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Filing# 176565093 E-Filed 06/3 0/2023 03:34:49 PM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
PETER TREPPEDA AND MONICA
TREPPEDA, Case No.: CACE-21-007431
Plaintiff(s),
VS.
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
AMENDED NOTICE OF TAKING VIDEOTAPED DEPOSITION DUCES TECUM
PLEASE TAKE NOTICE that the undersignedattorneys will take the video deposition
Ofi
Name Date and Time Location
Defendant's Expert
Carter Terry July 13, 2023 Zoom Meeting Link
Fort Lauderdale office 2:00 P.M. ET https://app.parrothq.com/d/82669070
560 SW 12th Avenue
Deerfield Beach, FL 33442
This is a that will occur before a Notary Public,or any officer authorized bylaw
videotapeddeposition
to take in the
depositions State of Florida,via Zoom. This depositionwill be videotapedby Parrot,
LLC. This videotapedexamination will continue from day to day until completed.This videotaped
depositionis being taken for the purpose of discovery,for the use at trial or for such other purposes
as are permittedunder the applicable and governing rules of Court. In accordance with Florida Rule
of the depositionwill be videotaped by a duly designatedFlorida
Procedure 1.310(b)(4)(A),
Civil
from Parrot Court Reporting,2261 Market Street #4503 San Francisco, CA
operator/representative
94114. The depositionwill continue from day to day until coinpleted.
In accordance with the Americans with Disabilities Act of 1990, persons needing special
accommodation to participatein this proceedingshould contact the within-named attorney at no later
than seven dayspriorto the proceeding.
Please see the attached Subpoena which will be served upon the deponent, attached
hereto as Exhibit A, including document requests.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/30/2023 03:34:47 PM.****
submitted,
Respectfully
The Property People FL, P.A.
forPlaintiff
Attorneys
80 SW 8th Street,Suite 2590
Miami, FL 33130
Telephone:844.776.7364
E-Service: Service@PropertyPeopleLaw.com
By: /s/ Daniel M. Ilani
Daniel M. Ilani,Esq.
Florida Bar No. 116189
Email: Danny(*PropertyPeopleLaw.com
Nicole S. Houtnan, Esq.
Florida Bar No. 1013527
Email: Nicole@PropertyPeopleLaw.com
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this June 30,2023, a true and correct copy of the foregoing
was served via Florida's e-filingportal to Rafael Reyes, Esq., Attorney for Defendant at
upciceservice01(*universalproperty.com, rr0308(*universalproperty.com,
vb0221@universalproperty.com.
/s/ Daniel M. Ilani
Daniel M. Ilani
EXHIBIT A
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
PETER TREPPEDA AND MONICA
TREPPEDA, Case No.: CACE-21-007431
Plaintiff(s),
VS.
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
SUBPOENA DUCES TECUM
STATE OF FLORIDA
TO: Defendant's Expert
Carter Terry / Fort Lauderdale office
560 SW 12th Avenue, Deerfield Beach, FL 33442
YOU ARE HEREBY COMMANDED to appear via Zoom Video
Conference on July
13, 2023 at 2:00 P.M. ET, and, at least ten davs pnor to Deposition, shall produce all items
regardinga loss at 16425 SAPPHIRE PLACE, WESTON, FL, 33331, with assignedClaim Number
to the subjectmatters described as follows:
FL20-0153899E420, as well as testify
EXHIBIT A
1. All correspondence between you regarding Claim Number:
and the Plaintiff(s) FL20-
0153899E420 and this litigation, their
including agents, regardingthe subjectmatter of this instant
litigation.
2 All correspondence between you and the Defendant regarding Claim Number: FL20-
0153899E420 and this litigation,
includingtheir agents, regardingthe subjectmatter of this instant
litigation.
3 All the Defendant regardingClaim Number: FL20-
correspondencebetween the Plaintiff(s)and
0153899E420 and this litigation,
includingtheir agents, regardingthe subjectmatter of this instant
litigation.
