On August 27, 2021 a
Party Discovery
was filed
involving a dispute between
Middleton, Bridget,
Middleton, Christopher,
and
State Farm Florida Insurance Company,
for CONTRACT & INDEBTEDNESS
in the District Court of Escambia County.
Preview
Filing # 133590675 E-Filed 08/27/2021 04:28:43 PM
CHRISTOPHER MIDDLETON
AND BRIDGET MIDDLETON,
Plaintiffs,
Vv.
STATE FARM FLORIDA
INSURANCE COMPANY,
Defendant.
IN THE CIRCUIT COURT OF THE I*
JUDICIAL CIRCUIT IN AND FOR
ESCAMBIA COUNTY, FLORIDA
CASE NO.:
/
PLAINTIFFS’ NOTICE OF TAKING VIDEO DEPOSITION DUCES TECUM OF
RULE 1.310(b)(6)
NT’S DESIGNATED CORPORATE REPRESENTATIVE PURSUANT TO
PLEASE TAKE NOTICE that Plaintiffs, CHRISTOPHER MIDDLETON AND
BRIDGET MIDDLETON, through the undersigned counsel will take the deposition, by oral
examination of the following person pursuant to Fla.R.Civ.P. 1.310(b)(6) as indicated below or
at such other location, time, and date as is mutually agreed upon by counsel or ordered by the
Court, before an associate or deputy court reporter who is not of counsel to the parties or
interested in the events of this cause.
topics listed in Schedule A of this
notice. The persons so designated
must testify about matters known or
reasonably available to the
Defendant. Fla. R. Civ. P.
1.310(b)(6).
receipt of the summons. If
no date is provided a date
and time (EST) will be
selected by the Plaintiffs.
NAME DATE/TIME PLACE
Corporate representative designated |To be provided by | KANNER&
by the Defendant to testify as to the | Defendant within 30 days of | PINTALUGA, P.A.
925 S. Federal Highway,
Sixth Floor
Boca Raton, FL 33432
The deponent is directed to produce for inspection and/or copying the documents listed in
schedule B of this notice 10 days prior to the scheduled deposition. This is in an effort to
Page 1 of 6expedite the deposition in order to allow Plaintiffs to review the documents prior to the
deposition. If the documents are not provided prior to the deposition the Defendant is put on
notice that Plaintiffs will reserve the necessary time prior to the deposition in order to review the
documents. Plaintiffs will reimburse deponent for all reasonable costs associated with producing
the requested documents as allowed by the Florida Rules of Civil Procedure. If any documents
are being claimed as privileged, Defendant must file a privilege log prior to the deposition with
enough time for the Court to rule upon said objections prior to the deposition.
The deposition is being taken for the purpose of discovery, use at trial and/or for such
other purposes as permitted under the Florida Rules of Civil Procedure.
The deposition will be videotaped, and the name and address of the operator will be
provided after Defendant provides the date and location of the deposition as referenced above.
**Documents responsive to Schedule B of this notice over which Defendant has
claimed a privilege need not be produced to Plaintiffs but must be brought to the deposition
should the need arise to refresh the witness’ recollection as to questions regarding non-
privileged matters. Plaintiffs stipulate that the witness’ use of such documents to refresh
recollection will not waive any privilege Defendant has claimed over such documents, nor
entitle Plaintiffs to review or receive production of such documents at the deposition, and
Plaintiffs retain the right to challenge any claims of privilege prior to or after the
deposition. **
[Certificate of Service on Following Page]
Page 2 of 6CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of this document will be served on the Defendant with
the Complaint.
KANNER & PINTALUGA, P.A.
Attorneys for Plaintiffs
3615 East Frontage Road
Tampa, Florida 33607
Phone: (561) 892-9665
Fax: (561) 853-2188
Email: wparks@kpattorney.com
FirstPartyEService@kpattorney.com
By:_/s/ William F. Parks :
William F, Parks, ESQ.
Florida Bar No.: 1010816
Page 3 of 6SCHEDULE “A”
1. The Corporate Representative who can identify by full name and company title all
persons who participated in the handling of Plaintiffs’ insurance claim that is the subject of this
action.
2. The Corporate Representative who can testify as to the complete investigation of
Plaintiffs’ insurance claim that is the subject of this action.
