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 # 91808470 E-Filed 06/27/2019 04:30:31 PM
IN THE CIRCUIT COURT OF THE
FOURTEENTH JUDICIAL CIRCUIT IN
AND FOR BAY COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO.: 19001054CA
TIMOTHY CYR and
JESSICA CYR,
FLORIDA BAR NO.: 127612
Plaintiffs,
Vv.
EDISON INSURANCE COMPANY,
Defendant.
/
NOTICE OF TAKING DEPOSITION (DUCES TECUM)
(coordinated with opposing counsel)
PLEASE TAKE NOTICE that the Plaintiff will take the deposition(s) of the following
person(s) on the date and at the hour indicated herein at: 1900 Corporate Blvd NW Suite 200,
Boca Raton, FL 33431
NAME: Pursuant to Rule 1.130(b)(6), the designated officer, director, managing agent, or
other person (s) who consent to do so, regarding the following areas on behalf of
Edison Insurance Company ;
a. the specific handling and processing of the claim for Timothy Cyr and
Jessica Cyr which is the subject of this litigation;
b. the basis for any denial, reduction and/or non-payment of the subject
claim; and
Page 1 of 3c. information regarding the appraisal, estimate and/or other method of
computation used by the Defendant, or its representatives and/or agents, to
determine the value for the subject claim.
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.
DATE & TIME: October 8", 2019 at 10 am EST
upon oral examination before U.S. Legal Support, 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.
[continued on next page]
Page 2 of 3CERTIFICATE OF SERVICE
We hereby certify that a true and correct copy of the foregoing was furnished by e-service
pursuant to Rule 2.516(b)(1) this 27th day of June , 2019 via e-filing portal, upon: CONROY
SIMBERG, Attorney for Defendant, Edison Insurance Company, 1801 Centrepark Drive East,
Suite 200, West Palm Beach, FL 33401. Primary Email: eservicewpb@conroysimberg.com
Secondary Email: rhorwitz@conroysimberg.com
Thomas J. Morgan, Jr., Esquire
Fla, Bar No. 127612
John D, Lanpher, III, Esquire
Fla. Bar No. 118767
MORGAN LAW GROUP, P.A.
Attorneys for Plaintiffs
55 Merrick Way, Suite 404
Coral Gables, Florida 33134
Phone: 305.569.9900
Fax —: 305.443.6828
Pleadings only:
milg.eservice@morganlawgroup.net
Jlanpher@morganlawgroup.net
By: 4s/ Thomas J. Morgan, Jr.
Thomas J. Morgan, Jr.
/bg
Page 3 of 3
Document Filed Date
June 27, 2019
Case Filing Date
April 09, 2019
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Filing # 91808470 E-Filed 06/27/2019 04:30:31 PM IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO.: 19001054CA TIMOTHY CYR and JESSICA CYR, FLORIDA BAR NO.: 127612 Plaintiffs, Vv. EDISON INSURANCE COMPANY, Defendant. / NOTICE OF TAKING DEPOSITION (DUCES TECUM) (coordinated with opposing counsel) PLEASE TAKE NOTICE that the Plaintiff will take the deposition(s) of the following person(s) on the date and at the hour indicated herein at: 1900 Corporate Blvd NW Suite 200, Boca Raton, FL 33431 NAME: Pursuant to Rule 1.130(b)(6), the designated officer, director, managing agent, or other person (s) who consent to do so, regarding the following areas on behalf of Edison Insurance Company ; a. the specific handling and processing of the claim for Timothy Cyr and Jessica Cyr which is the subject of this litigation; b. the basis for any denial, reduction and/or non-payment of the subject claim; and Page 1 of 3c. information regarding the appraisal, estimate and/or other method of computation used by the Defendant, or its representatives and/or agents, to determine the value for the subject claim. 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. DATE & TIME: October 8", 2019 at 10 am EST upon oral examination before U.S. Legal Support, 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. [continued on next page] Page 2 of 3CERTIFICATE OF SERVICE We hereby certify that a true and correct copy of the foregoing was furnished by e-service pursuant to Rule 2.516(b)(1) this 27th day of June , 2019 via e-filing portal, upon: CONROY SIMBERG, Attorney for Defendant, Edison Insurance Company, 1801 Centrepark Drive East, Suite 200, West Palm Beach, FL 33401. Primary Email: eservicewpb@conroysimberg.com Secondary Email: rhorwitz@conroysimberg.com Thomas J. Morgan, Jr., Esquire Fla, Bar No. 127612 John D, Lanpher, III, Esquire Fla. Bar No. 118767 MORGAN LAW GROUP, P.A. Attorneys for Plaintiffs 55 Merrick Way, Suite 404 Coral Gables, Florida 33134 Phone: 305.569.9900 Fax —: 305.443.6828 Pleadings only: milg.eservice@morganlawgroup.net Jlanpher@morganlawgroup.net By: 4s/ Thomas J. Morgan, Jr. Thomas J. Morgan, Jr. /bg Page 3 of 3