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Filing # 120856735 E-Filed 02/04/2021 04:24:48 PM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT,
IN AND FOR BROWARD COUNTY, FLORIDA
KEITH FORBES,
Plaintiff,
v. CASE NO.: CACE-20-017837
HERITAGE PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
/
PLAINTIFF'S MOTION TO COMPEL EARLIER DEPOSITION DATES
COME NOW, Plaintiff, KEITH FORBES, this Court to compel Defendant’s
Corporate Representative depositions and states:
1. This case arises from a claim for homeowner’s insurance benefits as a result of
damage to the insured’s property.
2. By and through counsel, Plaintiff has sought the deposition of a basic fact witness
known or discovered to have knowledge concerning Plaintiff's insurance claim
3. The identity of this witness is defendant’s corporate representative pursuant to Fla.
R. Civ. P. 1. 310 (b)(6), has been derived by documents and information made known to Plaintiff's
through the claim and/or pre-trial discovery process.
4. On February 3, 2021, Defendant advised that dates for Corporate Representative’s
deposition will be provided to Plaintiff within the next (30) thirty days for deposition to occur in
the next (120) one hundred twenty days. See e-mail correspondence dated February 3, 2021,
attached hereto as Exhibit “A.”
5. This time frame offered by Defendant for its Corporate Representative’s deposition
in this matter unreasonably delays the case and there is no good faith basis or justification as to
why this deposition cannot be completed within sixty (60) to ninety (90) days.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/04/2021 04:24:48 PM.****6. Delaying discovery for this period of time is not only prejudicial to the Plaintiff but
has the unintended consequence of preventing efficient disposition of the Court’s docket.
7. Plaintiff's counsel submits that he has conferred or attempted to confer with
Defendant’s counsel in an effort to resolve the issues herein but have been unable to do so.
WHEREFORE, Plaintiff, Keith Forbes, respectfully request that this Honorable Court
enter an order (i) granting this Motion, (ii) compelling Defendant to coordinate dates for the
requested deposition to occur within ninety (90) days, and (iii) for any other relief deemed just and
proper.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via
the E-Portal to Attorney for Heritage Property & Casualty Insurance Company, Precious M.
Lawrence, Esq., at PLawrence@heritagepci.com; eservice@heritagepci.com on this 4" day
of February 2021.
By: /s/ Aaron D. Silvers
AARON D. SILVERS, ESQ.
Florida Bar No: 104811
WEISSER, ELAZAR & KANTOR, PLLC
Attorneys for Plaintiffs
800 East Broward Boulevard, Suite 510
Fort Lauderdale, FL 33301
T: (954) 486-2623 / F: (954) 572-8695
Email: AS@WEKLaw.com
DAR@WEKLaw.comExhibit A
From: Dialen Ariste
To: Jessica DeBlasio
Co: Aaron Silvers
Subject: RE: FORBES, KEITH VS HERITAGE PROPERTY & CASUALTY | CACE-20-017837 - CR/FA Depos - 1st Req
Date: Wednesday, February 3, 2021 3:59:42 PM
Attachments: image002.pnq
imaqe006.pnq
image008.pnq
image009.pnq
Jessica,
I will reiterate my response to your email concerning CR’s depo, we cannot agree to push
their deposition as far as June 28" as it will delay this matter even further.
If dates cannot be provided for depositions to take place within 90 days we will have to move to
compel earlier dates.
Can your office provide dates sooner than June?
Thank you,
Dialen Ariste
Legal Assistant to Aaron Silvers, Esq.
¢
Weisser Elazar & Kantor, PLLC
800 East Broward Boulevard, Suite 510
Fort Lauderdale, Florida 33301
T: (954) 486-2623
F; (954) 572-8695
www.weklaw.com
CONFIDENTIALITY NOTICE:“This message and any attached information is from Weisser
Elazar & Kantor PLLC, and may contain confidential and/or privileged material. It is intended for
receipt and review only by the intended person or entity to which it is addressed. Any review,
retransmission, dissemination or other use of this information by persons or entities other than the
recipient(s) is unauthorized and prohibited. Any transmission of confidential and/or privileged
material to persons or entities other than the intended recipient(s) shall not be construed as a waiver
of any privilege or confidence. If you receive this transmission in error, please contact the sender by
return e-mail and delete the material.”
From: Jessica DeBlasio
Sent: Wednesday, February 3, 2021 3:53 PM
To: Dialen Ariste
Cc: Aaron Silvers
Subject: RE: FORBES, KEITH VS HERITAGE PROPERTY & CASUALTY | CACE-20-017837 - CR/FA Depos -
Ist Req
Importance: HighDialen:
Good afternoon, respectfully please do not unilaterally the corporate representative’s deposition as
indicated below. | sent you the following request in the attached email on 1/29 and have not heard
back from your office until now:
As to your request for Corporate Representative deposition dates will you agree for us to provide
dates within the next 30 days for the deposition to occur in the next 120 days? Please advise and
thank you.