3. The Corporate Representative who can testify as to any payments that were made
to the Plaintiffs and/or on their behalf in reference to the insurance claim that is the subject of
this action.
4. The Corporate Representative who can testify as to the valuation of the insurance
claim that is the subject of this action.
5. The Corporate Representative who can testify as to the affirmative defenses
asserted by Defendant in this action.
6. The Corporate Representative who can testify as to Defendant’s responses to
written discovery in this action.
7. The Corporate Representative who can testify as to the insurance policy that is the
subject of this action.
8. The Corporate Representative who can testify as to the date the Defendant
anticipated litigation as to the insurance claim that is the subject of this claim.
9. The credentials of any individual who inspected the Plaintiffs’ property in
reference to the insurance claim that is the subject of this claim.
10. The credentials of any individual who Defendant retained to make repairs at the
Plaintiffs’ property for the subject claim.
Page 4 of 6SCHEDULE “B”
1. All documents the deponent reviewed in preparation of this deposition.
2. All documents the deponent will rely upon in responding to the topics listed in
Schedule “A” during the deposition.
3. The privilege log for any documents Defendant is claiming a privilege as to for
the deposition.
4. The entire claim file for Plaintiffs’ insurance claim that is the subject of this
action.
5. Any documents associated with the calculation of Plaintiffs’ insurance claim that
is the subject of this action.
6. The credentials of any person who inspected and/or handled the insurance claim
that is the subject of this claim.
7. The credentials of any person who Defendant retained to make repairs at the
subject property for the subject claim.
8. Any reports prepared for the insurance claim that is the subject of this action.
9. Any invoices for services performed in reference to the insurance claim that is the
subject of this action.
10. Any documents reflecting payments of any amounts in reference to the insurance
that is the subject of this action.
11. Any documents as to the directives and/or parameters for any inspections
conducted on behalf of the Defendant for Plaintiffs’ insurance claim that is the subject of this
action.
Page 5 of 62.
Any communications (including emails and/or text messages) that are anyway
associated with Plaintiffs’ insurance claim that is the subject of this action.
3.
4,
5.
6.
The insurance policy that is the subject of this action.
The underwriting file for the insurance policy that is the subject of this action.
Any documents that Defendant is relying upon in defense to this action.
The most recent resume or curriculum vitae (CV) of the Corporate
Representative.
Page 6 of 6
Document Filed Date
August 27, 2021
Case Filing Date
August 27, 2021
Category
CONTRACT & INDEBTEDNESS
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Filing # 133590675 E-Filed 08/27/2021 04:28:43 PM CHRISTOPHER MIDDLETON AND BRIDGET MIDDLETON, Plaintiffs, Vv. STATE FARM FLORIDA INSURANCE COMPANY, Defendant. IN THE CIRCUIT COURT OF THE I* JUDICIAL CIRCUIT IN AND FOR ESCAMBIA COUNTY, FLORIDA CASE NO.: / PLAINTIFFS’ NOTICE OF TAKING VIDEO DEPOSITION DUCES TECUM OF RULE 1.310(b)(6) NT’S DESIGNATED CORPORATE REPRESENTATIVE PURSUANT TO PLEASE TAKE NOTICE that Plaintiffs, CHRISTOPHER MIDDLETON AND BRIDGET MIDDLETON, through the undersigned counsel will take the deposition, by oral examination of the following person pursuant to Fla.R.Civ.P. 1.310(b)(6) as indicated below or at such other location, time, and date as is mutually agreed upon by counsel or ordered by the Court, before an associate or deputy court reporter who is not of counsel to the parties or interested in the events of this cause. topics listed in Schedule A of this notice. The persons so designated must testify about matters known or reasonably available to the Defendant. Fla. R. Civ. P. 1.310(b)(6). receipt of the summons. If no date is provided a date and time (EST) will be selected by the Plaintiffs. NAME DATE/TIME PLACE Corporate representative designated |To be provided by | KANNER& by the Defendant to testify as to the | Defendant within 30 days of | PINTALUGA, P.A. 925 S. Federal Highway, Sixth Floor Boca Raton, FL 33432 The deponent is directed to produce for inspection and/or copying the documents listed in schedule B of this notice 10 days prior to the scheduled deposition. This is in an effort to Page 1 of 6expedite the deposition in order to allow Plaintiffs to review the documents prior to the deposition. If the documents are not provided prior to the deposition the Defendant is put on notice that Plaintiffs will reserve the necessary time prior to the deposition in order to review the documents. Plaintiffs will reimburse deponent for all reasonable costs associated