On May 15, 2024 a
Party Discovery
was filed
involving a dispute between
Umana, Nelson,
and
Citizens Property Insurance Co,
for Contract And Indebtedness
in the District Court of Pasco County.
Preview
Filing # 198413782 E-Filed 05/15/2024 05:03:14 PM DIN: 7
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| YOUR INSURANCE
(ATTORNEY
SERVED WITH COMPLAINT
RE: NELSON UMANA, v. CITIZENS PROPERTY INSURANCE CORPORATION,
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 yial@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
KANEILY A. VALDES, Esq.
Electronically Filed Pasco Case # 2024CA001316CAAXES 05/15/2024 05:03:14 PM
IN THE CIRCUIT COURT OF THE 6TH
JUDICIAL CIRCUIT IN AND FOR PASCO
COUNTY, FLORIDA
NELSON UMANA,
CASE NO.:
Plaintiff,
Vv.
CITIZENS PROPERTY INSURANCE
CORPORATION,
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
I HEREBY CERTIFY that a true and correct copy of the foregoing was served to: CITIZENS
PROPERTY INSURANCE CORPORATION, on the day of May 2024.
Respectfully Submitted by,
Your Insurance Attorney, PLLC.
2601 South Bayshore Drive Sth Floor.
Coconut Grove, FL 33133
Phone No.: 1-888-570-5677
Fax: 1-888-745-5677
Email: YIAJ@Yourinsuranceattorney.com
Secondary Email:
Eservice@Y ourinsuranceattorney.com
By: /s/ Kaneily A. Valde:
Kaneily A. Valdes, Esq.
Florida Bar No. 1003825
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
May 15, 2024
Case Filing Date
May 15, 2024
Category
Contract And Indebtedness
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