Preview
Filing# 157327877 E-Filed 09/13/2022 03:54:58 PM
RETURN OF SERVICE
State of Florida County of Broward Circuit Court
Case Number: CACE-21-007603 Court Date: 9/12/2022 3:00 pm
Plaintiff: YOANDRIS MIGUEL CASTELLANOS
VS.
Defendant: CITIZENS PROPERTY INSURANCE
CORPORATION
For:
PATRICIA HAMILTON
LAW OFFICES OF HOFFMAN & HOFFMAN, P.A.
66 West Flagler Street
Suite 200
Miami, FL 33130
Received by Caplan, Caplan & Caplan Process Servers on the 30th day of August, 2022 at 3:52 pm to be
served on RESTORE ALL LLC, 304 INDIAN TRACE, #916, WESTON, FL 33326
I, Luzeneida Gonzalez, do hereby affirm that on the 1 st day of September, 2022 at 2:25 pm, ]:
SUBSTITUTE served by deliveringa true copy of the SUBPOENA FOR VIDEOTAPED DEPOSITION
DUCES TECUM, ZOOM INSTRUCTIONS, SCHEDULE A, SCHEDULE B, NOTICE OF V]DEOTAPED
DEPOSITION.DUgS TECUM, SCHEDULE A, SCHEDULE B to: CARLOS T: a person in charge at the
recipientsPRIVATE MAILBOX location at the address of: 304 INDIAN TRACE, #916, WESTON, FL
33326; the only address known discoverable through public record to effect service after reasonable
investigationand after determining that the person or business to be served maintains a mailbox at this
[ocation, in compliance with Florida Statute 48.031(6)(a).
Under penalty of perjury,I declare that I have read the foregoing and that the facts stated in it are true,
that l am a Sheriff Appointed Process Server in the county in which this defendant/Witness was served
and have no interest in the above action. Pursuant to FS 92.525(2) and 28 USC Section 1746, no notary
is required.
Luzeneida Go*#aiez
1089
Caplan, Caplan & Caplan Process Servers
12505 Orange Drive
Suite 907
Davie, FL 33330
(305) 374-3426
Our Job Serial Number: CPN-2022027117
Ref: 10792
Service Fee:
Copyright@ 1992-2022 DreamBuilt Softv,are, Inc. - Process Servers Toolbox V8.2k
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/13/2022 03:54:57 PM.****
r, n.. l
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO: CACE-21-007603
YOANDRIS MIGUEL C Cvr Ic,S 1
CASTELLANOS,
Plaintiff(s),
DATE 901.ZGJ TIME -2.25P-
V.
BAUGE# i 089
CITIZENS PROPERTY INSURANCE
INITIAL ---C. -
CORPORATION
Defendant.
66 SUBPOENA FOR VIDEOTAPED DEPOSITION
(PLEASE NOTIFY IF AN INTERPRETER WILL BE REQUIR-ED)
THE STATE OF FLORIDA:
850
TO: RESTORE ALL LLC
304 Indian Trace #916
' URS
Weston, Fl 33326
YOU ARE COMMANDED to appear via *Zoom Pursuant to the Supreme
Court of Florida Administrative Order AOSC20-16, on September 12, 2022, at 3:00
PM, to have your deposition
taken in regard to the above referenced matter and to bring
with you records requestedin the attached Schedule B.
*Zoom information: Join Zoom Meeting
https://us06web.zoom.us/j/89223 523246?pwd=dys2WmhKdlklREZFckh5W
1FrSU95dz09 Meeting ID: 892 2352 3246 and Passcode: 212164
Your depositionwill take placeupon oral examination(s)
before National Reporting
Service,Notary Public in and for the State of Florida at Large, or some other officer duly
authorized by law The deposition will
to take depositions. be videotapedby National
LAW OFFICE OF HOFFMAN & HOFFMAN PA. 1
66 W. FlagierStreet,Suite 200, Miami, Florida 33130- Telephone: 305.372.2877 Fax: 305.372.2875
27117
Reporting Service and/or an employee of the Law Offices of Hoffman & Hoffman, P.A.
located at 66 West FlaglerStreet,Suite 200, Miami, Florida 33130. The depositionwill
continue from day to day until completed. The depositionis being taken for the purpose
of discovery, for use at trial,and/or for such other purposes as are permittedunder the
applicableand governing rules.
