Preview
Filing# 138317767 E-Filed 11/10/2021 04:44:11 PM
MITCHELLE R ORDONEZ, an
IN THE CIRCUIT COURT OF THE 177TH
individual,
JUDICIAL CIRCUIT IN AND FOR
and DOREEN B ORDONEZ, an
BROWARD COUNTY, FLORIDA
individual,
Plaintiff,
GENERAL JURISDICTION DIVISION
V
CASE NO.: CACE-19-021656
UNIVERSAL PROPERTY &
CASUALTY INSURANCE COMPANY,
a Florida governmental entity,
Defendant.
i
NOTICE OF TAKING VIDEO TELECONFERENCE DEPOSITION DUCES TECUM
(AllParties to Appear Via Video Teleconference)
PLEASE TAKE NOTICE that the undersignedattorney will take the deposition,by oral
examination, of the person named below, at the time, date,and at the hour and placeindicated:
NAME:
Joseph North, General Contractor
DATE:
Wednesday, November 17, 2021
TIME:
9:00 AM
PLACE:
US Legal Support - Via Video Teleconference Link
The depositionit to take placeupon oral examination before a Notary Public or officer
authorized by law to take depositionsin the State of Florida. The oral examination will continue
from day to day until completed. This depositionis being taken for the purpose of discovery,for
use at trial,or for such other purposes as are permittedunder the rules of the Court includingthe
applicableFlorida Rules of Civil Procedure.
Pursuant to FLA. R. CIV. P. 1.310, the General Contractor's depositionwill cover matters
included in the enclosed proposed Notice of Taking DepositionDuces Tecum. Those areas will
relate to claim number FL19-0117529 made by the
(the "Claim") to the
Defendant for damages suffered or services performed to the property located at 610 SW 69 Way,
Pembroke Pines,Florida 33023 (the"Property").Specifically,
the depositionwill include,but will
not be limited to, the following:
1.
All facts,documents, entities,individuals,and reports relied upon by the Defendant to
make the coverage determination in this case.
2.
Any inspectionsof the Property related to the Claim.
Page 1 of 3
SILVERBERGIBRITO, PLLC
1695 NW 110th Avenue, Suite 224, Doral, FL, 33172? Tel (305) 735-3966 ? Fax (305) 440-1055
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/10/2021 04:44:11 PM.****
3.
The information contained in the correspondence between the Defendant and or its
agents, and the
or their agents in relation to the Claim.
4.
Prior claims, if any, made by the Plaintiff/Insured(s),
for damages to the Property.
5.
All facts relatingto the affirmative defenses raised by the Defendant in the subject
lawsuit.
6.
Documents produced by the Defendant in the subject lawsuit and all discovery
responses filed in the subjectlawsuit.
7.
Inspection(s)of the Property by the Defendant, for underwritingpurposes, that are
relied upon by the Defendant in this case.
8.
Insurance applicationsrelatingto the Property submitted and/or in possession of the
Defendant that are relied upon by the Defendant in this case.
9.
Correspondence between
the
Defendant
and
Plaintiff/Insured(s),
relating to
underwritingthat are relied upon by the Defendant in this case.
10. Any other documents and information relatingto the Defendant's underwritingfile
pertaining
to the Propertythat are relied upon by the Defendant in this case.
Said deponent is to have with him/her at the above indicated time and place the following:
SEE ATTACHED SCHEDULE "A".
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy ofthe foregoinghas been served via E-
filings
to: Simone Boston, Esq., ofUNIVERSAL PROPERTY & CASUALTY INS. CO., at
upciceservice02@universalproperty.com;
tj0521@universalproperty.com
;
sb0922@universalproperty.comon
;
this 10thday ofNovember, 2021.
SILVERBERGIBRITO, PLLC
Counsel for the Plaintiff.
1695 NW 110th Avenue,
Suite 224, Doral, FL, 33172
Telephone No. (305) 735-3966
Facsimile No.
