On June 30, 2021 a
Party Notice
was filed
involving a dispute between
Oceania Iv Condominium Association, Inc.,
and
Certain Underwriters At Lloyds, London,
General Security Indemnity Company Of Arizona,
International Insurance Company Of Hannover Se,
Interstate Fire & Casualty Company,
for Insurance Claim
in the District Court of Miami-Dade County.
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Filing # 140981064 E-Filed 12/27/2021 05:29:43 PM
IN THE CIRCUIT COURT OF THE 11TH
JUDICIAL CIRCUIT, IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
OCEANIA IV CONDOMINIUM
ASSOCIATION, INC.,
Plaintiff,
v.
CERTAIN UNDERWRITERS AT LLOYD'S, CASE NO. 2021-015900-CA-01
LONDON; INTERNATIONAL INSURANCE
COMPANY OF HANNOVER SE; GENERAL
SECURITY INDEMNITY COMPANY OF
ARIZONA; and INTERSTATE FIRE &
CASUAL COMPANY,
Defendants.
NOTICE OF PRODUCTION FROM NON-PARTIES
TO: Veronica M. Rabinowitz, Esq.
Siegfried Rivera
201 Alhambra Circle, Eleventh Floor
Coral Gables, Florida 33134
COMES NOW, Defendant, CERTAIN UNDERWRITERS AT LLOYD'S, LONDON,
SUBSCRIBING TO POLICY NO.'S AOP-170262 and AQS-170591, by and through its
undersigned counsel, and provides notice of its intent to serve the attached Subpoena(s) Duces
Tecum Without Deposition under Rule 1.351 after ten (10) days from the date of this notice for
the production of documents and things as noted on said Subpoena(s) to:
USPlate Glass Insurance Company
c/o Registered Agent Chief Financial Officer
200 East Gaines Street, Tallahassee, FL 32399
The non-parties, the parties to this cause of action, and all other interested parties have the
right to object to the production of said documents and things in which case the non-party will not
be required to surrender said documents or things pending determination of said objection by the
court upon hearing. If no objection is made, the attached Subpoena’s for production of said
23118959.1:10679-1395
documents or things will be issued in accordance with this Notice. The Subpoena recipient may
condition the preparation of copies on the payment in advance of the reasonable costs of preparing
the copies. On receipt of same, the undersigned shall furnish a legible copy of each item to any
other party who requests it upon the payment of the reasonable cost of preparing the copies.
Dated: December 27, 2021
Respectfully submitted,
/s/ Nicole M. Dominguez
VINCENT P. BEILMAN, III, ESQ.
Florida Bar No. 23966
RICHARD M. SINGER, ESQ.
Florida Bar No. 93036
MELISSA V. JORDON, ESQ.
Florida Bar No. 123576
NICOLE M. DOMINGUEZ, ESQ.
Florida Bar No. 1031225
WOOD, SMITH,
HENNING & BERMAN LLP
701 Brickell Avenue, Suite 1640
Miami, Florida 33131
Telephone: (786) 358-6420
Facsimile: (786) 358-6421
rsinger@wshblaw.com
mjordon@wshblaw.com
ndominguez@wshblaw.com
ezaher@wshblaw.com
Counsel for Defendants
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on December 27, 2021, a copy of the foregoing was served
via the Florida e-Portal filing system which will send notice to all counsel of record.
/s/ Nicole M. Dominguez
Nicole M. Dominguez, Esq.
23118959.1:10679-1395
Document Filed Date
December 27, 2021
Case Filing Date
June 30, 2021
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Filing # 140981064 E-Filed 12/27/2021 05:29:43 PM IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT, IN AND FOR MIAMI-DADE COUNTY, FLORIDA OCEANIA IV CONDOMINIUM ASSOCIATION, INC., Plaintiff, v. CERTAIN UNDERWRITERS AT LLOYD'S, CASE NO. 2021-015900-CA-01 LONDON; INTERNATIONAL INSURANCE COMPANY OF HANNOVER SE; GENERAL SECURITY INDEMNITY COMPANY OF ARIZONA; and INTERSTATE FIRE & CASUAL COMPANY, Defendants. NOTICE OF PRODUCTION FROM NON-PARTIES TO: Veronica M. Rabinowitz, Esq. Siegfried Rivera 201 Alhambra Circle, Eleventh Floor Coral Gables, Florida 33134 COMES NOW, Defendant, CERTAIN UNDERWRITERS AT LLOYD'S, LONDON, SUBSCRIBING TO POLICY NO.'S AOP-170262 and AQS-170591, by and through its undersigned counsel, and provides notice of its intent to serve the attached Subpoena(s) Duces Tecum Without Deposition under Rule 1.351 after ten (10) days from the date of this notice for the production of documents and things as noted on said Subpoena(s) to: USPlate Glass Insurance Company c/o Registered Agent Chief Financial Officer 200 East Gaines Street, Tallahassee, FL 32399 The non-parties, the parties to this cause of action, and all other interested parties have the right to object to the production of said documents and things in which case the non-party will not be required to surrender said documents or things pending determination of said objection by the court upon hearing. If no objection is made, the attached Subpoena’s for production of said 23118959.1:10679-1395 documents or things will be issued in accordance with this Notice. The Subpoena recipient may condition the preparation of copies on the payment in advance of the reasonable costs of preparing the copies. On receipt of same, the undersigned shall furnish a legible copy of each item to any other party who requests it upon the payment of the reasonable cost of preparing the copies. Dated: December 27, 2021 Respectfully submitted, /s/ Nicole M. Dominguez VINCENT P. BEILMAN, III, ESQ. Florida Bar No. 23966 RICHARD M. SINGER, ESQ. Florida Bar No. 93036 MELISSA V. JORDON, ESQ. Florida Bar No. 123576 NICOLE M. DOMINGUEZ, ESQ. Florida Bar No. 1031225 WOOD, SMITH, HENNING & BERMAN LLP 701 Brickell Avenue, Suite 1640 Miami, Florida 33131 Telephone: (786) 358-6420 Facsimile: (786) 358-6421 rsinger@wshblaw.com mjordon@wshblaw.com ndominguez@wshblaw.com ezaher@wshblaw.com Counsel for Defendants CERTIFICATE OF SERVICE I HEREBY CERTIFY that on December 27, 2021, a copy of the foregoing was served via the Florida e-Portal filing system which will send notice to all counsel of record. /s/ Nicole M. Dominguez Nicole M. Dominguez, Esq. 23118959.1:10679-1395