Please advise and thank you.
*NOTE: Pursuant to our company’s COVID-19 policy, most of our staff is working
remotely. Please allow our office additional time in which to respond to e-mails and
telephone calls during this time. Due to the current situation, staff members may not
receive all telephone calls. If you are trying to reach a staff member, please be sure
to send an e-mail to the staff member, rather than relying solely upon voice
messages. Thank you in advance for your understanding and patience.
Jessica DeBlasio
Legal Assistant to
Precious M. Lawrence, Esq.
Iftikhar Memon, Esq.
Staff Counsel
Heritage Property & Casualty Insurance Company
1571 Sawgrass Corporate Parkway
Suite 400
Sunrise, FL 33323
Ph: 954-315-1450 Ex. 7007
www.heritagepci.com
HERITAGE
Insurance
Pillars of Strength and Character.
“Note: We will not hold dates without a notice. If we do not receive a notice within 48 hours of
confirmation of any event, we will release that date and it will be given to another matter. “
CONFIDENTIALITY NOTICE: The information contained in this transmittal, including any attachment, is privileged
and confidential information and is intended only for the person or entity to which it is addressed. If you are neither
the intended recipient nor the employee or agent responsible for delivering this message to the intended recipient,
you are hereby notified that any disclosure, copying or distribution or taking action in reliance on the contents of
this transmittal is strictly prohibited. If you have received this transmittal in error, please contact the sender
immediately and delete this transmittal from any computer or other data bank.
Este mensaje es confidencial y puede contener informacién amparada por el secreto profesional. Si usted ha
recibido este e-mail por error, por favor comuniquelo inmediatamente via e-mail y tenga la amabilidad de
destruirlo; no debera copiar el mensaje ni divulgar su contenido a ninguna persona.P Please consider the environment before printing this email.
From: Dialen Ariste
Sent: Wednesday, February 3, 2021 3:42 PM
To: Jessica DeBlasio
Ce: Aaron Silvers
Subject: RE: FORBES, KEITH VS HERITAGE PROPERTY & CASUALTY | CACE-20-017837 - CR/FA Depos -
‘Ast Req
CAUTION: This email originated from outside the organization. Do NOT click links
lor open attachments unless you validate the sender and know the content is safe.
HPlease contact IT - Helpdesk if you believe this email is suspicious.
Helio Jessica,
I’m following up on our request to take the deposition of the designated Corporate Rep. Please see
dates below and advise.
March 234 Afternoon
March 25" Afternoon
March 31 Morning
April 1°! Afternoon
April 2" Morning
April 6"" Any time
April 8™ Any time
April gth Any time
Should we not hear from your office by the end of business Friday 1/5, we will select from one of
the dates above and set accordingly.
Thank you,
Dialen Ariste
Legal Assistant to Aaron Silvers, Esq.
y 4
Weisser Elazar & Kantor, PLLC
800 East Broward Boulevard, Suite 510
Fort Lauderdale, Florida 33301
T: (954) 486-2623
F: (954) 572-8695
www.weklaw.com
“This message and any attached information is from Weisser
Elazar & Kantor PLLC, and may contain confidential and/or privileged material. It is intended forreceipt and review only by the intended person or entity to which it is addressed. Any review,
retransmission, dissemination or other use of this information by persons or entities other than the
recipient(s) is unauthorized and prohibited. Any transmission of confidential and/or privileged
material to persons or entities other than the intended recipient(s) shall not be construed as a waiver
of any privilege or confidence. If you receive this transmission in error, please contact the sender by
return e-mail and delete the material.”
From: Dialen Ariste
Sent: Friday, January 29, 2021 2:28 PM
To: ‘Jessica DeBlasio'
Ce: Aaron Silvers
Subject: RE: FORBES, KEITH VS HERITAGE PROPERTY & CASUALTY | CACE-20-017837 - CR/FA Depos -
Ast Req
Good afternoon,
Attached hereto please find Plaintiff's NOD, which I will also forward to the FA via the
email provide by your office.
As for the CR, we cannot agree to push their deposition as far as June 28" as it will delay
this matter even further.
If dates cannot be provided for depositions to take place within 90 days we will have to move to
compel earlier dates.
Please advise.
