Preview
Filing # 95862553 E-Filed 09/17/2019 04:58:56 PM
IN THE COUNTY COURT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CASE NO.:2017-010841-CC-23
ST. CLAIR CLARKE AND LITA CLARKE
and INFINITY EMS, INC.
AIA/O ST. CLAIR and LITA CLARKE
Plaintiffs,
vs.
CITIZENS PROPERTY INSURANCE CORPORATION,
Defendant.
PLAINTIFFS’ MOTION TO COMPEL SEVERAL DEPOSITIONS PREVIOUSLY
REQUESTED PRIOR TO HEARING ON DEFENDANT’S MOTION FOR SUMMARY
JUDGMENT
Plaintiffs, ST. CLAIR CLARKE AND LITA CLARKE and INFINITY EMS, INC.
A/A/O ST. CLAIR and LITA CLARKE, hereinafter (“Plaintiffs”), by and through its
undersigned counsel and pursuant to Florida Rule of Civil Procedure 1.310, hereby files
its Motion to Compel Several Depositions Previously Requested Prior to Hearing on
Defendant's Motion for Summary Judgment, and in support thereof states as follows:
This matter arises out of a homeowner's insurance claim dispute brought by
Plaintiff against Defendant.
1. Defendant issued an insurance policy to St. Clair and Lita Clarke (the
“assignors’). On May 17, 2017 the assignors suffered extensive water damages to their
residence located at 8045 NW 16th Ave., Miami, Florida 33147.
2. Due to the water loss, the assignor utilized the services of Infinity EMS to
perform water dry out and mitigation services to her property. Infinity EMS soughtpayment from Defendant for services performed under a validly executed assignment of
benefits and was wrongfully refused payment.
3. The assignors filed their own lawsuit for damages to their property from the
same water loss.
4. Subsequently, these matters were consolidated by this Court for procedural
purposes.
5. Defendant filed its Motion for Summary Judgment and supplemented this
Motion with deposition transcripts filed eight months later arguing that the loss is subject
to an exclusion in the policy and that Plaintiff is barred from recovering any proceeds
under the claim.
6. Through the course of this dispute Plaintiffs have attempted to get all discovery
necessary to thoroughly prosecute this matter. See Exhibit “A”.
7. The parties previously coordinated the deposition of the field adjuster and
corporate representative and despite the coordination, neither appeared. See Exhibit “B”
and Exhibit “C”.
8. An integral part of this process is obtaining the deposition of the field adjuster,
who acts as “the eyes’ of the insurance company (hopefully) relatively soon after the claim
has been reported.
9. Additionally, the corporate representative acts as the physical person who can
provide testimony as to the facts utilized in support of Defendant's several affirmative
defenses.
10. Finally, the Plaintiffs also requested the desk adjuster who made the actual
decision to deny the subject claim.11. Plaintiffs have yet to receive a response regarding the desk adjuster and
hence, must now renew its long standing request.
12. Plaintiff respectfully requests that Plaintiff's Motion to Compel Several
Depositions be granted to allow Plaintiff to complete discovery prior to the Court
entertaining Defendant’s Motion for Summary Judgment.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the foregoing was furnished
via Email, pursuant to Rule 2.516(b)(1) to: Lyndsay D. Fichtenbaum, Esq. and Harris B.
Katz, Esq. GOEDE, ADAMCZYK, DEBOEST, & CROSS, PLLC, via transmission of
Notice of Electronic Filing generated by eservice@myflcourtaccess.com and/or was sent
by electronic mail to the above addressees, September 17, 2019.
ARNESEN WEBB, P.A.
Attorneys for Plaintiffs
197 South Federal Highway, Ste. 300
Boca Raton, FL 33432
Telephone: (561)-757-6000
Facsimile: (877)-241-2411
eservice@insurancelawyers.org
paris@insurancelawyers.org
By_b/ 4402 4. LL
Paris R. Webb, Esq.
Florida Bar No.: 713074IN THE COUNTY COURT IN FOR
MIAMI-DADE COUNTY, FLORIDA
CASE NO.: 2017-010841-CC-23
ST. CLAIR CLARKE AND
LITE CLARKE,
Plaintiff,
vs.
