On January 30, 2024 a
was filed
involving a dispute between
Dorzema, Frantseau,
Dorzema, Marie,
and
Universal Property And Casualty Insurance Company,
for Contract And Indebtedness
in the District Court of Flagler County.
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Filing # 190862891 E-Filed 01/30/2024 03:40:44 PM
| YOUR INSURANCE
[ATTORNEY
SERVED WITH COMPLAINT
RE: FRANTSEAU DORZEMA AND MARIE DORZEMA vy. UNIVERSAL
PROPERTY & CASUALTY INSURANCE COMPANY
To Whom It May Concern
At this time we would like to request that your office provide five or more dates to
coordinate the deposition of your corporate representative(s), in connection with the above-
referenced matter within one hundred and sixty (160) days. I have attached the proposed areas
of inquiry for your convenience. Please note this is not an exhaustive list and additional areas of
inquiry may be necessary depending upon additional discovery and responses to questions asked
at the deposition. Please forward all dates to yial9@yourinsuranceattorney.com.
Should you have any questions, please do not hesitate to contact us. In the meantime, I
look forward to your anticipated prompt cooperation in this matter. Failure to provide dates
within the prescribed time may necessitate the filing of a Motion to Compel.
Kind Regards,
YOUR INSURANCE ATTORNEY, PLLC
MATTHEW S. MESSINA, Esq.
Electronically Received in the Office of the Clerk of the Circuit Court - Flagler County, Florida - 01/31/2024 08:43 AM - DIN: 8
IN THE CIRCUIT COURT OF THE
7TH JUDICIAL CIRCUIT IN AND FOR
FLAGER COUNTY, FLORIDA
FRANTSEAU DORZEMA AND MARIE
DORZEMA, CASE NO.::
Plaintiff,
v.
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant,
PROPOSED NOTICE OF TAKING DEPOSITION DUCES TECUM
PLEASE TAKE NOTICE that the undersigned attorneys will take the following
deposition at the place, date and time indicated below:
NAME DATE TIME PLACE
Corporate Representative
with knowledge pursuant
to Fla. R. Civ. P.
1.310(b)(6)
In accordance with the Americans with Disabilities Act of 1990, persons needing a special
accommodation to participate in this proceeding should contact the offices of the
undersigned at 305-444-5969
Pursuant to Rule 1.310(b)(6) of the Florida Rules of Civil Procedure, you are hereby requested to
designate one or more officers, directors, managing agents or other persons who consent to
testify on behalf of the parties being deposed as the persons having the most knowledge
concerning the area of the subject matter described on Schedule A attached hereto.
Upon oral examination before a commissioner appointed by the Court, a Notary Public, or any
other officer authorized to administer oaths by the laws of the State of Florida, who is neither a
relative nor employee of such attorney or counsel and who is not financially interested in this
action. The deposition will continue from day to day until completed. The deposition is being
taken for purposes of discovery and for use as evidence in this case, for use at trial, or for such
other purposes as are permitted under the Florida Rules of Civil Procedure.
The deponent is to bring at the above time and place the following documents listed on the
attached Schedule B.
CERTIFICATE OF SERVICE
THEREBY CERTIFY that a true and correct copy of the foregoing was served to: UNIVERSAL
PROPERTY & CASUALTY INSURANCE COMPANY, on the day of January 2024
Respectfully Submitted by,
Your Insurance Attorney, PLLC.
2300 Maitland Center Parkway, Suite 122
Maitland, Florida 32751
Phone No.: (407) 751-1370
Fax: 1-888-745-5677
Email: YIA19@Yourinsuranceattorney.com
Secondary Email: Eservice@Y ourinsuranceattorney.com
By. /s/ Matthew S. Messina, Esq.
Matthew S. Messina, Esq
Florida Bar No. 1033021
Cameron Lewis, Esq
Florida Bar No. 1028356
SCHEDULE A
The allegations set forth in the Complaint.
The Insurance Policy entered into between the Insurer and the Insured as referenced in
the Complaint.
All facts related to the Insurer’s involvement in the Insured’s claim as referenced in the
Complaint.
All facts related to communications between the Insured and agents of the Insurer as it
relates to the allegations set forth in the Complaint
The adjustment and claim handling of the instant claim alleged in the Complaint.
The dollar value of the Insured’s damages.
All facts and information supporting your defenses to the Plaintiff(s) claim for
insurance proceeds as alleged in the Complaint.
All facts and information supporting Your Answer and Affirrmative Defenses.
All facts and information supporting any defense or exclusion of coverage under the
Insurance Policy entered into between Plaintiff and Defendant as referenced in the
Complaint.