Thank you,
Dialen Ariste
Legal Assistant to Aaron Silvers, Esq.
c
Weisser Elazar & Kantor, PLLC
800 East Broward Boulevard, Suite 510
Fort Lauderdale, Florida 33301
T: (954) 486-2623
F; (954) 572-8695
www.weklaw.com
CONFIDENTIALITY NOTICE:“This message and any attached information is from Weisser
Elazar & Kantor PLLC, and may contain confidential and/or privileged material. It is intended for
receipt and review only by the intended person or entity to which it is addressed. Any review,
retransmission, dissemination or other use of this information by persons or entities other than the
recipient(s) is unauthorized and prohibited. Any transmission of confidential and/or privileged
material to persons or entities other than the intended recipient(s) shall not be construed as a waiver
of any privilege or confidence. If you receive this transmission in error, please contact the sender by
return e-mail and delete the material.”From: Jessica DeBlasio
Sent: Friday, January 29, 2021 11:02 AM
To: Dialen Ariste
Cc: Aaron Silvers
Subject: RE: FORBES, KEITH VS HERITAGE PROPERTY & CASUALTY | CACE-20-017837 - CR/FA Depos -
Ast Req
Importance: High
Good morning. Please be advised my FA is available for zoom deposition on 3/24/2021 — 1:00 p.m.
My FA Jeff Parady has requested you serve him via email at the following email address (we will not
be producing him): allaroundadjusting@gmail.com. Please file the Notice.
As to your request for Corporate Representative deposition dates will you agree for us to provide
dates within the next 30 days for the deposition to occur in the next 120 days? Please advise and
thank you.
*NOTE: Pursuant to our company’s COVID-19 policy, most of our staff is working
remotely. Please allow our office additional time in which to respond to e-mails and
telephone calls during this time. Due to the current situation, staff members may not
receive all telephone calls. If you are trying to reach a staff member, please be sure
to send an e-mail to the staff member, rather than relying solely upon voice
messages. Thank you in advance for your understanding and patience.
Jessica DeBlasio
Legal Assistant to
Precious M. Lawrence, Esq.
Iftikhar Memon, Esq.
Staff Counsel
Heritage Property & Casualty Insurance Company
1571 Sawgrass Corporate Parkway
Suite 400
Sunrise, FL 33323
Ph: 954-315-1450 Ex. 7007
deblasio@heritagepci.com
rit i.
HERITAGE
Insurance
Pillars of Strength and Character.
“Note: We will not hold dates without a notice. If we do not receive a notice within 48 hours of
confirmation of any event, we will release that date and it will be given to another matter. “CONFIDENTIALITY NOTICE: The information contained in this transmittal, including any attachment, is privileged
and confidential information and is intended only for the person or entity to which it is addressed. If you are neither
the intended recipient nor the employee or agent responsible for delivering this message to the intended recipient,
you are hereby notified that any disclosure, copying or distribution or taking action in reliance on the contents of
this transmittal is strictly prohibited. If you have received this transmittal in error, please contact the sender
immediately and delete this transmittal from any computer or other data bank.
Este mensaje es confidencial y puede contener informacion amparada por el secreto profesional. Si usted ha
recibido este e-mail por error, por favor comuniquelo inmediatamente via e-mail y tenga la amabilidad de
destruirlo; no debera copiar el mensaje ni divulgar su contenido a ninguna persona.
P Please consider the environment before printing this email.
From: Dialen Ariste
Sent: Thursday, January 28, 2021 2:53 PM
To: Precious Lawrence ; HPCI Eservice ;
Jessica DeBlasio
Ce: Aaron Silvers
Subject: RE: FORBES, KEITH VS HERITAGE PROPERTY & CASUALTY | CACE-20-017837 - CR/FA Depos -
1st Req
ECAUTION: This email originated from outside the organization. Do NOT click links
lg open attachments unless you validate the sender and know the content is safe.
‘eeeekcon eta ie Helpdesk if you believe this email is suspicious.
Dear counsel, 1° Attempt
We are requesting to depose the Corporate Representative and Field Adjuster relating to the above-
referenced matter within the next 60 — 90 days. Please see dates of availability below and advise
March 23" Any time
March 24" Any time
March 25" afternoon
March 30 1:00pm
March 31° 9:00am
April 2"¢ Morning
April 5 9:00am
April 6th _ oth Any time
**Should we not hear from your office by the end of business Monday, we will select from one of
the dates above and set accordingly.
Thank you,
Dialen Ariste
Legal Assistant to Aaron Silvers, Esq.¢
ar & Kantor, PLUG
800 East Broward Boulevard, Suite 510
Fort Lauderdale, Florida 33301
T: (954) 486-2623
F: (954) 572-8695
www.weklaw,com
Weisser
CONFIDENTIALITY NOTICE:“This message and any attached information is from Weisser
Elazar & Kantor PLLC, and may contain confidential and/or privileged material. It is intended for
receipt and review only by the intended person or entity to which it is addressed. Any review,
retransmission, dissemination or other use of this information by persons or entities other than the
recipient(s) is unauthorized and prohibited. Any transmission of confidential and/or privileged
material to persons or entities other than the intended recipient(s) shall not be construed as a waiver
of any privilege or confidence. If you receive this transmission in error, please contact the sender by
return e-mail and delete the material.”