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
PLAINTIFFS’ MOTION TO COMPEL DEPOSITION DEFENDANT’S CORPORATE
REPRESENTATIVE, FIELD ADJUSTER, AND DESK ADJUSTER
Plaintiffs, ST. CLAIR CLARKE and LITA CLARKE, hereinafter (“Plaintiffs”), by and
through their undersigned counsel and pursuant to Florida Rule of Civil Procedure 1.310,
hereby files his Motion to Compel Depositions, and in support thereof states as follows:
1. This matter arises out of a homeowner's insurance claim dispute brought
by Plaintiffs against Defendant.
2. Plaintiffs desire to take the deposition of Defendant’s corporate
representative, field adjuster, and desk adjuster to discover facts underlying the issues in
this matter.
3. On or about October 3, 2018, pursuant to Florida Rule of Civil Procedure
1.310, Plaintiff emailed correspondence to Defendant requesting dates for the
Defendant's corporate representative, field adjuster, and desk adjuster depositions.
4. On or about October 18, 2018, Plaintiffs sent a follow up email to Defendant
requesting dates for the depositions and informing Defendant that if Plaintiffs had not
EXHIBIT Aheard back from Defendant with deposition dates by the end of the week, Plaintiffs would
be forced to file a Motion to Compel Depositions. See Exhibit A.
6. To date, the Defendant has not provided dates for the depositions of its
corporate representative, field adjuster, or desk adjuster. Plaintiffs are in need of these
deposition to obtain information about the case.
9. The foregoing is essential to this case and the Defendants’ failure to
respond to the undersigned has caused substantial delay and unfair prejudice to Plaintiffs.
10. As such, Plaintiffs requests that the Court enter an order compelling
Defendant to designate and provide dates for the deposition of its corporate
representative, field adjuster, and desk adjuster, to take place within ninety (90) days from
the date of the order.
WHEREFORE, Plaintiffs requests that this Honorable Court enter an Order
compelling the Defendant to designate and provide dates for the deposition of its
corporate representative, field adjuster, and desk adjuster to take place within ninety (90)
days from the date of the order, along with any other relief this Honorable Court may
deem just and proper.CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the foregoing was furnished
via Email, pursuant to Rule 2.516(b)(1) to: Ana Causo, Goede, Adamcyk, Deboest, &
Cross, PLLC, via transmission of Notice of Electronic Filing generated by
eservice@myticourtaccess.com and/or was sent by electronic mail to the above
addressees, October 22 , 2018.
ARNESEN WEBB, P.A.
Attorneys for Plaintiff
197 South Federal Highway, Ste. 300
Boca Raton, FL 33432
Telephone: (561)-757-6000
Facsimile: (877)-241-2411
matt@insurancelawyers.org
eservice@insurancelawyers.org
By: /s/ Meiettbew g OL
MATTHEW J. LEMAKOS
Florida Bar No.: 1001611
PARIS R. WEBB
Florida Bar No.: 713074matt@insurancelawyers.org
From: roatt@insurancelawyers.org
Sent: Thursday, October 18, 2018 9:05 AM
Te: ‘Ana Causo’
Subject: RE: Clarke, St. Clair and Lita v. Citizens & infinity (Clarke) v, Citizens
Hello Ana,
{just tired te give you a call but had to leave a voicemail. { still haven't heard back from you with dates of availability for
the below depositions. Please let me know some dates so that | can move forward. if | don't hear from yau by the end of
the week, | am going to need to file Motions ta Compeat.
Thanks,
WMlatihew G. Lomakas : Associate
197 8. Federal Hwy., Ste. goo
Boca Raton, Florida 33432-2747
Ph:
Fram: matt@insurancelawyers.org
Sant: Wednesday, Gctober 3, 2018 9:43 AM
To: ‘Ana Cause’
Subject: Clarke, 5t. Clair and Lita v. Citizens & infinity (Clarke) v. Citizens
Hello Ana,
| just triad to give you a cali but [had to jeave a voicemail. | want to follow up with you on the four above files to see
where we are at. | would also like to request dates of availability for the depositions of the following people at citizens
oan all four files:
1. Corporate Representative
2. Field Adjuster
3. Desk Adjuster
Please see the attached correspondence for more information regarding this request. Since we are dealing with four
files with the same insured, ! dan't have a problem doubling {or quadrupling in this case) sp if one person is able to fulfill
one of these roles on ail files. Please let me know. ff you would fike to discuss this case further, feel free to give me a call,
Matthew £ Lemasas : Associate
1978.
