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Filing # 59801531 E-Filed 08/01/2017 03:37:08 PM
STJ-179134 IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT IN AND FOR
ORANGE COUNTY, FLORIDA
RAMON SANCHEZ, CASE NO: 2017-CA-4878
Plaintiff,
vs.
ST. JOHNS INSURANCE COMPANY,
INC,
Defendant.
NOTICE OF TAKING LIVE DEPOSITION * DUCES TECUM
(Date and time cleared with opposing counsel on 7/20/17)
YOU ARE HEREBY NOTIFIED that the undersigned attorney in the above-styled
action will take the deposition of:
NAME: Wescott Roofing & Painting, LLC
DATE: October 11, 2017
TIME: 1:00 p.m.
PLACE: U.S. Legal Support
20 N. Orange Avenue, Suite 1209
Orlando, Florida, 32801 (407) 649-9193
*DUCES TECUM
1. SCHEDULE “A”
Said deposition will commence and continue from day to day until completed for
purposes of discovery, de bene esse, or for such other purposes as to be determined by
the above-styled Court. Said Deposition will be taken before U.S. Legal Support, or an
officer or Notary Public who is duly licensed to administer oaths in the State of Florida.
CASE NO: 2017-CA-4878
Such individual is not a relative to any party in the above-styled action and is not
financially interested in said action.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished by E-mail to: Derek L. Metts, Esq., (laura.dowdell@mettslegal.com;
derek.metts@mettslegal.com), Metts Legal, P.A., 607 N. Wymore Road, Winter Park,
FL 32789 on August 1, 2017.
BAZINSKY, KORMAN & BAKER, P.A.
7901 SW 6th Court, Suite 450
Plantation, FL 33324
Tel: (954) 626-0000
Fax: (954) 626-0011
By: /s/SHANNON WILLIAMS-LEON
Florida Bar No.: 111819
Primary E-Mail: courtdocs@bktriallaw.com
Secondary E-Mail: williams-leon@bktriallaw.com
Attorneys for Defendant
cc: U.S. Legal Support. (via email)
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CASE NO: 2017-CA-4878
SCHEDULE “A”
1. THE ENTIRE CONTENTS of your written, printed, or electronic files pertaining to
the property owned by Ramon Sanchez, located at 9108 Lake Fischer Boulevard,
Gotha, FL, 34734, including but not limited to any and all documents that reflect the
nature and duration of the assignment, as well as any and all written, printed or
electronic reports, contracts, notes, logs, invoices, estimates and color photographs.
2. ANY AND ALL records of any repairs you or others on your behalf performed or
were asked to perform but did not start or complete for Ramon Sanchez at 9108 Lake
Fischer Boulevard, Gotha, FL, 34734, at any time.
3. ANY AND ALL estimates, invoices, or other documents, including blueprints or
diagrams, prepared for Ramon Sanchez at 9108 Lake Fischer Boulevard, Gotha, FL,
34734, at any time.
4. ANY AND ALL estimates, invoices or other documents prepared for Ramon
Sanchez at 9108 Lake Fischer Boulevard, Gotha, FL, 34734, for a hail and/or wind
damage claim on or about July 12, 2016.
5. ANY AND ALL photographs, videos or other depictions of the property for
Ramon Sanchez at 9108 Lake Fischer Boulevard, Gotha, FL, 34734, at any time.
6. ANY AND ALL correspondence, telephone logs, notes or other documents
which evidence conversations, agreements or any other communication between you or
those on your behalf and Ramon Sanchez at anytime.
7. ANY AND ALL correspondence, telephone logs, notes or other documents
which evidence conversations, agreements or any other communication between you or
those on your behalf and Ramon Sanchez for a hail and/or wind damage loss on or
about July 12, 2016, at the location of 9108 Lake Fischer Boulevard, Gotha, FL, 34734.
8. ANY AND ALL correspondence, telephone logs, notes or other documents
which evidence conversations, agreements or any other communication between you or
those on your behalf and St. Johns Insurance Company for a hail/wind loss on or about
July 12, 2016, at the location of 9108 Lake Fischer Boulevard, Gotha, FL, 34734.