From: Dialen Ariste
Sent: Thursday, January 7, 2021 2:29 PM
To: Precious Lawrence ; HPCI Eservice ;
Jessica DeBlasio
Cc: Aaron Silvers
Subject: RE: FORBES, KEITH VS HERITAGE PROPERTY & CASUALTY | CACE-20-017837 AO Motion For
Extension Of Time
Dear counsel:
Thad to revise the AO to also include Defendant’s MET to Respond to Plaintiff's Discovery. Please
review the revised AO and advise and I will submit.
Thank you,
Dialen Ariste
Legal Assistant to Aaron Silvers, Esq.
800 East Broward Boulevard, Suite 510
Fort Lauderdale, Florida 33301
T: (954) 486-2623
F: (954) 572-8695
www.weklaw.com
CONFIDENTIALITY NOTICE:“This message and any attached information is from Weisser
Elazar & Kantor PLLC, and may contain confidential and/or privileged material. It is intended for
receipt and review only by the intended person or entity to which it is addressed. Any review,
retransmission, dissemination or other use of this information by persons or entities other than therecipient(s) is unauthorized and prohibited. Any transmission of confidential and/or privileged
material to persons or entities other than the intended recipient(s) shall not be construed as a waiver
of any privilege or confidence. If you receive this transmission in error, please contact the sender by
return e-mail and delete the material.”
From: Precious Lawrence
Sent: Thursday, January 7, 2021 2:19 PM
To: Dialen Ariste ; HPCI Eservice ; Jessica DeBlasio
Ce: Aaron Silvers
Subject: RE: FORBES, KEITH VS HERITAGE PROPERTY & CASUALTY | CACE-20-017837 AO Motion For
Extension Of Time
No objection. May you kindly submit? Thank you!
Sincerely,
Precious M. Lawrence, Esq.
Staff Counsel
1571 Sawgrass Corporate Parkway, Suite 400
Sunrise, Florida 33323
Office: 727-362-7200 ext. 7460
Mobile: 954-205-0244
www.
FB) ERLIAGE
Pillars of Strength and Character.
o
*NOTE: Pursuant to our company’s COVID-19 policy, most of our staff is working
remotely. Please allow our office additional time in which to respond to e-mails and
telephone calls during this time. Due to the current situation, staff members may not
receive all telephone calls. If you are trying to reach a staff member, please be sure
to send an e-mail to the staff member, rather than relying solely upon voice
messages. Thank you in advance for your understanding and patience.
From: Dialen Ariste
Sent: Thursday, January 7, 2021 2:18 PM
To: Precious Lawrence ; HPCI Eservice ;Jessica DeBlasio
Ce: Aaron Silvers
Subject: FORBES, KEITH VS HERITAGE PROPERTY & CASUALTY | CACE-20-017837 AO Motion For
Extension Of Time
AUTION: This email originated from outside the organization. Do NOT click links
r open attachments unless you validate the sender and know the content is safe.
lease contact IT - Helpdesk if you believe this email is suspicious.
Attached hereto, please find AO on Defendant’s Motion for Extension of Time to Respond to
Complaint for your reviewal. If agreeable, please advise and we will submit to Judge Rodriguez for
execution.
Should we not hear from you by Monday close of business we will submit to court for entry.
Thank you,
Dialen Ariste
Legal Assistant to Aaron Silvers, Esq.
4
\
Weisser Elazar & Kantor, PLLC
800 East Broward Boulevard, Suite 510
Fort Lauderdale, Florida 33301
T: (954) 486-2623
F: (954) 572-8695
www.weklaw.com
CONFIDENTIALITY NOTICE:“This message and any attached information is from Weisser
Elazar & Kantor PLLC, and may contain confidential and/or privileged material. It is intended for
receipt and review only by the intended person or entity to which it is addressed. Any review,
retransmission, dissemination or other use of this information by persons or entities other than the
recipient(s) is unauthorized and prohibited. Any transmission of confidential and/or privileged
material to persons or entities other than the intended recipient(s) shall not be construed as a waiver
of any privilege or confidence. If you receive this transmission in error, please contact the sender by
return e-mail and delete the material.”