Bova Raton, Flori
BAZAA78T
Ph 5
aBR
oo
jet
pt
3
20
Page 1
IN THE COUNTY
MIAMI-~
RE IN AND
DADE COUNTY, FLORIDA
Certified Original
ZENS PROPERTY INSURANCE CORPORATION,
Defendant.
ICATE OF NAPPBA
I, JUNE S. SANDBERG,
301 Northeast Sist Street,
il @, 2019 £ ti 10:00 A.M.
cpose of repo
an ive, whic
pursuant to Defendant's
na Duces Tecum.
Raton,
10
Lo
No
further certify
sentative did not é
day of April, ZOl
* * *
Veritext Legal Solutions
800-726-7007 305-376-8800
EXHIBIT B{10:00 - witness]
i
16:00 1:14,16
2
2017-O10841 1:2
2019 114,18
23 1:2
3
Lil4
5
$194 1:22
Sist 1:14
8
8 f:14
8th 1:18
a
am. 1:14,15,16
appear 1:18
april 1:14,18
b
114
301
boca
¢
ease 1:2
ce 1:2
certificate b:11
eertify 1:13,17
citizens 1:8
clair 1:4,5
clark 1:4,5
elarke 1:4,5
corporate £215.18
corporation 1:8
county i:1.1
court tt
a
dade [ci
day 1:18
800-726-7007
defendant 1:10
defendant's 1:16
deponent 1:17
deposition 1:15,16
duces 1:16
2
ems 1:4
ft
florida 11.14
further 1:17
i
infinity 1:4 -
insurance 1:8
i
“june 1:13.24
I
lta 1:45
nt
miami tcl
a
nonappearance
iil
northeast 1:14
notice 1:16
a
o id
B
plaintiffs 1:6
present 1:14
property 1:8
purpose [:15
pursaant 1:16
r
raton 1:14
reporting 1:15
representative 1:15
1:18
Page 2
: 8
gs 1:13,24
sandberg 1:13,24
scheduled 1:15
signature 1:22
signed 1:18
st 1:45
street 1:14
t
tecum 1:16
time 1:14
. . ¥v
vs 1:7
w
witness 1:11
Veritext Legal Solutions
0:
tH
ts
76-8800
a9/17/2019 Workspace Webmail :: Print
Print | Close Window
Deposition (FA - Scheduling attempt) « St. Clair Clarke cases
rittany Boltz
ri, Apr 05, 2019 2:16 pm
‘scheduling@insurancelawyers.org”
image001 jpg
imageoo2.png
Hello,
| wanted to follow-up on my email from this morning as the FA is not available on Monday at 10am. Please advise if you can reschedule this deposition.
Thank you,
Brittany Boltz
Legal Assistant
Goede, Adamezyk, DeBoest & Cross, PLLC
Phone: 561-368-9200 / Direct: 561-948-0861 / Fax: 561-395-7050
From: Brittany Boltz
Sent: Friday, April 5, 2019 9:49 AM
To: ‘scheduling@insurancelawyers.org'
Subject: RE: Deposition (FA - Scheduling attempt) - St. Clair Clarke cases
Good morning Kelly,
| just received a call from the Field Adjuster and he advised that he’s not available as he was never served with the Notices. It was on my attorney’s calendar
‘but the FA is no longer available. He Is available in May and my attorney is available on the below dates. Can we please reschedule this for May and re-notice
the deposition and serve the FA?
May 2"4— 1pm
May 7" — 10am
May 9" — tom,
May 22"¢~ 10am
May 29°" 1pm
May 315'— 10am or pm
Thank you,
Brittany Boltz
Legal Assistant
Goede, Adamezyk, DeBoest & Cross, PLLC
Phone: 561-368-9200 / Direct: 561-948-0861 / Fax: 561-395-7050
yers.org
Sent: Friday, April 5, 2019 9:01 AM
To: Brittany Boltz
Subject: RE: Deposition (FA - Scheduling attempt) - St. Clair Clarke cases
From: schedulin che ing@insurancelaw
Good morning,
Please confirm the deposition set for Monday, of your FA.
Also, we can set the MSJ if you want this morning or whenever you have time. | just want to let you know that | have to set it in
June, as that is when we will be available.
Call me when you can, | know we have to call into the JA's office together.
Thanks!
