Preview
Filing# 177852268 E-Filed 07/20/2023 11:36:42 AM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
VALERIE BROOKS, CASE NO.: CACE-22-014300
Plaintiff.
VS.
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
i
RE-NOTICE OF TAKING DEPOSITION DUCES TECUM
PLEASE TAKE NOTICE that Defendant, UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY, will take the depositionset forth below:
NAME OF DEPONENT DATE/TIME LOCATION
Travis Baldeo Thursday, November 16, 2023 at Esquire Deposition Solutions
c/o Five Star Claims 10:00 a.m. Via Zoom
Adjusting
Upon oral of EsquireDeposition Solutions, or any
examination before a representative
other officer authorized by law to take depositionsin the State of Florida. The oral examination
will continue from day to day until completed.
This depositionis being taken for the purpose of discovery,for use at or both of the
trial,
foregoing,or for such other purposes as are permittedunder the Florida Rules of Civil Procedure
and other applicablelaw. And, pursuant to Fla. R. Civ. P. 1.350, said Defendant requests the
deponent have the followingitems listed in Schedule "A" at the time and place of the foregoing
deposition,for purposes of inspectionand/or copying by this Defendant.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/20/2023 11:36:42 AM.****
Valerie Brooks v. UPCIC
CASE NO.: CACE-22-014300
Page 2 of 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoingwas furnished via E-
Service to: Michael E. Chisholm, SONDELA LAW LLC, 1825 Ponce De Leon Blvd, Suite: 514,
Coral Gables, FL 33134 on the 20th day of July,2023.
AttorneyM Defendant
Universal Property & CasualtyCompany
P.O. Box 9388
Fort Lauderdale, Florida 33309
Telephone: (954) 958-3319
Toll-Free: 1-833-658-8594 (JudgesOnly)
Facsimile: (954) 958-1262
By: Shannon West
/s/
Shannon West, Esq.
Florida Bar No. 106419
For Service of Court Documents onlv:
Primary upcicservice01@universalpropertv.com
Secondary kpl 102@universalpropertv.com
si0907@universalpropertv.com
Tertiary:
For Scheduling Matters:
kp1102@universalpropertv.com
*Please do not send any inquiries or scheduling matters to
upciceservice@universalpropertv.com or upcicservice01@universalproperty.com.
Valerie Brooks v. UPCIC
CASE NO.: CACE-22-014300
Page 3 of 5
ATTACHMENT"A"
1. Your entire
file(s), to the property located
cover-to-cover, relating at 673 NW 2ND TER,
DEERFIELD BEACH, FL 33441 includingbut not limited to:
a. Any and all contracts, agreements, amendments, addendums with the
insureds;
b. Any and correspondence,e-mail correspondence,and facsimile to the
all
insureds or the insured's agent from you;
c. Any and all correspondencefrom the insureds or the insured s agentto
you;
d. Any and correspondence,e-mail correspondence,and facsimile sent by
all
you or received by you from any third party;
e. Any and all documents relatingto the evaluation of the property;
f. Any and all inspections,
estimates, or reports of the property;
g. Any and all inspections,estimates, or reports provided to you by third
parties;
h. Any and all memoranda, reports, logs, notes, calendar entries, or other
documents regardingthe insureds or the insured's agent or the property;
i. Any and all measurements, samples, worksheets, and diagrams of the
property;
j. Any and all internal working papers, correspondence, notes, preliminary
reports, report work-sheets, graphs,surveys, studies,safetystandards,or other
documentation or data prepared by you or anyone associated with you or
employed by you. Any document containinginformation related directlyor
indirectlyto any proposed expert advice, opinions or testimony which you
have or
may render regarding the property located at 673 NW 2ND TER ,
DEERFIELD BEACH, FL 33441.
k. Any and photographs and/or videographs. Please provide color
all
photographs. If there is cost involved with producing color photographs,
please contact the undersigned with a cost-estimate.
1. Any and all measurements, samples,worksheets, and diagrams;
Valerie Brooks v. UPCIC
CASE NO.: CACE-22-014300
Page 4 of 5
m. Any and evidence of any request for payment of payment(s) by the
all
insureds, includinginvoices,checks, bills,and statements for your services in
this matter.
2. Copies of any and all reports, drafts,charts,drawings,diagrams, and memoranda and/or
results of any testingshowing or intending to show the cause of damage to insured's
property located at 673 NW
2ND TER, DEERFIELD BEACH, FL 33441.
3. All telephone messages to or from you, or any of your employees or contractors
regarding requests for service and/or repairof the subjectproperty located at 673 NW
2ND TER, DEERFIELD BEACH, FL 33441.
4. Any removed from the insured's
material or property that you or your representatives
residence or business located at 673 NW
2ND TER, DEERFIELD BEACH, FL 33441.
