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Filing # 60777172 E-Filed 08/23/2017 10:23:56 AM
IN THE CIRCUIT COURT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
LISE BAPTISTE, CASE NO.: 2017-14299 CA 01
Plaintiff(s),
vs.
CITIZENS PROPERTY
INSURANCE CORPORATION,
Defendant.
/
NOTICE OF INTENT TO SERVE A SUBPOENA UNDER RULE 1.351
FOR PRODUCTION OF DOCUMENTS AND THINGS WITHOUT DEPOSITION
YOU ARE HEREBY NOTIFIED that fifteen (15) days after the date of this Notice, or ten
(10) days if notice is via fax, the Defendant, CITIZENS PROPERTY INSURANCE
CORPORATION, will serve a Subpoena Duces Tecum Without Deposition on the following
person(s)/entity(s) for the production of documents or things at the time, place and method
designated in the attached Subpoena Duces Tecum directed to:
1. Records Custodian
Platinum Public Adjusters, Inc.
18425 NW 2" Ave, Suite 400
Miami Gardens, Florida 33169
(786) 279-5561
to produce the items listed at the time and place specified in the subpoena.CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was submitted via
Service this_ 23" day of August , 2017 to the attached Service List.
Peter Mineo, Esq.
The Mineo Salcedo Law Firm, P.A.
pjmineo@mineolaw.com
Kubicki Draper, PA
25 West Flagler Street, Penthouse
Miami, Florida 33130
Direct Line: (305) 982-6735
SRG@Kubickidraper.com
BY:_/s/ Sarah CR. Goldberg
SARAH R. GOLDBERG, ESQ.
Florida Bar No. 92085
SERVICE LISTIN THE CIRCUIT COURT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
LISE BAPTISTE, CASE NO.: 2017-14299 CA 01
Plaintiff(s),
vs.
CITIZENS PROPERTY
INSURANCE CORPORATION,
Defendant.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: Records Custodian
Platinum Public Adjusters, Inc.
18425 NW 2™ Ave, Suite 400
Miami Gardens, Florida 33169
(786) 279-5561
YOU ARE HEREBY COMMANDED to produce the following without deposition and
deliver by mail to KUBICKI DRAPER, 25 West Flagler Street, Penthouse, Miami, Florida on
September 21, 2017 at 4:00 p.m. copies of the following:
THE COMPLETE FILE, cover to cover, of Platinum Public Adjusters, Inc.,
including but not limited to: any and all documents, statements, engagement and/or retainer
agreements, correspondence, reports, handwritten notes, inspection reports, bills, contracts,
invoices, estimates, photographs, video, sketches regarding the property located at 1331 NW
133" Street, Miami, Florida 33167, and owned by the insured, Lise Baptiste, copies of all
insurance licenses, copy of any applicable state license and/or any other professional license,
whether in the state of Florida or in any other state, under your name that is/are presently
active, a complete copy of your cv or resume, testimony list for the past three (3) years, and
all professional licenses in the State of Florida.
PLEASE ATTACH A COPY OF THIS SUBPOENA TO THE RECORDS
PROVIDED.Bapiste v. Citizens
Case No.: 17-14299 CA O01
Page 2
These items will be inspected and may be copied at that time. 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 eliminate your appearance at the time and place 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.
THIS WILL NOT BE A DEPOSITION, NO TESTIMONY WILL BE TAKEN.
If you fail to:
(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) 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.
If you are a person with a disability who needs any accommodation in order to participate
in this deposition, you are entitled, at no cost to you, to the provision of certain assistance.
Please contact Sarah Goldberg, 25 West Flagler Street, Penthouse, Miami, Florida 33130 at
305-374-1212 at least 7 days before your scheduled deposition, or immediately upon
receiving this notification if the time before the scheduled deposition is less than 7 days; if
you are hearing or voice impaired, call 711.
DATED ON: 8/23 /17
By: /s/ QS arah CR. Goldberg
SARAH GOLDBERG, ESQ.
KUBICKI, DRAPER, P.A.
