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Filing # 128677922 E-Filed 06/14/2021 12:07:21 PM
IN THE COUNTY COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
BRICKHOUSE INSPECTIONS, INC.,
(A/NO LATOYA WARD),
Plaintiff,
Case No.: COSO-21-001383
VS.
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
i
NOTICE OF TAKING DEPOSITION OF
FIELD ADJUSTER
PLEASE BE ADVISED that the undersigned will bring on the deposition of the Field
Adjuster to Citizens Property Insurance Corporationdesignatedby the Plaintiff pursuant to Florida
Rule of Civil Procedure 1.310(b)(1) on Thursday, March 3rd, 2022 at 10:OOAM (ET), to testify
concerning matters identified in Schedule "A" attached hereto. The deponent shall have with
him/her the records identified in Schedule "B" attachedhereto.
NAME DATE & TIME PLACE
Field Adjuster to Citizens Thursday, March 3rd, U.S.Legal Support, Inc.
Property Insurance 2022 at 10:00AM (ET) Via Zoom (Zoom instructionswill be
Corporation provided prior to deposition)
The deposition(s) will take place before an officer qualified to administerthe deposition(s)
at U.S. Legal Support via Zoom.
The deposition(s) shall be conducted pursuant to the Florida Rules of Civil Procedure and
shall be continuedday to day, weekends and holidays accepted, until completed. The deposition(s)
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/14/2021 12:07:21 PM.****
is/are being taken for the purpose of discovery, for use at trial, or both of the foregoing, or for such
other purposes as are pennitted under the applicable and governing rules pursuant to the Florida
Rules of Civil Procedure.
CERTIFICATE OF SERVICE
ith
I HEREBY CERTIFY that a true and correct copy of the foregoing was e-mailed this 14t
day of June 2021 to all parties on the Florida E-Portal Service List.
THE TARICH LAW FIRM P.A.
1946 Tyler Street
Hollywood, Florida 33020
Phone: (305) 503-5097
Facsimile: (866) 858-1226
Primary Email: Manny@TarichLaw.com
Secondary Email:
Alternative Email: Alex@TarichLaw.com
By. /s/ Manny M. Tarich
Manny M. Tarich, Esq.
Florida Bar No. 654876
SCHEDULE A
1. All communications, in any form, by and between Plaintiff and Defendant,
including their respectiveemployees, agents, and representative.
2. All correspondence, emails, letters, memoranda, notes, telephone messages,
recorded conversations, statements, and any other documents or materials that are,
or reflect, communications by and between Plaintiff and Defendant.
3. All facts related to the Insurer's involvementin the insured' s claim as referenced
in the complaint.
4. The adjustment and claim handling ofthe instant claim alleged in the Complaint.
5. All facts and information supporting your defenses to the Plaintiff's claim for
insurance proceeds as alleged in the Complaint.
6. All facts and information supporting any basis for denial, defense or exclusion of
coverage under the Insurance Policy entered into between Plaintiffand Defendant
as referenced in the Complaint.
7. The identity, job title, job description, and activities of all persons (including any
nonemployees) who partic*ated in any way in Defendant's investigation of the
Loss as described in the Complaint.
8. All facts and information Defendant learned during Defendant's investigation,
adjustment, and valuation of Plaintiff" s
claim, which supports the claim decision
made by Defendant regarding Plaintiff's claim.
9. All decisions made by or on behalf of Defendant regarding the adjustment,
investigation, and coverage determination by Defendant of Plaintiff's claim, which
is the subject of the lawsuit and basis for those decisions.
10. All written discovery responses served by Defendant in this matter.
11. All facts, knowledge, and information contained within the Defendant S
underwriting file, and underwriting of the policy that reveal condition of the
property and that may support Defendant's affirmative defenses.
12. All coverages, conditions, exclusions, definitions, etc. for the subjectpolicy.
13. All inspections or examinations of the subject property conducted by Defendant,
including their respective employees, agents, and representatives, with regards to
the subject loss that is the subject matter of the Complaint.