This e-mail message (including attachments, if any) is intended for the use of the individual or entity to which it is
addressed and may contain information that is privileged, proprietary, confidential and exempt from disclosure. If
you are not the intended recipient, you are notified that any dissemination, distribution or copying of this
communication is strictly prohibited, If you have received this communication in error, please notify the sender and
erase this e-mail message immediately.This e-mail message (including attachments, if any) is intended for the use of the individual or entity to which it is
addressed and may contain information that is privileged, proprietary, confidential and exempt from disclosure, If
you are not the intended recipient, you are notified that any dissemination, distribution or copying of this
communication is strictly prohibited, If you have received this communication in error, please notify the sender and
erase this e-mail message immediately
This e-mail message (including attachments, if any) is intended for the use of the individual or entity to which it is
addressed and may contain information that is privileged, proprietary, confidentia! and exempt from disclosure. If
you are not the intended recipient, you are notified that any dissemination, distribution or copying of this
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Filing # 120856735 E-Filed 02/04/2021 04:24:48 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA KEITH FORBES, Plaintiff, v. CASE NO.: CACE-20-017837 HERITAGE PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. / PLAINTIFF'S MOTION TO COMPEL EARLIER DEPOSITION DATES COME NOW, Plaintiff, KEITH FORBES, this Court to compel Defendant’s Corporate Representative depositions and states: 1. This case arises from a claim for homeowner’s insurance benefits as a result of damage to the insured’s property. 2. By and through counsel, Plaintiff has sought the deposition of a basic fact witness known or discovered to have knowledge concerning Plaintiff's insurance claim 3. The identity of this witness is defendant’s corporate representative pursuant to Fla. R. Civ. P. 1. 310 (b)(6), has been derived by documents and information made known to Plaintiff's through the claim and/or pre-trial discovery process. 4. On February 3, 2021, Defendant advised that dates for Corporate Representative’s deposition will be provided to Plaintiff within the next (30) thirty days for deposition to occur in the next (120) one hundred twenty days. See e-mail correspondence dated February 3, 2021, attached hereto as Exhibit “A.” 5. This time frame offered by Defendant for its Corporate Representative’s deposition in this matter unreasonably delays the case and there is no good faith basis or justification as to why this deposition cannot be completed within sixty (60) to ninety (90) days. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/04/2021 04:24:48 PM.****6. Delaying discovery for this period of time is not only prejudicial to the Plaintiff but has the unintended consequence of preventing efficient disposition of the Court’s docket. 7. Plaintiff's counsel submits that he has conferred or attempted to confer with Defendant’s counsel in an effort to resolve the issues herein but have been unable to do so. WHEREFORE, Plaintiff, Keith Forbes, respectfully request that this Honorable Court enter an order (i) granting this Motion, (ii) compelling Defendant to coordinate dates for the requested deposition to occur within ninety (90) days, and (iii) for any other relief deemed just and proper. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via the E-Portal to Attorney for Heritage Property & Casualty Insurance Company, Precious M. Lawrence, Esq., at PLawrence@heritagepci.com; eservice@heritagepci.com on this 4" day of February 2021. By: /s/ Aaron D. Silvers AARON D. SILVERS, ESQ. Florida Bar No: 104811 WEISSER, ELAZAR & KANTOR, PLLC Attorneys for Plaintiffs 800 East Broward Boulevard, Suite 510 Fort Lauderdale, FL 33301 T: (954) 486-2623 / F: (954) 572-8695 Email: AS@WEKLaw.com DAR@WEKLaw.comExhibit A From: Dialen Ariste To: Jessica DeBlasio Co: Aaron Silvers Subject: RE: FORBES, KEITH VS HERITAGE PROPERTY & CASUALTY | CACE-20-017837 - CR/FA Depos - 1st Req Date: Wednesday, February 3, 2021 3:59:42 PM Attachments: image002.pnq imaqe006.pnq image008.pnq image009.pnq Jessica, I will reiterate my response to your email concerning CR’s depo, we cannot agree to push their deposition as far as June 28" as it will delay this matter even further. If dates cannot be provided for depositions to take place within 90 days we will have to move to compel earlier dates. Can your office provide dates sooner than June? Thank you, Dialen Ariste Legal Assistant to Aaron Silvers, Esq. ¢ Weisser Elazar & Kantor, PLLC 800 East Broward Boulevard, Suite 510 Fort Lauderdale, Florida 33301 T: (954) 486-2623 F; (954) 572-8695 www.weklaw.com CONFIDENTIALITY NOTICE:“This message and any attached information is from Weisser Elazar & Kantor PLLC, and may contain confidential and/or privileged material. It is intended for receipt and review only by the intended person or entity to which it is addressed. Any review, retransmission, dissemination or other use of this information by persons or entities other than the recipient(s) is unauthorized and prohibited. Any transmission of confidential and/or