On April 09, 2019 a
Party Discovery
was filed
involving a dispute between
Cyr, Jessica,
Cyr, Timothy,
and
Edison Insurance Company,
for INSURANCE CLAIM
in the District Court of Bay County.
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Filing # 112104380 E-Filed 08/20/2020 10:20:45 AM
IN THE CIRCUIT COURT OF THE
14TH JUDICIAL CIRCUIT IN AND FOR
BAY COUNTY, FLORIDA
TIMOTHY CYR & JESSICA CYR, CASE NO.: 19001054CA
Plaintiff,
Vv.
EDISON INSURANCE COMPANY,
Defendant.
RE-NOTICE OF TAKING DEPOSITION (DUCES TECUM)
(Plaintiff's Counsel to appear via video/telephone)
PLEASE TAKE NOTICE that the Plaintiff will take the deposition(s) of the following
person(s) as indicated below:
NAME:
DATE:
TIME:
LOCATION:
Field adjuster, Chad King, regarding the following areas on behalf of
EDISON INSURANCE COMPANY.
The witness is to bring with him/her to the deposition, unless provided in
advance thereto, the original and complete claim file for the subject claim,
with any items removed based upon a privilege to be noted and marked
accordingly in a privileged log.
October 26, 2020
10:00 a.m. Eastern Time
U.S. Legal Support — Regus
5051 Peachtree Corners Circle, Suite 200
Norcross, Georgia, 30092
(Remote appearance will be provided by court reporter)Upon oral examination before a Court Reporter, a Notary Public or other official authorized
by law to take depositions. The deposition will continue from day to day until completed. The
deposition is being taken for the purpose of discovery, for use at trial, or both of the foregoing, or
for such other purposes as are permitted under the applicable and governing rules.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via the
Florida e-filing portal this 20th day of August, 2020 to: Lateshia Frye, Esquire, CONROY
SIMBERG; 3440 Hollywood Boulevard, Second Floor, Hollywood, FL 33021; Attorney for
Defendant, eservicchwd@conroysimberg.com, Lfrye@conroysimberg.com.
By: 4/ Daniel Castro
Daniel D. Castro, Esq.
FL Bar No. 90954
Thomas J. Morgan, Jr., Esq.
Fla. Bar No. 127612
MORGAN LAW GROUP, P.A.
Attorneys for Plaintiff
55 Merrick Way, Suite 404
Coral Gables, Florida 33134
Phone: 305-569-9900
Fax: 305-443-6828
Pleadings only:
DCastro@morganlawgroup.net
/me
Document Filed Date
August 20, 2020
Case Filing Date
April 09, 2019
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Filing # 112104380 E-Filed 08/20/2020 10:20:45 AM IN THE CIRCUIT COURT OF THE 14TH JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA TIMOTHY CYR & JESSICA CYR, CASE NO.: 19001054CA Plaintiff, Vv. EDISON INSURANCE COMPANY, Defendant. RE-NOTICE OF TAKING DEPOSITION (DUCES TECUM) (Plaintiff's Counsel to appear via video/telephone) PLEASE TAKE NOTICE that the Plaintiff will take the deposition(s) of the following person(s) as indicated below: NAME: DATE: TIME: LOCATION: Field adjuster, Chad King, regarding the following areas on behalf of EDISON INSURANCE COMPANY. The witness is to bring with him/her to the deposition, unless provided in advance thereto, the original and complete claim file for the subject claim, with any items removed based upon a privilege to be noted and marked accordingly in a privileged log. October 26, 2020 10:00 a.m. Eastern Time U.S. Legal Support — Regus 5051 Peachtree Corners Circle, Suite 200 Norcross, Georgia, 30092 (Remote appearance will be provided by court reporter)Upon oral examination before a Court Reporter, a Notary Public or other official authorized by law to take depositions. The deposition will continue from day to day until completed. The deposition is being taken for the purpose of discovery, for use at trial, or both of the foregoing, or for such other purposes as are permitted under the applicable and governing rules. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via the Florida e-filing portal this 20th day of August, 2020 to: Lateshia Frye, Esquire, CONROY SIMBERG; 3440 Hollywood Boulevard, Second Floor, Hollywood, FL 33021; Attorney for Defendant, eservicchwd@conroysimberg.com, Lfrye@conroysimberg.com. By: 4/ Daniel Castro Daniel D. Castro, Esq. FL Bar No. 90954 Thomas J. Morgan, Jr., Esq. Fla. Bar No. 127612 MORGAN LAW GROUP, P.A. Attorneys for Plaintiff 55 Merrick Way, Suite 404 Coral Gables, Florida 33134 Phone: 305-569-9900 Fax: 305-443-6828 Pleadings only: DCastro@morganlawgroup.net /me