIVE 05-2022-CA-040480-XXXX-XX
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Filing # 171929080 E-Filed 04/27/2023 11:39:36 AM IN THE CIRCUIT COURT OF THE 18TH JUDICIAL CIRCUIT, IN AND FOR BREVARD COUNTY, FLORIDA CASE NO.: 2022-CA-040480 IRENE DAYTON AND TRAVIS DAYTON, Plaintiffs, vs. FIRST PROTECTIVE INSURANCE COMPANY d/b/a FRONTLINE INSURANCE, Defendant. NOTICE OF PRODUCTION FROM NON-PARTY (Mail in Records Only) YOU ARE NOTIFIED that after ten (10) days from the date of service of this Notice, the undersigned will issue the attached Subpoenas pursuant to Florida Rules of Civil Procedure 1.351 and directed to: 1 City of Cocoa Utilities c/o Records Custodian 351 Shearer Blvd. Cocoa, FL 32922 (321) 433-8700 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that on the 27" day of April, 2023, we electronically filed the foregoing document with the Clerk of the Court using the Florida Courts E-Filing Portal. We also certify that the foregoing document is being served this day on Michael J. Friedman, Esquire at FRIEDMAN LEGAL at mfriedman@friedmanlegalfl.com; nmoss@friedmanlegalfl.com & Filing 171929080 | DAYTON VS FIRST PROTECTIVE 05-2022-CA-040480-XXXX-XX pleadings@friedmanlegalfl.com by the Florida Courts E-Filing Portal, or in some other authorized manner for those counsel or parties who are not authorized to receive electronic Notices of Electronic Filing. THE TEEBAGY & MEDEIROS LAW GROUP, PLLC Attorneys for Defendant P.O. Box 221647 West Palm Beach, FL 33422 Telephone: (561) 229-0280 Facsimile: (561) 229-0281 Primary Email: eservice@thetmlaw.com By: ___/s/Steven C. Teebagy Steven C. Teebagy, Esquire Non-Service Email: steebagy@thetmlaw.com Florida Bar No.: 64823 Crystalin Medeiros, Esquire Non-Service Email: cmedeiros@thetmlaw.com Florida Bar No.: 56342 Filing 171929080 | DAYTON VS FIRST PROTECTIVE 05-2022-CA-040480-XXXX-XX IN THE CIRCUIT COURT OF THE 18TH JUDICIAL — CIRCUIT. IN AND FOR BREVARD COUNTY, FLORIDA CASE NO.: 2022-CA-040480 IRENE DAYTON AND TRAVIS DAYTON. Plaintiffs, VS. FIRST PROTECTIVE INSURANCE COMPANY d/b/a FRONTLINE INSURANCE. Defendant SUBPOENA DUCES TECUM (Mail-In Records Only) THE STATE OF FLORIDA: TO: City of Cocoa Utilities c/o Records Custodian 351 Shearer Blvd. Cocoa, FL 32922 (321) 433-8700 YOU ARE COMMANDED TO APPEAR AT THE TEEBAGY AND MEDEIROS LAW GROUP, PLLC., 470 COLUMBIA DRIVE, UNIT A201, WEST PALM BEACH, FL 33422, or mail the documents to P.O. Box 221647, West Palm Beach, FL 33422, (Please note, in the alternative, the documents can be sent electronically to eservice@thetmlaw.com), on or before 4:00 p.m. on Monday, May 31, 2023, and to have with you at that time and place the following items. Copies of any all-monthly invoices, bills, and usage/ meters logs from January 1, 2021, through January 1, 2023, as it relates to the account / property owned by TRAVIS DAYTON and/or IRENE DAYTON for the property located at 27508. Courtenay Phwy., Merritt Island, FL_32952 including but not limited to any service requests, outages or repairs made, or needed during the time frame indicated. Filing 171929080 | DAYTON VS FIRST PROTECTIVE 05-2022-CA-040480-XXXX-XX These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this Subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above. You have the right to object to the production pursuant to this Subpoena at any time before production by giving written notice to the attorney whose name appears on this Subpoena. This will not be a deposition. No testimony will be taken. IF YOU FAIL TO: appear as specified; or XX _ furnish the records instead of appearing as provided above; or object to this subpoena; you may be in contempt of Court. You are subpoenaed to appear by the following attorney, and unless excused from this Subpoena by this attorney or the Court, you shall respond to this Subpoena as directed. DATED this day of May, 2023. FOR THE COURT By: St DRAF wre Fla. Bar Now 36345 THE TEEBAGY & MEDEIROS LAW GROUP, PLLC. Attorneys for Defendant P.O. Box 221647 West Palm Beach, FL 33422 Telephone: (561) 229-0280 Facsimile: (561) 229-0281 Primary Email: eservice(@thetmlaw.com Filing 171929080 | DAYTON VS FIRST PROTECTIVE 05-2022-CA-040480-XXXX-XX