Party Discovery: Natacha Beaufils Plaintiff vs. Citizens Property Insurance Corporation Defendant

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                                Filing# 143882092 E-Filed 02/14/2022 03:42:13 PM
 IN THE CIRCUIT COURT OF THE 17TH
 JUDICIAL
 CIRCUIT
 IN
 AND FOR
 BROWARD COUNTY, FLORIDA
 NATACHA BEAUFILS,
 CIVIL DIVISION
 Plaintiff(s),
 CASE NO.: CACE-21-007700
 V
 CITIZENS PROPERTY INSURANCE
 CORPORATION,
 Defendant.
 i
 RE- NOTICE OF TAKING REMOTE DEPOSITION DUCES TECUM
 (Date Change)
 (Depositionwit! be conducted via Zoom)
 PLEASE TAKE NOTICE that the undersigned attorney will take the depositionof:
 NAME:
 CorporateRepresentativeof Citizens PropertyInsurance
 Corporation
 DATE:
 May 23,2022
 TIME:
 1:30PM
 LOCATION:
 Deposition will be conducted via Zoom
 (Linkwill be Provided Upon Receipt)
 COURT
 DLE Court Reporters
 REPORTER:
 Pursuant to Fla. R. Civ. P. 1.310(b)(6),
 Defendant shall be requiredto produce a representative
 capableof testifying
 on Defendant's behalf for the followingareas of inquiry:
 1.
 The evidence supportingeach denial of Plaintiff's allegations
 in the Complaint listed in
 Defendant's Answer and Affirmative Defenses.
 2.
 The evidence supportingthe affirmative defenses listed in Defendant's Answer and
 Affirmative Defenses.
 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/14/2022 03:42:12 PM.****
 CASE NO. CACE-21-007700
 3.
 Any priorclaims for the subjectproperty investigatedduringthe course of this claim.
 4.
 The relationshipbetween Defendant and non-employees that investigatedthis claim on
 Defendant's behalf. Specifically
 a.
 Have the non-employee individuals and companies that investigatedthis claim
 performed work for Defendant before?
 b.
 How many times in the last three years has Defendant contracted these individuals
 or companies?
 c.
 How much does Defendant pay these individuals for their participationin claims
 investigation?
 5.
 The qualifications
 and curriculum vitae of any person that has provided Defendant an
 opinion regardingthe cause of originof the loss in this case.
 6.
 Whether the Defendant observed any damage duringthe investigation
 of this claim.
 7.
 The cause and originofthe damage inspectedduringthe investigationofthis claim.
 8.
 The qualifications
 and curriculum vitae of any person that has providedDefendant with an
 estimate ofthe cost to repairdamage observed duringthe inspectionofthis claim.
 9.
 The cost to repairdamage observed duringthe inspectionofthis case.
 10. The scope of work to be performed as a result of Defendant allegedlyinvoking the option
 to repair.
 11. Any payments issued by Defendant to Plaintiff for this claim.
 12. Any and all written and verbal communications between Defendant's agents, employees,
 inspectors,
 adjustersand attorneys and Plaintiff's agents, adjustersand attorneys.
 13. All of the Defendant's requests for post loss compliance and Plaintiff's response to those
 requests.
 Page 2 of 5
 CASE NO. CACE-21-007700
 14. All evidence in Defendant's possessionevidencingthe condition ofthe property before the
 subjectloss.
 Upon oral examination before any Notary Public or office authorized by the law to take
 depositionsin the State of Florida and to have with you at the before mentioned time and placeor
 provide via mail to arrive on the said date,the followingitems listed in the attached SCHEDULE
 "1,,,
 Such oral examination will continue from day to day until completed.The depositionis
 being takingfor the purpose of discovery,for use at trial,or for such other purposes as permitted
 under the applicableStatutes or Rules of the Court.
 CERTIFICATE OF SERVICE
 I HEREBY CERTIFY that a true and correct copy of the foregoingwas furnished Via
 E-mail on this February 14,2022.
 VARGAS GONZALEZ
 BALDWIN DELOMBARD, LLP.
 815 Ponce De Leon Blvd. ird
 31
 Floor
 Coral Gables, FL 33134
 Tel: 305.631.2528
 Fax: 305.631.2741
 E-mail: Servicel
 E-mail: EOchoa@VargasGonzalez.com
 By-.
 /s/ Eduardo J. Ochoa, Esq.
 Eduardo J. Ochoa, Esq.
 Fla. Bar No.: 1025044
 CC:
 DLE Court Reporters,Inc. (info@dlecourtreporters.com)
 (SPACE LEFT INTENTIONALLY BLANK)
 Page 3 of 5
 CASE NO. CACE-21-007700
 SCHEDULE "A"
 1.
 All evidence in Defendant's possessionevidencingthe condition ofthe property before the
 subjectpolicyof insurance was issued.
 2.
 All evidence in Defendant's possessionevidencingthe condition ofthe property priorto
 the date of loss.
 3.
 All evidence in Defendant's possessionevidencingthe condition ofthe property after the
 loss.
 4.
 Any priorclaims for the subjectproperty known to or investigatedby the Defendant and
 the results thereof.
 5.
 The complete factual basis supportingeach denial of Plaintiff's allegationsin the
 Complaint listed in Defendant's Answer and Affirmative Defenses.
 6.
 The complete factual basis supportingthe affirmative defenses listed in Defendant's
 Answer and Affirmative Defenses.
 7.
 The Defendant's interpretation
 and implementationofthe policy'sterms, includingthe
 coverage provisions,exclusions and exceptions.
 8.
 The relationsh*between Defendant and its agents or experts that worked on, investigated,
 or opined on this claim on Defendant's behalf,includingbut not limited to:
 a.
 Those individuals' identities and contact information, with the exceptionofwork
 productimmune non-testifying
 experts or consultants;
 b.
 Those individuals' qualifications
 and curriculum vitae;
 c.
 Those individuals' opinionsin this matter;
 d.
 Whether and to what extent in the past three years those agents or experts that
 Page 4 of 5
 CASE NO. CACE-21-007700
 investigated
 or consulted on this claim have been retained by the Defendant;
 e.
 The compensation(orrelative percentage of any agent'sother total compensation
 paidby the Defendant to these agents or experts in the past three years;
 f.
 The relative percentages of expert witness or other consultingwork any such
 experts have done for insureds versus insurers.
 9.
 The Defendant or its agents'estimate of Plaintiffs damages, irrespectiveof coverage,
 includingbut not limited to the factual basis,legalbasis,and method of calculation
 for
 such estimated damages.
 10. The estimated costs or damages for any consequentialor other covered damages due the
 insured for this loss,includingbut not limited to loss of use or alternative livingexpenses.
 11. Any and all written and verbal communications between Defendant's agents, employees,
 inspectors,adjustersand attorneys and Plaintiff's agents, adjustersand attorneys.
 12.
 The facts relatingto your investigationof Plaintiff' s loss.
 Page 5 of 5