On December 13, 2019 a
Party Discovery
was filed
involving a dispute between
Varnes, Cynthia,
Varnes, Travis,
and
Security First Insurance Company,
for INSURANCE CLAIM
in the District Court of Bay County.
Preview
Filing # 112289216 E-Filed 08/24/2020 04:12:48 PM
IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL
CIRCUIT IN AND FOR BAY COUNTY, FLORIDA
CASE NO: 19-004515-CA
TRAVIS AND CYNTHIA VARNES,
Plaintiff,
vs.
SECURITY FIRST INSURANCE COMPANY
D/B/A SECURITY FIRST FLORIDA,
Defendant.
NOTICE OF TAKING DEPOSITION
DUCES TECUM VIA VIRTUAL PLATFORM
PLEASE TAKE NOTICE that a deposition will be taking place via virtual platform
before Veritext, or some other Notary Public for the State of Florida at Large. The attorney for
the Plaintiff will be taking the deposition of the below listed individual via virtual platform
pursuant to Administrative Order No. AOSC20-16.
DEPONENT: Frank Stilley
DATE: December 17, 2020
TIME: 11:00 AM
Witness is to have available for upload to the virtual platform or submission to the parties and
reporter at set time and place the following:
1. Any and all documents you reviewed regarding the subject matter of this case upon which you
base any claim decisions, opinions, or actions;
2. Any reports you generated;
3. Your entire file relating to this matter; and,4. Any and all reports, documents, photographs, whether electronic or otherwise, you gathered,
collected, placed in the claim file, or in any way relied on for any decisions, opinions, or
actions regarding this claim.
**Documents for which Defendant has raised, or intends to raise, a privilege (e.g., claims file
documents) need not be produced to Plaintiff for examination, however must be brought so
that deponent may adequately respond to non-privileged areas of inquiry***
PLEASE TAKE NOTICE that we reserve the right to record the deposition by
stenographic means or by utilizing digital audio recording equipment or any other alternative
methods of capture. This deposition is being taken for the purpose of discovery, for use at trial,
or both of the foregoing, and for such other purposes as are permitted under the Florida Rules of
Civil Procedure and other applicable law.
CERTIFICATE OF SERVICE
1 HEREBY CERTIFY that on August 24, 2020, I electronically filed the foregoing with
the Clerk of the Court by using the Florida Courts E-Filing Portal which will send notice of this
electronic filing to counsel of record.
s/ Michael D. Quintero
COHEN LAW GROUP
Michael D. Quintero, Esquire
Florida Bar No. 91963
FOR THE FIRM
350 N. Lake Destiny Road
Maitland, Florida 32751
Telephone: (407) 478-4878
Facsimile: (407) 478-0204
mquintero@itsaboutjustice.law
heather@itsaboutjustice.law
Attorneys for Plaintiff
Copy: Veritext
Document Filed Date
August 24, 2020
Case Filing Date
December 13, 2019
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing # 112289216 E-Filed 08/24/2020 04:12:48 PM IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA CASE NO: 19-004515-CA TRAVIS AND CYNTHIA VARNES, Plaintiff, vs. SECURITY FIRST INSURANCE COMPANY D/B/A SECURITY FIRST FLORIDA, Defendant. NOTICE OF TAKING DEPOSITION DUCES TECUM VIA VIRTUAL PLATFORM PLEASE TAKE NOTICE that a deposition will be taking place via virtual platform before Veritext, or some other Notary Public for the State of Florida at Large. The attorney for the Plaintiff will be taking the deposition of the below listed individual via virtual platform pursuant to Administrative Order No. AOSC20-16. DEPONENT: Frank Stilley DATE: December 17, 2020 TIME: 11:00 AM Witness is to have available for upload to the virtual platform or submission to the parties and reporter at set time and place the following: 1. Any and all documents you reviewed regarding the subject matter of this case upon which you base any claim decisions, opinions, or actions; 2. Any reports you generated; 3. Your entire file relating to this matter; and,4. Any and all reports, documents, photographs, whether electronic or otherwise, you gathered, collected, placed in the claim file, or in any way relied on for any decisions, opinions, or actions regarding this claim. **Documents for which Defendant has raised, or intends to raise, a privilege (e.g., claims file documents) need not be produced to Plaintiff for examination, however must be brought so that deponent may adequately respond to non-privileged areas of inquiry*** PLEASE TAKE NOTICE that we reserve the right to record the deposition by stenographic means or by utilizing digital audio recording equipment or any other alternative methods of capture. This deposition is being taken for the purpose of discovery, for use at trial, or both of the foregoing, and for such other purposes as are permitted under the Florida Rules of Civil Procedure and other applicable law. CERTIFICATE OF SERVICE 1 HEREBY CERTIFY that on August 24, 2020, I electronically filed the foregoing with the Clerk of the Court by using the Florida Courts E-Filing Portal which will send notice of this electronic filing to counsel of record. s/ Michael D. Quintero COHEN LAW GROUP Michael D. Quintero, Esquire Florida Bar No. 91963 FOR THE FIRM 350 N. Lake Destiny Road Maitland, Florida 32751 Telephone: (407) 478-4878 Facsimile: (407) 478-0204 mquintero@itsaboutjustice.law heather@itsaboutjustice.law Attorneys for Plaintiff Copy: Veritext