On April 12, 2021 a
Complaint
was filed
involving a dispute between
John Giaccone,
Sonia Ransom,
and
St Johns Insurance Company Inc,
for CA Insurance Claims
in the District Court of Lee County.
Preview
Filing # 124764347 E-Filed 04/12/2021 04:14:38 PM
IN THE CIRCUIT COURT OF THE 20™
JUDICIAL CIRCUIT, IN AND FOR LEE
JOHN GIACCONE COUNTY, FLORIDA
AND SONIA RANSOM,
CASE NO.:
Plaintiff,
Vv.
ST. JOHNS INSURANCE
COMPANY, INC.,
Defendant.
/
NOTICE OF FILING
PLAINTIFF’S REQUEST FOR DEPOSITIONS
Plaintiff, JOHN GIACCONE AND SONIA RANSOM (hereinafter “Plaintiff’), by and
through undersigned counsel, and hereby gives notice of filing Plaintiff's Formal Deposition Requests
with the Court, which is attached hereto as Exhibit “A”:
1. Plaintiff's Request for Depositions
[CERTIFICATE OF SERVICE ON THE FOLLOWING PAGE]
Page 1 of 3
eFiled Lee County Clerk of Courts Page 1CERTIFICATE OF SERVICE
THEREBY CERTIFY that a true and correct copy of the above foregoing has been served
along with the Summons and Complaint in this matter.
HL LAW GROUP, P.A.
By:__/s/ Daniel Rosenbaum
Daniel Rosenbaum, Esquire
FBN: 123674
Attorney for Plaintiff
2601 East Oakland Park Boulevard, Suite 503
Fort Lauderdale, Florida 33306
Telephone: (954) 713-1212
Facsimile: (954) 760-4239
Primary Email: | DRosenbaum@HLLawGroup.com
Secondary Email: Service@HLLawGroup.com
Tertiary Email: = SJames@HLLawGroup.com
Page 2 of 3
eFiled Lee County Clerk of Courts Page 2EXHIBIT A
Page 3 of 3
eFiled Lee County Clerk of Courts Page 3HL LAW GROUP. P.A.
ND PARK BLVD., SUITE 503, FORT L.
713-1212 F
www. HLLaw
2801 E:
DERDALE, FLORID
SUITE 360
ORLANDO, FLORID.
Jn Re: JOH
ST. JOHNS
Insured:
On or About June
dvised that Plaintiff, JOHN
epositions of the following 1
ACCONE AND SONIA
dividuals in connection with the abov
requests the
place within nt days of filing the instant action,
> INC;
> Desk Adjuster, on behalf of ST, JOHNS INS OMPAI INC
> Claims Examiner, on behalf of ST, JOH?
> The Corporate Representative on behalf of ST, JOHNS ID
The areas of inquiry include but are not limited to:
-Clarification for all responses to interrogatories;
-What post loss conditions have not been ¢
-Basis for all affirmatn
-All documents requested from the Plaintiff prior to suit for the subject claim, and reason
for requesting sare;
aFilad LFormal Request for Depositions
April 12, 2021
Page| 2
-Estimates prepared by Defendant and provided previously to Plaintiff;
-Identification of all policy language relied upon to deny coverage;
-Clarification and understanding of all documents produced in response to request for
production.
Please contact our office to coordinate mutually convenient dates and times.
Thank you for your prompt attention in this regard.
Sincerely,
/s/ Daniel Rosenbaum
Daniel Rosenbaum, Esquire
For the Firm
eFiled Lee County Clerk of Courts Page 5
Document Filed Date
April 12, 2021
Case Filing Date
April 12, 2021
Category
CA Insurance Claims
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Filing # 124764347 E-Filed 04/12/2021 04:14:38 PM IN THE CIRCUIT COURT OF THE 20™ JUDICIAL CIRCUIT, IN AND FOR LEE JOHN GIACCONE COUNTY, FLORIDA AND SONIA RANSOM, CASE NO.: Plaintiff, Vv. ST. JOHNS INSURANCE COMPANY, INC., Defendant. / NOTICE OF FILING PLAINTIFF’S REQUEST FOR DEPOSITIONS Plaintiff, JOHN GIACCONE AND SONIA RANSOM (hereinafter “Plaintiff’), by and through undersigned counsel, and hereby gives notice of filing Plaintiff's Formal Deposition Requests with the Court, which is attached hereto as Exhibit “A”: 1. Plaintiff's Request for Depositions [CERTIFICATE OF SERVICE ON THE FOLLOWING PAGE] Page 1 of 3 eFiled Lee County Clerk of Courts Page 1CERTIFICATE OF SERVICE THEREBY CERTIFY that a true and correct copy of the above foregoing has been served along with the Summons and Complaint in this matter. HL LAW GROUP, P.A. By:__/s/ Daniel Rosenbaum Daniel Rosenbaum, Esquire FBN: 123674 Attorney for Plaintiff 2601 East Oakland Park Boulevard, Suite 503 Fort Lauderdale, Florida 33306 Telephone: (954) 713-1212 Facsimile: (954) 760-4239 Primary Email: | DRosenbaum@HLLawGroup.com Secondary Email: Service@HLLawGroup.com Tertiary Email: = SJames@HLLawGroup.com Page 2 of 3 eFiled Lee County Clerk of Courts Page 2EXHIBIT A Page 3 of 3 eFiled Lee County Clerk of Courts Page 3HL LAW GROUP. P.A. ND PARK BLVD., SUITE 503, FORT L. 713-1212 F www. HLLaw 2801 E: DERDALE, FLORID SUITE 360 ORLANDO, FLORID. Jn Re: JOH ST. JOHNS Insured: On or About June dvised that Plaintiff, JOHN epositions of the following 1 ACCONE AND SONIA dividuals in connection with the abov requests the place within nt days of filing the instant action, > INC; > Desk Adjuster, on behalf of ST, JOHNS INS OMPAI INC > Claims Examiner, on behalf of ST, JOH? > The Corporate Representative on behalf of ST, JOHNS ID The areas of inquiry include but are not limited to: -Clarification for all responses to interrogatories; -What post loss conditions have not been ¢ -Basis for all affirmatn -All documents requested from the Plaintiff prior to suit for the subject claim, and reason for requesting sare; aFilad LFormal Request for Depositions April 12, 2021 Page| 2 -Estimates prepared by Defendant and provided previously to Plaintiff; -Identification of all policy language relied upon to deny coverage; -Clarification and understanding of all documents produced in response to request for production. Please contact our office to coordinate mutually convenient dates and times. Thank you for your prompt attention in this regard. Sincerely, /s/ Daniel Rosenbaum Daniel Rosenbaum, Esquire For the Firm eFiled Lee County Clerk of Courts Page 5