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Filing # 81545990 E-Filed 12/03/2018 03:35:10 PM
IN THE CIRCUIT COURT OF THE 9TH
JUDICIAL CIRCUIT IN AND FOR
ORANGE COUNTY, FLORIDA
MARIA LAFLEUR, CASE NO.: 2017-CA-004500-O
Plaintiff,
v.
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
___________________________________/
NOTICE OF TAKING DEPOSITION DUCES TECUM OF PLAINTIFF
(Coordinated with Plaintiff’s Counsel)
PLEASE TAKE NOTICE that, pursuant to the Florida Rules of Civil Procedure
1.310(b)(6), UNIVERSAL PROPERTY AND CASUALTY INSURANCE COMPANY, will take
the deposition set forth below:
NAME OF DATE/TIME DEPOSITION
DEPONENT LOCATION
Esquire Deposition
Solutions
Maria LaFleur March 5, 2019 at 10:00 a.m. 200 East Robinson Street
Ste. 725
Orlando, FL 32801
Upon oral examination before a representative of Esquire Deposition Solutions or any other
officer authorized by law to take depositions in the State of Florida. The oral examination will
continue from day to day until completed.
This 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 Florida Rules of Civil Procedure
CASE NO. 2017-CA-004500
and other applicable law. And, pursuant to Fla. R. Civ. P. 1.350, said Defendant requests the
deponent have the following items listed in Attachment “A” at the time and place of the foregoing
deposition, for purposes of inspection and/or copying by this Defendant.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true copy of the foregoing has been furnished by electronic
filing to:. Kenneth R. Duboff, Esq., Duboff Law Firm, 680 NE 127 Street, North Miami, FL 33161
(CourtDocument@DuboffLawFirm.com) on this 3rd day of December, 2018.
Attorneys for Defendant
Universal Property & Casualty Ins. Co.
1855 West State Road 434, Suite 282
Longwood, Florida 32750
Telephone: 833-658-8594
Facsimile: 954-958-1262
By: /s/ Jason R. Urbanowicz
Jason R. Urbanowicz, Esq.
Florida Bar No. 391026
For Service of Court Documents only:
Primary: upciceservice05@universalproperty.com
Secondary: lb1101@universalproperty.com
Tertiary: ju1010@universalproperty.com
CASE NO. 2017-CA-004500
ATTACHMENT “A”
1. Copies of any and all correspondence between Plaintiff and Defendant with regard
to this claim or the allegations contained within Plaintiff’s Complaint.
2. Copies of any and all correspondence between Plaintiff and any public adjuster
assisting with the claim with respect to the property located at 1710 N Powers Drive, Orlando, FL
32818.
3. Copies of any and all correspondence between Plaintiff and any contractor,
repair/service company providing any services or preparing any estimate for repairs with respect
to any claimed damages in the Complaint.
4. Copies of any and all reports, drafts, charts, drawings, diagrams, and memoranda
and/or results of any testing showing or intending to show the cause of damage to Plaintiff’s
property located at 1710 N Powers Drive, Orlando, FL 32818 as asserted in the Complaint.
5. Copies of any documents which support any claim for damages set forth in the
Complaint
6. Copies of any and all repair estimates for alleged damages to Plaintiff’s property
located at 1710 N Powers Drive, Orlando, FL 32818 that are claimed in the Complaint.
7. Copies of any and all photographs or videotape taken of the property located at
1511 Golden Poppy Court, Orlando, FL 32824 prior to the alleged date of loss in the Complaint.
Please provide all photos or videos in electronic/digital format.
8. Copies of any and all photographs or videotape taken of the property located 1710
N Powers Drive, Orlando, FL 32818 on or subsequent to the alleged date of loss in the Complaint.
Please provide all photos or videos in electronic/digital format.
9. Copies of any and all photographs or videotape taken of the area(s) of the interior
of the home located at 1710 N Powers Drive, Orlando, FL 32818 to which you are claiming
damages in this Complaint. Please provide all photos or videos in electronic/digital format.