with producing the requested documents as allowed by the Florida Rules of Civil Procedure. If any documents are being claimed as privileged, Defendant must file a privilege log prior to the deposition with enough time for the Court to rule upon said objections prior to the deposition. The deposition is being taken for the purpose of discovery, use at trial and/or for such other purposes as permitted under the Florida Rules of Civil Procedure. The deposition will be videotaped, and the name and address of the operator will be provided after Defendant provides the date and location of the deposition as referenced above. **Documents responsive to Schedule B of this notice over which Defendant has claimed a privilege need not be produced to Plaintiffs but must be brought to the deposition should the need arise to refresh the witness’ recollection as to questions regarding non- privileged matters. Plaintiffs stipulate that the witness’ use of such documents to refresh recollection will not waive any privilege Defendant has claimed over such documents, nor entitle Plaintiffs to review or receive production of such documents at the deposition, and Plaintiffs retain the right to challenge any claims of privilege prior to or after the deposition. ** [Certificate of Service on Following Page] Page 2 of 6CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of this document will be served on the Defendant with the Complaint. KANNER & PINTALUGA, P.A. Attorneys for Plaintiffs 3615 East Frontage Road Tampa, Florida 33607 Phone: (561) 892-9665 Fax: (561) 853-2188 Email: wparks@kpattorney.com FirstPartyEService@kpattorney.com By:_/s/ William F. Parks : William F, Parks, ESQ. Florida Bar No.: 1010816 Page 3 of 6SCHEDULE “A” 1. The Corporate Representative who can identify by full name and company title all persons who participated in the handling of Plaintiffs’ insurance claim that is the subject of this action. 2. The Corporate Representative who can testify as to the complete investigation of Plaintiffs’ insurance claim that is the subject of this action. 3. The Corporate Representative who can testify as to any payments that were made to the Plaintiffs and/or on their behalf in reference to the insurance claim that is the subject of this action. 4. The Corporate Representative who can testify as to the valuation of the insurance claim that is the subject of this action. 5. The Corporate Representative who can testify as to the affirmative defenses asserted by Defendant in this action. 6. The Corporate Representative who can testify as to Defendant’s responses to written discovery in this action. 7. The Corporate Representative who can testify as to the insurance policy that is the subject of this action. 8. The Corporate Representative who can testify as to the date the Defendant anticipated litigation as to the insurance claim that is the subject of this claim. 9. The credentials of any individual who inspected the Plaintiffs’ property in reference to the insurance claim that is the subject of this claim. 10. The credentials of any individual who Defendant retained to make repairs at the Plaintiffs’ property for the subject claim. Page 4 of 6SCHEDULE “B” 1. All documents the deponent reviewed in preparation of this deposition. 2. All documents the deponent will rely upon in responding to the topics listed in Schedule “A” during the deposition. 3. The privilege log for any documents Defendant is claiming a privilege as to for the deposition. 4. The entire claim file for Plaintiffs’ insurance claim that is the subject of this action. 5. Any documents associated with the calculation of Plaintiffs’ insurance claim that is the subject of this action. 6. The credentials of any person who inspected and/or handled the insurance claim that is the subject of this claim. 7. The credentials of any person who Defendant retained to make repairs at the subject property for the subject claim. 8. Any reports prepared for the insurance claim that is the subject of this action. 9. Any invoices for services performed in reference to the insurance claim that is the subject of this action. 10. Any documents reflecting payments of any amounts in reference to the insurance that is the subject of this action. 11. Any documents as to the directives and/or parameters for any inspections conducted on behalf of the Defendant for Plaintiffs’ insurance claim that is the subject of this action. Page 5 of 62. Any communications (including emails and/or text messages) that are anyway associated with Plaintiffs’ insurance claim that is the subject of this action. 3. 4, 5. 6. The insurance policy that is the subject of this action. The underwriting file for the insurance policy that is the subject of this action. Any documents that Defendant is relying upon in defense to this action. The most recent resume or curriculum vitae (CV) of the Corporate Representative. Page 6 of 6