Document for Brickhouse Inspection Inc Plaintiff vs. Citizens Property Insurance Corporation Defendant

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                                Filing #   128126205 E-Filed 06/04/2021 01:22:43 PM




           2148278
            IN THE COUNTY COURT OF THE 17TH JUDICIAL
            CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA

            CASE NO. COSO 21-001383



            BRICKHOUSE INSPECTIONS, INC., Wa/o
            LATOYA WARD,


                Plaintiff,

            V



            CITIZENS PROPERTY INSURANCE
            CORPORATION,

                Defendant.



                               RE-NOTICE OF TAKING DEPOSITION DUCES TECUM
                 (PLEASE CONTACT THE UNDERSIGNED IF AN INTERPRETER IS NEEDED)
                  (COORDINATED WITH ANNE MARIE OF OPPOSING COUNSEL'S OFFICE)


            TO:         Manny M. Tarich, Esquire
                        Attorney for Plaintiff
                        The Tarich Law Firm, P.A.
                        1946 Tyler Street
                        Hollywood, FL 33020


           PLEASE TAKE NOTICE that the undersigned will take the deposition of.

            Name and Address:                  Date and Time:               Place:
            Pif's     Corp. Rep. of            December   7,2021            VIA ZOOM
            Brickhouse       Inspections,      @   10am                     Link will be provided
            Inc.                                                            upon   receipt
            TO BE PRODUCED


           Upon       oral examination before PHIPPS
                                                   REPORTING, Notary Public, or any other Notary
           Public or officer authorized by law to take depositions in the State of Florida. The oral
           examination will continue from day to day until completed. The depositions are being
           taken for the purpose of discovery, for use at trial, or for such other purposes as are
           permitted under the Rules of Court.




                ***
                      FILED: BROWARD   COUNTY, FL BRENDA D. FORMAN, CLERK 06/04/2021 01:22:43 PM.****
                                                                   CASE NO. COSO 21-001383


                                CERTIFICATE OF SERVICE

       I HEREBY CERTIFY that       a   copy of the     foregoing has been served     on   all Counsel


of Record via the Florida   E-Filing Portal   this   dill day of December,   2021.


                                        CONROY SIMBERG
                                        Attorney for Defendant, Citizens Property Insurance
                                        Corporation
                                        5201 Blue Lagoon Drive, Office Number 925
                                        Miami, FL 33126
                                        Telephone: (305) 373-2888
                                        Facsimile: (954) 967-8577
                                        Primary Email:
                                        Secondary Email:




                                        By:       /s/ Rachel H. Minetree
                                                  Rachel H. Minetree, Esquire
                                                  Florida Bar No. 0519774


 CC              PHIPPS REPORTING




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                                                                           CASE NO. COSO 21-001383


                                        AREAS OF TESTIMONY



1.   All issues contained within Plaintiff's Complaint;


2.   Damages      to the   subject property at          issue in this   matter;

3.   Plaintiffs   reason      for   claiming   the denial of the claim      was    not   warranted;

4.   Any computerized damage estimating system                      used    by    the Plaintiff in the   subject
     claim;

5.   Plaintiffs responses to          discovery;

6.   Plaintiff's evaluation of the        subject claim;

7.   License      and     IICRC certification information for all                 employees, contractors,
     tradespersons or         other    representativesinvolved          with the services rendered at the
     subject property;

8.   Plaintiff's inspection of the         subject property subsequent             to the occurrence of the
     subject loss;

9.   Plaintiff's services rendered at the              subject property    in   regards to the subject loss;

10. Plaintiffs services rendered at the                subject property prior to     the   subject loss;

11. Plaintiffs    assignment of benefits;

12. Invoices, bills and             payments concerning         services rendered          arising   out of the
     claimed   loss;

13. All documents Plaintiff produced in                support of the claim presented in this matter;

14.All estimates        prepared by Plaintiff related         to the    subject claim;

15. The   nature, substance and location of all records in Plaintiffs possession, custody,
     care or  control, including expert reports, which pertain to the subject loss and
     subject   claim


16.Any    and all evidence and/or documentation                   demonstrating that an opening             was

     first created   by   a   peril   insured against and rain entered     through the opening.




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