On February 23, 2021 a
Response - Party: Defendant Fednat Insurance Company
was filed
involving a dispute between
Andreu, Riguhey,
Vargas, Francisco,
and
Fednat Insurance Company,
for Other - Insurance Claim
in the District Court of Broward County.
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Filing # 123674975 E-Filed 03/24/2021 12:22:55 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA.
CASE NO. CACE-21-003794 (02)
RIGUHEY ANDREU and FRANCISCO
VARGAS,
Plaintiffs,
vs.
FEDNAT INSURANCE COMPANY,
Defendant.
/
DEFENDANT’S RESPONSES AND OBJECTIONS TO PLAINTIFF’S MARCH 22, 2021
NOTICE OF TAKING DEPOSITION DUCES TECUM OF DEFENDANT’S
DESIGNATED CORPORATE REPRESENTATIVE
Defendant files its Responses and Objections to Plaintiff's March 22, 2021 Notice of Taking
Deposition Duces Tecum of Defendant’s Designated Corporate Representative as follows: Objection:
overly broad, unduly burdensome, harassing, vague, not reasonably calculated to lead to the
discovery of admissible evidence, trade secret, and protected by the attorney-client and work-
product privileges.
Notwithstanding these objections, the following non-privileged documents responsive to
the Duces Tecum will be brought to the deposition:
Notice of Taking Deposition Duces Tecum of Corporate Representative;
Responses and Objections to Notice of Taking Deposition Duces Tecum;
Plaintiff's Complaint;
Answer and Affirmative Defenses;
Plaintiff's Answers to Defendant’s Interrogatories;
Plaintiff's Responses to Defendant’s Request for Production;
Defendant’s Answers and Objections to Plaintiff's Interrogatories;
Defendant’s Responses and Objections to Plaintiff's Request for Production; and
A copy of the policy applicable to the date of loss.
MW PADAMWPWNE
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/24/2021 12:22:54 PM.****Privilege Log
All correspondence and emails between FedNat
Insurance Company and the undersigned’s
office.
Attorney-—client privileged and work-product
privileged.
to Plaintiffs’ Request for Production.
Defendant incorporates by reference the Privilege Logs as set forth in its Responses and Objections
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true copy of the foregoing was furnished via Electronic
Service via the Florida Courts E-filing Eportal pursuant to the Supreme Court Administrative Order
AOSC13-490 this date, March 24, 2021 to: Jaci R. Mattocks, Esq., Schirmer Law LLC, 888 S.E. 3
Ave. Suite 300, FL
jmattocks@schirmerlaw.com .
Fort Lauderdale,
33316, tpomaranski@schirmerlaw.com ;
COONEY TRYBUS KWAVNICK PEETS
Attorneys for Defendant
1600 West Commercial Boulevard, Suite 200
Fort Lauderdale, FL 33309
Telephone: (954) 568-6669
Fax: (954) 568-0085
Primary E-Mail:
reception@ctkplaw.com
Secondary E-Mails: yhall@ctkplaw.com
Icalzadilla@ctkplaw.com
gvioli@ctkplaw.com
byl
“(Signed by attorney electronically after review)”
By:
[21-0057/4433473/1]
BRUCE TRYBUS
Florida Bar No. 972983
Document Filed Date
March 24, 2021
Case Filing Date
February 23, 2021
Category
Other - Insurance Claim
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Filing # 123674975 E-Filed 03/24/2021 12:22:55 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA. CASE NO. CACE-21-003794 (02) RIGUHEY ANDREU and FRANCISCO VARGAS, Plaintiffs, vs. FEDNAT INSURANCE COMPANY, Defendant. / DEFENDANT’S RESPONSES AND OBJECTIONS TO PLAINTIFF’S MARCH 22, 2021 NOTICE OF TAKING DEPOSITION DUCES TECUM OF DEFENDANT’S DESIGNATED CORPORATE REPRESENTATIVE Defendant files its Responses and Objections to Plaintiff's March 22, 2021 Notice of Taking Deposition Duces Tecum of Defendant’s Designated Corporate Representative as follows: Objection: overly broad, unduly burdensome, harassing, vague, not reasonably calculated to lead to the discovery of admissible evidence, trade secret, and protected by the attorney-client and work- product privileges. Notwithstanding these objections, the following non-privileged documents responsive to the Duces Tecum will be brought to the deposition: Notice of Taking Deposition Duces Tecum of Corporate Representative; Responses and Objections to Notice of Taking Deposition Duces Tecum; Plaintiff's Complaint; Answer and Affirmative Defenses; Plaintiff's Answers to Defendant’s Interrogatories; Plaintiff's Responses to Defendant’s Request for Production; Defendant’s Answers and Objections to Plaintiff's Interrogatories; Defendant’s Responses and Objections to Plaintiff's Request for Production; and A copy of the policy applicable to the date of loss. MW PADAMWPWNE *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/24/2021 12:22:54 PM.****Privilege Log All correspondence and emails between FedNat Insurance Company and the undersigned’s office. Attorney-—client privileged and work-product privileged. to Plaintiffs’ Request for Production. Defendant incorporates by reference the Privilege Logs as set forth in its Responses and Objections CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true copy of the foregoing was furnished via Electronic Service via the Florida Courts E-filing Eportal pursuant to the Supreme Court Administrative Order AOSC13-490 this date, March 24, 2021 to: Jaci R. Mattocks, Esq., Schirmer Law LLC, 888 S.E. 3 Ave. Suite 300, FL jmattocks@schirmerlaw.com . Fort Lauderdale, 33316, tpomaranski@schirmerlaw.com ; COONEY TRYBUS KWAVNICK PEETS Attorneys for Defendant 1600 West Commercial Boulevard, Suite 200 Fort Lauderdale, FL 33309 Telephone: (954) 568-6669 Fax: (954) 568-0085 Primary E-Mail: reception@ctkplaw.com Secondary E-Mails: yhall@ctkplaw.com Icalzadilla@ctkplaw.com gvioli@ctkplaw.com byl “(Signed by attorney electronically after review)” By: [21-0057/4433473/1] BRUCE TRYBUS Florida Bar No. 972983