5. All documents reflecting any payment made to you by any person or entityfor any reason
as a result of insured's claim for damages allegedlyoccurring on March 8,2022 at 673
NW 2ND TER, DEERFIELD BEACH, FL 33441.
6. All tapes and or transcr*tsof statements taken of any person regarding the insured's
claim for damages occurringon March 8,2022 for the property located at 673 2ND NW
TER, DEERFIELD BEACH, FL 33441.
7. All writings, examination of the property
memoranda, notes or other materials reflecting
located at 673 NW2ND TER , DEERFIELD BEACH, FL 33441 by Deponent or its
agents with respect to the allegeddamage occurringon March 8,2022.
8. A copy of any and all documents maintained by Deponent pertainingto its pricing
policiesand procedures in place for the Broward County on March 8,2022.
9. Copies of any and all manuals, service manuals or instruction manuals for the equipment
utilized at the property located at 673NW 2ND TER, DEERFIELD BEACH, FL 33441.
10. The name and current address of any individual that performed work at the insured's
residence.
11. A complete copy of the personnel file for any individual that performed work at the
insured's residence.
12. Complete copies of the time-sheets,punch-cards or other evidence of time spent working
for any and all employees or individuals that performed work at the insured's residence
for all days that Deponent performed work at insured's home located at 673 NW
2ND
TER, DEERFIELD BEACH, FL 33441.
13. A complete copy of any and all documents, records,sheets,forms, etc. evidencing the
equipment utilized at the property located at 673 NW
2ND TER, DEERFIELD BEACH,
Valerie Brooks v. UPCIC
CASE NO.: CACE-22-014300
Page 5 of 5
FL 33441.
14. Copies of any and all photographs or videotapetaken of the area(s)of the interior of the
home located at 673 NW 2ND TER DEERFIELD BEACH, FL 33441 with respect to
,
the allegeddamage occurringon March 8,2022.
15. Copies of any and all correspondence between insured's and any contractor,
repair/service company providing any services or preparingany estimate for repairswith
respect to allegeddamage occurringon March 8,2022.
16. Copies of any documents which support any claim with respect to the allegeddamage
occurringon March 8,2022.
17. Copies of any and all invoices,cancelled checks or other evidence of payment for repairs,
remodels or renovations made to 673 NW 2ND TER, DEERFIELD BEACH, FL 33441
for the five (5)years priorto the date of loss.
18. Copies of any and inspections,appraisalsor other investigationsfor the property
all
located at 673 NW 2ND TER DEERFIELD BEACH, FL 33441 prior to the date of
,
purchase.
19. The Curriculum Vitae (CV) for Deponent.
20. All professional
licenses for Deponent.
21. All occupationallicenses for Deponent.
Preview
Filing# 177852268 E-Filed 07/20/2023 11:36:42 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA VALERIE BROOKS, CASE NO.: CACE-22-014300 Plaintiff. VS. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. i RE-NOTICE OF TAKING DEPOSITION DUCES TECUM PLEASE TAKE NOTICE that Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, will take the depositionset forth below: NAME OF DEPONENT DATE/TIME LOCATION Travis Baldeo Thursday, November 16, 2023 at Esquire Deposition Solutions c/o Five Star Claims 10:00 a.m. Via Zoom Adjusting Upon oral of EsquireDeposition Solutions, or any examination before a representative other officer authorized by law to take depositionsin the State of Florida. The oral examination will continue from day to day until completed. This depositionis being taken for the purpose of discovery,for use at or both of the trial, foregoing,or for such other purposes as are permittedunder the Florida Rules of Civil Procedure and other applicablelaw. And, pursuant to Fla. R. Civ. P. 1.350, said Defendant requests the deponent have the followingitems listed in Schedule "A" at the time and place of the foregoing deposition,for purposes of inspectionand/or copying by this Defendant. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/20/2023 11:36:42 AM.**** Valerie Brooks v. UPCIC CASE NO.: CACE-22-014300 Page 2 of 5 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoingwas furnished via E- Service to: Michael E. Chisholm, SONDELA LAW LLC, 1825 Ponce De Leon Blvd, Suite: 514, Coral Gables, FL 33134 on the 20th day of July,2023. AttorneyM Defendant Universal Property & CasualtyCompany P.O. Box 9388 Fort Lauderdale, Florida 33309 Telephone: (954) 958-3319 Toll-Free: 1-833-658-8594 (JudgesOnly) Facsimile: (954) 958-1262 By: Shannon West /s/ Shannon West, Esq. Florida Bar No. 106419 For Service of Court Documents onlv: Primary upcicservice01@universalpropertv.com Secondary kpl 102@universalpropertv.com si0907@universalpropertv.com Tertiary: For Scheduling Matters: kp1102@universalpropertv.com *Please do not send any inquiries or scheduling matters to upciceservice@universalpropertv.com or upcicservice01@universalproperty.com. Valerie Brooks v. UPCIC CASE NO.: CACE-22-014300 Page 3 of 5 ATTACHMENT"A" 1. Your entire file(s), to the property located cover-to-cover, relating at 673 NW 2ND TER, DEERFIELD BEACH, FL 33441 includingbut not