SCHEDULE B
1 Please bring a copy of all documents in your possession for the instant Claim as defined
in the Complaint that are not protected by a claimed privilege. If you are not producing
documents pursuant to this Schedule B request because you are claiming a privilege
please provide a privilege log. If a document is not produced and not referenced on a
privilege log we will assume it does not exist
Document Filed Date
February 05, 2024
Case Filing Date
January 30, 2024
Category
Contract And Indebtedness
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Filing # 190862891 E-Filed 01/30/2024 03:40:44 PM | YOUR INSURANCE [ATTORNEY SERVED WITH COMPLAINT RE: FRANTSEAU DORZEMA AND MARIE DORZEMA vy. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY To Whom It May Concern At this time we would like to request that your office provide five or more dates to coordinate the deposition of your corporate representative(s), in connection with the above- referenced matter within one hundred and sixty (160) days. I have attached the proposed areas of inquiry for your convenience. Please note this is not an exhaustive list and additional areas of inquiry may be necessary depending upon additional discovery and responses to questions asked at the deposition. Please forward all dates to yial9@yourinsuranceattorney.com. Should you have any questions, please do not hesitate to contact us. In the meantime, I look forward to your anticipated prompt cooperation in this matter. Failure to provide dates within the prescribed time may necessitate the filing of a Motion to Compel. Kind Regards, YOUR INSURANCE ATTORNEY, PLLC MATTHEW S. MESSINA, Esq. Electronically Received in the Office of the Clerk of the Circuit Court - Flagler County, Florida - 01/31/2024 08:43 AM - DIN: 8 IN THE CIRCUIT COURT OF THE 7TH JUDICIAL CIRCUIT IN AND FOR FLAGER COUNTY, FLORIDA FRANTSEAU DORZEMA AND MARIE DORZEMA, CASE NO.:: Plaintiff, v. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant, PROPOSED NOTICE OF TAKING DEPOSITION DUCES TECUM PLEASE TAKE NOTICE that the undersigned attorneys will take the following deposition at the place, date and time indicated below: NAME DATE TIME PLACE Corporate Representative with knowledge pursuant to Fla. R. Civ. P. 1.310(b)(6) In accordance with the Americans with Disabilities Act of 1990, persons needing a special accommodation to participate in this proceeding should contact the offices of the undersigned at 305-444-5969 Pursuant to Rule 1.310(b)(6) of the Florida Rules of Civil Procedure, you are hereby requested to designate one or more officers, directors, managing agents or other persons who consent to testify on behalf of the parties being deposed as the persons having the most knowledge concerning the area of the subject matter described on Schedule A attached hereto. Upon oral examination before a commissioner appointed by the Court, a Notary Public, or any other officer authorized to administer oaths by the laws of the State of Florida, who is neither a relative nor employee of such attorney or counsel and who is not financially interested in this action. The deposition will continue from day to day until completed. The deposition is being taken for purposes of discovery and for use as evidence in this case, for use at trial, or for such other purposes as are permitted under the Florida Rules of Civil Procedure. The deponent is to bring at the above time and place the following documents listed on the attached Schedule B. CERTIFICATE OF SERVICE THEREBY CERTIFY that a true and correct copy of the foregoing was served to: UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, on the day of January 2024 Respectfully Submitted by, Your Insurance Attorney, PLLC. 2300 Maitland Center Parkway, Suite 122 Maitland, Florida 32751 Phone No.: (407) 751-1370 Fax: 1-888-745-5677 Email: YIA19@Yourinsuranceattorney.com Secondary Email: Eservice@Y ourinsuranceattorney.com By. /s/ Matthew S. Messina, Esq. Matthew S. Messina, Esq Florida Bar No. 1033021 Cameron Lewis, Esq Florida Bar No. 1028356 SCHEDULE A The allegations set forth in the Complaint. The Insurance Policy entered into between the Insurer and the Insured as referenced in the Complaint. All facts related to the Insurer’s involvement in the Insured’s claim as referenced in the Complaint. All facts related to communications between the Insured and agents of the Insurer as it relates to the allegations set forth in the Complaint The adjustment and claim handling of the instant claim alleged in the Complaint. The dollar value of the Insured’s damages. All facts and information supporting your defenses to the Plaintiff(s) claim for insurance proceeds as alleged in the Complaint. All facts and information supporting Your Answer and Affirrmative Defenses. All facts and information supporting any defense or exclusion of coverage under the Insurance Policy entered into between Plaintiff and Defendant as referenced in the Complaint. SCHEDULE B 1 Please bring a copy of all documents in your possession for the instant Claim as defined in the Complaint that are not protected by a claimed privilege. If you are not producing documents pursuant to this Schedule B request because you are claiming a privilege please provide a privilege log. If a document is not produced and not referenced on a privilege log we will assume it does not exist