Preview
Filing# 149509160 E-Filed 05/12/2022 05:53:11 PM
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
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
Person with Most Wednesday, May 25,2022 at EsquireDeposition Solutions via
Knowledge A Crown 1:00 porn. Zoorn
Roofing, Inc.
ZOOM LINK:
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 05/12/2022 05:53:10 PM.****
Neil Espendez vs.UPCIC
CASENO.. CACE-21-011840
Page 2 of 3
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 ofthe foregoingwas furnished via Email
Service to: Peter Mineo, Jr.,Esq.,The Mineo Salcedo Law Firm, P.A., Service@mineolaw.com;
on this
counsel for Plaintiff, ,th
12' day of May, 2022.
AttorneyMDefendant
Universal Property & CasualtyIns. Co.
PO Box 9388
Fort Lauderdale, Florida 33310
Telephone: 954-958-3319
Toll-Fee: 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 upciceserviceO1@universalproperty.com
Secondary: kv0921@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
CASENO.. CACE-21-011840
Page 3 of 3
SCHEDULE "A"
1. Your entire cover-to-cover, relatingto inspectionor repairservices performed by
file(s),
You on behalf of A Crown Roofing, Inc., at the property located at 2034 NW 183 rd
Terrace, Pembroke Pines, FL 33029 ("InsuredProperty")includingbut not limited to:
a. All contracts and agreements relatingto the Insured Property for the past 10
years;
b. All correspondence, e-mail correspondence, and facsimile with the owners ofthe
Insured Property for the past 10 years concerning inspectionor repairservices;
c. All correspondencefrom the owners of the Insured Property to your company for
the past 10 years concerninginspectionor repairservices to be performed at the
Insured Property;
d. All documents concerninginspectionor repairservices to the Insured Property
and related evaluation of damages for the past 10 years;
e. All reports of inspections,
estimates, or repairservices performed at the Insured
Property by your company for the past 10 years;
f. All documents confirming the date and time any work was performed by your
company at the Insured Property,such as reports, logsnotes, or calendar entries;
g. All measurements, samples, worksheets, and diagrams maintained by your
company for the Insured Property;
h. Any all photographs and/or videos taken of the Insured Property. Please
and
provide color photographs. If there is cost involved with producing color
photographs,pleasecontact the undersigned with a cost-estimate.
i. All evidence of any request for payment including invoices,checks, bills,and
statements for your services to perform work at the Insured Property.
j. All invoices, cancelled checks or other evidence of payment for services
performed at the Insured Property, for the past 10 years.
k. Copies of all documents prepared by your company concerning inspectionsor
investigations performed at the Insured Property to determine the cause of any
observed damages for the past 10 years.
1. All professionaland occupationallicenses for A Crown Roofing, Inc.
m. All communications, includingemails and texts, regardingthe Insured Property.
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
SUBPOENA DUCES TECUM FOR DEPOSITION
TO: A Crown Roofing, Inc.
1560 Sawgrass Corporate Pkwy., 4?? Floor,
Sunrise, FL 33323
YOU ARE COMMANDED to appear before a person authorized by law to take
depositionson Wednesday May 25, 2022 at 1:00 PM via Video Conference, Zoom Details
below, for the taking of your depositionin this action and to have with you at that time and place
the following:
ALL MATERIALS LISTED IN "'ATTACHMENT A ,,
Attached hereto and incorporated herein by reference.
ZOOM DETAILS
Neil Espedenz vs.UPCIC
CASE NO.: CACE-21-011840
Please contact the undersigned counsel at er0810@universalprQperty.com and
op 1215@universalproperty.comfor the video conference link for appearance, or to coordinate a
mutual date and time if unavailable at the date and time in this notice.
IF YOU FAIL TO APPEAR, you may be in contempt of court. You are subpoenaed to
appear by the following attorney, and unless excused from this subpoena by this attorney or the
court, you shall respond to this subpoena as directed.
IN ACCORDANCE WITH THE AMERICANS WITH DISABILITIES ACT OF 1990
(ADA), ALL PERSONS WHO ARE DISABLED AND NEED SPECIAL
ACCOMMODATIONS TO PARTICIPATE IN THIS PROCEEDING BECAUSE OF
THAT DISABILITY SHOULD CONTACT TIYA ROLLE, ESQUIRE, AT TELEPHONE
(954) 958-1200 WITHIN 2 WORKING DAYS OF YOUR RECEIPT OF THIS SUBPOENA;
IF YOU ARE HEARING OR VOICE IMPAIRED, CALL 711.
DATED on
,th
this 12 day of May, 2022.
Omar J. Perez, Esq.
Florida Bar No: 1010823
For the Court
/s/ Omar J. Perez, Esq.
