Preview
Filing # 42731626 E-Filed 06/14/2016 03:31:26 PM
IN THE CIRCUIT COURT, OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE-14-016655 DIV. 02
DEBRA HINES,
Plaintiff,
vs.
HOMEOWNERS CHOICE PROPERTY &
CASUALTY INSURANCE COMPANY, INC.
a Florida Corporation,
Defendant.
/
NOTICE OF PRODUCTION OF N
(Mail in Records Only)
YOU ARE NOTIFIED that after fifteen (15) days from the date of service of this Notice,
the undersigned will issue the attached Subpoena pursuant to Florida Rules of Civil Procedure
1.351 and directed to:
FLORIDA TESTING AND ENVIRONMENTAL, INC.
c/o Sonny Gulati, Registered Agent
5935 S. Florida Avenue
Lakeland, Florida 33813
who is not a party to this action, to produce the items listed at the time and place specified in the
attached Subpoena.
-PARTY
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been
forwarded by electronic mail to: Ryan H. Sherman at eserviceSLPA@gmail.com, and
Morgan Barfield at Mbarfield@ CorlessBarfield.com on this 14" day of June, 2016.
GROELLE & SALMON, P.A.
Attorneys for Defendant
Waterford Plaza
7650 W. Courtney Campbell Causeway
Suite 800
Tampa, FL 33607
(813) 849-7200 (telephone)
(813) 849-7201 (fax)
py, Ser T Debcber
ROBERT T. SCHULTE, ESQ.
HCP.14211 FBN: 88819
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 6/14/2016 3:31:26 PM.****IN THE CIRCUIT COURT, OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE-14-016655 DIV. 02
DEBRA HINES,
Plaintiff,
vs.
HOMEOWNERS CHOICE PROPERTY &
CASUALTY INSURANCE COMPANY, INC.
a Florida Corporation,
Defendant.
SUBPOENA DUCES TECUM
(Mail in Records Only)
STATE OF FLORIDA
TO: FLORIDA TESTING AND ENVIRONMENTAL, INC.
c/o Sonny Gulati, Registered Agent
5935 S. Florida Avenue
Lakeland, Florida 33813
YOU ARE COMMANDED TO PRODUCE TO THE LAW OFFICES OF GROELLE
& SALMON, P.A., 7650 West Courtney Campbell Causeway, Suite 800, Tampa, FL 33607, at
5:00 p.m., , the following items:
All items listed in Exhibit “A” attached hereto.
These items will be inspected and copied. You will not be required to surrender the original
items. You may comply with this Subpoena by providing legible copies of the items to be
produced to the attorney whose name appears on this subpoena on or before the scheduled date
of production. You may condition the preparation of the copies upon the payment in advance of
the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose
name appears on this subpoena and thereby eliminated your appearance at the time andplace specified above. You have the right to object to the production pursuant to this Subpoena
at any time before production by giving written notice to the attorney whose name appears on
this Subpoena.
IF YOU FAIL TO:
appear as specified;
x furnish the records;
object to this Subpoena;
you may be in contempt of Court. You are subpoenaed by the attorneys whose names appear on
this Subpoena and unless excused from this Subpoena by the attorneys or the Court, you shall
respond to this Subpoena as directed.
WITNESS my hand and seal of this Court on this day of » 2016.
GROELLE & SALMON, P.A.
Attorneys for Defendant
7650 W. Courtney Campbell Causeway
Suite 800
Tampa, Florida 33607
(813) 849-7200 (telephone)
(813) 849-7201 (fax)
By:
ROBERT T. SCHULTE, ESQUIRE
FBN: 88819
HCP.142111.
EXHIBIT A
Any and all documents and records pertaining to the property located at 3816 S.
LAKE TERRACE, MIRAMAR, FLORIDA, 33023, and/or DEBRA HINES
(Plaintiff) and/or SHERMAN LAW, P.A. and/or CORLESS BARFIELD TRIAL
GROUP, P.A. (Plaintiff’s Attorneys) This request shall include but not be limited
to:
a,
Any and all file materials, including but not limited to, documents,
videotapes, photos, statements, notes, test results, guidelines, calculations, file
or other materials furnished, reviewed and/or utilized by you in formulating
and rendering any and all expert opinions and/or reports regarding
estimated damages and/or repairs for the property located at 3816 S. LAKE
TERRACE, MIRAMAR, FLORIDA, 33023 including, but not limited to, the
cause of said alleged loss and damages claimed.