4 All expert reports, includingbut not limited to diagrams,photographs,notes, memoranda, field
notes, samples,contracts, video tapes, calculations,
correspondence, rough drafts,partial
drafts,
and laboratoryreports related in any way to the facts of this Claim or litigation.
5 Any and all written communication between Defendant and any third party concerning the
acceptance, or denial of any portionof Plaintiff(s)'
processing, Claim.
d Any and all materials,papers, documents, photographs or tangiblethingsof any type relied upon
by Defendant, other than the insurance Policy,as a basis for of the Claim.
7. summaries relating
Damage investigation to, or regardingthe subjectClaim.
& Copies of any and all estimates of damages to real property, personal property, expenses for
removal for any coverage available under the subjectproperty.
9.
Copies of any and all documents that show payments made if any, on this Claim.
to Plaintiff(s),
10.
Any and all recorded statements and/or transcripts or his agents,
hereto givenby the Plaintiff(s),
to the Defendant, or its agents.
11.
Any and all statements taken by, for,or on behalf of the Defendant regardingthe subjectClaim
forinsurance.
12 Any materials,documents or tangiblethingsprovidedto Defendant by the Plaintiff(s),
or their
agents, before the commencement of litigation
in the matter.
13 All of loss or value of loss preparedby, for, or on behalf of the Defendant regarding
appraisals
the subjectloss of the Plaintiff(s).
14 Copies of any diagrams,models, drawings,sketches, blueprints
or any other reproductionof the
subjectrisk made before or after the subjectloss.
15. Copies of any and all Proofs of Loss forms submitted by Plaintiff(s),
or their agents, to Defendant,
with copiesof all supportingdocuments.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this June 30,2023, a true and correct copy of the foregoing
was served via Florida's e-filingportal to Rafael Reyes, Esq., Attorney for Defendant at
upciceservice01@universalproperty.com, rr0308@universalproperty.com,
vb0221(*universalproperty.com.
/s/ DanielM. Ilani
Daniel M. Ilani
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Filing# 176565093 E-Filed 06/3 0/2023 03:34:49 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA PETER TREPPEDA AND MONICA TREPPEDA, Case No.: CACE-21-007431 Plaintiff(s), VS. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. AMENDED NOTICE OF TAKING VIDEOTAPED DEPOSITION DUCES TECUM PLEASE TAKE NOTICE that the undersignedattorneys will take the video deposition Ofi Name Date and Time Location Defendant's Expert Carter Terry July 13, 2023 Zoom Meeting Link Fort Lauderdale office 2:00 P.M. ET https://app.parrothq.com/d/82669070 560 SW 12th Avenue Deerfield Beach, FL 33442 This is a that will occur before a Notary Public,or any officer authorized bylaw videotapeddeposition to take in the depositions State of Florida,via Zoom. This depositionwill be videotapedby Parrot, LLC. This videotapedexamination will continue from day to day until completed.This videotaped depositionis being taken for the purpose of discovery,for the use at trial or for such other purposes as are permittedunder the applicable and governing rules of Court. In accordance with Florida Rule of the depositionwill be videotaped by a duly designatedFlorida Procedure 1.310(b)(4)(A), Civil from Parrot Court Reporting,2261 Market Street #4503 San Francisco, CA operator/representative 94114. The depositionwill continue from day to day until coinpleted. In accordance with the Americans with Disabilities Act of 1990, persons needing special accommodation to participatein this proceedingshould contact the within-named attorney at no later than seven dayspriorto the proceeding. Please see the attached Subpoena which will be served upon the deponent, attached hereto as Exhibit A, including document requests. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/30/2023 03:34:47 PM.