On July 06, 156 a
No Value
was filed
involving a dispute between
Huber, Scott,
and
United Services Automobile Association,
for Insurance Claim
in the District Court of Charlotte County.
Preview
Filing # 184454486 E-Filed 10/20/2023 03:35:35 PM
IN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT, IN AND FOR
CHARLOTTE COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO.: 2023-001812-CA
SCOTT HUBER AND TONYA
HUBER,
Plaintiffs,
VS.
UNITED SERVICES
AUTOMOBILE ASSOCIATION,
Defendant.
/
PLAINTIFF'S MOTION TO COMPEL DEPOSITIONS
Plaintiffs, Scott Huber And Tonya Huber (hereinafter “Plaintiffs”), by and through
undersigned counsel, hereby serve this Motion to Compel Depositions, and state:
1 Plaintiffs requested that Defendant provide dates for Plaintiffs to take the
depositions of Defendant’s Corporate Representative and Field Adjuster on July 14, 2023, July 25,
2023, September 8, 2023, and September 11, 2023.
2. To date, Defendant has failed to provide dates for the requested depositions.
3 Accordingly, Defendant should be compelled to provide available dates for the
depositions of the Corporate Representative and Field Adjuster within the next fifteen (15) days,
for those depositions to occur within the next sixty (60) days.
4 Plaintiffs are entitled to depose these individuals and failure to provide available
dates to depose them has prejudiced Plaintiffs’ case.
5 Plaintiffs have been forced to incur attorney’s fees and costs in preparing, setting
and attending a hearing on this motion.
CASE NO.: 2023-001812-CA
Page | 2 of 2
6 Plaintiffs request that this Court enter sanctions against Defendant including the
attorney’s fees and costs incurred by Plaintiffs in prosecuting this motion.
7 The undersigned certifies that a good faith effort was made to obtain the deposition
dates prior to the filing of this motion.
WHEREFORE, Plaintiffs request that this Court enter an order compelling Defendant to
provide dates for the deposition of its Corporate Representative and Field Adjuster within fifteen
(15) days, for the deposition to take place within sixty (60) days and for such other relief this Court
deems just and proper.
CERTIFICATE OF SERVICE
I CERTIFY that the foregoing document is being served on October 20, 2023, via an
automatic email generated by the Florida Courts E-Filing Portal to: Jose F. Campos, Esq., COLE,
SCOTT & KISSANE, P.A., P.A. (jose.campos@esklegal.com, connor.holzknecht@csklegal.com,
elizabeth.almodovar@csklegal.com, alexander. bistritz@csklegal.com).
INSURANCE LITIGATION GROUP, P.A.
Attorney for Plaintiff
1500 NE 162" Street
Miami, Florida 33162
Telephone: (786) 529-0090
Facsimile: (866) 239-9520
E-Mail: service@ILGPA.com
By: /s/ Faith D. Everett
FAITH D. EVERETT, ESQ.
FL Bar No. 96339
ILG File #: 29704
Claim #: 018674027-010
Case #: 2023-001812-CA
Document Filed Date
January 02, 2024
Case Filing Date
July 06, 156
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Filing # 184454486 E-Filed 10/20/2023 03:35:35 PM IN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT, IN AND FOR CHARLOTTE COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO.: 2023-001812-CA SCOTT HUBER AND TONYA HUBER, Plaintiffs, VS. UNITED SERVICES AUTOMOBILE ASSOCIATION, Defendant. / PLAINTIFF'S MOTION TO COMPEL DEPOSITIONS Plaintiffs, Scott Huber And Tonya Huber (hereinafter “Plaintiffs”), by and through undersigned counsel, hereby serve this Motion to Compel Depositions, and state: 1 Plaintiffs requested that Defendant provide dates for Plaintiffs to take the depositions of Defendant’s Corporate Representative and Field Adjuster on July 14, 2023, July 25, 2023, September 8, 2023, and September 11, 2023. 2. To date, Defendant has failed to provide dates for the requested depositions. 3 Accordingly, Defendant should be compelled to provide available dates for the depositions of the Corporate Representative and Field Adjuster within the next fifteen (15) days, for those depositions to occur within the next sixty (60) days. 4 Plaintiffs are entitled to depose these individuals and failure to provide available dates to depose them has prejudiced Plaintiffs’ case. 5 Plaintiffs have been forced to incur attorney’s fees and costs in preparing, setting and attending a hearing on this motion. CASE NO.: 2023-001812-CA Page | 2 of 2 6 Plaintiffs request that this Court enter sanctions against Defendant including the attorney’s fees and costs incurred by Plaintiffs in prosecuting this motion. 7 The undersigned certifies that a good faith effort was made to obtain the deposition dates prior to the filing of this motion. WHEREFORE, Plaintiffs request that this Court enter an order compelling Defendant to provide dates for the deposition of its Corporate Representative and Field Adjuster within fifteen (15) days, for the deposition to take place within sixty (60) days and for such other relief this Court deems just and proper. CERTIFICATE OF SERVICE I CERTIFY that the foregoing document is being served on October 20, 2023, via an automatic email generated by the Florida Courts E-Filing Portal to: Jose F. Campos, Esq., COLE, SCOTT & KISSANE, P.A., P.A. (jose.campos@esklegal.com, connor.holzknecht@csklegal.com, elizabeth.almodovar@csklegal.com, alexander. bistritz@csklegal.com). INSURANCE LITIGATION GROUP, P.A. Attorney for Plaintiff 1500 NE 162" Street Miami, Florida 33162 Telephone: (786) 529-0090 Facsimile: (866) 239-9520 E-Mail: service@ILGPA.com By: /s/ Faith D. Everett FAITH D. EVERETT, ESQ. FL Bar No. 96339 ILG File #: 29704 Claim #: 018674027-010 Case #: 2023-001812-CA