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Filing# 149807038 E-Filed 05/18/2022 10:12:58 AM
IN THE CIRCUIT COURT OF THE 17
7TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE-21-011840
NEIL ESPENDEZ,
Plaintiff(s),
VS.
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
i
RE-NOTICE OF TAKING VIDEO DEPOSITION DUCES TECUM
(Coordinated with Plaintiff's
Counsel)
PLEASE TAKE NOTICE that, pursuant to the Florida Rules of Civil Procedure,
Defendant UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY will take the
depositionset forth below:
NAME OF DEPONENT DATE/TIME LOCATION
Scott D. Dyer of Scott D May 24,2022 at 10:00 a.m. EsquireDepositionSolutions
Dyer Architect, P.A. (Will via Zoom
be Produced by Plaintiff)
Zoom Link:
Will be provided prior to deposition.
Upon oral of Esquire Deposition Solutions, or any
examination before a representative
other officer authorized by law to take depositionin 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
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/18/2022 10:12:57 AM.****
Neil Espendez vs. UPCIC
CASE NO.: CACE-21-011840
Page 2 of 4
deponent have the followingitems listed in Schedule "A" at the time and place of the foregoing
Deposition.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoingwas furnished via E-
Service to: Peter Mineo, Jr.,Esq., The Mineo Salcedo Law Firm, P.A.,
th
on this 18
Counsel, Counsel for Plaintiff, day of May, 2022.
AttorneyMDefendant
Universal Property & Casualty Ins. Co.
PO Box 9388
Fort Lauderdale, Florida 33310
Telephone:954-958-3319
Toll Free: 1-833-658-8594 (JudgesOnly)
Facsimile: 954-958-1262
By: /s/ Omar J. Perez
Omar J. Perez, Esq.
Florida Bar No. 1010823
For Service of Court Documents onlv:
Primary: upciceservice01@universalproperty.com
Secondary er0810@universalproperty.com
Tertiary: op1215@universalproperty.com
For Scheduling Matters:
er0810@universalproperty.com
Please do not send any inquiries or scheduling matters to upciceservice@universalpropertv.com
or upciceservice01@universalpropertv.com.
Neil Espendez vs. UPCIC
CASE NO.: CACE-21-011840
Page 3 of 4
SCHEDULE "A"
DOCUMENTS REQUESTED
1. The Curriculum Vitae (CV) for Scott D. Dyer.
2. All professional
licenses for Scott D. Dyer.
3. All occupationallicenses for Scott D. Dyer.
4. Your entire file,
cover-to-cover, relating to the property located at 2034 NW 183r rd
Terrace, Pembroke Pines, FL 33029 but not limited to:
a. Any and all contracts, agreements, amendments, addendums with the
Plaintiff;
b. Any and all correspondence,e-mail correspondence,and facsimile to the
Plaintiff from you;
c. Any and all correspondence from the Plaintiff to you;
d. Any and all correspondence,e-mail correspondence,and facsimile sent by
you on behalf o f the Plaintiff to third parties;
e.
Any and all documents relating
to the evaluation of the property;
f. Any and all estimates,or reports;
inspections,
g. Any and all inspections,estimates, or reports provided to you by third
partieson behalf o f the Plaintiff;
h. Any and all memoranda, reports, logs, notes, calendar entries, or other
documents evidencing communications with the Plaintiffs or on behalf of the
Plaintiff;
i. Any and all measurements, samples,worksheets, and diagrams;
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, which contain information related directlyor indirectly
to
any proposed expert advice, opinions or testimony which you have or may
render for this claim.
k. Any and all photographs and/or videography. Please provide color
Neil Espendez vs. UPCIC
CASE NO.: CACE-21-011840
Page 4 of 4
photographs (digita!).
1. Any and all measurements, samples, worksheets, and diagrams;
m. Any and all evidence of payment by the Plaintiff,
includinginvoices checks,
bills,and statements for your services in this matter.
5. All time records, diaries and invoices prepared and rendered by you in connection
and evaluation ofthe issues involved in the evaluation or inspectionof the
with your investigation
subjectproperty.
6. All documents furnished to you regardingthe claim, includingbut not limited to
the Plaintiffs and/or Plaintiffs' representatives.
7. All documents created by you regarding the claim.
8. All documents in which you reviewed, referred to, or relied upon in arrivingat any
of your opinions of conclusions as an engineerconcerning the issues involved in the claim,
includingbut not limited to all scientific and technical articles, codes, standards,and
publications,
other materials.
9. Any and all photographs,illustrations, videotape,or other exhibits or documents of
any kind which you intend or contemplateusing explain,illustrate or support your opinionand
to
testimony as an engineerat the trial of this matter. #there is cost involved withproducing same,
please contact the undersigned with a cost-estimate.
10. Copies of all data,literature,
texts, treatises,documents, information,authoritative
material(s)and references considered and relied upon by you as an engineerin forming any
opinionsconcerningthe issues involved in this lawsuit. #there is cost involved with producing
same, please contact the undersigned with a cost-estimate.
11. Copies of all scientific and technical publications,articles,texts, or treatises
authoredby you. Ifthereis costinvoh,edwithproducing same, please contact the undersigned
with a cost-estimate.