**** submitted, Respectfully The Property People FL, P.A. forPlaintiff Attorneys 80 SW 8th Street,Suite 2590 Miami, FL 33130 Telephone:844.776.7364 E-Service: Service@PropertyPeopleLaw.com By: /s/ Daniel M. Ilani Daniel M. Ilani,Esq. Florida Bar No. 116189 Email: Danny(*PropertyPeopleLaw.com Nicole S. Houtnan, Esq. Florida Bar No. 1013527 Email: Nicole@PropertyPeopleLaw.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this June 30,2023, a true and correct copy of the foregoing was served via Florida's e-filingportal to Rafael Reyes, Esq., Attorney for Defendant at upciceservice01(*universalproperty.com, rr0308(*universalproperty.com, vb0221@universalproperty.com. /s/ Daniel M. Ilani Daniel M. Ilani EXHIBIT A IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA PETER TREPPEDA AND MONICA TREPPEDA, Case No.: CACE-21-007431 Plaintiff(s), VS. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. SUBPOENA DUCES TECUM STATE OF FLORIDA TO: Defendant's Expert Carter Terry / Fort Lauderdale office 560 SW 12th Avenue, Deerfield Beach, FL 33442 YOU ARE HEREBY COMMANDED to appear via Zoom Video Conference on July 13, 2023 at 2:00 P.M. ET, and, at least ten davs pnor to Deposition, shall produce all items regardinga loss at 16425 SAPPHIRE PLACE, WESTON, FL, 33331, with assignedClaim Number to the subjectmatters described as follows: FL20-0153899E420, as well as testify EXHIBIT A 1. All correspondence between you regarding Claim Number: and the Plaintiff(s) FL20- 0153899E420 and this litigation, their including agents, regardingthe subjectmatter of this instant litigation. 2 All correspondence between you and the Defendant regarding Claim Number: FL20- 0153899E420 and this litigation, includingtheir agents, regardingthe subjectmatter of this instant litigation. 3 All the Defendant regardingClaim Number: FL20- correspondencebetween the Plaintiff(s)and 0153899E420 and this litigation, includingtheir agents, regardingthe subjectmatter of this instant litigation. 4 All expert reports, includingbut not limited to diagrams,photographs,notes, memoranda, field notes, samples,contracts, video tapes, calculations, correspondence, rough drafts,partial drafts, and laboratoryreports related in any way to the facts of this Claim or litigation. 5 Any and all written communication between Defendant and any third party concerning the acceptance, or denial of any portionof Plaintiff(s)' processing, Claim. d Any and all materials,papers, documents, photographs or tangiblethingsof any type relied upon by Defendant, other than the insurance Policy,as a basis for of the Claim. 7. summaries relating Damage investigation to, or regardingthe subjectClaim. & Copies of any and all estimates of damages to real property, personal property, expenses for removal for any coverage available under the subjectproperty. 9. Copies of any and all documents that show payments made if any, on this Claim. to Plaintiff(s), 10. Any and all recorded statements and/or transcripts or his agents, hereto givenby the Plaintiff(s), to the Defendant, or its agents. 11. Any and all statements taken by, for,or on behalf of the Defendant regardingthe subjectClaim forinsurance. 12 Any materials,documents or tangiblethingsprovidedto Defendant by the Plaintiff(s), or their agents, before the commencement of litigation in the matter. 13 All of loss or value of loss preparedby, for, or on behalf of the Defendant regarding appraisals the subjectloss of the Plaintiff(s). 14 Copies of any diagrams,models, drawings,sketches, blueprints or any other reproductionof the subjectrisk made before or after the subjectloss. 15. Copies of any and all Proofs of Loss forms submitted by Plaintiff(s), or their agents, to Defendant, with copiesof all supportingdocuments. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this June 30,2023, a true and correct copy of the foregoing was served via Florida's e-filingportal to Rafael Reyes, Esq., Attorney for Defendant at upciceservice01@universalproperty.com, rr0308@universalproperty.com, vb0221(*universalproperty.com. /s/ DanielM. Ilani Daniel M. Ilani