limited to: a. Any and all contracts, agreements, amendments, addendums with the insureds; b. Any and correspondence,e-mail correspondence,and facsimile to the all insureds or the insured's agent from you; c. Any and all correspondencefrom the insureds or the insured s agentto you; d. Any and correspondence,e-mail correspondence,and facsimile sent by all you or received by you from any third party; e. Any and all documents relatingto the evaluation of the property; f. Any and all inspections, estimates, or reports of the property; g. Any and all inspections,estimates, or reports provided to you by third parties; h. Any and all memoranda, reports, logs, notes, calendar entries, or other documents regardingthe insureds or the insured's agent or the property; i. Any and all measurements, samples, worksheets, and diagrams of the property; j. Any and all internal working papers, correspondence, notes, preliminary reports, report work-sheets, graphs,surveys, studies,safetystandards,or other documentation or data prepared by you or anyone associated with you or employed by you. Any document containinginformation related directlyor indirectlyto any proposed expert advice, opinions or testimony which you have or may render regarding the property located at 673 NW 2ND TER , DEERFIELD BEACH, FL 33441. k. Any and photographs and/or videographs. Please provide color all photographs. If there is cost involved with producing color photographs, please contact the undersigned with a cost-estimate. 1. Any and all measurements, samples,worksheets, and diagrams; Valerie Brooks v. UPCIC CASE NO.: CACE-22-014300 Page 4 of 5 m. Any and evidence of any request for payment of payment(s) by the all insureds, includinginvoices,checks, bills,and statements for your services in this matter. 2. Copies of any and all reports, drafts,charts,drawings,diagrams, and memoranda and/or results of any testingshowing or intending to show the cause of damage to insured's property located at 673 NW 2ND TER, DEERFIELD BEACH, FL 33441. 3. All telephone messages to or from you, or any of your employees or contractors regarding requests for service and/or repairof the subjectproperty located at 673 NW 2ND TER, DEERFIELD BEACH, FL 33441. 4. Any removed from the insured's material or property that you or your representatives residence or business located at 673 NW 2ND TER, DEERFIELD BEACH, FL 33441. 5. All documents reflecting any payment made to you by any person or entityfor any reason as a result of insured's claim for damages allegedlyoccurring on March 8,2022 at 673 NW 2ND TER, DEERFIELD BEACH, FL 33441. 6. All tapes and or transcr*tsof statements taken of any person regarding the insured's claim for damages occurringon March 8,2022 for the property located at 673 2ND NW TER, DEERFIELD BEACH, FL 33441. 7. All writings, examination of the property memoranda, notes or other materials reflecting located at 673 NW2ND TER , DEERFIELD BEACH, FL 33441 by Deponent or its agents with respect to the allegeddamage occurringon March 8,2022. 8. A copy of any and all documents maintained by Deponent pertainingto its pricing policiesand procedures in place for the Broward County on March 8,2022. 9. Copies of any and all manuals, service manuals or instruction manuals for the equipment utilized at the property located at 673NW 2ND TER, DEERFIELD BEACH, FL 33441. 10. The name and current address of any individual that performed work at the insured's residence. 11. A complete copy of the personnel file for any individual that performed work at the insured's residence. 12. Complete copies of the time-sheets,punch-cards or other evidence of time spent working for any and all employees or individuals that performed work at the insured's residence for all days that Deponent performed work at insured's home located at 673 NW 2ND TER, DEERFIELD BEACH, FL 33441. 13. A complete copy of any and all documents, records,sheets,forms, etc. evidencing the equipment utilized at the property located at 673 NW 2ND TER, DEERFIELD BEACH, Valerie Brooks v. UPCIC CASE NO.: CACE-22-014300 Page 5 of 5 FL 33441. 14. Copies of any and all photographs or videotapetaken of the area(s)of the interior of the home located at 673 NW 2ND TER DEERFIELD BEACH, FL 33441 with respect to , the allegeddamage occurringon March 8,2022. 15. Copies of any and all correspondence between insured's and any contractor, repair/service company providing any services or preparingany estimate for repairswith respect to allegeddamage occurringon March 8,2022. 16. Copies of any documents which support any claim with respect to the allegeddamage occurringon March 8,2022. 17. Copies of any and all invoices,cancelled checks or other evidence of payment for repairs, remodels or renovations made to 673 NW 2ND TER, DEERFIELD BEACH, FL 33441 for the five (5)years priorto the date of loss. 18. Copies of any and inspections,appraisalsor other investigationsfor the property all located at 673 NW 2ND TER DEERFIELD BEACH, FL 33441 prior to the date of , purchase. 19. The Curriculum Vitae (CV) for Deponent. 20. All professional licenses for Deponent. 21. All occupationallicenses for Deponent.