privileged material to persons or entities other than the intended recipient(s) shall not be construed as a waiver of any privilege or confidence. If you receive this transmission in error, please contact the sender by return e-mail and delete the material.” From: Jessica DeBlasio Sent: Wednesday, February 3, 2021 3:53 PM To: Dialen Ariste Cc: Aaron Silvers Subject: RE: FORBES, KEITH VS HERITAGE PROPERTY & CASUALTY | CACE-20-017837 - CR/FA Depos - Ist Req Importance: HighDialen: Good afternoon, respectfully please do not unilaterally the corporate representative’s deposition as indicated below. | sent you the following request in the attached email on 1/29 and have not heard back from your office until now: As to your request for Corporate Representative deposition dates will you agree for us to provide dates within the next 30 days for the deposition to occur in the next 120 days? Please advise and thank you. Please advise and thank you. *NOTE: Pursuant to our company’s COVID-19 policy, most of our staff is working remotely. Please allow our office additional time in which to respond to e-mails and telephone calls during this time. Due to the current situation, staff members may not receive all telephone calls. If you are trying to reach a staff member, please be sure to send an e-mail to the staff member, rather than relying solely upon voice messages. Thank you in advance for your understanding and patience. Jessica DeBlasio Legal Assistant to Precious M. Lawrence, Esq. Iftikhar Memon, Esq. Staff Counsel Heritage Property & Casualty Insurance Company 1571 Sawgrass Corporate Parkway Suite 400 Sunrise, FL 33323 Ph: 954-315-1450 Ex. 7007 www.heritagepci.com HERITAGE Insurance Pillars of Strength and Character. “Note: We will not hold dates without a notice. If we do not receive a notice within 48 hours of confirmation of any event, we will release that date and it will be given to another matter. “ CONFIDENTIALITY NOTICE: The information contained in this transmittal, including any attachment, is privileged and confidential information and is intended only for the person or entity to which it is addressed. If you are neither the intended recipient nor the employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any disclosure, copying or distribution or taking action in reliance on the contents of this transmittal is strictly prohibited. If you have received this transmittal in error, please contact the sender immediately and delete this transmittal from any computer or other data bank. Este mensaje es confidencial y puede contener informacién amparada por el secreto profesional. Si usted ha recibido este e-mail por error, por favor comuniquelo inmediatamente via e-mail y tenga la amabilidad de destruirlo; no debera copiar el mensaje ni divulgar su contenido a ninguna persona.P Please consider the environment before printing this email. From: Dialen Ariste Sent: Wednesday, February 3, 2021 3:42 PM To: Jessica DeBlasio Ce: Aaron Silvers Subject: RE: FORBES, KEITH VS HERITAGE PROPERTY & CASUALTY | CACE-20-017837 - CR/FA Depos - ‘Ast Req CAUTION: This email originated from outside the organization. Do NOT click links lor open attachments unless you validate the sender and know the content is safe. HPlease contact IT - Helpdesk if you believe this email is suspicious. Helio Jessica, I’m following up on our request to take the deposition of the designated Corporate Rep. Please see dates below and advise. March 234 Afternoon March 25" Afternoon March 31 Morning April 1°! Afternoon April 2" Morning April 6"" Any time April 8™ Any time April gth Any time Should we not hear from your office by the end of business Friday 1/5, we will select from one of the dates above and set accordingly. Thank you, Dialen Ariste Legal Assistant to Aaron Silvers, Esq. y 4 Weisser Elazar & Kantor, PLLC 800 East Broward Boulevard, Suite 510 Fort Lauderdale, Florida 33301 T: (954) 486-2623 F: (954) 572-8695 www.weklaw.com “This message and any attached information is from Weisser Elazar & Kantor PLLC, and may contain confidential and/or privileged material. It is intended forreceipt and review only by the intended person or entity to which it is addressed. Any review, retransmission, dissemination or other use of this information by persons or entities other than the recipient(s) is unauthorized and prohibited. Any transmission of confidential and/or privileged material to persons or entities other than the intended recipient(s) shall not be construed as a waiver of any privilege or confidence. If you receive this transmission in error, please contact the sender by return e-mail and delete the material.” From: Dialen Ariste Sent: Friday, January 29, 2021 2:28 PM To: ‘Jessica DeBlasio' Ce: Aaron Silvers Subject: RE: FORBES, KEITH VS HERITAGE PROPERTY & CASUALTY | CACE-20-017837 - CR/FA Depos - Ast Req Good afternoon, Attached hereto please find Plaintiff's NOD, which I will also forward to the FA via the email provide by your office. As for the CR, we cannot agree to push their deposition as far as June 28" as it will delay this matter even further. If dates cannot be provided for depositions to take place within 90 days we will have to move to compel earlier dates. Please advise. Thank you, Dialen Ariste Legal Assistant to Aaron Silvers, Esq. c Weisser Elazar & Kantor, PLLC 800 East Broward Boulevard, Suite 510 Fort Lauderdale, Florida 