10. Copies of any and all invoices, cancelled checks or other evidence of payment for
repairs, remodels or renovations made to 1710 N Powers Drive, Orlando, FL 32818 relative to the
Loss alleged in the Complaint.
11. Copies of any and all invoices, cancelled checks or other evidence of payment for
repairs, remodels or renovations made 1710 N Powers Drive, Orlando, FL 32818 after to the date
of loss.
12. Copies of any and all invoices, cancelled checks or other evidence of payment for
repairs, remodels or renovations made to 1710 N Powers Drive, Orlando, FL 32818 for the five
(5) years prior to the date of loss.
CASE NO. 2017-CA-004500
13. Copies of any and all inspections, appraisals or other investigations for the property
located at 1710 N Powers Drive, Orlando, FL 32818 prior to the date of purchase.
14. Copies of any and all rules or regulation violations notices or correspondence issued
by any homeowner’s association regarding the property located at 1710 N Powers Drive, Orlando,
FL 32818 for the three (3) year period prior to the date of loss.
15. Copies of any and all rules or regulation violations notices or correspondence issued
by any homeowner’s association regarding the property located at 1710 N Powers Drive, Orlando,
FL 32818 subsequent to the date of loss.
16. Copies of any and all ordinance or code violations notices or correspondence issued
by any city/county municipality regarding the property located 1710 N Powers Drive, Orlando, FL
32818 for the three (3) year period prior to the date of loss.
17. Copies of any and all ordinance or code violations notices or correspondence issued
by any city/county municipality regarding the property located at 1710 N Powers Drive, Orlando,
FL 32818 subsequent to the date of loss.
18. Copies of any documents relating to any and all insurance claims made to
homeowner’s insurance companies relating to damages at the property located at 1710 N Powers
Drive, Orlando, FL 32818.
19. Copies of all documents relating to the purchase of the property located at 1710 N
Powers Drive, Orlando, FL 32818, including but not limited to home inspection reports, deeds
and mortgage documentation.
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Filing # 81545990 E-Filed 12/03/2018 03:35:10 PM IN THE CIRCUIT COURT OF THE 9TH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA MARIA LAFLEUR, CASE NO.: 2017-CA-004500-O Plaintiff, v. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. ___________________________________/ NOTICE OF TAKING DEPOSITION DUCES TECUM OF PLAINTIFF (Coordinated with Plaintiff’s Counsel) PLEASE TAKE NOTICE that, pursuant to the Florida Rules of Civil Procedure 1.310(b)(6), UNIVERSAL PROPERTY AND CASUALTY INSURANCE COMPANY, will take the deposition set forth below: NAME OF DATE/TIME DEPOSITION DEPONENT LOCATION Esquire Deposition Solutions Maria LaFleur March 5, 2019 at 10:00 a.m. 200 East Robinson Street Ste. 725 Orlando, FL 32801 Upon oral examination before a representative of Esquire Deposition Solutions or any other officer authorized by law to take depositions in the State of Florida. The oral examination will continue from day to day until completed. This 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 Florida Rules of Civil Procedure CASE NO. 2017-CA-004500 and other applicable law. And, pursuant to Fla. R. Civ. P. 1.350, said Defendant requests the deponent have the following items listed in Attachment “A” at the time and place of the foregoing deposition, for purposes of inspection and/or copying by this Defendant. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing has been furnished by electronic filing to:. Kenneth R. Duboff, Esq., Duboff Law Firm, 680 NE 127 Street, North Miami, FL 33161 (CourtDocument@DuboffLawFirm.com) on this 3rd day of December, 2018. Attorneys for Defendant Universal Property & Casualty Ins. Co. 1855 West State Road 434, Suite 282 Longwood, Florida 32750 Telephone: 833-658-8594 Facsimile: 954-958-1262 By: /s/ Jason R. Urbanowicz Jason R. Urbanowicz, Esq. Florida Bar No. 391026 For Service of Court Documents only: Primary: upciceservice05@universalproperty.com Secondary: lb1101@universalproperty.com Tertiary: ju1010@universalproperty.com CASE NO. 2017-CA-004500 ATTACHMENT “A” 1. Copies of any and all correspondence between Plaintiff and Defendant with regard to this claim or the allegations contained within Plaintiff’s Complaint. 