AttorneysMDefendant
Universal Property & CasualtyIns. Co.
P.O Box 9388
Fort Lauderdale, Florida 33310
Telephone: 954-958-3319
Toll-Free: 1-833-658-8594 (Judges Only)
Facsimile: 954-958-1262
For Service of Court Documents onlv:
Primary upciceserviceO1@universalproperty.com
Secondary:
er0810@universalproperty.com
Tertiary:
op1215@universalproperty.com
For Scheduling Matters:
er0810@universalproperty.com
Please do not send any inquiriesor scheduling matters to
upciceservice@universalproperty.com or upciceservice01@universalproperty.com.
Neil Espedenz vs.UPCIC
CASE NO.: CACE-21-011840
SCHEDULE "A"
1. Your entire cover-to-cover, relatingto inspectionor repairservices performed by
file(s),
You on behalf of A Crown Roofing, Inc., at the property located at 2034 NW 183 rd
Terrace, Pembroke Pines, FL 33029 ("InsuredProperty")includingbut not limited to:
a. All contracts and agreements relatingto the Insured Property for the past 10
years;
b. All correspondence, e-mail correspondence, and facsimile with the owners ofthe
Insured Property for the past 10 years concerning inspectionor repairservices;
c. All correspondencefrom the owners of the Insured Property to your company for
the past 10 years concerninginspectionor repairservices to be performed at the
Insured Property;
d. All documents concerninginspectionor repairservices to the Insured Property
and related evaluation of damages for the past 10 years;
e. All reports of inspections,
estimates, or repairservices performed at the Insured
Property by your company for the past 10 years;
f. All documents confirming the date and time any work was performed by your
company at the Insured Property,such as reports, logsnotes, or calendar entries;
g. All measurements, samples, worksheets, and diagrams maintained by your
company for the Insured Property;
h. Any all photographs and/or videos taken of the Insured Property. Please
and
provide color photographs. If there is cost involved with producing color
photographs,pleasecontact the undersigned with a cost-estimate.
i. All evidence of any request for payment including invoices,checks, bills,and
statements for your services to perform work at the Insured Property.
j. All invoices, cancelled checks or other evidence of payment for services
performed at the Insured Property, for the past 10 years.
k. Copies of all documents prepared by your company concerning inspectionsor
investigations performed at the Insured Property to determine the cause of any
observed damages for the past 10 years.
1. All professionaland occupationallicenses for A Crown Roofing, Inc.
m. All communications, includingemails and texts, regardingthe Insured Property.
Preview
Filing# 149509160 E-Filed 05/12/2022 05:53:11 PM 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 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 Person with Most Wednesday, May 25,2022 at EsquireDeposition Solutions via Knowledge A Crown 1:00 porn. Zoorn Roofing, Inc. ZOOM LINK: 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 05/12/2022 05:53:10 PM.**** Neil Espendez vs.UPCIC CASENO.. CACE-21-011840 Page 2 of 3 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 ofthe foregoingwas furnished via Email Service to: Peter Mineo, Jr.,Esq.,The Mineo Salcedo Law Firm, P.A., Service@mineolaw.com; on this counsel for Plaintiff, ,th 12' day of May, 2022. AttorneyMDefendant Universal Property & CasualtyIns. Co. PO Box 9388 Fort Lauderdale, Florida 33310 Telephone: 954-958-3319 Toll-Fee: 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 upciceserviceO1@universalproperty.com Secondary: kv0921@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 CASENO.. CACE-21-011840 Page 3 of 3 SCHEDULE "A" 1. Your entire cover-to-cover, relatingto inspectionor repairservices performed by file(s), You on behalf of A Crown Roofing, Inc., at the property located at 2034 NW 183 rd Terrace, Pembroke Pines, FL 33029 ("InsuredProperty")includingbut not limited to: a. All contracts and agreements relatingto the Insured Property for the past 10 years; b. All correspondence, e-mail correspondence, and facsimile with the owners ofthe Insured Property for the past 10 years concerning inspectionor repairservices; c. All correspondencefrom the owners of the Insured Property to your company for the past 10 years concerninginspectionor repairservices to be performed at the Insured Property; d. All documents concerninginspectionor repairservices to the Insured Property and related evaluation of damages for the past 10 years; e. All reports of inspections, estimates, or repairservices performed at the Insured Property by your company for the past 10 years; f. All documents confirming the date and time any work was performed by your company at the Insured Property,such as reports, logsnotes, or calendar entries; g. All measurements, samples, worksheets, and diagrams maintained by your company for the Insured Property; h. Any all photographs and/or videos taken of the Insured Property. Please and provide color photographs. If there is cost involved with producing color photographs,pleasecontact the undersigned with a cost-estimate. i. All evidence of any request for payment including invoices,checks, bills,and statements for your services to perform work at the Insured Property. j. All invoices, cancelled checks or other evidence of payment for services performed at the Insured Property, for the past 10 years. k. Copies of all documents prepared by your company concerning inspectionsor investigations performed at the Insured Property to determine the cause of any observed damages for the past 10 years. 