Miscellaneous: RADFORD, MIKE et al Plaintiff vs MONARCH NATIONAL INSURANCE COMPANY Defendant

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                                Filing # 195442516 E-Filed 04/03/2024 09:46:31 PM


                                                          IN THE CIRCUIT COURT OF THE
                                                          TWENTIETH JUDICIAL CIRCUIT IN AND
                                                          FOR LEE COUNTY, FLORIDA
        KIRK PATRICK,

               PLAINTIFF,                                 CASE NO.:

        VS.

        FLORIDA INSURANCE GUARANTY
        ASSOCIATION, INC. (FIGA),

              DEFENDANT.
        ____________________________________/

                PLAINTIFF’S NOTICE OF TAKING DEPOSITION DUCES TECUM OF
                        DEFENDANT’S CORPORATE REPRESENTATIVE

               PLEASE TAKE NOTICE that the undersigned attorney will take the deposition duces
        tecum of:

        Name: Defendant’s Corporate Representative to discuss the matters set forth on Schedule A ***

        Date: TBD
        Time: TBD
        Place: TBD

                 Upon oral examination before notaries 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. This deposition is being taken for the purpose of discovery, for
        use at trial, or for such other purposes as are permitted under the rules of the court.

               *** In addition to being present at the deposition, you shall have with you the following:
        Your complete claim file(s) related to the insurance the claim(s) which is/are the subject of this
        lawsuit, including but not limited to any and all documents related to any investigation, estimates,
        incident reports, adjuster reports, claim file notes, samples, testing results, correspondence, emails
        photos, videos, assignment of benefits, payments, and any other documents relating to the claim(s),
        and otherwise related to the issues of the lawsuit.

                                                          Respectfully Submitted,

                                                          Attorney for Plaintiff,

                                                          /s/ Irina Tarnovsky
                                                          Irina Tarnovsky, Esq.




                                    eFiled Lee County Clerk of Courts Page 1
                    Florida Bar No. 103397
                    Tarnovsky Law
                    7000 W. Palmetto Park Road, Suite 210
                    Boca Raton, FL 33433
                    Office:    (561) 368-2755
                    Email:     irina@tarnovskylaw.com
                    Email:     brianna@tarnovskylaw.com
                    Email:     service@tarnovskylaw.com
                    Email:     scheduling@tarnovvskylaw.com




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                          SCHEDULE A
   CORPORATE REPRESENTATIVE DEPOSITION DESIGNATION OF MATTERS

The designation of requested matters on which examination is requested, pursuant to
Fla.R.Civ.P. 1.310(b)(6):

1. Each paragraph and/or allegation within the pleadings not otherwise admitted.

2. All of Defendant’s denials and defenses set forth in, or expected to be included within, its
pleadings, motions, and any correspondence relating to the claim.

3. All of Defendant’s discovery responses or anticipated responses.

4. Prior losses, inspections, policy issues, and underwriting issues relating to the scope and
coverages within the policy.

5. All sections, provisions, terms and conditions within the policy and how they relate to the
claim(s).

6. Defendant’s actions or inactions involved with the adjustment of the Claim(s).

7. Defendant’s review and analysis of its adjuster’s/expert’s reports and/or estimates, focusing on
impartiality, bias, accuracy and honesty.

8. The facts and witnesses supporting Defendant’s defenses, denials or expected defenses and
denials.

9. Defendant’s inspection(s) of the propert y prior to the losses at issue.

10. Defendant’s inspection(s) of the property after the loss(es).

11. All documents listed or to be listed by Defendant on its Privilege Log.

12. Defendant’s coverage issues with respect to the Claim(s).

13. The entire claims file(s).




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