If you (1) fail to appear as provided above; or (2) fail to objectto the Subpoena,
you may be in contempt of Court. You are subpoenaed to appear by the followingattorney,
and unless excused from this subpoena by this attorney or the Court, you shall respond to
this subpoena as directed.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoingwas furnished
via Email, pursuant to Fla. R. Jud. Admin. 2.516(b)(1) via transmission of Notice of
Electronic Filinggeneratedby eservice@myflcourtaccess.com or by EFileMadeEasy.com
and/or was sent by electronic mail on August 29,2022 to:
Jonathan Schwartz, Esq. Service@mspglawgroup.com
M.S.P.G. LAW
GROUP, P.A. Jonathan@mspglawgroup.com
770 Ponce De Leon Blvd, Suite 101
Coral Gables, FL 33134
305-444-1887
LAW OFFICES OF HOFFMAN & HOFFMAN, PA.
66 W. FlaglerStreet,Suite
200, Miami, Florida 33130
Telephone:305.372.2877 / Facsimile: 305.372.2875
EService E,-mail: eservice@hoffmanpa.com
By: /s/ Patricia Hamilton, Esq.
John D. Hoffman, Esq.
Board CertifiedCivil Trial Lawyer
Florida Bar No. 825859 / E-mail: john@hoffmanpa.com
Claudia Feldman, Esq.
Florida Bar No. 99646 / E-mail: claudia@hoffmanpa.coin
Patricia Hamilton, Esq.
Florida Bar No. 81683 / E-mail: phamilton@hoffmanpa.com
LAW OFFICE OF HOFFMAN & HOFFMAN P.A. 2
66 W. FlagterStreet, Suite 200, Miami, Florida 33130 - Telephone: 305.372.2877 Fax: 305.372.2875
SCHEDULE A - AREAS OF INQUIRY
Each of the areas of inquirylisted below pertains
to the property located at the following
address:
7837 Orleans Street,Miami, FL 33023
is requestedto designateas its corporate representative
Restore All a person(s)having
knowledge of the followingareas of inquiry:
1. All claims made by or on behalf of Plaintiff for the property located at the above
referenced address.
2. adjust,and/or handle the claim(s)
All steps taken by Restore All to investigate,
reportedby or on behalf of Plaintiff.
3. Inspectionsand knowledge of the above referenced property.
4. Estimates prepared by Restore All concerningthe property located at the above
referenced address.
5. between Restore All and Plaintiff.
Relationship(s)
6. Services provided concerningthe above referenced properties,including but not
limited to all dates when a representative
on behalf of Restore All inspected the above
referenced property and the dates that Restore All was notified of a problem/loss/claim
concerning the above referenced property.
7. Correspondence and communication between Restore All and Plaintiff.
8. Correspondenceand communication between Restore All and M.S.P.G. LAW
GROUP, P.A.
LAW OFFICE OF HOFFMAN & HOFFMAN P.A. 3
66 W. Flagler Street,Suite 200, Miami, Florida 33130 -Telephone: 305.372.2877 Fax: 305.372.2875
SCHEDULE B-DUCES TECUM REQUESTS
Each of the duces tecum requests listed below pertainto the property located at the
following address:
7837 Orleans Street,Miami, FL 33023
Restore All is requestedto produce the documents listed below at, or before,the
depositionof the corporate representative(s)
from: Restore All
1. The organization's
complete file,both physicaland digital,concerningthe property
identified above.
2. All inspection
notes, reports, diagrams,etc. related to the property identified above.
3. All invoices,estimates,and/or other financial documents related to the property
identified above.
correspondence between Restore All and Plaintiff,includingall email
4. All
correspondence,written correspondence,and text messages.
5. All correspondence between Restore All and M.S.P.G. LAW GROUP, P.A., including
all email correspondence.
6. All photographs and/or videos related to the property identified above.
7. All documents received by Restore All concerningthe property identified above.
8. All written or computerizedrecords made by Restore All concerning all
performed by Restore All for the property identified above.
investigations/inspections
9. All estimates or reports prepared or received by Restore All concerning the property
identified above.
10. Allactivity
logs,diaries, claim
claim notes, or log notes created by any adjuster,
manager,
representative, or supervisor of Restore All or any third duringthe
parties
adjustmentof any claim made concerning the property identified above.
