On December 16, 2019 a
Party Discovery
was filed
involving a dispute between
Union Restoration Inc,
and
Edison Insurance Company,
for INSURANCE CLAIM
in the District Court of Bay County.
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Filing # 100347288 E-Filed 12/16/2019 11:01:03 AM
IN THE CIRCUIT COURT OF THE 14TH
JUDICIAL CIRCUIT, IN AND FOR BAY COUNTY, FLORIDA
CASENO.: 19004524CA
UNION RESTORATION, INC.
a/a/o Raquel Estrada,
Plaintiff,
Vv.
EDISON INSURANCE COMPANY,
Defendant.
/
NOTICE OF REQUEST FOR DEPOSITION DATES
COMES NOW the Plaintiff, UNION RESTORATION, INC., (hereinafter referred to
collectively as the “Plaintiff’), by and through the undersigned counsel, and hereby files the
following, Notice of Request for Deposition Dates from the Defendant, EDISON INSURANCE
COMPANY (hereinafter referred to as the “Defendant”), of the individuals identified below to be
provided to the undersigned in writing within forty-five (45) days from the date of service of the
Summons and Complaint.
NOTE: The depositions of these individuals will take place more than thirty (30) days after
the commencement of this lawsuit.
Please provide dates for:
1. The designated corporate representative(s) of Defendant with the most knowledge
of the issues raised in this lawsuit and who will be testifying about this claim;
2. The desk adjuster(s) for the Defendant;
3. The field adjuster(s) for the Defendant;4. All person(s) who inspected the property on behalf of Defendant for the date of loss
that is the subject of this lawsuit and;
5. All professionals, including but not limited to engineers, environmental
professionals, general contractors, or other specialized contractors that rendered any opinions or
reports to the Defendant who may have contributed to any coverage decision, or scope of the loss
decision.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of this Request for Deposition Dates
has been furnished along with the Summons and Complaint.
Respectfully submitted,
LARRY MOSKOWITZ, P.A.
Attorneys for Plaintiff
400 SE 9" Street
Fort Lauderdale, Florida 33316
Telephone: (954) 797-7990
pleadings@werepresentyou.com
By: /s/. Lamy Waskewity
Larry Moskowitz, Esq.
Fla. Bar No.: 829587
Document Filed Date
December 16, 2019
Case Filing Date
December 16, 2019
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Filing # 100347288 E-Filed 12/16/2019 11:01:03 AM IN THE CIRCUIT COURT OF THE 14TH JUDICIAL CIRCUIT, IN AND FOR BAY COUNTY, FLORIDA CASENO.: 19004524CA UNION RESTORATION, INC. a/a/o Raquel Estrada, Plaintiff, Vv. EDISON INSURANCE COMPANY, Defendant. / NOTICE OF REQUEST FOR DEPOSITION DATES COMES NOW the Plaintiff, UNION RESTORATION, INC., (hereinafter referred to collectively as the “Plaintiff’), by and through the undersigned counsel, and hereby files the following, Notice of Request for Deposition Dates from the Defendant, EDISON INSURANCE COMPANY (hereinafter referred to as the “Defendant”), of the individuals identified below to be provided to the undersigned in writing within forty-five (45) days from the date of service of the Summons and Complaint. NOTE: The depositions of these individuals will take place more than thirty (30) days after the commencement of this lawsuit. Please provide dates for: 1. The designated corporate representative(s) of Defendant with the most knowledge of the issues raised in this lawsuit and who will be testifying about this claim; 2. The desk adjuster(s) for the Defendant; 3. The field adjuster(s) for the Defendant;4. All person(s) who inspected the property on behalf of Defendant for the date of loss that is the subject of this lawsuit and; 5. All professionals, including but not limited to engineers, environmental professionals, general contractors, or other specialized contractors that rendered any opinions or reports to the Defendant who may have contributed to any coverage decision, or scope of the loss decision. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of this Request for Deposition Dates has been furnished along with the Summons and Complaint. Respectfully submitted, LARRY MOSKOWITZ, P.A. Attorneys for Plaintiff 400 SE 9" Street Fort Lauderdale, Florida 33316 Telephone: (954) 797-7990 pleadings@werepresentyou.com By: /s/. Lamy Waskewity Larry Moskowitz, Esq. Fla. Bar No.: 829587