Kelly M. Hunt | Paralegal
ARNESEN WEBB, P.A,
197 South Federal Hwy., Ste. 300
Boca Raton, Florida 33432
Ph: 561.757.6000 | Fax: 877.241.2411
| scheduling @insurancelawyers.org| Website : ae
EXHIBIT C
https://email09.godaddy.com/view_print_multi.php?uidArray=28739|INBOX.Completed&aEmiPart=0
U3
Preview
Filing # 95862553 E-Filed 09/17/2019 04:58:56 PM IN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NO.:2017-010841-CC-23 ST. CLAIR CLARKE AND LITA CLARKE and INFINITY EMS, INC. AIA/O ST. CLAIR and LITA CLARKE Plaintiffs, vs. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. PLAINTIFFS’ MOTION TO COMPEL SEVERAL DEPOSITIONS PREVIOUSLY REQUESTED PRIOR TO HEARING ON DEFENDANT’S MOTION FOR SUMMARY JUDGMENT Plaintiffs, ST. CLAIR CLARKE AND LITA CLARKE and INFINITY EMS, INC. A/A/O ST. CLAIR and LITA CLARKE, hereinafter (“Plaintiffs”), by and through its undersigned counsel and pursuant to Florida Rule of Civil Procedure 1.310, hereby files its Motion to Compel Several Depositions Previously Requested Prior to Hearing on Defendant's Motion for Summary Judgment, and in support thereof states as follows: This matter arises out of a homeowner's insurance claim dispute brought by Plaintiff against Defendant. 1. Defendant issued an insurance policy to St. Clair and Lita Clarke (the “assignors’). On May 17, 2017 the assignors suffered extensive water damages to their residence located at 8045 NW 16th Ave., Miami, Florida 33147. 2. Due to the water loss, the assignor utilized the services of Infinity EMS to perform water dry out and mitigation services to her property. Infinity EMS soughtpayment from Defendant for services performed under a validly executed assignment of benefits and was wrongfully refused payment. 3. The assignors filed their own lawsuit for damages to their property from the same water loss. 4. Subsequently, these matters were consolidated by this Court for procedural purposes. 5. Defendant filed its Motion for Summary Judgment and supplemented this Motion with deposition transcripts filed eight months later arguing that the loss is subject to an exclusion in the policy and that Plaintiff is barred from recovering any proceeds under the claim. 6. Through the course of this dispute Plaintiffs have attempted to get all discovery necessary to thoroughly prosecute this matter. See Exhibit “A”. 7. The parties previously coordinated the deposition of the field adjuster and corporate representative and despite the coordination, neither appeared. See Exhibit “B” and Exhibit “C”. 8. An integral part of this process is obtaining the deposition of the field adjuster, who acts as “the eyes’ of the insurance company (hopefully) relatively soon after the claim has been reported. 9. Additionally, the corporate representative acts as the physical person who can provide testimony as to the facts utilized in support of Defendant's several affirmative defenses. 10. Finally, the Plaintiffs also requested the desk adjuster who made the actual decision to deny the subject claim.11. Plaintiffs have yet to receive a response regarding the desk adjuster and hence, must now renew its long standing request. 12. Plaintiff respectfully requests that Plaintiff's Motion to Compel Several Depositions be granted to allow Plaintiff to complete discovery prior to the Court entertaining Defendant’s Motion for Summary Judgment. CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via Email, pursuant to Rule 2.516(b)(1) to: Lyndsay D. Fichtenbaum, Esq. and Harris B. Katz, Esq. GOEDE, ADAMCZYK, DEBOEST, & CROSS, PLLC, via transmission of Notice of Electronic Filing generated by eservice@myflcourtaccess.com and/or was sent by electronic mail to the above addressees, September 17, 2019. ARNESEN WEBB, P.A. Attorneys for Plaintiffs 197 South Federal Highway, Ste. 300 Boca Raton, FL 33432 Telephone: (561)-757-6000 Facsimile: (877)-241-2411 eservice@insurancelawyers.org paris@insurancelawyers.org By_b/ 4402 4. LL Paris R. Webb, Esq. Florida Bar No.: 713074IN THE COUNTY COURT IN FOR MIAMI-DADE COUNTY, FLORIDA CASE NO.: 2017-010841-CC-23 ST. CLAIR CLARKE AND LITE CLARKE, Plaintiff, vs. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. PLAINTIFFS’ MOTION TO COMPEL DEPOSITION DEFENDANT’S CORPORATE REPRESENTATIVE, FIELD ADJUSTER, AND DESK ADJUSTER Plaintiffs, ST. CLAIR CLARKE and LITA CLARKE, hereinafter (“Plaintiffs”), by and through their undersigned counsel and pursuant to Florida Rule of Civil Procedure 1.310, hereby files his Motion to Compel Depositions, and in support thereof states as follows: 1. This matter arises out of a homeowner's insurance claim dispute brought by Plaintiffs against Defendant. 2. Plaintiffs desire to take the deposition of Defendant’s corporate representative, field adjuster, and desk adjuster to discover facts underlying the issues in this matter. 3. On or about October 3, 2018, pursuant to Florida Rule of Civil Procedure 1.310, Plaintiff emailed correspondence to Defendant requesting dates for the Defendant's corporate representative, field adjuster, and desk adjuster depositions. 4. On or about October 18, 2018, Plaintiffs sent a follow up email to Defendant requesting dates for the depositions and informing Defendant that if Plaintiffs had not EXHIBIT Aheard back from Defendant with deposition dates by the end of the week, Plaintiffs would be forced to file a Motion to Compel Depositions. See Exhibit A. 6. To date, the Defendant has not provided dates for the depositions of its corporate representative, field adjuster, or desk adjuster. Plaintiffs are in need of these deposition to obtain information about the case. 9. The foregoing is essential to this case and the Defendants’ failure to respond to the undersigned has caused substantial delay and unfair prejudice to Plaintiffs. 10. As such, Plaintiffs requests that the Court enter an order compelling Defendant to designate and provide dates for the deposition of its corporate representative, field adjuster, and desk adjuster, to take place within ninety (90) days from the date of the order. WHEREFORE, Plaintiffs requests that this Honorable Court enter an Order compelling the Defendant to designate and provide dates for the deposition of its corporate representative, field adjuster, and desk adjuster to take place within ninety (90) days from the date of the order, along with any other relief this Honorable Court may deem just and proper.CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via Email, pursuant to Rule 2.516(b)(1) to: Ana Causo, Goede, Adamcyk, Deboest, & Cross, PLLC, via transmission of Notice of Electronic Filing generated by eservice@myticourtaccess.com and/or was sent by electronic mail to the above addressees, October 22 , 2018. ARNESEN WEBB, P.A. Attorneys for Plaintiff 197 South Federal Highway, Ste. 300 Boca Raton, FL 33432 Telephone: (561)-757-6000 Facsimile: (877)-241-2411 matt@insurancelawyers.org eservice@insurancelawyers.org By: /s/ Meiettbew g OL MATTHEW J. LEMAKOS Florida Bar No.: 1001611 PARIS R. WEBB Florida Bar No.: 713074matt@insurancelawyers.org From: roatt@insurancelawyers.org Sent: Thursday, October 18, 2018 9:05 AM Te: ‘Ana Causo’ Subject: RE: Clarke, St. Clair and Lita v. Citizens & infinity (Clarke) v, Citizens Hello Ana, {just tired te give you a call but had to leave a voicemail. { still haven't heard back from you with dates of availability for the below depositions. Please let me know some dates so that | can move forward. if | don't hear from yau by the end of the week, | am going to need to file Motions ta Compeat. Thanks, WMlatihew G. Lomakas : Associate 197 8. Federal Hwy., Ste. goo Boca Raton, Florida 33432-2747 Ph: Fram: matt@insurancelawyers.org Sant: Wednesday, Gctober 3, 2018 9:43 AM To: ‘Ana Cause’ Subject: Clarke, 5t. Clair and Lita v. Citizens & infinity (Clarke) v. Citizens Hello Ana, | just triad to give you a cali but [had to jeave a voicemail. | want to follow up with you on the four above files to see where we are at. | would also like to request dates of availability for the depositions