1. All professionaland occupationallicenses for A Crown Roofing, Inc. m. All communications, includingemails and texts, regardingthe Insured Property. 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 SUBPOENA DUCES TECUM FOR DEPOSITION TO: A Crown Roofing, Inc. 1560 Sawgrass Corporate Pkwy., 4?? Floor, Sunrise, FL 33323 YOU ARE COMMANDED to appear before a person authorized by law to take depositionson Wednesday May 25, 2022 at 1:00 PM via Video Conference, Zoom Details below, for the taking of your depositionin this action and to have with you at that time and place the following: ALL MATERIALS LISTED IN "'ATTACHMENT A ,, Attached hereto and incorporated herein by reference. ZOOM DETAILS Neil Espedenz vs.UPCIC CASE NO.: CACE-21-011840 Please contact the undersigned counsel at er0810@universalprQperty.com and op 1215@universalproperty.comfor the video conference link for appearance, or to coordinate a mutual date and time if unavailable at the date and time in this notice. IF YOU FAIL TO APPEAR, you may be in contempt of court. You are subpoenaed to appear by the following attorney, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. IN ACCORDANCE WITH THE AMERICANS WITH DISABILITIES ACT OF 1990 (ADA), ALL PERSONS WHO ARE DISABLED AND NEED SPECIAL ACCOMMODATIONS TO PARTICIPATE IN THIS PROCEEDING BECAUSE OF THAT DISABILITY SHOULD CONTACT TIYA ROLLE, ESQUIRE, AT TELEPHONE (954) 958-1200 WITHIN 2 WORKING DAYS OF YOUR RECEIPT OF THIS SUBPOENA; IF YOU ARE HEARING OR VOICE IMPAIRED, CALL 711. DATED on ,th this 12 day of May, 2022. Omar J. Perez, Esq. Florida Bar No: 1010823 For the Court /s/ Omar J. Perez, Esq. AttorneysMDefendant Universal Property & CasualtyIns. Co. P.O Box 9388 Fort Lauderdale, Florida 33310 Telephone: 954-958-3319 Toll-Free: 1-833-658-8594 (Judges Only) Facsimile: 954-958-1262 For Service of Court Documents onlv: Primary upciceserviceO1@universalproperty.com Secondary: er0810@universalproperty.com Tertiary: op1215@universalproperty.com For Scheduling Matters: er0810@universalproperty.com Please do not send any inquiriesor scheduling matters to upciceservice@universalproperty.com or upciceservice01@universalproperty.com. Neil Espedenz vs.UPCIC CASE NO.: CACE-21-011840 SCHEDULE "A" 1. Your entire cover-to-cover, relatingto inspectionor repairservices performed by file(s), You on behalf of A Crown Roofing, Inc., at the property located at 2034 NW 183 rd Terrace, Pembroke Pines, FL 33029 ("InsuredProperty")includingbut not limited to: a. All contracts and agreements relatingto the Insured Property for the past 10 years; b. All correspondence, e-mail correspondence, and facsimile with the owners ofthe Insured Property for the past 10 years concerning inspectionor repairservices; c. All correspondencefrom the owners of the Insured Property to your company for the past 10 years concerninginspectionor repairservices to be performed at the Insured Property; d. All documents concerninginspectionor repairservices to the Insured Property and related evaluation of damages for the past 10 years; e. All reports of inspections, estimates, or repairservices performed at the Insured Property by your company for the past 10 years; f. All documents confirming the date and time any work was performed by your company at the Insured Property,such as reports, logsnotes, or calendar entries; g. All measurements, samples, worksheets, and diagrams maintained by your company for the Insured Property; h. Any all photographs and/or videos taken of the Insured Property. Please and provide color photographs. If there is cost involved with producing color photographs,pleasecontact the undersigned with a cost-estimate. i. All evidence of any request for payment including invoices,checks, bills,and statements for your services to perform work at the Insured Property. j. All invoices, cancelled checks or other evidence of payment for services performed at the Insured Property, for the past 10 years. k. Copies of all documents prepared by your company concerning inspectionsor investigations performed at the Insured Property to determine the cause of any observed damages for the past 10 years. 1. All professionaland occupationallicenses for A Crown Roofing, Inc. m. All communications, includingemails and texts, regardingthe Insured Property.