Any and all file materials, including but not limited to, notes, drafts, reports,
correspondence, invoices, memoranda, computer generated data, schedules,
working papers, audio tapes, photographs, videotapes or other items or
documents prepared by you in formulating and all expert opinions and/or
reports for the property located at 3816 S. LAKE TERRACE, MIRAMAR.
FLORIDA, 33023.
Any and all documents, including but not limited to, test results, analysis,
time sheets, soil samples, working papers, worksheets, estimates, plans,
engineer’s activity logs, including but not limited to, any and all soil
investigation reports and site plans, any boring location plans or similar
graphs and/or logs prepared by you for the property located at 3816 S.
LAKE TERRACE, MIRAMAR, FLORIDA, 33023.
Any and all time sheets/records and invoices reflecting dates, amount of time
spent, and charges for professional services rendered by employees of
Florida Testing and Environmental, Inc., in connection with the alleged loss
at 3816 S. LAKE TERRACE, MIRAMAR, FLORIDA, 33023 that is the
subject of this lawsuit.
2. The current resume of Florida Testing and Environmental, Inc. employee Sonny
Gulati, and in the event there is no current resume, a copy of his most recent
resume.
3.
A list of, or any documentation that reflects, the styles (names) and case numbers of
all lawsuits in which Florida Testing and Environmental, Inc. employee Sonny
Gulati has testified as an expert witness at trial and/or deposition within the past
three (3) years, which lists or documentation includes, the names, addresses, and
telephone numbers of the parties and attorneys involved in said lawsuit.4. Documents which disclose the nature of the financial relationship between Florida
Testing and Environmental, Inc. and/or Sonny Gulati and the Plaintiff and/or
Plaintiff’s Attorneys. This request shall include but not be limited to:
a. Any documentation relating to any agreement between Sonny Gulati and/or
Florida Testing and Environmental, Inc. and Plaintiff and/or Plaintiff's
Attorneys concerning any payments or income, including but not limited to
any letters of protection or indemnity, deferred payment agreements, or any
other documents of any kind relating to any cost agreements.
b. Any documentation that indicates the number of times Plaintiffs and/or
Plaintiffs’ Attorneys retained:
i. Sonny Gulati and/or
ii. Florida Testing and Environmental, Inc.
for the past three (3) years.
c. Any documentation that indicates the amount of money Plaintiffs and/or
Plaintiffs’ Attorneys have paid:
i. Sonny Gulati and/or
ii. Florida Testing and Environmental, Inc.
for the past three (3) years.
Preview
Filing # 42731626 E-Filed 06/14/2016 03:31:26 PM IN THE CIRCUIT COURT, OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-14-016655 DIV. 02 DEBRA HINES, Plaintiff, vs. HOMEOWNERS CHOICE PROPERTY & CASUALTY INSURANCE COMPANY, INC. a Florida Corporation, Defendant. / NOTICE OF PRODUCTION OF N (Mail in Records Only) YOU ARE NOTIFIED that after fifteen (15) days from the date of service of this Notice, the undersigned will issue the attached Subpoena pursuant to Florida Rules of Civil Procedure 1.351 and directed to: FLORIDA TESTING AND ENVIRONMENTAL, INC. c/o Sonny Gulati, Registered Agent 5935 S. Florida Avenue Lakeland, Florida 33813 who is not a party to this action, to produce the items listed at the time and place specified in the attached Subpoena. -PARTY CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been forwarded by electronic mail to: Ryan H. Sherman at eserviceSLPA@gmail.com, and Morgan Barfield at Mbarfield@ CorlessBarfield.com on this 14" day of June, 2016. GROELLE & SALMON, P.A. Attorneys for Defendant Waterford Plaza 7650 W. Courtney Campbell Causeway Suite 800 Tampa, FL 33607 (813) 849-7200 (telephone) (813) 849-7201 (fax) py, Ser T Debcber ROBERT T. SCHULTE, ESQ. HCP.14211 FBN: 88819 *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 6/14/2016 3:31:26 PM.