9. ANY AND ALL licenses, certificates, and other documents reflecting your
experience, skill-level, and expertise.
3
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Filing # 59801531 E-Filed 08/01/2017 03:37:08 PM STJ-179134 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA RAMON SANCHEZ, CASE NO: 2017-CA-4878 Plaintiff, vs. ST. JOHNS INSURANCE COMPANY, INC, Defendant. NOTICE OF TAKING LIVE DEPOSITION * DUCES TECUM (Date and time cleared with opposing counsel on 7/20/17) YOU ARE HEREBY NOTIFIED that the undersigned attorney in the above-styled action will take the deposition of: NAME: Wescott Roofing & Painting, LLC DATE: October 11, 2017 TIME: 1:00 p.m. PLACE: U.S. Legal Support 20 N. Orange Avenue, Suite 1209 Orlando, Florida, 32801 (407) 649-9193 *DUCES TECUM 1. SCHEDULE “A” Said deposition will commence and continue from day to day until completed for purposes of discovery, de bene esse, or for such other purposes as to be determined by the above-styled Court. Said Deposition will be taken before U.S. Legal Support, or an officer or Notary Public who is duly licensed to administer oaths in the State of Florida. CASE NO: 2017-CA-4878 Such individual is not a relative to any party in the above-styled action and is not financially interested in said action. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by E-mail to: Derek L. Metts, Esq., (laura.dowdell@mettslegal.com; derek.metts@mettslegal.com), Metts Legal, P.A., 607 N. Wymore Road, Winter Park, FL 32789 on August 1, 2017. BAZINSKY, KORMAN & BAKER, P.A. 7901 SW 6th Court, Suite 450 Plantation, FL 33324 Tel: (954) 626-0000 Fax: (954) 626-0011 By: /s/SHANNON WILLIAMS-LEON Florida Bar No.: 111819 Primary E-Mail: courtdocs@bktriallaw.com Secondary E-Mail: williams-leon@bktriallaw.com Attorneys for Defendant cc: U.S. Legal Support. (via email) 2 CASE NO: 2017-CA-4878 SCHEDULE “A” 1. THE ENTIRE CONTENTS of your written, printed, or electronic files pertaining to the property owned by Ramon Sanchez, located at 9108 Lake Fischer Boulevard, Gotha, FL, 34734, including but not limited to any and all documents that reflect the nature and duration of the assignment, as well as any and all written, printed or electronic reports, contracts, notes, logs, invoices, estimates and color photographs. 2. ANY AND ALL records of any repairs you or others on your behalf performed or were asked to perform but did not start or complete for Ramon Sanchez at 9108 Lake Fischer Boulevard, Gotha, FL, 34734, at any time. 3. ANY AND ALL estimates, invoices, or other documents, including blueprints or diagrams, prepared for Ramon Sanchez at 9108 Lake Fischer Boulevard, Gotha, FL, 34734, at any time. 4. ANY AND ALL estimates, invoices or other documents prepared for Ramon Sanchez at 9108 Lake Fischer Boulevard, Gotha, FL, 34734, for a hail and/or wind damage claim on or about July 12, 2016. 5. ANY AND ALL photographs, videos or other depictions of the property for Ramon Sanchez at 9108 Lake Fischer Boulevard, Gotha, FL, 34734, at any time. 6. ANY AND ALL correspondence, telephone logs, notes or other documents which evidence conversations, agreements or any other communication between you or those on your behalf and Ramon Sanchez at anytime. 7. ANY AND ALL correspondence, telephone logs, notes or other documents which evidence conversations, agreements or any other communication between you or those on your behalf and Ramon Sanchez for a hail and/or wind damage loss on or about July 12, 2016, at the location of 9108 Lake Fischer Boulevard, Gotha, FL, 34734. 8. ANY AND ALL correspondence, telephone logs, notes or other documents which evidence conversations, agreements or any other communication between you or those on your behalf and St. Johns Insurance Company for a hail/wind loss on or about July 12, 2016, at the location of 9108 Lake Fischer Boulevard, Gotha, FL, 34734. 9. ANY AND ALL licenses, certificates, and other documents reflecting your experience, skill-level, and expertise. 3