SCHEDULE B
1. Copies of all documents supporting or pertaining to Defendant's affirmative
defenses, or that Defendant anticipateswill support Defendant's reason for denying
Plaintiff's claim.
2. All documents, photographs, videos, or other materials related to the insurance
claim of Plaintiff that Defendant reasonably expects to use at trial, including but
not limited to inspections and examinations that pertain to the damage caused by
the Plaintiff's property.
3. All correspondence, emails, and other documents provided by Plaintiff or its
representatives, to Defendant or its representatives, in any way related to Plaintiff's
claim.
4. All correspondence, emails, and other documents provided by Defendant or its
representatives, to Plaintiffor its representatives, in any way related to Plaintiff's
claim.
5. All documents supporting the action taken and/or coverage decisions made by
Defendant in refusing to pay Plaintiff for their claim.
6. All estimates prepared by or on Defendant in any way related to Plaintiff's claim.
7. All documents evidencing all payments made by Defendant to the Insured and/or
for the Insured's benefit involving a prior claim made by the Insured or prior
damage sustained by an Insured, involving the Insured Property.
8. All documents, written and computerized, memorializing the steps taken by
Defendant to adjust, process, and otherwise handle Plaintiff's claim.
9. All reports prepared by or on behalf of the Defendant in any way related to
Defendant's investigation, evaluation and/or handling o f Plaintiff's claim.
10. All damage estimates, reports or memoranda made by Defendant's adjuster(s)
regarding the extent of damage of Plaintiff's claim.
11. Copies of all photographs, videotapes, estimates, sketches, drawings, filed notes,
estimates for damages, reports relied upon by Defendant, reports prepared by
Defendant or reports prepared for Defendant or on Defendant's behalf or on behalf
o f the Plaintiff' s claim.
12. All property damage inventories, estimates or reports prepared and/or received by
Defendant and upon which Defendant relied in reaching Defendant's conclusions
concerning Plaintiff's claim.
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Filing # 128677922 E-Filed 06/14/2021 12:07:21 PM IN THE COUNTY COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA BRICKHOUSE INSPECTIONS, INC., (A/NO LATOYA WARD), Plaintiff, Case No.: COSO-21-001383 VS. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. i NOTICE OF TAKING DEPOSITION OF FIELD ADJUSTER PLEASE BE ADVISED that the undersigned will bring on the deposition of the Field Adjuster to Citizens Property Insurance Corporationdesignatedby the Plaintiff pursuant to Florida Rule of Civil Procedure 1.310(b)(1) on Thursday, March 3rd, 2022 at 10:OOAM (ET), to testify concerning matters identified in Schedule "A" attached hereto. The deponent shall have with him/her the records identified in Schedule "B" attachedhereto. NAME DATE & TIME PLACE Field Adjuster to Citizens Thursday, March 3rd, U.S.Legal Support, Inc. Property Insurance 2022 at 10:00AM (ET) Via Zoom (Zoom instructionswill be Corporation provided prior to deposition) The deposition(s) will take place before an officer qualified to administerthe deposition(s) at U.S. Legal Support via Zoom. The deposition(s) shall be conducted pursuant to the Florida Rules of Civil Procedure and shall be continuedday to day, weekends and holidays accepted, until completed. The deposition(s) *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/14/2021 12:07:21 PM.**** is/are being taken for the purpose of discovery, for use at trial, or both of the foregoing, or for such other purposes as are pennitted under the applicable and governing rules pursuant to the Florida Rules of Civil Procedure. CERTIFICATE OF SERVICE ith I HEREBY CERTIFY that a true and correct copy of the foregoing was e-mailed this 14t day of June 2021 to all parties on the Florida E-Portal Service List. THE TARICH LAW FIRM P.A. 1946 Tyler Street Hollywood, Florida 33020 Phone: (305) 503-5097 Facsimile: (866) 858-1226 Primary Email: Manny@TarichLaw.com Secondary Email: Alternative Email: Alex@TarichLaw.com By. /s/ Manny M. Tarich Manny M. Tarich, Esq. Florida Bar No. 654876 SCHEDULE A 1. All communications, in any form, by and between Plaintiff and Defendant, including their respectiveemployees, agents, and representative. 