****IN THE CIRCUIT COURT, OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-14-016655 DIV. 02 DEBRA HINES, Plaintiff, vs. HOMEOWNERS CHOICE PROPERTY & CASUALTY INSURANCE COMPANY, INC. a Florida Corporation, Defendant. SUBPOENA DUCES TECUM (Mail in Records Only) STATE OF FLORIDA TO: FLORIDA TESTING AND ENVIRONMENTAL, INC. c/o Sonny Gulati, Registered Agent 5935 S. Florida Avenue Lakeland, Florida 33813 YOU ARE COMMANDED TO PRODUCE TO THE LAW OFFICES OF GROELLE & SALMON, P.A., 7650 West Courtney Campbell Causeway, Suite 800, Tampa, FL 33607, at 5:00 p.m., , the following items: All items listed in Exhibit “A” attached hereto. These items will be inspected and copied. You will not be required to surrender the original items. You may comply with this Subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminated your appearance at the time andplace specified above. You have the right to object to the production pursuant to this Subpoena at any time before production by giving written notice to the attorney whose name appears on this Subpoena. IF YOU FAIL TO: appear as specified; x furnish the records; object to this Subpoena; you may be in contempt of Court. You are subpoenaed by the attorneys whose names appear on this Subpoena and unless excused from this Subpoena by the attorneys or the Court, you shall respond to this Subpoena as directed. WITNESS my hand and seal of this Court on this day of » 2016. GROELLE & SALMON, P.A. Attorneys for Defendant 7650 W. Courtney Campbell Causeway Suite 800 Tampa, Florida 33607 (813) 849-7200 (telephone) (813) 849-7201 (fax) By: ROBERT T. SCHULTE, ESQUIRE FBN: 88819 HCP.142111. EXHIBIT A Any and all documents and records pertaining to the property located at 3816 S. LAKE TERRACE, MIRAMAR, FLORIDA, 33023, and/or DEBRA HINES (Plaintiff) and/or SHERMAN LAW, P.A. and/or CORLESS BARFIELD TRIAL GROUP, P.A. (Plaintiff’s Attorneys) This request shall include but not be limited to: a, Any and all file materials, including but not limited to, documents, videotapes, photos, statements, notes, test results, guidelines, calculations, file or other materials furnished, reviewed and/or utilized by you in formulating and rendering any and all expert opinions and/or reports regarding estimated damages and/or repairs for the property located at 3816 S. LAKE TERRACE, MIRAMAR, FLORIDA, 33023 including, but not limited to, the cause of said alleged loss and damages claimed. Any and all file materials, including but not limited to, notes, drafts, reports, correspondence, invoices, memoranda, computer generated data, schedules, working papers, audio tapes, photographs, videotapes or other items or documents prepared by you in formulating and all expert opinions and/or reports for the property located at 3816 S. LAKE TERRACE, MIRAMAR. FLORIDA, 33023. Any and all documents, including but not limited to, test results, analysis, time sheets, soil samples, working papers, worksheets, estimates, plans, engineer’s activity logs, including but not limited to, any and all soil investigation reports and site plans, any boring location plans or similar graphs and/or logs prepared by you for the property located at 3816 S. LAKE TERRACE, MIRAMAR, FLORIDA, 33023. Any and all time sheets/records and invoices reflecting dates, amount of time spent, and charges for professional services rendered by employees of Florida Testing and Environmental, Inc., in connection with the alleged loss at 3816 S. LAKE TERRACE, MIRAMAR, FLORIDA, 33023 that is the subject of this lawsuit. 2. The current resume of Florida Testing and Environmental, Inc. employee Sonny Gulati, and in the event there is no current resume, a copy of his most recent resume. 3. A list of, or any documentation that reflects, the styles (names) and case numbers of all lawsuits in which Florida Testing and Environmental, Inc. employee Sonny Gulati has testified as an expert witness at trial and/or deposition within the past three (3) years, which lists or documentation includes, the names, addresses, and telephone numbers of the parties and attorneys involved in said lawsuit.4. Documents which disclose the nature of the financial relationship between Florida Testing and Environmental, Inc. and/or Sonny Gulati and the Plaintiff and/or Plaintiff’s Attorneys. This request shall include but not be limited to: a. Any documentation relating to any agreement between Sonny Gulati and/or Florida Testing and Environmental, Inc. and Plaintiff and/or Plaintiff's Attorneys concerning any payments or income, including but not limited to any letters of protection or indemnity, deferred payment agreements, or any other documents of any kind relating to any cost agreements. b. Any documentation that indicates the number of times Plaintiffs and/or Plaintiffs’ Attorneys retained: i. Sonny Gulati and/or ii. Florida Testing and Environmental, Inc. for the past three (3) years. c. Any documentation that indicates the amount of money Plaintiffs and/or Plaintiffs’ Attorneys have paid: i. Sonny Gulati and/or ii. Florida Testing and Environmental, Inc. for the past three (3) years.