2. Copies of any and all correspondence between Plaintiff and any public adjuster assisting with the claim with respect to the property located at 1710 N Powers Drive, Orlando, FL 32818. 3. Copies of any and all correspondence between Plaintiff and any contractor, repair/service company providing any services or preparing any estimate for repairs with respect to any claimed damages in the Complaint. 4. Copies of any and all reports, drafts, charts, drawings, diagrams, and memoranda and/or results of any testing showing or intending to show the cause of damage to Plaintiff’s property located at 1710 N Powers Drive, Orlando, FL 32818 as asserted in the Complaint. 5. Copies of any documents which support any claim for damages set forth in the Complaint 6. Copies of any and all repair estimates for alleged damages to Plaintiff’s property located at 1710 N Powers Drive, Orlando, FL 32818 that are claimed in the Complaint. 7. Copies of any and all photographs or videotape taken of the property located at 1511 Golden Poppy Court, Orlando, FL 32824 prior to the alleged date of loss in the Complaint. Please provide all photos or videos in electronic/digital format. 8. Copies of any and all photographs or videotape taken of the property located 1710 N Powers Drive, Orlando, FL 32818 on or subsequent to the alleged date of loss in the Complaint. Please provide all photos or videos in electronic/digital format. 9. Copies of any and all photographs or videotape taken of the area(s) of the interior of the home located at 1710 N Powers Drive, Orlando, FL 32818 to which you are claiming damages in this Complaint. Please provide all photos or videos in electronic/digital format. 10. Copies of any and all invoices, cancelled checks or other evidence of payment for repairs, remodels or renovations made to 1710 N Powers Drive, Orlando, FL 32818 relative to the Loss alleged in the Complaint. 11. Copies of any and all invoices, cancelled checks or other evidence of payment for repairs, remodels or renovations made 1710 N Powers Drive, Orlando, FL 32818 after to the date of loss. 12. Copies of any and all invoices, cancelled checks or other evidence of payment for repairs, remodels or renovations made to 1710 N Powers Drive, Orlando, FL 32818 for the five (5) years prior to the date of loss. CASE NO. 2017-CA-004500 13. Copies of any and all inspections, appraisals or other investigations for the property located at 1710 N Powers Drive, Orlando, FL 32818 prior to the date of purchase. 14. Copies of any and all rules or regulation violations notices or correspondence issued by any homeowner’s association regarding the property located at 1710 N Powers Drive, Orlando, FL 32818 for the three (3) year period prior to the date of loss. 15. Copies of any and all rules or regulation violations notices or correspondence issued by any homeowner’s association regarding the property located at 1710 N Powers Drive, Orlando, FL 32818 subsequent to the date of loss. 16. Copies of any and all ordinance or code violations notices or correspondence issued by any city/county municipality regarding the property located 1710 N Powers Drive, Orlando, FL 32818 for the three (3) year period prior to the date of loss. 17. Copies of any and all ordinance or code violations notices or correspondence issued by any city/county municipality regarding the property located at 1710 N Powers Drive, Orlando, FL 32818 subsequent to the date of loss. 18. Copies of any documents relating to any and all insurance claims made to homeowner’s insurance companies relating to damages at the property located at 1710 N Powers Drive, Orlando, FL 32818. 19. Copies of all documents relating to the purchase of the property located at 1710 N Powers Drive, Orlando, FL 32818, including but not limited to home inspection reports, deeds and mortgage documentation.