33301 T: (954) 486-2623 F; (954) 572-8695 www.weklaw.com CONFIDENTIALITY NOTICE:“This message and any attached information is from Weisser Elazar & Kantor PLLC, and may contain confidential and/or privileged material. It is intended for receipt and review only by the intended person or entity to which it is addressed. Any review, retransmission, dissemination or other use of this information by persons or entities other than the recipient(s) is unauthorized and prohibited. Any transmission of confidential and/or privileged material to persons or entities other than the intended recipient(s) shall not be construed as a waiver of any privilege or confidence. If you receive this transmission in error, please contact the sender by return e-mail and delete the material.”From: Jessica DeBlasio Sent: Friday, January 29, 2021 11:02 AM To: Dialen Ariste Cc: Aaron Silvers Subject: RE: FORBES, KEITH VS HERITAGE PROPERTY & CASUALTY | CACE-20-017837 - CR/FA Depos - Ast Req Importance: High Good morning. Please be advised my FA is available for zoom deposition on 3/24/2021 — 1:00 p.m. My FA Jeff Parady has requested you serve him via email at the following email address (we will not be producing him): allaroundadjusting@gmail.com. Please file the Notice. As to your request for Corporate Representative deposition dates will you agree for us to provide dates within the next 30 days for the deposition to occur in the next 120 days? Please advise and thank you. *NOTE: Pursuant to our company’s COVID-19 policy, most of our staff is working remotely. Please allow our office additional time in which to respond to e-mails and telephone calls during this time. Due to the current situation, staff members may not receive all telephone calls. If you are trying to reach a staff member, please be sure to send an e-mail to the staff member, rather than relying solely upon voice messages. Thank you in advance for your understanding and patience. Jessica DeBlasio Legal Assistant to Precious M. Lawrence, Esq. Iftikhar Memon, Esq. Staff Counsel Heritage Property & Casualty Insurance Company 1571 Sawgrass Corporate Parkway Suite 400 Sunrise, FL 33323 Ph: 954-315-1450 Ex. 7007 deblasio@heritagepci.com rit i. HERITAGE Insurance Pillars of Strength and Character. “Note: We will not hold dates without a notice. If we do not receive a notice within 48 hours of confirmation of any event, we will release that date and it will be given to another matter. “CONFIDENTIALITY NOTICE: The information contained in this transmittal, including any attachment, is privileged and confidential information and is intended only for the person or entity to which it is addressed. If you are neither the intended recipient nor the employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any disclosure, copying or distribution or taking action in reliance on the contents of this transmittal is strictly prohibited. If you have received this transmittal in error, please contact the sender immediately and delete this transmittal from any computer or other data bank. Este mensaje es confidencial y puede contener informacion amparada por el secreto profesional. Si usted ha recibido este e-mail por error, por favor comuniquelo inmediatamente via e-mail y tenga la amabilidad de destruirlo; no debera copiar el mensaje ni divulgar su contenido a ninguna persona. P Please consider the environment before printing this email. From: Dialen Ariste Sent: Thursday, January 28, 2021 2:53 PM To: Precious Lawrence ; HPCI Eservice ; Jessica DeBlasio Ce: Aaron Silvers Subject: RE: FORBES, KEITH VS HERITAGE PROPERTY & CASUALTY | CACE-20-017837 - CR/FA Depos - 1st Req ECAUTION: This email originated from outside the organization. Do NOT click links lg open attachments unless you validate the sender and know the content is safe. ‘eeeekcon eta ie Helpdesk if you believe this email is suspicious. Dear counsel, 1° Attempt We are requesting to depose the Corporate Representative and Field Adjuster relating to the above- referenced matter within the next 60 — 90 days. Please see dates of availability below and advise March 23" Any time March 24" Any time March 25" afternoon March 30 1:00pm March 31° 9:00am April 2"¢ Morning April 5 9:00am April 6th _ oth Any time **Should we not hear from your office by the end of business Monday, we will select from one of the dates above and set accordingly. Thank you, Dialen Ariste Legal Assistant to Aaron Silvers, Esq.¢ ar & Kantor, PLUG 800 East Broward Boulevard, Suite 510 Fort Lauderdale, Florida 33301 T: (954) 486-2623 F: (954) 572-8695 www.weklaw,com Weisser CONFIDENTIALITY NOTICE:“This message and any attached information is from Weisser Elazar & Kantor PLLC, and may contain confidential and/or privileged material. It is intended for receipt and review only by the intended person or entity to which it is addressed. Any review, retransmission, dissemination or other use of this information by persons or entities other than the recipient(s) is unauthorized and prohibited. Any transmission of confidential and/or privileged material to persons or entities other than the intended recipient(s) shall not be construed as a waiver of any privilege or confidence. If you receive this transmission in error, please contact the sender by return e-mail and delete the material.” From: Dialen Ariste Sent: Thursday, January 7, 2021 2:29 PM To: Precious Lawrence ; HPCI