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Filing #62819638 E-Filed 10/13/2017 02:51:42 PM
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT IN AND
FOR ORANGE COUNTY, FLORIDA
CASE NO. 2017-CA-004877-O
RAMON A. SOLANO and
JOSEFINA SOLANO,
Plaintiffs,
VS.
UNIVERSAL INSURANCE COMPANY
OF NORTH AMERICA,
Defendant.
/
NOTICE OF TAKING DEPOSITION DUCES TECUM
TO: David D. Gongora, Esq.
Law Office of David D. Gongora, P.A.
David@davidgongora.com
LegalAssistA @davidgongora.com
DavidGongoraEsq@gmail.com
PLEASE TAKE NOTICE that pursuant to the Florida Rules of Civil Procedure,
Defendant, Universal Insurance Company of North America, will take the deposition duces
tecum as set forth below:
DEPONENT: Josefina Solano
DATE: January 22, 2018
TIME: 12:00 p.m. (or immediately following deposition of
Ramon Solano)
LOCATION: Orange Legal
633 E. Colonial Drive
Orlando, FL 32803
upon oral examination before Orange Legal Reporting Service, Official Court Reporters, or a
Notary Public in and for the State of Florida at Large, or some other officer fully authorized by
law to take the deposition. s
The witness is to produce the items listed in the Attachment “A,” a copy of which is
attached.
The deposition is being taken for the purpose of discovery, for use at trial or for such
other purposes as permitted under the Florida Rules of Civil Procedure and other applicable law.
The deposition(s) will continue until the testimony is completed.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on October 4 2017, a true and correct copy of the
foregoing document was filed with the Clerk of Court using the Florida Courts e-Filing Portal
which will send an automatic e-mail message to all parties who have registered with the e-Filing
Portal system and to: David D. Gongora, Esq., Law Office of David D. Gongora, P.A. at
David@davidgongora.com; LegalAssistA@davidgongora.com; DavidGongoraEsq@gmail.com.
onl Cu
Andrew P. Rock, Esquire
Florida Bar No. 0656437
arock@rocklawpa.com
F. Caroline H. Cranton, Esquire
Florida Bar No. 96369
cranton@rocklawpa.com
The Rock Law Group, P.A.
1760 Fennell Street
Maitland, FL 32751
Telephone: (407) 647-9881
Telecopier: (407) 647-9966
Attorneys for Defendant, Universal
Insurance Company of North America
cc: Orange Legal
ATTACHMENT “A”
Your current driver’s license.
The original Insurance Policy No. UICD0000053425 issued to
Ramon Solano, and any other documents pertaining to that policy,
including any communications from your agent or UNIVERSAL
INSURANCE COMPANY OF NORTH AMERICA.
Any contract of insurance and insurance documents, which you
believe may provide coverage for this loss.
All original receipts, bills, invoices, cancelled checks, and other
documents with respect to the property claimed in this loss, and
any extra expenses incurred as a result of this loss.
All photographs of the damaged property and claimed items, taken
at any time and from any source.
Any and all documents evidencing your efforts to repair, whether
temporarily or permanently, any claimed damage.
All documents referencing any claimed damage on your property,
including all reports, correspondence, memoranda, repair
estimates, invoices, and any other such documents.
All notes, journals, diaries, calendar entries, memoranda,
correspondence, and other records prepared by you or anyone on
your behalf documenting any of the damage for which you have
made a claim.
Any and all documents concerning any expenses incurred or
anticipated by you with regard to any claimed damage in this
insurance claim.
10. Any and all documents supporting any amount of money claimed
by you with respect to this insurance claim.
i Any and all documents relating to any previous damage to any area
involved in the current insurance claim, including documentation
referencing that damage and any insurance claim associated with it.
12 Any other document or record which documents or supports your
claim.
Preview
Filing #62819638 E-Filed 10/13/2017 02:51:42 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CASE NO. 2017-CA-004877-O RAMON A. SOLANO and JOSEFINA SOLANO, Plaintiffs, VS. UNIVERSAL INSURANCE COMPANY OF NORTH AMERICA, Defendant. / NOTICE OF TAKING DEPOSITION DUCES TECUM TO: David D. Gongora, Esq. Law Office of David D. Gongora, P.A. David@davidgongora.com LegalAssistA @davidgongora.com DavidGongoraEsq@gmail.com PLEASE TAKE NOTICE that pursuant to the Florida Rules of Civil Procedure, Defendant, Universal Insurance Company of North America, will take the deposition duces tecum as set forth below: DEPONENT: Josefina Solano DATE: January 22, 2018 TIME: 12:00 p.m. (or immediately following deposition of Ramon Solano) LOCATION: Orange Legal 633 E. Colonial Drive Orlando, FL 32803 upon oral examination before Orange Legal Reporting Service, Official Court Reporters, or a Notary Public in and for the State of Florida at Large, or some other officer fully authorized by law to take the deposition. s The witness is to produce the items listed in the Attachment “A,” a copy of which is attached. The deposition is being taken for the purpose of discovery, for use at trial or for such other purposes as permitted under the Florida Rules of Civil Procedure and other applicable law. The deposition(s) will continue until the testimony is completed. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on October 4 2017, a true and correct copy of the foregoing document was filed with the Clerk of Court using the Florida Courts e-Filing Portal which will send an automatic e-mail message to all parties who have registered with the e-Filing Portal system and to: David D. Gongora, Esq., Law Office of David D. Gongora, P.A. at David@davidgongora.com; LegalAssistA@davidgongora.com; DavidGongoraEsq@gmail.com. onl Cu Andrew P. Rock, Esquire Florida Bar No. 0656437 arock@rocklawpa.com F. Caroline H. Cranton, Esquire Florida Bar No. 96369 cranton@rocklawpa.com The Rock Law Group, P.A. 1760 Fennell Street Maitland, FL 32751 Telephone: (407) 647-9881 Telecopier: (407) 647-9966 Attorneys for Defendant, Universal Insurance Company of North America cc: Orange Legal ATTACHMENT “A” Your current driver’s license. The original Insurance Policy No. UICD0000053425 issued to Ramon Solano, and any other documents pertaining to that policy, including any communications from your agent or UNIVERSAL INSURANCE COMPANY OF NORTH AMERICA. Any contract of insurance and insurance documents, which you believe may provide coverage for this loss. All original receipts, bills, invoices, cancelled checks, and other documents with respect to the property claimed in this loss, and any extra expenses incurred as a result of this loss. All photographs of the damaged property and claimed items, taken at any time and from any source. Any and all documents evidencing your efforts to repair, whether temporarily or permanently, any claimed damage. All documents referencing any claimed damage on your property, including all reports, correspondence, memoranda, repair estimates, invoices, and any other such documents. All notes, journals, diaries, calendar entries, memoranda, correspondence, and other records prepared by you or anyone on your behalf documenting any of the damage for which you have made a claim. Any and all documents concerning any expenses incurred or anticipated by you with regard to any claimed damage in this insurance claim. 10. Any and all documents supporting any amount of money claimed by you with respect to this insurance claim. i Any and all documents relating to any previous damage to any area involved in the current insurance claim, including documentation referencing that damage and any insurance claim associated with it. 12 Any other document or record which documents or supports your claim.