12. A listingof any other cases in which you have testified as an expert at trial or by
depositionwithin the last five (5)years.
Preview
Filing# 149807038 E-Filed 05/18/2022 10:12:58 AM IN THE CIRCUIT COURT OF THE 17 7TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-21-011840 NEIL ESPENDEZ, Plaintiff(s), VS. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. i RE-NOTICE OF TAKING VIDEO DEPOSITION DUCES TECUM (Coordinated with Plaintiff's Counsel) PLEASE TAKE NOTICE that, pursuant to the Florida Rules of Civil Procedure, Defendant UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY will take the depositionset forth below: NAME OF DEPONENT DATE/TIME LOCATION Scott D. Dyer of Scott D May 24,2022 at 10:00 a.m. EsquireDepositionSolutions Dyer Architect, P.A. (Will via Zoom be Produced by Plaintiff) Zoom Link: Will be provided prior to deposition. Upon oral of Esquire Deposition Solutions, or any examination before a representative other officer authorized by law to take depositionin 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 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/18/2022 10:12:57 AM.**** Neil Espendez vs. UPCIC CASE NO.: CACE-21-011840 Page 2 of 4 deponent have the followingitems listed in Schedule "A" at the time and place of the foregoing Deposition. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoingwas furnished via E- Service to: Peter Mineo, Jr.,Esq., The Mineo Salcedo Law Firm, P.A., th on this 18 Counsel, Counsel for Plaintiff, day of May, 2022. AttorneyMDefendant Universal Property & Casualty Ins. Co. PO Box 9388 Fort Lauderdale, Florida 33310 Telephone:954-958-3319 Toll Free: 1-833-658-8594 (JudgesOnly) Facsimile: 954-958-1262 By: /s/ Omar J. Perez Omar J. Perez, Esq. Florida Bar No. 1010823 For Service of Court Documents onlv: Primary: upciceservice01@universalproperty.com Secondary er0810@universalproperty.com Tertiary: op1215@universalproperty.com For Scheduling Matters: er0810@universalproperty.com Please do not send any inquiries or scheduling matters to upciceservice@universalpropertv.com or upciceservice01@universalpropertv.com. Neil Espendez vs. UPCIC CASE NO.: CACE-21-011840 Page 3 of 4 SCHEDULE "A" DOCUMENTS REQUESTED 1. The Curriculum Vitae (CV) for Scott D. Dyer. 2. All professional licenses for Scott D. Dyer. 3. All occupationallicenses for Scott D. Dyer. 4. Your entire file, cover-to-cover, relating to the property located at 2034 NW 183r rd Terrace, Pembroke Pines, FL 33029 but not limited to: a. Any and all contracts, agreements, amendments, addendums with the Plaintiff; b. Any and all correspondence,e-mail correspondence,and facsimile to the Plaintiff from you; c. Any and all correspondence from the Plaintiff to you; d. Any and all correspondence,e-mail correspondence,and facsimile sent by you on behalf o f the Plaintiff to third parties; e. Any and all documents relating to the evaluation of the property; f. Any and all estimates,or reports; inspections, g. Any and all inspections,estimates, or reports provided to you by third partieson behalf o f the Plaintiff; h. Any and all memoranda, reports, logs, notes, calendar entries, or other documents evidencing communications with the Plaintiffs or on behalf of the Plaintiff; i. Any and all measurements, samples,worksheets, and diagrams; 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, which contain information related directlyor indirectly to any proposed expert advice, opinions or testimony which you have or may render for this claim. k. Any and all photographs and/or videography. Please provide color Neil Espendez vs. UPCIC CASE NO.: CACE-21-011840 Page 4 of 4 photographs (digita!). 1. Any and all measurements, samples, worksheets, and diagrams; m. Any and all evidence of payment by the Plaintiff, includinginvoices checks, bills,and statements for your services in this matter. 5. All time records, diaries and invoices prepared and rendered by you in connection and evaluation ofthe issues involved in the evaluation or inspectionof the with your investigation subjectproperty. 6. All documents furnished to you regardingthe claim, includingbut not limited to the Plaintiffs and/or Plaintiffs' representatives. 7. All documents created by you regarding the claim. 8. All documents in which you reviewed, referred to, or relied upon in arrivingat any of your opinions of conclusions as an engineerconcerning the issues involved in the claim, includingbut not limited to all scientific and technical articles, codes, standards,and publications, other materials. 9. Any and all photographs,illustrations, videotape,or other exhibits or documents of any kind which you intend or contemplateusing explain,illustrate or support your opinionand to testimony as an engineerat the trial of this matter. #there is cost involved withproducing same, please contact the undersigned with a cost-estimate. 10. Copies of all data,literature, texts, treatises,documents, information,authoritative material(s)and references considered and relied upon by you as an engineerin forming any opinionsconcerningthe issues involved in this lawsuit. #there is cost involved with producing same, please contact the undersigned with a cost-estimate. 11. Copies of all scientific and technical publications,articles,texts, or treatises authoredby you. Ifthereis costinvoh,edwithproducing same, please contact the undersigned with a cost-estimate. 12. A listingof any other cases in which you have testified as an expert at trial or by depositionwithin the last five (5)years.