Eservice ; Jessica DeBlasio Cc: Aaron Silvers Subject: RE: FORBES, KEITH VS HERITAGE PROPERTY & CASUALTY | CACE-20-017837 AO Motion For Extension Of Time Dear counsel: Thad to revise the AO to also include Defendant’s MET to Respond to Plaintiff's Discovery. Please review the revised AO and advise and I will submit. Thank you, Dialen Ariste Legal Assistant to Aaron Silvers, Esq. 800 East Broward Boulevard, Suite 510 Fort Lauderdale, Florida 33301 T: (954) 486-2623 F: (954) 572-8695 www.weklaw.com CONFIDENTIALITY NOTICE:“This message and any attached information is from Weisser Elazar & Kantor PLLC, and may contain confidential and/or privileged material. It is intended for receipt and review only by the intended person or entity to which it is addressed. Any review, retransmission, dissemination or other use of this information by persons or entities other than therecipient(s) is unauthorized and prohibited. Any transmission of confidential and/or privileged material to persons or entities other than the intended recipient(s) shall not be construed as a waiver of any privilege or confidence. If you receive this transmission in error, please contact the sender by return e-mail and delete the material.” From: Precious Lawrence Sent: Thursday, January 7, 2021 2:19 PM To: Dialen Ariste ; HPCI Eservice ; Jessica DeBlasio Ce: Aaron Silvers Subject: RE: FORBES, KEITH VS HERITAGE PROPERTY & CASUALTY | CACE-20-017837 AO Motion For Extension Of Time No objection. May you kindly submit? Thank you! Sincerely, Precious M. Lawrence, Esq. Staff Counsel 1571 Sawgrass Corporate Parkway, Suite 400 Sunrise, Florida 33323 Office: 727-362-7200 ext. 7460 Mobile: 954-205-0244 www. FB) ERLIAGE Pillars of Strength and Character. o *NOTE: Pursuant to our company’s COVID-19 policy, most of our staff is working remotely. Please allow our office additional time in which to respond to e-mails and telephone calls during this time. Due to the current situation, staff members may not receive all telephone calls. If you are trying to reach a staff member, please be sure to send an e-mail to the staff member, rather than relying solely upon voice messages. Thank you in advance for your understanding and patience. From: Dialen Ariste Sent: Thursday, January 7, 2021 2:18 PM To: Precious Lawrence ; HPCI Eservice ;Jessica DeBlasio Ce: Aaron Silvers Subject: FORBES, KEITH VS HERITAGE PROPERTY & CASUALTY | CACE-20-017837 AO Motion For Extension Of Time AUTION: This email originated from outside the organization. Do NOT click links r open attachments unless you validate the sender and know the content is safe. lease contact IT - Helpdesk if you believe this email is suspicious. Attached hereto, please find AO on Defendant’s Motion for Extension of Time to Respond to Complaint for your reviewal. If agreeable, please advise and we will submit to Judge Rodriguez for execution. Should we not hear from you by Monday close of business we will submit to court for entry. Thank you, Dialen Ariste Legal Assistant to Aaron Silvers, Esq. 4 \ Weisser Elazar & Kantor, PLLC 800 East Broward Boulevard, Suite 510 Fort Lauderdale, Florida 33301 T: (954) 486-2623 F: (954) 572-8695 www.weklaw.com CONFIDENTIALITY NOTICE:“This message and any attached information is from Weisser Elazar & Kantor PLLC, and may contain confidential and/or privileged material. It is intended for receipt and review only by the intended person or entity to which it is addressed. Any review, retransmission, dissemination or other use of this information by persons or entities other than the recipient(s) is unauthorized and prohibited. Any transmission of confidential and/or privileged material to persons or entities other than the intended recipient(s) shall not be construed as a waiver of any privilege or confidence. If you receive this transmission in error, please contact the sender by return e-mail and delete the material.” This e-mail message (including attachments, if any) is intended for the use of the individual or entity to which it is addressed and may contain information that is privileged, proprietary, confidential and exempt from disclosure. If you are not the intended recipient, you are notified that any dissemination, distribution or copying of this communication is strictly prohibited, If you have received this communication in error, please notify the sender and erase this e-mail message immediately.This e-mail message (including attachments, if any) is intended for the use of the individual or entity to which it is addressed and may contain information that is privileged, proprietary, confidential and exempt from disclosure, If you are not the intended recipient, you are notified that any dissemination, distribution or copying of this communication is strictly prohibited, If you have received this communication in error, please notify the sender and erase this e-mail message immediately This e-mail message (including attachments, if any) is intended for the use of the individual or entity to which it is addressed and may contain information that is privileged, proprietary, confidentia! and exempt from disclosure. If you are not the intended recipient, you are notified that any dissemination, distribution or copying of this communication is strictly prohibited, If you have received this communication in error, please notify the sender and erase this e-mail message immediately.