Attorneys for Defendant
City National Bank Bldg., PH
25 West Flagler Street
Miami, Florida 33130
Telephone: (305) 374-1212
Fax: (305) 374-7846
Preview
Filing # 60777172 E-Filed 08/23/2017 10:23:56 AM IN THE CIRCUIT COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA LISE BAPTISTE, CASE NO.: 2017-14299 CA 01 Plaintiff(s), vs. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. / NOTICE OF INTENT TO SERVE A SUBPOENA UNDER RULE 1.351 FOR PRODUCTION OF DOCUMENTS AND THINGS WITHOUT DEPOSITION YOU ARE HEREBY NOTIFIED that fifteen (15) days after the date of this Notice, or ten (10) days if notice is via fax, the Defendant, CITIZENS PROPERTY INSURANCE CORPORATION, will serve a Subpoena Duces Tecum Without Deposition on the following person(s)/entity(s) for the production of documents or things at the time, place and method designated in the attached Subpoena Duces Tecum directed to: 1. Records Custodian Platinum Public Adjusters, Inc. 18425 NW 2" Ave, Suite 400 Miami Gardens, Florida 33169 (786) 279-5561 to produce the items listed at the time and place specified in the subpoena.CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was submitted via Service this_ 23" day of August , 2017 to the attached Service List. Peter Mineo, Esq. The Mineo Salcedo Law Firm, P.A. pjmineo@mineolaw.com Kubicki Draper, PA 25 West Flagler Street, Penthouse Miami, Florida 33130 Direct Line: (305) 982-6735 SRG@Kubickidraper.com BY:_/s/ Sarah CR. Goldberg SARAH R. GOLDBERG, ESQ. Florida Bar No. 92085 SERVICE LISTIN THE CIRCUIT COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA LISE BAPTISTE, CASE NO.: 2017-14299 CA 01 Plaintiff(s), vs. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: Records Custodian Platinum Public Adjusters, Inc. 18425 NW 2™ Ave, Suite 400 Miami Gardens, Florida 33169 (786) 279-5561 YOU ARE HEREBY COMMANDED to produce the following without deposition and deliver by mail to KUBICKI DRAPER, 25 West Flagler Street, Penthouse, Miami, Florida on September 21, 2017 at 4:00 p.m. copies of the following: THE COMPLETE FILE, cover to cover, of Platinum Public Adjusters, Inc., including but not limited to: any and all documents, statements, engagement and/or retainer agreements, correspondence, reports, handwritten notes, inspection reports, bills, contracts, invoices, estimates, photographs, video, sketches regarding the property located at 1331 NW 133" Street, Miami, Florida 33167, and owned by the insured, Lise Baptiste, copies of all insurance licenses, copy of any applicable state license and/or any other professional license, whether in the state of Florida or in any other state, under your name that is/are presently active, a complete copy of your cv or resume, testimony list for the past three (3) years, and all professional licenses in the State of Florida. PLEASE ATTACH A COPY OF THIS SUBPOENA TO THE RECORDS PROVIDED.Bapiste v. Citizens Case No.: 17-14299 CA O01 Page 2 These items will be inspected and may be copied at that time. 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 eliminate your appearance at the time and place 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. THIS WILL NOT BE A DEPOSITION, NO TESTIMONY WILL BE TAKEN. If you fail to: (1) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) 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. If you are a person with a disability who needs any accommodation in order to participate in this deposition, you are entitled, at no cost to you, to the provision of certain assistance. Please contact Sarah Goldberg, 25 West Flagler Street, Penthouse, Miami, Florida 33130 at 305-374-1212 at least 7 days before your scheduled deposition, or immediately upon receiving this notification if the time before the scheduled deposition is less than 7 days; if you are hearing or voice impaired, call 711. DATED ON: 8/23 /17 By: /s/ QS arah CR. Goldberg SARAH GOLDBERG, ESQ. KUBICKI, DRAPER, P.A. Attorneys for Defendant City National Bank Bldg., PH 25 West Flagler Street Miami, Florida 33130 Telephone: (305) 374-1212 Fax: (305) 374-7846