2. All correspondence, emails, letters, memoranda, notes, telephone messages, recorded conversations, statements, and any other documents or materials that are, or reflect, communications by and between Plaintiff and Defendant. 3. All facts related to the Insurer's involvementin the insured' s claim as referenced in the complaint. 4. The adjustment and claim handling ofthe instant claim alleged in the Complaint. 5. All facts and information supporting your defenses to the Plaintiff's claim for insurance proceeds as alleged in the Complaint. 6. All facts and information supporting any basis for denial, defense or exclusion of coverage under the Insurance Policy entered into between Plaintiffand Defendant as referenced in the Complaint. 7. The identity, job title, job description, and activities of all persons (including any nonemployees) who partic*ated in any way in Defendant's investigation of the Loss as described in the Complaint. 8. All facts and information Defendant learned during Defendant's investigation, adjustment, and valuation of Plaintiff" s claim, which supports the claim decision made by Defendant regarding Plaintiff's claim. 9. All decisions made by or on behalf of Defendant regarding the adjustment, investigation, and coverage determination by Defendant of Plaintiff's claim, which is the subject of the lawsuit and basis for those decisions. 10. All written discovery responses served by Defendant in this matter. 11. All facts, knowledge, and information contained within the Defendant S underwriting file, and underwriting of the policy that reveal condition of the property and that may support Defendant's affirmative defenses. 12. All coverages, conditions, exclusions, definitions, etc. for the subjectpolicy. 13. All inspections or examinations of the subject property conducted by Defendant, including their respective employees, agents, and representatives, with regards to the subject loss that is the subject matter of the Complaint. SCHEDULE B 1. Copies of all documents supporting or pertaining to Defendant's affirmative defenses, or that Defendant anticipateswill support Defendant's reason for denying Plaintiff's claim. 2. All documents, photographs, videos, or other materials related to the insurance claim of Plaintiff that Defendant reasonably expects to use at trial, including but not limited to inspections and examinations that pertain to the damage caused by the Plaintiff's property. 3. All correspondence, emails, and other documents provided by Plaintiff or its representatives, to Defendant or its representatives, in any way related to Plaintiff's claim. 4. All correspondence, emails, and other documents provided by Defendant or its representatives, to Plaintiffor its representatives, in any way related to Plaintiff's claim. 5. All documents supporting the action taken and/or coverage decisions made by Defendant in refusing to pay Plaintiff for their claim. 6. All estimates prepared by or on Defendant in any way related to Plaintiff's claim. 7. All documents evidencing all payments made by Defendant to the Insured and/or for the Insured's benefit involving a prior claim made by the Insured or prior damage sustained by an Insured, involving the Insured Property. 8. All documents, written and computerized, memorializing the steps taken by Defendant to adjust, process, and otherwise handle Plaintiff's claim. 9. All reports prepared by or on behalf of the Defendant in any way related to Defendant's investigation, evaluation and/or handling o f Plaintiff's claim. 10. All damage estimates, reports or memoranda made by Defendant's adjuster(s) regarding the extent of damage of Plaintiff's claim. 11. Copies of all photographs, videotapes, estimates, sketches, drawings, filed notes, estimates for damages, reports relied upon by Defendant, reports prepared by Defendant or reports prepared for Defendant or on Defendant's behalf or on behalf o f the Plaintiff' s claim. 12. All property damage inventories, estimates or reports prepared and/or received by Defendant and upon which Defendant relied in reaching Defendant's conclusions concerning Plaintiff's claim.