LAW OFFICE OF HOFFMAN & HOFFMAN P.A. 4
66 W. Flagler Street, Suite 200, Miami, Florida 33130 -Telephone: 305.372.2877 Fax: 305.372.2875
Preview
Filing# 157327877 E-Filed 09/13/2022 03:54:58 PM RETURN OF SERVICE State of Florida County of Broward Circuit Court Case Number: CACE-21-007603 Court Date: 9/12/2022 3:00 pm Plaintiff: YOANDRIS MIGUEL CASTELLANOS VS. Defendant: CITIZENS PROPERTY INSURANCE CORPORATION For: PATRICIA HAMILTON LAW OFFICES OF HOFFMAN & HOFFMAN, P.A. 66 West Flagler Street Suite 200 Miami, FL 33130 Received by Caplan, Caplan & Caplan Process Servers on the 30th day of August, 2022 at 3:52 pm to be served on RESTORE ALL LLC, 304 INDIAN TRACE, #916, WESTON, FL 33326 I, Luzeneida Gonzalez, do hereby affirm that on the 1 st day of September, 2022 at 2:25 pm, ]: SUBSTITUTE served by deliveringa true copy of the SUBPOENA FOR VIDEOTAPED DEPOSITION DUCES TECUM, ZOOM INSTRUCTIONS, SCHEDULE A, SCHEDULE B, NOTICE OF V]DEOTAPED DEPOSITION.DUgS TECUM, SCHEDULE A, SCHEDULE B to: CARLOS T: a person in charge at the recipientsPRIVATE MAILBOX location at the address of: 304 INDIAN TRACE, #916, WESTON, FL 33326; the only address known discoverable through public record to effect service after reasonable investigationand after determining that the person or business to be served maintains a mailbox at this [ocation, in compliance with Florida Statute 48.031(6)(a). Under penalty of perjury,I declare that I have read the foregoing and that the facts stated in it are true, that l am a Sheriff Appointed Process Server in the county in which this defendant/Witness was served and have no interest in the above action. Pursuant to FS 92.525(2) and 28 USC Section 1746, no notary is required. Luzeneida Go*#aiez 1089 Caplan, Caplan & Caplan Process Servers 12505 Orange Drive Suite 907 Davie, FL 33330 (305) 374-3426 Our Job Serial Number: CPN-2022027117 Ref: 10792 Service Fee: Copyright@ 1992-2022 DreamBuilt Softv,are, Inc. - Process Servers Toolbox V8.2k *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/13/2022 03:54:57 PM.**** r, n.. l IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO: CACE-21-007603 YOANDRIS MIGUEL C Cvr Ic,S 1 CASTELLANOS, Plaintiff(s), DATE 901.ZGJ TIME -2.25P- V. BAUGE# i 089 CITIZENS PROPERTY INSURANCE INITIAL ---C. - CORPORATION Defendant. 66 SUBPOENA FOR VIDEOTAPED DEPOSITION (PLEASE NOTIFY IF AN INTERPRETER WILL BE REQUIR-ED) THE STATE OF FLORIDA: 850 TO: RESTORE ALL LLC 304 Indian Trace #916 ' URS Weston, Fl 33326 YOU ARE COMMANDED to appear via *Zoom Pursuant to the Supreme Court of Florida Administrative Order AOSC20-16, on September 12, 2022, at 3:00 PM, to have your deposition taken in regard to the above referenced matter and to bring with you records requestedin the attached Schedule B. *Zoom information: Join Zoom Meeting https://us06web.zoom.us/j/89223 523246?pwd=dys2WmhKdlklREZFckh5W 1FrSU95dz09 Meeting ID: 892 2352 3246 and Passcode: 212164 Your depositionwill take placeupon oral examination(s) before National Reporting Service,Notary Public in and for the State of Florida at Large, or some other officer duly authorized by law The deposition will to take depositions. be videotapedby National LAW OFFICE OF HOFFMAN & HOFFMAN PA. 1 66 W. FlagierStreet,Suite 200, Miami, Florida 33130- Telephone: 305.372.2877 Fax: 305.372.2875 27117 Reporting Service and/or an employee of the Law Offices of Hoffman & Hoffman, P.A. located at 66 West FlaglerStreet,Suite 200, Miami, Florida 33130. The depositionwill continue from day to day until completed. The depositionis being taken for the purpose of discovery, for use at trial,and/or for such other purposes as are permittedunder the applicableand governing rules. If you (1) fail to appear as provided above; or (2) fail to objectto the Subpoena, you may be in contempt of Court. You are subpoenaed to appear by the followingattorney, and unless excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as directed. