Document for MUIRHEAD, SAMANTHA vs. UNIVERSAL PROPERTY AND CASUALTY INSURANCE COMPANY

• 
• 
• 
• 

						
                                
Preview
                                Filing # 173669499 E-Filed 05/22/2023 12:19:34 PM



            IN THE CIRCUIT COURT OF THE
            TWENTIETH JUDICIAL CIRCUIT
            IN AND FOR CHARLOTTE COUNTY, FLORIDA

            CASE NO: 23001596CA

            SAMANTHA          & TYLER MUIRHEAD,

                     Plaintiff,
           Vs.


            UNIVERSAL PROPERTY                & CASUALTY
            INSURANCE COMPANY,

                     Defendant.
                                                            /

                             NOTICE OF TAKING DEPOSITION DUCES TECUM

                     PLEASE TAKE NOTICE that a deposition will be taking place before Veritext,
            or some other Notary Public for the State of Florida at Large. The attorney for the
            Plaintiff will be taking the deposition of the below listed individual at the following
            location, on the following date and time:


                     DEPONE                    Danniela Cadavid, Field Adjuster
                     LOCATIO:                  Veritext Court Reporting via Zoom
                     DAT                       October 10, 2023
                     TIM.                      2:00 PM EST

            Witness is to have at set time and place the following:

                 1. Any and all documents you reviewed regarding the subject matter of this case upon

                     which you base any claim decisions, opinions, or actions;

                 2. Any reports you generated;

                 3. Your entire file relating to this matter; and,

                 4. Any and all reports, documents, photographs, whether electronic or otherwise, you

                     gathered, collected, placed in the claim file, or in any way relied on for any decisions,

                     opinions, or actions regarding this claim.
***Documents for which Defendant has raised, or intends to raise, a privilege (e.g.,
claims file documents) need not be produced to Plaintiff for examination, however must
be brought so that deponent may adequately respond to non-privileged areas of
inquiry***


        PLEASE TAKE NOTICE that the deposition is being taken for the purpose of

discovery, for use at trial, or both of the foregoing, and for such other purposes as are

permitted under the Florida Rules of Civil Procedure and other applicable law.




                              CERTIFICATE OF SERVICE

        I HEREBY      CERTIFY that on May 22, 2023, I electronically filed the foregoing
with the Clerk of the Court by using the Florida Courts E-Filing Portal which will send
notice of this electronic filing to counsel of record.



                                                   /s/ Brittany Birs
                                                COHEN LAW GROUP
                                                Brittany Birs, Esq.
                                                FOR THE FIRM
                                                Florida Bar Number: 125648
                                                350 North Lake Destiny Road, Suite 200
                                                Maitland, Florida 32751
                                                Primary: bbirs@itsaboutjustice.law
                                                Secondary: kate@itsaboutjustice.law
                                                Phone: (407) 478-4878
                                                Fax:    (407) 478-0204
                                                Attorneys for Plaintiff

Copy: Veritext Court Reporting