(305) 440-1055
Primary Email: teamdelta@silverbergbrito.com
Secondary Email: Dalvz@Silverbergbrito.com
-By.js/ Dalvz Limm
Dalyz Limia
Florida Bar No. 1017895
Page 2 of 3
SILVERBERGIBRITO, PLLC
1695 NW 110th Avenue, Suite 224, Doral, FL, 33172? Tel (305) 735-3966 ? Fax (305) 440-1055
SCHEDULE "A"
Claim Number:
FL19-0117529
Insurance Company:
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY
Property Address:
610 SW 69 Way, Pembroke Pines, Florida 33023
Your complete filelin connection with your investigationand evaluation of the
issues involved in the above-referenced claim including,but not limited to:
a) All documents reviewed in preparationfor this deposition;
b) All documents obtained or preparedby you;
c) All
documents
you,
as
the
General
Contractor
of UNIVERSAL
PROPERTY & CASUALTY INSURANCE COMPANY, reviewed,
referred to or relied upon in arrivingat any of your opinions or conclusions
concerning the issues involved in the claim;
d) All models, permits,photographs,or other exhibits or documents of any kind
such as, any and all videos, estimates for repairs,invoices,receipts,
work
orders, memoranda,
correspondence, reports
of inspections,layouts,
diagrams, telephone conversation, phone messages that will be relied upon
by the Defendant in this case; and
e) All contract, agreements, statements, and any other documents that regarding
the property located at: 610 SW 69 Way, Pembroke Pines, Florida 33023
f) All documents relied upon the Defendant to deny coverage or afford coverage
for the Claim.
g) All documents relied upon by any of Defendant's experts to assist the
Defendant in denying coverage or affordingcoverage for the Claim.
h) All estimates the Defendant and/or any of its agents preparedregardingthe
Claim.
i) All other documents that could reasonablylead to the discoveryof admissible
evidence.
j) All other documents, not included above, relied upon by the Defendant or
that the Defendant will relyupon in the subjectcase.
1
Pursuant to Fla. R. Civ. P. 1.280, any assertion of documents being protected and therefore not produced, please
bring with you a privilegelog containing the following information: the title of the document, the date the document
was created, who prepared the document, the number of pages the document contains, the privilegebeing claimed,
and any other information that will enable other partiesto assess the applicabilityof the privilegeor protection.
Page 3 of 3
SILVERBERGIBRITO, PLLC
1695 NW 110th Avenue, Suite 224, Doral, FL, 33172? Tel (305) 735-3966 ? Fax (305) 440-1055
Preview
Filing# 138317767 E-Filed 11/10/2021 04:44:11 PM MITCHELLE R ORDONEZ, an IN THE CIRCUIT COURT OF THE 177TH individual, JUDICIAL CIRCUIT IN AND FOR and DOREEN B ORDONEZ, an BROWARD COUNTY, FLORIDA individual, Plaintiff, GENERAL JURISDICTION DIVISION V CASE NO.: CACE-19-021656 UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, a Florida governmental entity, Defendant. i NOTICE OF TAKING VIDEO TELECONFERENCE DEPOSITION DUCES TECUM (AllParties to Appear Via Video Teleconference) PLEASE TAKE NOTICE that the undersignedattorney will take the deposition,by oral examination, of the person named below, at the time, date,and at the hour and placeindicated: NAME: Joseph North, General Contractor DATE: Wednesday, November 17, 2021 TIME: 9:00 AM PLACE: US Legal Support - Via Video Teleconference Link The depositionit to take placeupon oral examination before a Notary Public or officer authorized by law to take depositionsin the State of Florida. The oral examination will continue from day to day until completed. This depositionis being taken for the purpose of discovery,for use at trial,or for such other purposes as are permittedunder the rules of the Court includingthe applicableFlorida Rules of Civil Procedure. Pursuant to FLA. R. CIV. P. 1.310, the General Contractor's depositionwill cover matters included in the enclosed proposed Notice of Taking DepositionDuces Tecum. Those areas will relate to claim number FL19-0117529 made by the (the "Claim") to the Defendant for damages suffered or services performed to the property located at 610 SW 69 Way, Pembroke Pines,Florida 33023 (the"Property").Specifically, the depositionwill include,but will not be limited to, the following: 1. All facts,documents, entities,individuals,and reports relied upon by the Defendant to make the coverage determination in this case. 2. Any inspectionsof the Property related to the Claim. Page 1 of 3 SILVERBERGIBRITO, PLLC 1695 NW 110th Avenue, Suite 224, Doral, FL, 33172? Tel (305) 735-3966 ? Fax (305) 440-1055 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/10/2021 04:44:11 PM.