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoingwas furnished via Email, pursuant to Fla. R. Jud. Admin. 2.516(b)(1) via transmission of Notice of Electronic Filinggeneratedby eservice@myflcourtaccess.com or by EFileMadeEasy.com and/or was sent by electronic mail on August 29,2022 to: Jonathan Schwartz, Esq. Service@mspglawgroup.com M.S.P.G. LAW GROUP, P.A. Jonathan@mspglawgroup.com 770 Ponce De Leon Blvd, Suite 101 Coral Gables, FL 33134 305-444-1887 LAW OFFICES OF HOFFMAN & HOFFMAN, PA. 66 W. FlaglerStreet,Suite 200, Miami, Florida 33130 Telephone:305.372.2877 / Facsimile: 305.372.2875 EService E,-mail: eservice@hoffmanpa.com By: /s/ Patricia Hamilton, Esq. John D. Hoffman, Esq. Board CertifiedCivil Trial Lawyer Florida Bar No. 825859 / E-mail: john@hoffmanpa.com Claudia Feldman, Esq. Florida Bar No. 99646 / E-mail: claudia@hoffmanpa.coin Patricia Hamilton, Esq. Florida Bar No. 81683 / E-mail: phamilton@hoffmanpa.com LAW OFFICE OF HOFFMAN & HOFFMAN P.A. 2 66 W. FlagterStreet, Suite 200, Miami, Florida 33130 - Telephone: 305.372.2877 Fax: 305.372.2875 SCHEDULE A - AREAS OF INQUIRY Each of the areas of inquirylisted below pertains to the property located at the following address: 7837 Orleans Street,Miami, FL 33023 is requestedto designateas its corporate representative Restore All a person(s)having knowledge of the followingareas of inquiry: 1. All claims made by or on behalf of Plaintiff for the property located at the above referenced address. 2. adjust,and/or handle the claim(s) All steps taken by Restore All to investigate, reportedby or on behalf of Plaintiff. 3. Inspectionsand knowledge of the above referenced property. 4. Estimates prepared by Restore All concerningthe property located at the above referenced address. 5. between Restore All and Plaintiff. Relationship(s) 6. Services provided concerningthe above referenced properties,including but not limited to all dates when a representative on behalf of Restore All inspected the above referenced property and the dates that Restore All was notified of a problem/loss/claim concerning the above referenced property. 7. Correspondence and communication between Restore All and Plaintiff. 8. Correspondenceand communication between Restore All and M.S.P.G. LAW GROUP, P.A. LAW OFFICE OF HOFFMAN & HOFFMAN P.A. 3 66 W. Flagler Street,Suite 200, Miami, Florida 33130 -Telephone: 305.372.2877 Fax: 305.372.2875 SCHEDULE B-DUCES TECUM REQUESTS Each of the duces tecum requests listed below pertainto the property located at the following address: 7837 Orleans Street,Miami, FL 33023 Restore All is requestedto produce the documents listed below at, or before,the depositionof the corporate representative(s) from: Restore All 1. The organization's complete file,both physicaland digital,concerningthe property identified above. 2. All inspection notes, reports, diagrams,etc. related to the property identified above. 3. All invoices,estimates,and/or other financial documents related to the property identified above. correspondence between Restore All and Plaintiff,includingall email 4. All correspondence,written correspondence,and text messages. 5. All correspondence between Restore All and M.S.P.G. LAW GROUP, P.A., including all email correspondence. 6. All photographs and/or videos related to the property identified above. 7. All documents received by Restore All concerningthe property identified above. 8. All written or computerizedrecords made by Restore All concerning all performed by Restore All for the property identified above. investigations/inspections 9. All estimates or reports prepared or received by Restore All concerning the property identified above. 10. Allactivity logs,diaries, claim claim notes, or log notes created by any adjuster, manager, representative, or supervisor of Restore All or any third duringthe parties adjustmentof any claim made concerning the property identified above. LAW OFFICE OF HOFFMAN & HOFFMAN P.A. 4 66 W. Flagler Street, Suite 200, Miami, Florida 33130 -Telephone: 305.372.2877 Fax: 305.372.2875