of the following people at citizens oan all four files: 1. Corporate Representative 2. Field Adjuster 3. Desk Adjuster Please see the attached correspondence for more information regarding this request. Since we are dealing with four files with the same insured, ! dan't have a problem doubling {or quadrupling in this case) sp if one person is able to fulfill one of these roles on ail files. Please let me know. ff you would fike to discuss this case further, feel free to give me a call, Matthew £ Lemasas : Associate 1978. Bova Raton, Flori BAZAA78T Ph 5 aBR oo jet pt 3 20 Page 1 IN THE COUNTY MIAMI-~ RE IN AND DADE COUNTY, FLORIDA Certified Original ZENS PROPERTY INSURANCE CORPORATION, Defendant. ICATE OF NAPPBA I, JUNE S. SANDBERG, 301 Northeast Sist Street, il @, 2019 £ ti 10:00 A.M. cpose of repo an ive, whic pursuant to Defendant's na Duces Tecum. Raton, 10 Lo No further certify sentative did not é day of April, ZOl * * * Veritext Legal Solutions 800-726-7007 305-376-8800 EXHIBIT B{10:00 - witness] i 16:00 1:14,16 2 2017-O10841 1:2 2019 114,18 23 1:2 3 Lil4 5 $194 1:22 Sist 1:14 8 8 f:14 8th 1:18 a am. 1:14,15,16 appear 1:18 april 1:14,18 b 114 301 boca ¢ ease 1:2 ce 1:2 certificate b:11 eertify 1:13,17 citizens 1:8 clair 1:4,5 clark 1:4,5 elarke 1:4,5 corporate £215.18 corporation 1:8 county i:1.1 court tt a dade [ci day 1:18 800-726-7007 defendant 1:10 defendant's 1:16 deponent 1:17 deposition 1:15,16 duces 1:16 2 ems 1:4 ft florida 11.14 further 1:17 i infinity 1:4 - insurance 1:8 i “june 1:13.24 I lta 1:45 nt miami tcl a nonappearance iil northeast 1:14 notice 1:16 a o id B plaintiffs 1:6 present 1:14 property 1:8 purpose [:15 pursaant 1:16 r raton 1:14 reporting 1:15 representative 1:15 1:18 Page 2 : 8 gs 1:13,24 sandberg 1:13,24 scheduled 1:15 signature 1:22 signed 1:18 st 1:45 street 1:14 t tecum 1:16 time 1:14 . . ¥v vs 1:7 w witness 1:11 Veritext Legal Solutions 0: tH ts 76-8800 a9/17/2019 Workspace Webmail :: Print Print | Close Window Deposition (FA - Scheduling attempt) « St. Clair Clarke cases rittany Boltz ri, Apr 05, 2019 2:16 pm ‘scheduling@insurancelawyers.org” image001 jpg imageoo2.png Hello, | wanted to follow-up on my email from this morning as the FA is not available on Monday at 10am. Please advise if you can reschedule this deposition. Thank you, Brittany Boltz Legal Assistant Goede, Adamezyk, DeBoest & Cross, PLLC Phone: 561-368-9200 / Direct: 561-948-0861 / Fax: 561-395-7050 From: Brittany Boltz Sent: Friday, April 5, 2019 9:49 AM To: ‘scheduling@insurancelawyers.org' Subject: RE: Deposition (FA - Scheduling attempt) - St. Clair Clarke cases Good morning Kelly, | just received a call from the Field Adjuster and he advised that he’s not available as he was never served with the Notices. It was on my attorney’s calendar ‘but the FA is no longer available. He Is available in May and my attorney is available on the below dates. Can we please reschedule this for May and re-notice the deposition and serve the FA? May 2"4— 1pm May 7" — 10am May 9" — tom, May 22"¢~ 10am May 29°" 1pm May 315'— 10am or pm Thank you, Brittany Boltz Legal Assistant Goede, Adamezyk, DeBoest & Cross, PLLC Phone: 561-368-9200 / Direct: 561-948-0861 / Fax: 561-395-7050 yers.org Sent: Friday, April 5, 2019 9:01 AM To: Brittany Boltz Subject: RE: Deposition (FA - Scheduling attempt) - St. Clair Clarke cases From: schedulin che ing@insurancelaw Good morning, Please confirm the deposition set for Monday, of your FA. Also, we can set the MSJ if you want this morning or whenever you have time. | just want to let you know that | have to set it in June, as that is when we will be available. Call me when you can, | know we have to call into the JA's office together. Thanks! Kelly M. Hunt | Paralegal ARNESEN WEBB, P.A, 197 South Federal Hwy., Ste. 300 Boca Raton, Florida 33432 Ph: 561.757.6000 | Fax: 877.241.2411 | scheduling @insurancelawyers.org| Website : ae EXHIBIT C https://email09.godaddy.com/view_print_multi.php?uidArray=28739|INBOX.Completed&aEmiPart=0 U3