**** 3. The information contained in the correspondence between the Defendant and or its agents, and the or their agents in relation to the Claim. 4. Prior claims, if any, made by the Plaintiff/Insured(s), for damages to the Property. 5. All facts relatingto the affirmative defenses raised by the Defendant in the subject lawsuit. 6. Documents produced by the Defendant in the subject lawsuit and all discovery responses filed in the subjectlawsuit. 7. Inspection(s)of the Property by the Defendant, for underwritingpurposes, that are relied upon by the Defendant in this case. 8. Insurance applicationsrelatingto the Property submitted and/or in possession of the Defendant that are relied upon by the Defendant in this case. 9. Correspondence between the Defendant and Plaintiff/Insured(s), relating to underwritingthat are relied upon by the Defendant in this case. 10. Any other documents and information relatingto the Defendant's underwritingfile pertaining to the Propertythat are relied upon by the Defendant in this case. Said deponent is to have with him/her at the above indicated time and place the following: SEE ATTACHED SCHEDULE "A". CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy ofthe foregoinghas been served via E- filings to: Simone Boston, Esq., ofUNIVERSAL PROPERTY & CASUALTY INS. CO., at upciceservice02@universalproperty.com; tj0521@universalproperty.com ; sb0922@universalproperty.comon ; this 10thday ofNovember, 2021. SILVERBERGIBRITO, PLLC Counsel for the Plaintiff. 1695 NW 110th Avenue, Suite 224, Doral, FL, 33172 Telephone No. (305) 735-3966 Facsimile No. (305) 440-1055 Primary Email: teamdelta@silverbergbrito.com Secondary Email: Dalvz@Silverbergbrito.com -By.js/ Dalvz Limm Dalyz Limia Florida Bar No. 1017895 Page 2 of 3 SILVERBERGIBRITO, PLLC 1695 NW 110th Avenue, Suite 224, Doral, FL, 33172? Tel (305) 735-3966 ? Fax (305) 440-1055 SCHEDULE "A" Claim Number: FL19-0117529 Insurance Company: UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY Property Address: 610 SW 69 Way, Pembroke Pines, Florida 33023 Your complete filelin connection with your investigationand evaluation of the issues involved in the above-referenced claim including,but not limited to: a) All documents reviewed in preparationfor this deposition; b) All documents obtained or preparedby you; c) All documents you, as the General Contractor of UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, reviewed, referred to or relied upon in arrivingat any of your opinions or conclusions concerning the issues involved in the claim; d) All models, permits,photographs,or other exhibits or documents of any kind such as, any and all videos, estimates for repairs,invoices,receipts, work orders, memoranda, correspondence, reports of inspections,layouts, diagrams, telephone conversation, phone messages that will be relied upon by the Defendant in this case; and e) All contract, agreements, statements, and any other documents that regarding the property located at: 610 SW 69 Way, Pembroke Pines, Florida 33023 f) All documents relied upon the Defendant to deny coverage or afford coverage for the Claim. g) All documents relied upon by any of Defendant's experts to assist the Defendant in denying coverage or affordingcoverage for the Claim. h) All estimates the Defendant and/or any of its agents preparedregardingthe Claim. i) All other documents that could reasonablylead to the discoveryof admissible evidence. j) All other documents, not included above, relied upon by the Defendant or that the Defendant will relyupon in the subjectcase. 1 Pursuant to Fla. R. Civ. P. 1.280, any assertion of documents being protected and therefore not produced, please bring with you a privilegelog containing the following information: the title of the document, the date the document was created, who prepared the document, the number of pages the document contains, the privilegebeing claimed, and any other information that will enable other partiesto assess the applicabilityof the privilegeor protection. Page 3 of 3 SILVERBERGIBRITO, PLLC 1695 NW 110th Avenue, Suite 224, Doral, FL, 33172? Tel (305) 735-3966 ? Fax (305) 440-1055